FCSA chief executive Chris Bryce will speak at the Westminster Employment Forum’s Labour Market conference on 23rd October 2026, on the session covering next steps for regulation of agency work, umbrella companies and the temporary labour market. His contribution focuses squarely on umbrella company regulation and how responsibility should sit across labour supply chains as the new PAYE joint and several liability rules bed in.
The session arrives as the Government prepares its response to the consultation on modernising the Agency Work Regulatory Framework, and as umbrella regulation moves towards its April 2027 start date.
What Chris Bryce Will Cover
Chris Bryce is speaking on the regulation of agency work and umbrella companies, not on a general enforcement panel. His session examines how the rules will actually operate for the businesses that have to comply with them.
The agenda for the session runs across several connected questions:
- Implications of the consultation on modernising the Agency Work Regulatory Framework
- Regulation of agencies and umbrella companies
- Allocation of responsibilities across complex labour supply chains
- Operation of the new PAYE joint and several liability (JSL) rules, and what they mean for agencies, umbrella companies and end clients
- Financial responsibility, due diligence and contractual arrangements
- Transparency around pay, deductions, contracts and employment rights
- Employment status and protections for self-employed, freelance and contracted labour
- Maintaining labour market flexibility and access to skilled temporary workers
- Workforce planning, administrative costs and business preparedness
That is the working reality for FCSA Members: where the money sits, who carries the liability, and what has to be documented before a compliance check rather than after one.
Who Is Speaking Alongside Chris Bryce
Chris Bryce, Chief Executive of the Freelancer and Contractor Services Association (FCSA), shares the session with three speakers who bring the employer, legal and provider perspectives to the same set of questions:
- Karan Chhabra, Head of Policy, UK Warehousing Association
- Frances Lewis, Head of Contingent Workforce UK, Osborne Clarke
- Lucy Smith, Founder, Clarity Umbrella
The mix matters. A trade body representing labour users, a specialist employment lawyer, an umbrella operator and the standards body sit on the same platform because the JSL rules deliberately spread responsibility across all of them. No single party in the chain can now treat compliance as someone else’s problem.
Why Joint and Several Liability Changes the Picture
The PAYE joint and several liability rules for labour supply chains involving umbrella companies took effect on 6th April 2026. Under these rules, where an umbrella company fails to account for PAYE income tax and National Insurance, HMRC can recover the unpaid amounts from another party in the chain — typically the agency, and in some cases the end client.
The practical effect is straightforward. An agency that places workers through an umbrella can be held financially responsible for tax the umbrella should have paid but did not. Contractual comfort alone will not discharge that liability. What protects a business is evidence of genuine due diligence on the providers it uses.
This is precisely where FCSA Accreditation earns its place. Independent assessment against the FCSA Codes of Compliance gives agencies and end clients a documented basis for the checks they carry out on the umbrella companies in their supply chain. It is not a substitute for a firm’s own due diligence, but it is a recognised standard to build that diligence around.
What Agencies and End Clients Should Do Now
The regulatory direction is confirmed, not speculative. The Employment Rights Act 2025 brought umbrella companies within the scope of employment agency legislation, and the Fair Work Agency, launched on 7th April 2026 under Part 5 of that Act, now consolidates enforcement functions previously split across the Employment Agency Standards Inspectorate, the Gangmasters and Labour Abuse Authority and HMRC’s National Minimum Wage teams.
Against that backdrop, agencies and end clients should treat the period before April 2027 as preparation time, not breathing space. That means knowing exactly which umbrella companies sit in the supply chain, confirming where PAYE responsibility actually rests, and holding the records to prove the checks were done. Transparency on pay, deductions and contract terms is no longer a nicety — it is the ground on which liability decisions will be made.
FCSA’s position is consistent. Regulation of the umbrella sector is welcome, provided it targets non-compliant operators without stripping the flexibility that recruiters, contractors and end clients rely on. A supply chain built on accredited, independently assessed providers is the surest way to meet the new liability rules and keep skilled temporary labour available.
Conclusion
Chris Bryce’s session on 23rd October puts FCSA’s compliance-first case directly to policymakers, employers and providers as umbrella regulation takes shape. For any agency or end client working out where responsibility now sits, the answer starts with the providers you use.
Recruiters and end clients can check accredited providers on the FCSA Members register, and umbrella companies can review the requirements for FCSA Accreditation ahead of the April 2027 changes.
Sources
- Westminster Employment Forum, Labour Market conference agenda, 23rd October 2026
- Fair Work Agency advisory board and April 2026 launch: gov.uk
- Employment Rights Act 2025, Part 5 (Fair Work Agency and enforcement)
- HMRC guidance on PAYE joint and several liability for umbrella company arrangements, in force 6th April 2026
