2026 umbrella company reforms

HMRC’s 2026 umbrella company reforms: what they mean for you and why now is the time to speak to Bank Partners and Acacium Group

Significant changes are coming to the way umbrella companies operate within the UK staffing landscape. From 6 April 2026, new HMRC legislation will reshape how risk is shared across labour supply chains. Organisations that rely on temporary staffing will need to prepare for a very different compliance environment.

These reforms are designed to close long-standing tax compliance gaps. However, they also introduce new financial, regulatory and reputational exposure for end clients, agencies and MSPs that engage umbrella workers. For NHS Trusts and public sector organisations in particular, the impact is substantial.

At Bank Partners, we see this as far more than a compliance update. It goes to the heart of how we protect our clients, our workers and our reputation as a trusted partner to the NHS and wider public sector.

What is changing and why it matters

Umbrella companies play a well-established role in healthcare staffing. They employ temporary workers on behalf of agencies or MSPs, run PAYE payroll, deduct the correct tax and National Insurance, and ensure statutory employment rights.

A typical arrangement works as follows:

The end client receives the worker’s services
The agency or MSP pays the umbrella company
The umbrella company employs the worker and pays them via PAYE

Umbrella models offer flexibility and continuity for workers moving between assignments, but they also introduce risk if not properly governed.

Historically, some umbrella companies have:

Applied incorrect tax or National Insurance deductions
Used schemes that artificially inflated take home pay
Failed to operate PAYE correctly

This is why HMRC is tightening the rules.

Joint and several liability: a new risk landscape

From April 2026, HMRC will introduce joint and several liability (JSL) across labour supply chains that use umbrella companies.

This means:

Umbrella companies will remain responsible for operating PAYE
Liability for unpaid tax and National Insurance can now extend to agencies, MSPs and end clients

In practice, organisations can be held accountable for the actions of umbrella companies they do not directly control.

For NHS Trusts and public sector bodies, this represents a significant shift. The financial and reputational consequences of non-compliance are too great to overlook.

Why MSP models are now more valuable than ever

The introduction of JSL strengthens the case for managed service provider (MSP) models as risk management solutions, not just staffing solutions.

An MSP helps clients navigate the new rules by:

Centralising control of agencies and umbrella companies
Applying consistent compliance standards across the supply chain
Providing clear accountability and auditability
Reducing exposure to tax and payroll risk

With extensive experience operating compliant umbrella frameworks, Acacium Group is well placed to support clients through this transition.

Why you should be speaking to Bank Partners and Acacium Group

The 2026 reforms may feel distant, but the preparation required is significant. Organisations that act early will be best placed to:

Protect themselves from financial and reputational risk
Ensure continuity of supply
Avoid disruption to critical staffing pipelines
Strengthen governance before HMRC scrutiny increases

Bank Partners and Acacium Group already have the structures, controls and expertise in place. We can help you:

Review your current umbrella exposure
Transition to compliant, approved providers
Implement an MSP model that centralises risk management
Build a future proof staffing strategy ahead of the legislative change

The message is clear. The way umbrella companies operate is changing and so is your risk. Now is the time to act.

If you would like support navigating the upcoming HMRC reforms or want to explore how our bank and MSP staffing solutions can protect your organisation, we are ready to help.