Joint & Several Liability (JSL) Reform — What It Means for Umbrella Companies

​

The UK government has confirmed plans to introduce Joint and Several Liability (JSL) legislation across the recruitment supply chain — a reform expected to come into force in 2026. This change will make agencies, end clients and umbrella companies collectively responsible for ensuring compliance and correct payment of tax, National Insurance and employment rights.

​

What is JSL?

Under the new Joint and Several Liability rules, if non-compliance or tax avoidance is found anywhere in the supply chain, liability can be shared between all parties — including the recruitment agency and any umbrella or payroll intermediary involved.

That means even if your umbrella hasn’t directly made an error, you could still be held financially and legally accountable for the actions of others.

​

Why JSL Matters

This reform aims to stamp out tax avoidance and disguised remuneration schemes by holding all supply-chain partners to a higher standard of due diligence.

For compliant umbrellas, it’s an opportunity to stand out — but it also means the days of weak governance and “trust-based” relationships are over.

Agencies will expect far greater transparency around:

• PAYE and employment models

• Holiday pay accrual and payment

• Assignment rates, margins and deductions

• SafeRec or FCSA accreditation

• Real-time verification of payments to workers

​

How I Can Help You Navigate JSL

Preparing for Joint and Several Liability requires more than policy tweaks — it calls for a complete compliance mindset shift.

I work closely with umbrella companies, agencies and payroll providers to translate the JSL reforms into practical, actionable steps that strengthen your business, protect your directors, and reassure your clients.

Here’s how I can support you:

✅ Gap Analysis and Risk Review
A full review of your current compliance framework, identifying where your contracts, controls or processes may expose you under JSL.

✅ End-to-End Compliance Redesign
Support to update onboarding, payroll and reporting processes so that your due diligence aligns with what agencies and regulators will expect post-2026.

✅ Accreditation Alignment
Guidance on achieving or maintaining FCSA and SafeRec accreditation — giving you an external validation of compliance that will carry weight under JSL.

✅ Contract and Supply Chain Mapping
Review and restructure agreements between umbrella, agency and worker to ensure roles, liabilities and indemnities are watertight.

✅ Training and Briefings
Tailored sessions for directors, compliance teams and client-facing staff — ensuring your whole team understands the JSL implications and how to communicate them confidently.

✅ Ongoing Compliance Partner
Through Umbrella Ready+, I provide monthly support, audit templates, and practical guidance to help you stay JSL-ready as new details emerge.

​

Get Ready for 2026

​

The countdown to Joint and Several Liability reform has already begun. Umbrellas that act now will not only meet new compliance standards — they’ll be in a stronger position to win preferred-supplier status with top agencies.

If you’d like to understand what JSL means for your business, or start preparing your internal framework, get in touch for a consultation.

​

Umbrella Ready – Compliance that wins clients.