Umbrella company reform and why it matters for HR

October 16, 2025

When HMRC introduces joint and several liability for umbrella company tax failures in April 2026, many organisations will discover they have a significant blind spot. Nobody is actually accountable for their extended workforce. This isn’t just a tax issue, though that’s how it’s being presented. It’s a strategic workforce governance problem that’s been hiding in plain sight for years, and HR leaders are uniquely positioned to fix it.

The Risk Nobody’s Managing

From April 2026, if an umbrella company fails to pay the correct PAYE tax and National Insurance Contributions, HMRC can pursue your organisation for the full amount. Not just a portion. Not a penalty. The entire unpaid tax bill, plus interest and potential penalties. Whether you’re the recruitment agency in the supply chain or the end client using the workers, you’re now on the hook.

Before we go further, let’s be clear about scope. Your extended workforce includes contractors, consultants, temporary workers, freelancers, interim specialists, and agency workers. Not all of these are engaged through umbrella companies – consultants often work through their own firms, freelancers may be genuinely self-employed. But if your organisation uses umbrella companies for any part of your extended workforce – typically contractors, temporary workers, and interim specialists – this legislation creates direct financial liability for you. More importantly, it exposes a much wider governance gap affecting your entire extended workforce.

The shift in risk here is fundamental. Previously, if an umbrella company didn’t meet its tax obligations, that was between the umbrella and HMRC. Now? Your organisation becomes jointly and severally liable. In practical terms, HMRC can choose to pursue your business first, before even attempting to recover from the non-compliant umbrella company. There’s no “reasonable steps” defence. No safe harbour. The liability is absolute.

For organisations with significant extended workforces, this exposure could run into millions of pounds. Here’s the uncomfortable truth, though: in most organisations, nobody has their eye on this particular ball.

The Ownership Gap

I see the same pattern repeatedly in my work with organisations across multiple sectors. Extended workforce management falls between the cracks of traditional business functions. Procurement manages supplier relationships and contracts. Finance processes invoices. HR focuses on permanent employees. And the extended workforce? It somehow becomes everybody’s responsibility, which means it’s nobody’s responsibility.

This fragmentation creates risk. Real, measurable risk. When contractors, consultants, and temporary workers are engaged through umbrellas, who in your organisation can answer these questions:

  • Which umbrella companies are currently in your supply chain?
  • How many workers are engaged through each one?
  • What due diligence has been conducted on these umbrellas?
  • Who is responsible for monitoring ongoing compliance?
  • When was the last time someone verified that PAYE is being paid correctly?

If these questions are met with silence, blank looks, or a vague gesture towards “Procurement,” your organisation is exposed. And you’ve got less than six months to fix it.

Why This Is HR’s Opportunity

The umbrella company reforms aren’t just creating a compliance headache. They’re creating an opportunity for HR to step into a strategic space that desperately needs ownership. I genuinely believe HR is the right function to lead this charge, and here’s why.

You understand people strategy. Extended workers aren’t just suppliers or cost centres – they’re part of your workforce strategy. HR already thinks about talent holistically, and this is simply extending that lens beyond permanent employees.

You bridge multiple stakeholders. Effective extended workforce governance requires collaboration between HR, Procurement, Finance, and Legal. HR leaders are already skilled at navigating these cross-functional relationships. You do this every day.

You care about duty of care. While this legislation focuses on tax compliance, the underlying issue is broader: how organisations treat all their workers. HR’s values-driven approach to workforce management is exactly what’s needed here.

You’re positioned to see the bigger picture. While others focus on transactional elements – contracts, invoices, payment terms – HR can see the strategic opportunity in getting extended workforce management right.

The Wider Strategic Context

The extended workforce represents a significant and growing component of how organisations get work done. In some sectors, extended workers now comprise up to 50% of the total workforce, and that proportion continues to rise. Yet this substantial population often operates in a governance vacuum.

The umbrella legislation is just the beginning. The Employment Rights Bill will bring umbrella companies under regulatory oversight from 2027. IR35 has already shifted off-payroll working responsibilities to end clients. The direction of travel is clear: organisations will increasingly be held accountable for their entire workforce, not just those on the permanent payroll.

Organisations that treat this as purely a compliance exercise will miss the strategic opportunity. I’ve seen this happen. They tick the boxes, maybe switch to accredited umbrellas, and think they’re done. Those that get extended workforce governance right, though? They don’t just mitigate risk. They build competitive advantage. They access talent more efficiently. They make better workforce planning decisions. They understand their true workforce costs and capabilities.

What HR Needs to Do Now

With April 2026 approaching fast, HR leaders should take these immediate steps:

Start the conversation. Schedule a meeting with Legal, Finance, and Procurement. Put umbrella company reform on the agenda. Ask the difficult questions about who currently owns extended workforce governance. Don’t wait for someone else to raise this.

Map the current state. Understand how your organisation currently engages external workers. Which routes to market exist? Where are umbrella companies being used? Who makes decisions about which umbrellas to use? You might be surprised by what you find.

Identify the gaps. Where is accountability unclear? What due diligence processes exist? Are they fit for purpose under the new liability regime? Be honest about the answers.

Flag this to the C-Suite. Frame this as a strategic workforce issue, not just a compliance matter. The extended workforce is part of your talent strategy, and the new legislation means it requires proper governance. Your board needs to understand the financial exposure.

Consider accreditation. Organisations will need to work only with compliant umbrella companies. Look at accreditation bodies like FCSA and SafeRec as a baseline for due diligence. This isn’t a guarantee, but it’s a starting point.

Think beyond April 2026. This is the start of a longer journey toward proper extended workforce governance. What does strategic management of all your workforce look like? Start sketching that vision now.

The Hidden Workforce No Longer

For too long, the extended workforce has been the hidden workforce. Managed through ad hoc arrangements and siloed processes, never quite getting the strategic attention it deserves. The umbrella company reforms are forcing this into the light. While the immediate driver is tax compliance, the underlying need is for proper strategic governance of how organisations engage, manage, and take responsibility for all their workers.

HR leaders who recognise this opportunity won’t just protect their organisations from financial risk. They’ll position their function as the strategic owner of total workforce management. That’s a conversation worth having at board level, and one that elevates HR’s role in the business.

The gap exists. The risk is real. The opportunity is yours. It’s time for HR to step forward, flag the gaps, and shine a light on this critical area. Your C-Suite needs to hear from you before April 2026 arrives, because once that deadline hits, the organisations that haven’t sorted this out will be learning some very expensive lessons.

Your biggest talent risk is not where you think

September 18, 2025

The Evolution of Temporary Labour Programmes

In recent years, organisations have fundamentally reconsidered how they manage their temporary workforce programmes. Traditionally, these programmes were led by Procurement departments, focusing primarily on cost savings and supplier management. However, experience has shown that successful temporary workforce management requires active collaboration between multiple business functions: Procurement, HR, Operations, and IT.

Beyond Traditional Boundaries

The historical approach of procurement-led programmes brought rigour. However, this single-function approach often created unintended challenges. Departments found themselves working with processes that, whilst efficient from a procurement perspective, didn’t always align with their operational needs. HR teams struggled to ensure temporary workers integrated effectively with permanent staff, while IT were brought in too late to provide the necessary tech infrastructure.

Building Effective Collaboration

Working as a transformation partner, we recently helped a leading organisation address these challenges by establishing a Temporary Workforce Centre of Excellence (CoE). This innovative approach brings together not only internal stakeholders but also includes the organisation’s top five strategic suppliers as active participants in programme governance.

The CoE operates through bi-annual meetings where all stakeholders collaborate on programme strategy, operational improvements, and innovation opportunities. As an independent facilitator, we ensure these meetings remain focused and productive, managing potential conflicts of interest whilst driving genuine programme improvements. This neutral coordination has proved crucial in maintaining momentum and ensuring all voices are heard.

From Temporary Workforce to Holistic Talent Strategy

What began as a temporary workforce initiative has evolved into something far more significant. The CoE has become a catalyst for broader discussions about talent strategy, creating a pathway toward truly holistic workforce management. By bringing together diverse stakeholders regularly, the organisation has begun breaking down traditional barriers between permanent and temporary workforce management.

This evolution has revealed several key insights:

  • Future workforce planning must consider all talent types simultaneously
  • Technology investments should support seamless management of both permanent and temporary workers
  • Supplier partnerships can extend beyond temporary staffing to support broader talent objectives
  • Skills development and career pathways can span both permanent and temporary workforce populations

The Strategic Advantage

Organisations that successfully integrate their approach to permanent and temporary talent gain significant competitive advantages. They can respond more quickly to market changes, access broader talent pools, and create more flexible workforce solutions. The CoE model provides a proven framework for beginning this journey, starting with temporary workforce management but naturally evolving toward comprehensive talent strategy.

Looking Forward

As the lines between different types of employment continue to blur, organisations need frameworks that support holistic talent management. The CoE model, particularly when facilitated by an experienced transformation partner, provides a practical starting point for this evolution. Regular reviews and adjustments ensure the programme continues to meet evolving business needs while maintaining efficiency and compliance.

Conclusion

The evolution from procurement-led temporary workforce programmes to integrated talent management represents a crucial strategic shift for modern organisations. The Centre of Excellence model, incorporating both internal stakeholders and strategic suppliers, provides a practical framework for beginning this journey. This balanced approach not only optimises current workforce management but creates pathways toward future talent solutions.

As the nature of work continues to evolve, organisations that successfully implement cross-functional partnerships will be better positioned to attract, retain, and deploy talent in all its forms. The key to success lies not in any one department taking the lead, but in creating a collaborative framework where all stakeholders’ expertise is valued and integrated into strategic workforce planning.

The future belongs to organisations that can break down traditional silos between permanent and temporary workforce management. By starting with a well-structured approach to total talent workforce management, supported by neutral facilitation, and innovation.

Skills-based hiring

November 4, 2024

The landscape of talent acquisition is undergoing a significant shift. As industries evolve and new technologies emerge, organisations are finding that traditional hiring methods based on qualifications and experience alone are no longer sufficient. Enter skills-based hiring: a recruitment strategy that focuses on a candidate’s demonstrable abilities, competencies, and knowledge relevant to a specific role.

The Rise of Skills-Based Hiring

The transition towards skills-based hiring is driven by several factors. The rapid pace of technological change means that job roles are evolving faster than ever before. Simultaneously, the rise of the gig economy and the increasing demand for specialised skills have created a more dynamic and diverse talent pool.

Traditional recruitment methods, which tend to emphasise factors such as educational qualifications and years of experience, are proving inadequate in this new landscape. They often fail to capture the full range of a candidate’s capabilities and can inadvertently exclude talented individuals who have acquired skills through non-traditional paths.

Benefits of a Skills-Based Approach

Adopting a skills-based hiring approach offers numerous advantages:

  1. Access to a Broader Talent Pool: By focusing on skills rather than traditional qualifications, organisations can tap into a more diverse range of candidates. This approach can help identify individuals with the right mix of abilities, regardless of their background or career path.
  2. Improved Job Performance: When hiring is based on specific, relevant skills, there’s often a stronger correlation with job performance. Candidates who can demonstrate the required competencies are more likely to excel in their roles.
  3. Enhanced Diversity and Inclusion: Skills-based hiring can help reduce unconscious bias in the recruitment process. By focusing on abilities rather than pedigree, organisations can create more diverse and inclusive teams.
  4. Increased Agility: In rapidly evolving industries, skills-based hiring allows organisations to quickly adapt to changing needs by bringing in individuals with the most relevant and up-to-date skills.
  5. Better Retention: When employees are hired based on their skills and can use these skills in their roles, they’re often more engaged and satisfied, leading to improved retention rates.

Implementing Skills-Based Hiring

Transitioning to a skills-based hiring approach requires a shift in mindset and processes:

  1. Identify Core Skills: For each role, determine the essential skills required for success. This goes beyond technical skills to include soft skills like problem-solving, communication, and adaptability.
  2. Develop Skills Assessments: Create or adopt assessment methods that effectively evaluate the identified skills. This could include practical tests, simulations, or project-based assessments.
  3. Rethink Job Descriptions: Move away from long lists of qualifications and instead focus on the key skills and competencies required for the role.
  4. Leverage Technology: Utilise AI and data-driven tools to help identify and assess skills more effectively and objectively.

Challenges and Considerations

While skills-based hiring offers many benefits, it’s not without challenges. Developing accurate skills assessments can be time-consuming and may require expertise.  There’s also the risk of overlooking valuable traits that don’t fit neatly into a skills framework, such as cultural fit or potential for growth.

Moreover, some industries with strict certification requirements may find it more difficult to fully embrace skills-based hiring. In these cases, a hybrid approach that combines skills assessment with traditional qualifications may be more appropriate.

The Future of Hiring

As we look to the future, skills-based hiring is likely to become increasingly prevalent. The rapid pace of technological change means that the half-life of skills is shrinking, making continuous learning and adaptability more crucial than ever.

Organisations that embrace skills-based hiring will be better positioned to attract diverse talent, adapt to changing market needs, and build agile, high-performing teams. For job seekers, this shift presents an opportunity to showcase their abilities and potential, regardless of their formal qualifications or career history.

The move towards skills-based hiring represents more than just a change in recruitment practices; it’s a fundamental shift in how we view talent and potential. As we continue to navigate an ever-changing work landscape, the ability to identify, attract, and nurture skills will be a key differentiator for successful organisations.

In this new paradigm, the question is no longer just “What have you done?” but “What can you do?” It’s a subtle but powerful shift that has the potential to reshape the world of work for the better.