Introduction: The UK government recently published a Call for Evidence in the umbrella company market, seeking to gain insights and perspectives on the current landscape. This article aims to provide a summary of the responses received and explore potential scenarios that could shape the future, including the possibility of agencies operating their own umbrella companies.

Summary of Responses: The Call for Evidence garnered a significant number of responses from various stakeholders, including contractors, recruitment agencies, umbrella companies, industry associations, and tax experts. The key themes and concerns highlighted in the responses were as follows:

  1. Regulation and Compliance:

Many responses emphasised the need for improved regulation and enforcement to address non-compliant practices within the umbrella company market. Stakeholders expressed concerns about issues such as tax avoidance, exploitation of workers, and opaque fee structures. There was a consensus that stronger regulation and clearer guidelines were necessary to ensure fair treatment of workers and a level playing field for compliant umbrella companies.

  1. Transparency and Disclosure:

Transparency emerged as a crucial aspect, with respondents advocating for clear and easily understandable breakdowns of fees and charges. Several suggestions were made, such as standardising reporting requirements, introducing mandatory fee templates, and increasing transparency regarding employment status and contractual arrangements.

  1. Employment Rights and Benefits:

A significant number of respondents called for better protection of workers’ employment rights and access to benefits. They highlighted the importance of ensuring that umbrella company workers receive the same benefits as permanent employees, including sick pay, holiday pay, and pension contributions. Many argued that existing legislation needed to be updated to address the unique nature of umbrella employment.

  1. Agency Responsibility:

Interestingly, a notable response from some agencies indicated a potential shift in the market. These agencies expressed an interest in operating their own umbrella companies to ensure greater control and compliance. They believed that by bringing the umbrella function in-house, agencies could directly manage compliance, enhance transparency, and streamline processes.

The Future: Agencies Operating Umbrella Companies: The notion of agencies operating their own umbrella companies presents an intriguing possibility for the future of the market. This approach could potentially address several concerns raised in the Call for Evidence.

Benefits of Agency-operated Umbrella Companies:

  1. Enhanced Compliance: Agencies, as the primary point of contact between contractors and clients, are well-positioned to ensure compliance with legal and regulatory requirements. By establishing their umbrella companies, agencies can directly manage compliance, reducing the risk of non-compliant practices.
  2. Improved Transparency: Operating an in-house umbrella company allows agencies to have complete visibility and control over fee structures, ensuring transparency for both contractors and clients. This transparency can help build trust and promote fair business practices within the industry.
  3. Streamlined Processes: Agencies that operate their umbrella companies may benefit from streamlined processes, as they have greater control over the employment and payment arrangements. This could lead to increased efficiency, reduced administrative burdens, and improved contractor experience.

Challenges and Considerations:

While the concept of agency-operated umbrella companies presents potential benefits, it also poses challenges that need to be carefully addressed:

  1. Compliance Burden: Agencies would need to ensure they have the expertise and resources to navigate the complex regulatory landscape associated with umbrella employment. Robust compliance measures and ongoing monitoring would be necessary to avoid the pitfalls associated with non-compliance.
  2. Potential Conflict of Interest: There is a possibility of a conflict of interest arising when agencies operate their umbrella companies. Agencies must demonstrate transparency and fairness in their dealings with both contractors and clients to maintain trust and credibility.


The Call for Evidence in the umbrella company market shed light on various concerns and suggested potential paths for the future. While the responses emphasised the need for improved regulation and compliance, the idea of agencies operating their umbrella companies emerged as a potential.