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Sourcing Labour from Third Parties? Due Diligence Required

  • Written by Katie
  • March 12, 2026
  • Business Advisory, Tax

A final reminder for any businesses that source workers through third parties, such as agencies or umbrella companies. New rules will come into effect from 6 April 2026 that could have significant tax implications.

Under the new legislation, businesses may become jointly and severally liable for PAYE and National Insurance contributions relating to workers supplied through these arrangements if the third party fails to meet its tax obligations to HMRC.

This means that if an agency or umbrella company in the labour supply chain does not correctly account for PAYE or NIC, HMRC may seek to recover the unpaid amounts from other parties involved in the arrangement, including the end client.

Given the potential financial exposure, it is important for businesses that rely on outsourced labour to review their current arrangements and understand how the new rules may apply.

Carrying out appropriate due diligence on labour providers and understanding how workers are engaged within the supply chain will be essential to reduce the risk of unexpected tax liabilities.

If your business regularly engages workers through agencies or umbrella companies, it would be sensible to review these arrangements before the new rules take effect in April 2026. We would be happy to help you assess your current position and ensure your processes are compliant.

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At A&C Chartered Accountants, we’re not just accountants; we’re your partners in success. Based in Manchester, our experienced team handles everything from managing limited company and sole trader accounts to expertly navigating tax returns. Beyond financials, we play a crucial role in driving your business’s growth, strategically steering it towards success with confidence and clarity.

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02/12/2025
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Very helpful - quick response and managed to deal with my VAT return super quickly in a time of need! Would recommend
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I had an outstanding experience with my accountant. They were incredibly helpful throughout the entire process of completing my UK tax return. Not only were they knowledgeable and efficient, but also exceptionally kind and patient. They guided me step by step, explained everything clearly, and made what could have been a stressful procedure feel easy and manageable. I truly appreciate the dedication and support they provided. Their professionalism and attention to detail were outstanding. I highly recommend their services and will definitely work with them again in the future.
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On Jan 28th this year, I checked into my HMRC account to fill in my self assessment as usual where I found out that I owe HMRC 12000 pounds! This was a big surprise to me and I had no idea what was going on. I desperately called different accounting firms to help me, however as you can imagine, all firms were fully booked and no one had time before the 31st Jan deadline. After checking several firms, I called A&C as one of the firms popping up in my google search and Paul was very kind to help me. He used an app, connected to my laptop, went through my P60 and P45 and quickly making the calculation. As it turned out, my employer made a mistake and used a wrong tax code and hence I was actually owing HMRC the money. He was highly efficient and knowledgable, went above and beyond to help me and didn't even charge me for the time he spent on the phone with me. I highly recommend their service and would definitely use them in future, whenever I need help with tax or accounting.

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