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Free printable pack · April 2026 evidence checklist
The April 2026 umbrella evidence file
Who is jointly and severally liable, and a checklist to work through for every umbrella in your chain — HMRC's recommended checks first.
Version 2026.09 · facts checked 2026-09-23
The position, stated exactly
For payments made on or after 6 April 2026, section 24 of the Finance Act 2026 (inserting sections 61Y to 61Z2 into the Income Tax (Earnings and Pensions) Act 2003, and extended to Class 1 National Insurance by regulations) leaves the umbrella company with the duty to operate PAYE, and makes the relevant party jointly and severally liable with it for the PAYE and National Insurance due.
The relevant party is the recruitment agency that holds the contract with the end client. It is the end client instead where the client contracts with the umbrella directly, or through an agency that is connected to the umbrella or is not resident in the UK.
There is no statutory list of records and no due-diligence defence. HMRC's guidance recommends keeping a record of the checks you make, and names the first four below.
This file covers
The checks HMRC recommends you record, per umbrella
- Payslips and reconciliation statements, obtained from the workers themselvesThey show what the worker was actually paid against what you paid the umbrella.
- The umbrella is VAT registered and charging VATAn umbrella not charging VAT on the full invoice is a warning sign HMRC names.
- Its details match Companies HouseName, number, directors and filing history, read rather than glanced at.
- It holds employer's liability insuranceA legal requirement for an employer, and one of HMRC's four checks.
Per provider, reviewed at least annually
- Accreditation certificate and its expiry dateA baseline, not a substitute for your own checks.
- The PAYE reference, and which entity in a group operates the payrollSo you know who is actually paying the tax.
- The fee in pounds per week or month, not a percentageA percentage fee hides what is being taken from the worker.
- A worked example payslip from assignment rate to net payIt shows every employer cost line by line.
- The indemnity clause, who signed it and whenAn indemnity only helps from a party able to honour it.
Per pay period, per worker
- Payroll reports that reconcile to your placements and timesheetsThe trail from work done to pay made.
- Evidence of RTI submissions for your workersShows the payroll was reported to HMRC.
- Evidence the tax was paid to HMRCA submission is not a payment.
- A payslip trail you could show a worker without asking the providerDisputes are answered from your own records.
In the contract
- Terms that state where responsibility sits and what the provider warrantsThe contract should match the law, not the old position.
- A right to audit, with a turnaround such as five working days"On request" is not a deadline.
- Notice terms that let you move workers without stranding themYou need a way out if the checks fail.
Inside your business
- A one-page map of every provider, worker and routeMost agencies are surprised by their own answer.
- A named owner for provider checks, with the review in a calendarChecks nobody owns do not happen.
- A brief for finance on the cash-flow and systems consequencesLiability for a provider's unpaid tax is a finance risk.