Umbrella Companies Research

The core evidence gap lies in understanding how agencies and end clients will respond behaviourally to the new legislation due to come into force in April 2026. This legislation shifts PAYE liability from umbrella companies to agencies or end clients, aiming to close tax loopholes and reduce risk around fraud. Whilst internal administrative data can, to some extent, tell us how businesses have responded to the new legislation, it is unable to give us the narrative on why they have responded the way they have. Additionally, it is also unable to tell us whether they have improved/increased their due diligence or assurance processes which would be key if they continue to use umbrella companies. It is in this granularity of detail, which we seek to explore through this research, HMRC will be able to understand the motivations of these agencies and any evolving models HMRC have not anticipated that come with new legislation. We are also interested in exploring reactions to the legislation through a qualitative lens. This will enhance HMRC understanding and provide a full assessment of the umbrella company space, evaluating the impact legislation has on agencies and their payroll behaviour. Additionally, through this externally commissioned research we seek to explore the effectiveness of HMRC education and awareness efforts around the policy reform which would not be achievable through an internal evaluation alone. We seek to understand how HMRC communication campaigns have impacted decision processes for these businesses to ensure any future communications land as desired. Without external research, HMRC cannot robustly evaluate whether the intended impact is being achieved or whether further policy or compliance interventions are needed.