HMRC defines payslip fraud plainly: it is a payslip or CIS deduction statement that shows tax and National Insurance deductions which were never actually paid over to HMRC. Guidance published on 25th August 2026, How to Avoid Payslip Fraud, sets this out for agency workers, temporary workers, contractors and anyone paid through an umbrella or payroll company. It is a worker-facing document, telling individuals what to check. For the businesses around them, it is a signal of what they now need to be able to prove.
What Does HMRC’s Payslip Fraud Guidance Actually Cover?
The guidance sits inside HMRC’s wider “Organised labour fraud” collection, consolidated on 10th June 2026, which brings together its approach to tax fraud across labour supply chains. The core message to workers is simple: a payslip is a claim, not proof. Deductions can be shown on the document and still never reach HMRC. HMRC’s advice to an individual is to check their own payslip against its free “work out pay from an umbrella company” tool, updated for the 2026-2027 tax year on 6th April 2026.
That advice works for one worker checking one payslip. It does not scale to an agency or umbrella running a supply chain of hundreds, and it does nothing to help an end-client that needs to show it checked before something went wrong, not after.
Why Payslip Fraud Is Now a Bigger Risk for the Whole Chain
Two changes make this guidance land differently than it would have a year ago. First, new PAYE rules apply to payments made on or after 6th April 2026, making the agency or end-client liable where PAYE has not been operated correctly on payments passing through the chain. This is joint and several liability (JSL). Fraud further down the chain becomes the agency’s or client’s problem, not just the worker’s.
Second, enforcement has consolidated and it is active. The Fair Work Agency has been operational since April 2026, bringing the HMRC National Minimum Wage team, the Employment Agency Standards Inspectorate and the Gangmasters and Labour Abuse Authority under one roof, with National Minimum Wage compliance as its stated first priority. In March 2026 alone it named 385 employers for underpayment, repaid £7.3m to around 60,000 workers and issued £12.6m in penalties. Deductions that quietly take a worker below the minimum wage floor are a breach regardless of what the headline rate on the contract says.
Put the two together and a worker checking their own payslip after the fact is not enough evidence for a business defending its position. The business needs to have checked first, and to be able to show it did.
How Diligence Hub and veriPAYE Answer What the Guidance Describes
This is precisely the gap veriPAYE closes. It verifies a payslip in real time against the underlying payroll data and HMRC-aligned records behind it: gross-to-net accuracy, PAYE and NIC deductions, holiday pay, pension contributions and the worker model in use. Where HMRC’s guidance describes deductions shown on paper that never reached HMRC, veriPAYE checks the numbers against the data behind them rather than taking the document on trust. It supports CIS, PEO and umbrella models, and it is free for FCSA Recruiter Partners and available at very low cost to other recruiters.
veriPAYE sits inside Diligence Hub, FCSA’s due-diligence platform, alongside Diligence Exchange for sharing compliance packs (checked by FCSA Compliance Officers rather than marked as homework by the party submitting them) and live dashboards giving a current view across the chain. Together, they replace the inbox-and-spreadsheet version of due diligence with one platform carrying an audit trail. That is evidence an agency, umbrella or end-client can point to when a client or a regulator asks what checks were actually done.
None of this is an FCSA assessment, and using veriPAYE or Diligence Hub is not the same as being an FCSA Member. It is real-time verification of individual payslips and packs, not an annual, independent assessment of a business against the FCSA Codes of Compliance.
FCSA Membership and the Codes Still Come First
That annual, independent assessment is what FCSA Membership actually is, and it remains the foundation. Diligence Hub and veriPAYE are additional layers that operate between assessments, evidencing day-to-day practice rather than replacing the standard Membership sets. A Member can show both: independent assessment against the FCSA Codes, and a live, verifiable record of the payslips and packs moving through their part of the chain.
For a sector now facing worker-facing fraud guidance, JSL and an active single enforcement body all at once, that combination is the practical answer. Agencies, umbrellas and end-clients who want to see what independently assessed compliance looks like in practice can search the FCSA Members register.
