Labour-supply-chain controls

Umbrella supplier compliance reviews for healthcare labour chains

Regular evidence reviews, issue tracking and documented decisions for agencies and end clients using umbrella companies in their worker supply chain.

The business issue

Assurances are not the same as evidence.

From 6 April 2026, PAYE rules for labour supply chains involving umbrella companies place direct financial exposure on the relevant agency or, where there is no agency, the end client. A supplier being on a preferred list does not remove the need for proportionate due diligence and ongoing monitoring.

Carrick helps build a practical monthly review around the evidence supplied by each umbrella company. The process records what was received, what was checked, which items are missing, what appears inconsistent and who approved the outcome.

The review does not replace HMRC, legal, tax or employment-status advice. It creates a controlled evidence trail and a clear route for specialist escalation when a concern cannot be resolved through routine checks.

What the work can include

What the monthly review can cover

The exact work is agreed around the organisation, the available information and the decision or control that needs improving.

Supplier standing

Company details, directors, registrations, banking checks, insurance and contractual information.

Payroll evidence

Sample payslips, payroll summaries, PAYE and National Insurance information and payment evidence.

Pension and VAT

Pension evidence, VAT returns and supporting payment or reconciliation information where relevant.

Worker documentation

Key information documents, contracts, assignment examples and checks around worker deductions and pay.

Issue management

Missing-evidence follow-up, inconsistencies, risk grading, escalation and documented approval decisions.

Governance reporting

A control sheet, supplier register, monthly status and clear ownership across payroll, procurement and management.

When this support may fit

Warning signs that need follow-up

  • Evidence is late, incomplete or changes format each month.
  • Payroll, payslip, bank and HMRC figures do not reconcile.
  • The supplier cannot explain deductions or pay calculations.
  • Company, bank or insurance details change without a clear reason.
  • The labour chain is unclear or includes additional intermediaries.
  • Concerns are discussed but not recorded, escalated or resolved.
A useful result

A review that can be evidenced

  • A consistent supplier evidence checklist.
  • Monthly pass, concern and fail criteria.
  • A clear record of missing and inconsistent information.
  • Named owners and deadlines for follow-up.
  • Documented decisions on continued supplier use.
  • A route to legal and tax specialists for unresolved risk.
How the work progresses

A clear route from question to action.

The scope, responsibilities, evidence, timetable and fees are agreed before the engagement begins.

  1. 01

    Set the standard

    Agree the supplier register, required evidence, submission deadlines and escalation criteria.

  2. 02

    Review each month

    Reconcile the documents received, record exceptions and follow up missing or inconsistent evidence.

  3. 03

    Report and decide

    Summarise the risk position, escalate concerns and retain the decision trail.

Official guidance

Primary sources for the rules and framework.

Frequently asked questions

What owners and management teams usually ask.

These answers are general. The appropriate approach depends on the organisation and the agreed remit.

Who is exposed under the umbrella PAYE rules from April 2026?

Government guidance says the agency with the contract to supply the worker is responsible for ensuring PAYE is operated correctly. Where there is no agency, the end client has that responsibility. Liability can be joint and several with the umbrella company.

Does due diligence remove the PAYE liability?

No. Due diligence can reduce operational and supplier risk, but it does not switch off a statutory liability. Specialist tax and legal advice may be needed for the supply-chain structure.

How often should umbrella suppliers be reviewed?

The frequency should reflect risk and the evidence available. Carrick's service is designed around a regular monthly pack, with standing documents reviewed when they change or expire.

Can Carrick approve an umbrella company?

Carrick can document the evidence review and provide a risk assessment against agreed criteria. The business remains responsible for its supplier decision and should obtain specialist advice where concerns are significant.

Related support

Connect this work to the wider financial position.

Healthcare finance issues rarely sit in isolation. These related services may be relevant to the same decision or risk.

Start with the situation, not a service label.

Tell us what is happening and what a useful outcome would look like. We will help define the right starting point.