Umbrella Company Due Diligence Checklist

Checks for contractors, recruitment agencies and end clients before using an umbrella company – accreditation, payslip and key information document, PAYE and holiday pay compliance, warning signs of tax avoidance schemes – reflecting the April 2026 rules making agencies liable for umbrella PAYE.

Editable Word document
4
10pages
Guidance notes included
aml consultancy solutions

Freelancers & contractors

Umbrella Company Due Diligence Checklist

About this document

What it’s for

Many contractors are paid through umbrella companies, which employ them and run PAYE. Some non-compliant umbrellas use tax avoidance or “mini umbrella” fraud schemes, leaving workers with large tax bills. From 6 April 2026, the recruitment agency that supplies the worker (or the end client if there is no agency) is jointly and severally liable for unpaid PAYE and National Insurance of the umbrella. Everyone in the chain therefore needs to check umbrellas carefully.

When to use it

  • For contractors: before signing up with an umbrella company
  • For agencies and end clients: before adding an umbrella to the supply chain and at regular intervals
  • When something on a payslip does not look right

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

A complete, ready-to-use document with every section written, your details shown in [square brackets], and guidance notes explaining how to complete it.

How to complete it

  • Work through the checks and record the evidence
  • Repeat the checks at least every [six] months for agencies and clients
  • Report suspected tax avoidance to HMRC

Key points to check

  • If take-home pay looks much higher than other umbrellas offer, it is almost certainly too good to be true
  • Check HMRC’s published list of named tax avoidance schemes, promoters and enablers

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

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