05/06/2026
🛑Are you running in-house payroll for your contractors?🛑
Agencies running in-house PAYE under a JSL (Joint Supply Labour) structure should be aware that they are effectively operating as the umbrella company in the supply chain.
This does not create a protective barrier for the end client; rather, it can place both the agency and end client closer to the point of tax liability.
If HMRC identifies unpaid PAYE, NICs, or non-compliance within the arrangement, liability transfer provisions may leave the end client increasingly exposed to recovery action.
It's important to recognise where the agency sits in the supply chain regarding liability. The below is from our friends at Saferec, the red indicates who is deemed as the 'relevant party' and where a potential liability exists