From 6th April 2026, unpaid PAYE and National Insurance in an umbrella chain can be recovered from the agency that supplied the worker. Where there is no UK agency in that chain, it comes to you.
Even when an agency does sit in between, the exposure does not stay there. If an umbrella fails and workers go unpaid, the story is about the organisation whose site they were working on.
Today that chain is largely invisible to you. Workers arrive through agencies, agencies engage umbrellas, and nobody has asked you to approve any of it. You are trusting a supplier’s supplier, on the strength of an assurance written by the party being checked.