External Workforce Governance Guide

IR35, umbrella company liability and right to work across your supply chain. Know who is doing the work, and what you owe for each engagement.

Since 6 April 2026, agencies and, in some chains, end clients are jointly liable for an umbrella company's unpaid PAYE. Since 1 October 2026, the right to work scheme covers new working arrangements and extended liability.
Each regime asks a different question. This guide shows you how to follow the work through your supply chain, gather information you can rely on and record decisions you can explain. With contributions from:

John Chaplin, Partner, London Employment Tax - BDO
Rebecca Seeley-Harris, Employment Status, Off-payroll & IR35 Expert - Re:legal Consulting

What you will learn

• How far down your supply chain to look, and what to ask at each step
• Who makes the IR35 determination, and how to complete the process, not just the assessment
• Who is jointly liable with the umbrella, and what the evidence actually proves
• What the right to work extension means for your role in the chain
• How to use spend to prioritise a review of existing suppliers
• How to build checks into purchasing, so new work starts with the right decisions in place