In the Firing Line: What April 2026 Means for End Hirers
As a leading recruitment agency, Pure Staff is acutely aware of the significant changes looming in the staffing landscape. From April 2026, new UK employment legislation will transform how agencies and end clients handle liability within the labour supply chain. The introduction of Chapter 11 ITEPA rules means end clients could be jointly and severally liable for PAYE and NIC if umbrella companies fail to comply.
Join us for an insightful webinar led by Kareena Prescott, APSCo Trusted Partner and Founder of C2E Law, a distinguished lawyer specialising in employment law and tax compliance.
The webinar addresses key areas, including:
Major shift from April 2026: New Chapter 11 ITEPA rules make agencies and, in many cases, end clients themselves jointly and severally liable for PAYE and NIC where umbrella companies are in the labour supply chain.
Draft legislation explained: Sections 61Y–61Z1 ITEPA 2003 set out when end clients become the “relevant party” and therefore directly liable.
Due diligence expectations: HMRC’s Guidelines for Compliance (GfC 12) show what end clients must check, including contracts, payroll records, and supply chain mapping.
No safe harbour: Reliance on umbrella assurances or fraudulent documents is no defence even good-faith clients can still be pursued for unpaid PAYE/NIC.
The end of mini-umbrella models: HMRC’s strengthened enforcement following the Elphysic case signals a crackdown on complex labour supply chains.
Off-payroll working and IR35: While genuine off-payroll arrangements are carved out of Chapter 11, HMRC can override this where PSCs are used without commercial justification.
Why off-payroll isn’t the full answer: IR35 compliance doesn’t neutralise Chapter 11 exposure liability can still fall on end clients if umbrellas or intermediaries default.
What’s next: End clients should expect enhanced supply chain audits, updated contractual protections, and possibly a shift away from umbrella engagement models to direct hires or fixed-term contracts.
This webinar offers essential guidance for organisations preparing for these regulatory updates.
For any queries or additional details, please contact David or Kirsty at Pure Staff.
Let’s work together to protect your business before the April 2026 deadline.
