Thank you for your request for information about the following:

Request

On 06 April 2026 Government introduced new umbrella tax legislation in Finance Act 2026, under Chapter 11 ITEPA 2003 https://www.gov.uk/hmrc-internal-manuals/employment-status-manual/esm2405

Also, see Finance Act 2026, Clause 24: Umbrella Companies: https://www.legislation.gov.uk/ukpga/2026/11/enacted

I am interested in obtaining a copy of your internal guidelines being used when on hiring flexible workers (directly or indirectly via recruitment agencies), where the new umbrella rules might apply.

Please can you:

1. send me a copy of your internal guidelines used for any internal guidance,
2. send me any policies you use surrounding the new legislation.
3. send me any documents you use to explain your policies to recruitment agencies who supply workers to you that may use umbrella companies.

The NHS Business Services Authority (NHSBSA) received your request on 25 April 2026.

We have handled your request under the Freedom of Information Act 2000 (FOIA).

Our response

I am writing to advise you that following a search of our paper and electronic records, I have established that the information you requested is not held by the NHSBSA.

Advice and assistance

We procure temporary staff through Alexander Mann Solutions (AMS), who are a supplier on the Crown Commercial Services Workforce Solutions RM6288 (PSR) framework, and not directly from umbrella companies. All managers involved in the hiring process are mandated to use this contract.

AMS has confirmed that where workers are provided by an Umbrella company the umbrella company is responsible for correctly managing PAYE and NICs. Under the Umbrella Tax Reform for contingent workers provided via AMS/PSR, the liability where an Umbrella company fails to process the accurate PAYE and NICs will lie with AMS and/or the umbrella company. This is stipulated in Chapter 11 ITEPA 2003 which states (not verbatim) –

• Where a worker employed by an umbrella provides their services to the end client via a contract which is held by an agency qualifying payments made from 6 April 2026 onwards will be subject to the new rules, with the liability resting jointly between the umbrella company and the agency.

AMS has implemented a reduced Umbrella Approved Supplier List of 4 Umbrella companies and these are the only Umbrella companies that can be used. The AMS Tax Team will conduct regular due diligence on these Umbrella companies including payslip audits to ensure compliance.