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PAYE rules for labour supply chains (umbrella companies)

From 6 April 2026, significant changes to PAYE rules will affect umbrella companies, recruitment agencies, and end clients, increasing shared responsibility for payroll compliance across labour supply chains.

Umbrella companies are often used by freelancers, contractors, and temporary workers who prefer not to operate as limited companies or set up their own businesses. Essentially, an umbrella company acts as an intermediary between the worker and the end client (or recruitment agency), handling payroll, taxes and other administrative tasks on behalf of the worker. This includes any business supplying labour under a contract of employment.

There are significant changes to the PAYE rules for labour supply chains taking effect from 6 April 2026. Under the new rules, if an umbrella company fails to operate PAYE correctly or underpays tax and NICs, HMRC can recover the amounts due from the recruitment agency that has the contract with the end client, rather than pursuing only the umbrella company. Where there is no recruitment agency involved, the end client becomes responsible. This significantly widens the requirement for all parts of the labour supply chain to ensure that these umbrella companies are fully compliant with all payroll obligations.

Umbrella companies still remain the legal employer of the workers, but recruitment agencies and end clients will now share responsibility for ensuring PAYE is operated correctly from April 2026 onwards.

Check your National Insurance record

It is recommended to check your National Insurance record as this can affect your future entitlement to the State Pension and other benefits.

By using the online service, you can see what National Insurance contributions you have paid up to the start of the current tax year, along with any National Insurance credits you have received. The record also highlights whether there are gaps in your contribution history. This will highlight tax years that do not count as qualifying years for State Pension purposes. These gaps can arise for a variety of reasons, such as periods of low earnings, time spent working abroad or career breaks.

The service also shows whether you are eligible to make voluntary National Insurance contributions to fill any missing years and how much this would cost. Importantly, it allows you to see how your State Pension forecast could change if you decide to make those additional contributions, helping you decide whether paying voluntarily contributions would be beneficial.

Do you need a company audit in the UK?

Not every UK limited company needs a statutory audit. Many smaller companies qualify for audit exemption, but it is important to understand the rules, as an audit may still be required in certain situations.

For financial years starting on or after 6 April 2025, a company is generally audit exempt if it qualifies as a small company and meets at least two of the following conditions:

  • Annual turnover of no more than £15 million
  • Balance sheet total (gross assets) of no more than £7.5 million
  • Average number of employees of no more than 50

If a company exceeds these limits, it will not usually lose audit exemption straight away. In most cases, the company must exceed the thresholds for two consecutive financial years before the exemption is lost.

However, some companies must have an audit regardless of size. This includes public companies and certain regulated businesses, such as banks, insurance companies, and some investment firms.

An audit may also be required if the company’s shareholders request one. Shareholders holding at least 10% of any class of shares, or 10% of voting rights, or 10% in number of members, can demand an audit. This request must be made in writing and received at least one month before the end of the financial year.

Charitable companies are subject to different rules and often face lower thresholds for mandatory audits. For example, a charity may require an audit once its gross income exceeds £1 million, depending on its circumstances.

If you are unsure whether your company needs an audit, or whether an audit could be beneficial for lenders, investors, or business planning, please get in touch and we will be happy to review your position.

Protecting your online passwords

With so many online accounts now in daily use, including banking, shopping, email and HMRC services, password security has never been more important. A weak or reused password can lead to fraud, identity theft, or unauthorised access to personal and business information.

A good first step is to use strong, unique passwords for every account. Avoid using the same password across multiple websites, as criminals often reuse stolen login details from one breach to access other accounts. Strong passwords are usually at least 12 characters long and do not rely on obvious words or personal information. Many people find passphrases easier to remember than random characters.

A password manager is one of the easiest ways to improve security. It securely stores passwords in an encrypted vault, generates complex passwords for you, and can warn you if you are using weak or repeated passwords. This means you only need to remember one strong master password.

Where possible, enable two-factor authentication (2FA). This adds a second step when logging in, such as a code from an authentication app or a prompt on your phone. Even if someone obtains your password, they may still be unable to access your account without the second factor.

Be cautious with password reset emails and links. Your email account is often the gateway to all other accounts, so secure it with a strong password and 2FA. Also watch for phishing emails and fake login pages designed to steal your details. If unsure, type the website address directly into your browser rather than clicking a link.

Finally, avoid sharing passwords by email or text message, especially in a business setting. Where possible, use separate logins for each person and restrict access appropriately.

Basis period reform – spreading rules for payment

If your business has transitional profits from basis period reform, spreading over five years may reduce the cash flow impact, but it is important to understand the deadlines.

The self-employed basis period reform has changed the way trading income is allocated to tax years. Under these reforms, the basis of assessment moved from a current year basis to a tax year basis.

As a result, all sole traders and partnership businesses are now required to report their profits on a tax year basis. This change fully came into effect from the self-assessment return due by 31 January 2025, covering the 2023–24 tax year.

Under the old rules, businesses could have overlapping basis periods. This sometimes resulted in profits being taxed twice, with corresponding overlap relief usually given when the business ceased. The move to a tax year basis removed the basis period rules and prevented the creation of any new overlap relief.

The spreading rules for the payment of transitional profits are still available. By default, transition profits are spread evenly over five tax years, from 2023–24 to 2027–28, helping to ease cash-flow pressures. Taxpayers can also elect to accelerate the taxation of transition profits if they wish, but spreading continues to apply automatically unless an election is made.

If your business ceases on or before 5 April 2027, any transition profit remaining after overlap relief that has not yet been taxed must be brought into charge in the final year of trading.