Today’s Treasury leaders sit at the heart of organisational success, balancing liquidity, managing risk and enabling strategic growth. But hiring the right talent can be challenging.

During a period of global growth and an ownership change our client, a leading FinTech organisation, needed to quickly build a strong Treasury function. The challenge was finding senior talent with the right mix of technical expertise, leadership and transformation experience.

Sanderson delivered a focused, efficient search, securing high-calibre Treasury professionals who could both manage today’s demands and shape their future operations.

The result was a fully equipped team ready to support global operations, drive strategy, and add long-term value, all with minimal disruption. Read on to find out how we did it…

What was the challenge?

Our client, a leading FinTech organisation providing infrastructure and workflow solutions for global financial markets, approached us during a period of significant transformation as they looked to build and strengthen their Treasury function.

They were already operating across more than 30 locations across the world and following a major ownership transition involving global shareholders and a private equity investment, they needed a Treasury capability that could not only support their next phase of growth and change, but that could operate across a complex international landscape.

First up, they needed us to identify a senior Treasury leadership team, including a Head of Treasury alongside a Senior Manager and Analyst-level appointments.

But there were challenges.

A Head of Treasury is a role requiring a rare blend of technical expertise, strategic thinking and leadership capability. It’s someone who can establish and develop a function while supporting wider business objectives, so they needed candidates with the right combination of experience across:

• Global cash and liquidity management
• Debt servicing and capital structure optimisation
• Financial risk management
• Covenant reporting and compliance
• Regulated business environments
• Treasury transformation and automation
• Stakeholder management with shareholders, lenders and senior executives

What was our solution?

Due to the seniority and specialist nature of the roles required, speed and precision were critical.

So, the Sanderson London team quickly set to work, immediately focusing our search on highly specialist Treasury expertise. We conducted a targeted search focused on candidates with experience covering:

• Treasury leadership within multinational organisations
• Private equity-backed or regulated businesses
• Complex debt structures and covenant management
• Global cash forecasting and liquidity optimisation
• FX, interest rate and wider financial risk management
• Treasury technology, automation and process improvement
• M&A and investment strategy support
• Building and transforming Treasury functions

We made sure to identify individuals who could not only manage the existing Treasury requirements, but who could also help shape the future operating model of our clients’ organisation.

What was the result?

With a targeted search process, we successfully delivered a strong pipeline of credible Treasury professionals for all the roles required, with the right combination of technical capability, transformation experience and commercial understanding.

The client successfully scaled their Treasury function with the right talent needed for their global organisation and to support them during a period of significant change.

Not only that, but the skills this new Treasury team brought helped them to establish a function capable of supporting not only their operational requirements, but their long-term strategic goals.

Key outcomes included:

• Identification of candidates with direct experience operating in complex global environments
• Shortlisted professionals aligned to the organisation’s strategic objectives
• Provided the exact leadership and operational Treasury expertise the client required
• A recruitment process managed with speed, precision and minimal business disruption
• Delivered significant cost savings by reducing contractor usage and cutting unnecessary third‑party spend.

Could we help you achieve similar outcomes?

Building specialist finance functions requires more than finding qualified candidates. It requires understanding the business challenge, the technical requirements and the future direction of the organisation.

Whether you’re strengthening your Treasury team, transforming finance operations or building specialist capability during a period of change, Sanderson can help you identify the talent needed to deliver critical business outcomes.

To discuss how we can support your next key hire, get in touch on [email protected]

Financial services recruitment has entered 2026 on a strong footing, with hiring activity increasing across insurance, banking and professional services.

While London remains the dominant centre for specialist talent, growth is becoming increasingly dispersed across the UK as employers respond to skills shortages, cost pressures and shifting business priorities. What’s emerging is a market shaped just as much by long-term structural change as by the wider economic environment.

But how is this playing out across different areas of financial services hiring?

At Sanderson, we keep our finger on the pulse of the latest market movements so we can help you understand how these trends may impact your hiring strategy and where the opportunities may lie.

That’s why we’re pleased to share our latest Report produced in partnership with VacancySoft, highlighting the key developments across the UK Financial Services market during May.

Here’s a sneak peek of some of the key insights:

Claims Hiring Driven by Talent Shortages

London claims vacancies were 12% higher in Q1 compared to last year, with March alone running approximately 30% ahead of March 2025, reflecting a widening experience gap, as retirements accelerate and insurers compete for highly specialised talent.

Northern Cities Continue to Attract Professional Roles

The North of England is seeing sustained growth, with professional vacancies reaching a record high in March and cities like Manchester and Leeds continuing to attract roles that would previously have been London-based.

Actuarial Demand Accelerates

Demand for actuarial talent remains elevated, particularly in London with vacancies running approximately 16% ahead of early 2025 levels.

Scottish Banking Market Sees Significant Growth

Scotland is emerging as a key growth area within banking with commercial banking vacancies roughly trebled since the beginning of 2025, now exceeding banking operations roles.

Underwriting Talent Shortages Intensify

London underwriter vacancies are running at almost double the volume of the next-largest role category, highlighting the scale of demand and ongoing talent shortages in this area.

If you’d like a more detailed overview of these trends, including the latest market data, vacancy totals and insights into the most in-demand roles, then download the full Report below.

Have any questions? Don’t hesitate to get in touch, we’re here to help you turn insight into action.

Insurance companies operate in highly complex and heavily regulated environments meaning they don’t just need to hire talent; they need to hire specialists.

Whether it’s understanding complex risk trends, meeting strict regulatory requirements like Solvency II or making sense of huge amounts of data, insurance companies need people with specific expertise to keep their operations running smoothly.

This need for specialist talent is especially clear in actuarial teams and even more sought-after in roles like Internal Model Specialists. These specialists require a strong understanding of how different asset classes behave under varying market conditions, alongside the ability to combine actuarial expertise with advanced stochastic and risk modelling techniques. They must assess how portfolios respond across a range of scenarios from expected market movements to severe stress events enabling insurers to better understand their risk exposure, capital requirements and financial resilience.

These roles are specialised and hard to fill, but insurance companies working with Sanderson trust us to deliver. Just as our London team did for this leading life insurer…

What was the challenge?

A market-leading life insurance provider came to us when they were looking to hire a candidate for a highly specialised interim actuarial position, an Internal Model Specialist. This was a role they needed to fill to support a critical enhancement to their Solvency II Internal Model framework.

The client needed us to identify an experienced contractor capable of designing and implementing an explicit interest rate volatility risk framework, including swaption-driven dynamics, calibration methodology, dependency modelling and even governance-ready documentation.

What was our solution?

It was clear from the outset that this role demanded highly niche expertise. Due to the technical complexity and scarcity of suitable contractors in the market, speed and precision were critical.

So, we quickly mobilised to conduct a thorough search that was broken down to look for candidates with experience covering:

• Solvency II / Solvency UK Internal Models
• Interest rate and swaption modelling
• Yield curve and PCA frameworks
• Correlation and dependency modelling
• Internal Model governance and validation

What was the result?

Within just 24 hours of receiving the brief, our team delivered a fully vetted shortlist of highly credible and niche actuarial specialists each with directly relevant Internal Model and derivative modelling experience, exactly what the client was looking for.

Key outcomes included:

• Highly technical quantitative requirements broken down into targeted searches
• 3 candidates shortlisted within just 24 hours
• 100% shortlist-to-interview conversion
• Successful placement completed within one week
• Full process managed end-to-end with minimal client downtime

The client was able to hire the specialist talent they needed, and the successful candidate brought extensive experience delivering governed Internal Model enhancements within life insurance environments including interest rate volatility calibration and capital model dependency design.

Could we help you achieve similar outcomes?

If you’re looking for a recruitment partner to help you source business-critical appointments in tight turnaround times, we’re here to help.

Whether for its actuarial talent as niche as this role, or other insurance specialities you need to move quickly on to stay competitive, then don’t hesitate to reach out on [email protected] and let’s have a chat about how we can help.

Insurance hiring has begun 2026 stronger than expected, with consistent growth across technology, security and transformation roles.

The market has even seen an acceleration in investment as regulatory pressure, geopolitical risk and AI adoption increasingly converge and we’re now looking at a market preparing for change as Insurers seem to be increasingly hiring for long-term structural change rather than short-term growth.

But how has this translated into the rest of financial services hiring?

At Sanderson we always have our finger on the pulse of the latest changes in the market so that we can help you better understand how new trends might impact your hiring plans and then support you to turn these into opportunities when it comes to your financial services recruitment.

So, with that in mind, we’re pleased to have produced this new Report with VacancySoft that sums up the latest trends we’ve been seeing in the UK Financial Services market during April.

Have a sneak peek at some of the highlights below and scroll down to grab your copy!

Insurance IT and AI Demand

Demand for insurance IT and AI professionals rose sharply through Q1, with March vacancy levels nearing record highs.

Rise in Cybersecurity and Operational Resilience

Cybersecurity recruitment has accelerated, with London accounting for over half of insurance IT security vacancies in Q1.

Insurance Hiring Strengthens

Hiring activity strengthened across the wider insurance market throughout Q1, with London seeing the most visible uplift. Increased claims complexity and continued investment in transformation capability are supporting demand.

Regional Shifts and Senior Hiring Trends

While London remains dominant, the North West has seen growing specialist hiring as middle office functions expand. Scotland also recorded increased executive hiring, reflecting a renewed focus on leadership.

If you would like a more detailed overview of these trends, including the latest market data, monthly vacancy totals and insight into the top job roles by sector, then please do download a copy of the full Report via the form below.

Have any further questions? Don’t hesitate to get in touch with us, we’re well placed to help.

A global Insurance company recently came to Sanderson needing to address their change management delivery and capability.

They were looking to build a permanent Enterprise Change team in a short space of time, so the Sanderson team quickly stepped in to help source, screen and deliver multiple roles in this space. Working as a strategic partner, our team delivered at pace and in a way that would set this client up for the future, and the project saw success highlights such as:

• Over 5500 candidates approached
• Creation of a bespoke cognitive assessment process
• 196hrs of hiring manager time saved
• 100% offer acceptance rates

Read on to discover how.   

The Challenge

The client had recently appointed a new Head of Enterprise Change, and they made some key observations such as the need for the company to bring in more experienced staff to support their change capabilities and delivery.

A proposal was then put together for a more effective change delivery framework which would reduce contractor cost and build a permanent internal change team. This structure came under four pillars: Portfolio Management, Change Management, Project Management and Business Analysis.

With only a handful of permanent Business Analysis and Project Managers and no Change Managers within Enterprise Change, the client needed to resource the team with the right disciplines in a short space of time.

Introducing Sanderson as a Resourcing Partner

Upon realising they needed to scale at pace, the client needed the help of a talent resourcing partner and so invited three recruitment companies to present a solution that would:

• Take responsibility for the end-to-end hiring process
• Elevate the client as an employer of choice
• Provide access to specialist talent in the insurance sector
• Save hiring managers time

During this process, it was clear for the client who would be their recruitment partner of choice.

“Sanderson was our first choice, we were drawn to their ways of working and instinctively knew it was the right path. It wasn’t just a good communication discussion, they stood out because they offered a sense of partnership but also a sense of transparency, agility and flexibility. Right from the get-go, it was their partnership approach that won the show.”

An Agile and Flexible Solution

The solution wasn’t just a “one-size-fits-all”. Led by Sanderson Insurance Practice Lead Denise Morris, we took the time to listen and work in partnership with the client. Here’s some of the key factors that stood out for them during the process:

Commitment

“They did all the heavy lifting for us”.

Sanderson hit the ground running with weekly meetings and created a dedicated reporting cycle in an interactive approach to screening, interviewing and shortlisting candidates in a short space of time.

“What worked was that we iterated our way to getting the best candidates, and that happened so fast, for the first round of screening they were coming to us with recommendations. It didn’t feel like a numbers game, Sanderson presented individuals who were quality candidates”.

With confidence in the top candidates, Sanderson offered advice and consultation in the final stages and presented the strongest CVs. This was then supported by a bespoke cognitive assessment process that was specific and unique for these types of change and transformation hires.

Flexibility

The client’s team really felt like they had a voice throughout and were heard when things needed to change. Sanderson were quick to respond to the evolving needs of the programme.

“As the recruitment process progressed, we had a much clearer vision and criteria for the type of candidates we wanted to interview. We knew what we needed, as did Sanderson, they helped to fine tune that process, they came on that journey with us.

While the scope of our requirements had evolved, our new recruits have surpassed expectations. They quality of candidates has been commented on by people outside of our team in their first 1-2 months of working here”.

A Strategic Partnership

The client reflected on the partnership and how Sanderson took their time to understand not just their strategic goals, but also their culture:

“I think one of the biggest things was the effort the team put into understanding us, what we were looking for and what we were building out. They understood the nature of the projects that we would be likely to drive and equally the projects we weren’t going to drive.

It was great to see the camaraderie being built by the new cohort of recruits. As they joined at the same time, there was a real sense of being in it together and we have worked to cement this attitude by organising workshops with the existing teams. The Sanderson team played a strategic role in helping us to construct our team charter”.

An Extension of the Team, Enabling BAU for Talent Acquisition

The client’s Talent Acquisition Lead expressed how Talent Acquisition worked seamlessly with both the Enterprise Change team, the team at Sanderson and together they delivered the work “as a triad”. Everyone had their role to play, and it freed up time for the TA team to work on the day-to-day support for the rest of the business.

“It was the effectiveness of Sanderson and the way they worked to ensure that I could carry on with my BAU job for the other parts of the business I support. I pretty much handed it over to Sanderson and trusted them to expedite this. And that’s exactly what happened. I was only really needed for facilitating admin or interviews. There was no disruption to the rest of Talent Acquisition, it was all in hand.”

Summary and reflections

A Project RPO Success

The solution we delivered here is called a Project RPO. This is a flexible recruitment solution that offers many of the benefits of outsourcing recruitment to a resourcing partner, but without the long-term commitment. You can find out more about Project RPO here.

Here’s what we delivered in numbers: 

Find out more about our RPO solution and get in touch with the team here if you’d like to have a conversation.

The UK insurance market has recently shown a clear divide in the number of vacancies available between London and the regions as economic pressures and technology reshape hiring.

In this blog we breakdown which regions across the UK currently have the biggest share of insurance vacancies as well as exploring reasons why some regions have a greater proportion of these roles than others.

Which region has the most Insurance vacancies?

London remains the largest centre for insurance vacancies, accounting for 44.3% of these specialist positions.

This is helped by the capital continuing to be the home of major underwriting, broking and claims operations as well as benefiting from international connections and a concentration of head offices for some of the biggest Insurance firms operating within the UK.

What are the regional trends in Insurance vacancies?

Outside of London however, trends in Insurance positions available vary widely.

The South East, West Midlands, South West and East of England have all seen significant falls in these vacancies recently, reflecting automation of routine roles and weaker regional investment.

Looking to the North East and Northern Ireland, these are regions that have also experienced a sharp decline in advertised insurance roles.

By contrast, the North West and Scotland have seen growth in the number of Insurance vacancies advertised. This has been supported by targeted public investment and regional innovation hubs.

Is company activity impacting Insurance vacancies?

Insurance company activity is mirroring these trends. For example, Aviva’s £3.7bn acquisition of Direct Line Group is expected to reduce duplicate roles across regions and so will impact the number of vacancies available outside of the capital.

Another example is how RSA, now rebranded as Intact Insurance, has started centralising some functions into larger hubs, thereby reducing the amount of insurance positions within the regions.

Conclusion

The result of these trends is a UK insurance sector that’s become increasingly focused on London, with selective regional growth where investment, policy support and company strategy combine.

But looking into the rest of 2026, how can the southern regions rebound? Or is this trend of Insurance vacancies now centralised in London, with some Northen regional activity irreversible?

To find out more about trends in the Insurance industry, why not download our UK Insurance Labour Market Trends: Year in Review Report which will arm you with market-leading data into this dynamic market such as the most in-demand skills in the industry right now and insight into companies to watch based on their current hiring practices.

The UK insurance industry is currently undergoing a major transformation as technology, automation and market pressures reshape recruitment. Artificial intelligence, digital platforms and data-driven underwriting are changing how insurers operate which is reducing demand for some roles but creating new opportunities in others.

The result?

A huge shift in both the number of vacancies available as well as the skills employers are now seeking.

Here we explore which skills are the most sought after and which are seeing decline in the UK Insurance industry right now.

Claims

Claims roles remain the largest area of in-demand specialist jobs in the insurance industry right now, accounting for nearly 30% of insurance vacancies, despite a 28% fall between 2023 and 2025.

We’re currently seeing automation and AI taking over routine claims processing, which is reducing the need for entry-level staff, while specialist and experienced professionals are remaining essential for complex cases.

Underwriting

Underwriting has seen only a slight drop in vacancies (just 1.1%), staying well above 2023 levels and reflecting the ongoing demand for expertise in risk assessment, pricing and regulatory compliance.

Broking

Broking has been hit hardest with vacancies falling from 4,721 to 2,114 over the surveyed period, a 38% decline.

Demand for skills here seems to be reducing thanks to digital platforms such Willis’s Gemini or Aon Broker Pilot which work to automate workflow and placements without the need for a human candidate. Startups such as Meshed, an AI-compliant broker for SMEs, are also accelerating this shift away from traditional candidate based roles.

IT, Digital & Finance

Across the Insurance sector, we’ve seen IT and digital roles growing in numbers. Demand for IT skills is in fact up 6.6% year-on-year. On the other hand, demand seems to be dipping in relation to Finance roles in the insurance sector which have fallen by 13.5%.

Actuarial

Actuarial vacancies continue to decline (down by 13.2% year on year), particularly at entry level as AI now handles routine modelling which reduces the demand to fill these positions.

Demand however is rising for specialists in predictive modelling, cyber risk and AI governance.

Conclusion

Fewer positions are now requiring purely traditional expertise and the most sought-after professionals now need to combine technical, analytical and strategic skills, with salaries rising to match.

The question for the industry is: what comes next?

Have the benefits of automation been realised, or will this trend continue to impact the sorts of skills the industry is seeking? And what will it mean for those seeking to enter the sector in the coming years?

To find out more about trends in the Insurance industry, why not download our UK Insurance Labour Market Trends: Year in Review Report which will arm you with market-leading data into this dynamic market such as regional breakdowns of the insurance recruitment market right now and insight into companies to watch based on their current hiring practices.

In case you missed it, we recently launched our brand-new Financial Services Hiring Trends Report for 2025 which focuses on Digital, Technology, Change and Transformation hiring in the Financial Services sector during 2025.

The Report shows the positive news that there’s been a 12% increase in industry wide vacancies, with all signs pointing towards an optimistic and energised 2026 in the finance sector.

With the signals clear that financial services employers are beginning to re-engage with long-term workforce planning, in this blog we get stuck into some of our six top predictions for Financial Services hiring throughout the rest of 2026.

Let’s get started!

1 Increase in hiring intentions

We’re predicting an increase in hiring intentions throughout the rest of 2026, backed up by recent survey data from KPMG that’s reported that 55% of financial services firms are planning to hire more staff this year than they did in 2025.

The focus of these hiring strategies also appear to be very much technology led, with data indicating that 57% of those firms planning to hire intending to invest in AI skills. This could indicate a clear shift this year towards digital capability and AI transformation.

2 Growing business confidence

According to many business leaders across Sanderson, there’s a clear theme emerging showing growing confidence among financial services employers. This is a theme we predict to continue through the rest of the year as many of our recruiters are expecting new vacancies to emerge from major banks finally progressing with their long-awaited and large-scale digitalisation projects.

We’re also predicting an uptick in the industry-wide appetite for strategic leadership as well as future investment in technology and change projects. A prediction backed up by many of our recruitment teams noticing a number of senior hires being prepared throughout Q1.

3 Steadier market conditions

We’re anticipating that the market will start to steady out quickly during the start of 2026 thanks to optimistic regional fintech investment as well as large public sector investment. This is backed up by the Bank of England going public with its desire to expand regionally and even allocate 50% of it’s roles outside of London by 2027.

4 Reignition of DEI programmes

Our recruitment teams are also predicting a reignition of Diversity, Equity & Inclusion (DEI) programmes throughout the financial services sector. This aligns with companies in the sector becoming less reactive in their hiring and moving towards more deliberate hiring with clearer strategies to attack the marker and then deliver on long-term projects.

5 Larger candidate supply

Another prediction we’re making for 2026 financial services hiring is that the start of this year will see some of the largest candidate supply opportunities that we’ve seen since the Covid-19 pandemic of 2020. This is backed up by recent KPMG data reporting that the end of 2025 saw permanent labour availability rise at its fastest rate in four months.

And what might this mean for financial services decision makers? Well, we’d expect organisations to be well positioned to reach any immediate transformation goals thanks to access to a strong pool of talented Project Managers, Business Analysts and Testers being available to tap into.

6 Stable salaries

Our recruiters are expecting stable salary conditions for the start of 2026. Despite busy hiring markets towards the end of last year, current salary trends are not implying that a big spike in salaries is on the cards. Combine this with current market activity showing steady but controlled competition, we’re predicting that salary conditions will balance out rather than overheat as we progress through the start of the year.

How to get ahead of your financial services hiring in 2026

We’re optimistic that thanks to greater market clarity and larger talent pools being available, businesses in the financial services sector will be able to bolster their teams with talented hires that can deliver on long-term strategies and goals.

So with this in mind, now may be the time to reassess your hiring strategies, enhance your understanding of emerging technologies and address your skills gaps with the right blend of permanent or contractor talent.

To get yourself feeling more prepared to tackle the year, why not download your own copy of our new Financial Services Hiring Trends Report which reflects on and provides insight into how market trends have shaped hiring throughout the Financial Services sector, as well as providing market-leading data to help organisations like yours position yourself competitively to secure top talent in an increasingly dynamic market.

Set yourself up for success by downloading a copy of the Report here:

We’re pleased to present Sanderson’s brand-new Hiring Trends Report focusing on Digital, Technology, Change and Transformation hiring in the Financial Services sector during 2025.

This much anticipated report provides an overview of which roles saw hiring surges and the most demand during 2025, insight into hiring conditions throughout the UK, our expert opinion on where demand might be headed for 2026 as well as data to help guide companies on where they can gain competitive advantages in the market to help them obtain the best candidates out there.

The beginning of 2025 saw many employers demonstrate hesitancy towards their permanent hiring, largely driven by budget restrictions and wider uncertainty in the economic environment. However by the end of the year thanks to factors like a prioritisation of digital transformation causing a surge in demand for AI skillsets, we were seeing hiring conditions improve significantly, even a permanent market that was 44% more active year on year by December 2025.

With market-wide data indicating that 2026 should open with more a more optimistic hiring outlook, now may be the time to reassess your hiring strategies, enhance your understanding of emerging technologies and then address your skills gaps with the right blend of permanent or contractor talent.

This report, using data from VacancySoft and LinkedIn and reviewed by Sanderson’s market-leading experts, reflects on how these trends have shaped hiring throughout the Financial Services sector in 2025, as well as providing predictions on how it may evolve throughout the remainder of 2026.

Do you feel ready for the Umbrella Reforms due to come into effect later this Spring?

Don’t worry, we’re here to help you feel more prepared!

You might have seen that last year we hosted a webinar with PayStream where our Recruitment Services Managing Director William Boney and Head of Operations & Organisational Change Anna Kramer sat down with the PayStream CEO Tony Hodkinson for an informative discussion all about the upcoming tax legislation changes and the Employment Rights Bill 2027.

These changes are set to have an impact on many umbrella companies and be felt across the whole recruitment industry, so we want to help you navigate this period of change.

Watch the Recording

As well as providing you with a link to watch the full recording to get you up to speed on discussion points such as:

• A clear overview of the tax legislation changes, including joint and several liability due in April 2026
• The impact of the Employment Rights Bill due in April 2027
• How this new legislation impacts you and how you can prepare for the change
• How you can protect yourself from liability and carry out appropriate due diligence, including insight into PaySteam’s own 6-Point Compliance Plan
• Exactly what we at Sanderson are doing to ensure compliance across the supply chain and to keep a smooth process for our clients and contractors

This blog will also provide an overview of key questions asked and answered in the informative Q&A session during the webinar. Scroll down to explore…

Umbrella Reforms FAQs

Could a client still be liable if they have not done due diligence on an agency?

Where there is a UK agency in the supply chain between the client and umbrella company, the agency and umbrella company are the ones liable if there is a tax liability. The client would not be jointly and severally liable in that scenario.

If an agency cannot pay a tax bill, does liability flow back up the contractual chain?

The legislation does not currently suggest that liability could flow up the chain if neither the umbrella or agency could pay the bill. However, we’re still waiting on official guidance and the legislation is only in draft format, it may of course change before it receives Royal Assent.

Could consulting companies who are acting like an MSP for a client be held liable under the Umbrella Reform legislation?

Yes, we believe that MSPs will be on the hook should any tax liability accrue in relation to a non-compliant umbrella company in the supply chain. “Umbrella company arrangements” are broadly defined in the draft legislation such as to include these types of contractual arrangements with the end client.

What steps are the FCSA are taking in regards to the Umbrella Reform legislation? And, if they find a member to be non-compliant could they reject their membership and be transparent to agencies?

The FCSA themselves will be best placed to answer this question in the most detail, but yes we do understand the FCSA to have robust policies in place to investigate members for alleged non-compliance with its compliance codes, and that can ultimately lead to suspension and even expulsion for serious breaches.

Do you see clients (or MSPs) simply banning the use of umbrella companies as a result of this legislation?

The Employment Rights Bill is adding more complexity and litigation risk to employers, causing a headache for many businesses. Where an end client engages with an agency that has a connected or in-house umbrella company, we perceive clients moving towards independent umbrella companies to ensure the joint and several risk falls on the umbrella company and the agency. We also perceive clients reducing and dictating the umbrella PSL to ensure only financially robust, compliant and trusted partners are engaged in the supply chain

Could all of this extra administration lead to higher umbrella fees?

Yes, we foresee that umbrella margins will be under more pressure. There will be additional cost for the umbrella in evidencing its compliance, such as third-party payslip checking software. However, it may hopefully level the playing field and increase volumes as non-compliant operators exit the market.

Why would agencies be liable before umbrella companies? What would this look like in practice, if, for example, a simple mistake is made by an umbrella company?

HMRC will consider what “relevant parties” there are in the supply chain. The umbrella and the agency that holds the contract with the client will be jointly and severally liable. If there is no agency, liability will sit with the umbrella and client. In a recent policy paper, HMRC said joint and several liability will allow them to pursue an agency in the first instances for any payroll taxes that a non-compliant umbrella company fails to remit to HMRC. If a compliant umbrella company has made an innocent error in their payroll taxes, it does seem more likely that HMRC will go directly to the umbrella company to resolve the issue. Official guidance may clarify this for us in the coming months.

Next Steps

Do you have any more questions in regards to the Umbrella Reform changes due to come into effect in a few months? Don’t hesitate to reach out to Will Boney to find out more.