Preparing for April 2026: a practical guide for healthcare recruiters

From April 2026, umbrella compliance can no longer be treated as something that sits safely elsewhere. 

Umbrella legislation changes introduce Joint & Several Liability (JSL) across labour supply chains that include umbrella companies. In simple terms, if an umbrella fails to operate PAYE correctly or doesn’t pay HMRC what it should, HMRC will be able to recover unpaid PAYE and National Insurance from another party in the chain – often the recruitment agency or MSP, and in some cases the end client. 

For recruiters supporting NHS trusts, local authorities, private care providers and social enterprises, the impact won’t be theoretical for long. In healthcare, pay problems quickly become service problems. Missed or incorrect pay can translate into rota gaps, service pressure and immediate escalation. 

The key point is that JSL changes the risk profile of your supply chain. Even if the umbrella sits several steps away from your day-to-day teams, the liability risk can still flow up the chain.  

It helps to be clear about what’s shifting in practice. 

• Supply chain risk moves up the chain. Where an umbrella is involved, liability for unpaid PAYE and NICs will not sit only with the umbrella. 
• Evidence matters. The JSL rules increase supply chain risk, making documented due diligence and audit trails operationally important. (Although if PAYE and NICs are not correctly paid to HMRC, recovery can still come up the chain)s. 
• Reassurance isn’t enough. Accreditations and written assurances may provide visibility, but they do not change legal exposure. What matters is how payroll is actually being operated in reality and whether tax is genuinely being paid correctly. 
• Healthcare will feel it fast. The sector’s scale, layered supply models and operational sensitivity mean issues tend to surface quickly and publicly. 

You can’t manage risk you can’t see – and in healthcare, supply chains are often complex. 

Ask: 

• Do you have a PSL and, if so, who’s on it?
• Which clients are direct, and which operate via an MSP? 

• Which umbrella companies are actually being used across NHS and care-provider placements today? 

• Are contractors operating outside your Preferred Supplier List (PSL)? 

You should be able to clearly explain who pays whom, who selected which provider, and where payroll responsibility sits at each point. 

From April 2026, your PSL becomes a risk-control tool.  

For each umbrella on your PSL, you should be able to obtain and refresh: 

• Current accreditation evidence and recent audit information (including scope and date) 

• Sample payslips and P32 information showing transparent PAYE and NIC deductions 

• evidence of payroll processes and money flows – not just written assurances 

• evidence that PAYE and NICs are actually being paid correctly and on time 

Documented checks won’t make the risk disappear, but they do matter. They show governance, help you spot issues earlier, and support conversations with MSPs, procurement teams and end clients. 

At a minimum, keep a dated record of: 

• What checks were carried out 

• What payroll evidence was reviewed 

• What actions were taken if issues were identified 

Independent reporting, such as SafeRec, or reconciliation tools, can help make this routine rather than reactive – particularly where contractor volumes are high, and payroll runs are frequent. 

Even a compliant umbrella can cause serious disruption if it becomes financially unstable. 

In healthcare, late or incorrect pay can quickly lead to disengagement, cancelled shifts or redeployment – and your recruiters end up firefighting. 

Basic sense checks should include: 

• Companies House filings and trends 

• Obvious signs of cashflow pressure 
• Cash at bank and reserve figures 

• Capacity to handle volume spikes, such as seasonal demand or short-notice cover 

April 2026 will sharpen focus on what’s written down. 

You’ll want clarity on: 

• Right-to-audit provisions 

• Who is responsible for fixing issues, how quickly, and at whose cost 

• What happens if a provider fails your standards mid-assignment 

This is particularly important in MSP-led healthcare arrangements, where an MSP can carry risk without having day-to-day control over every umbrella selection or payroll process. 

Contractors don’t need legislation quoted at them. 

What they do need: 

• A clear explanation of what’s changing and why 

• Reassurance that pay will be correct, compliant and on time 

• Simple guidance on what, if anything, they need to do 

One message is sensitive but often unavoidable: “take-home pay” may change as non-compliant models disappear. In publicly funded healthcare environments, where rates are tightly controlled, these conversations can involve difficult trade-offs. Handle them early, clearly and with empathy. 

By the time April 2026 arrives, you should be able to demonstrate that: 

• You know exactly which umbrella companies sit in your supply chain 

• Your PSL is actively managed based on evidence and operational reality, not habit 

• You maintain a clear audit trail of checks and decisions 

• Your teams understand that evidence supports governance – but does not remove liability completely 

• Your teams can explain the changes simply to contractors and their clients 

In healthcare, this isn’t just about liability. It’s about continuity of care, workforce stability and service resilience. When pay fails, services feel it. When trust breaks down, staff disengage. When supply chains fracture, patients are ultimately affected. 

JSL doesn’t mean there’s a need to panic, but it does mean control, visibility and operational reality matter more than ever – particularly in healthcare environments where workforce disruption has immediate human impact. 

If you’d like practical support preparing for April 2026, our expert team is here to help.