JSL Will Be Proved in Systems Not Statements

Setting the stakes for 2026

The incoming Joint and Several Liability regime in April 2026 will push accountability for labour supply risks up the chain to agencies and end clients. That shift means promises will no longer suffice when engaging umbrella companies. Agencies will increasingly ask for verifiable evidence that PAYE is operating correctly in real time and that worker protections are genuinely in place. The market is moving from comfort in badges to confidence in auditable data.

From badges to verifiable operations

Accreditation schemes emerged to solve a practical problem. Agencies had limited visibility of day-to-day payroll operations and little capacity to verify what happened beneath the surface. A third party badge became a proxy for diligence when time, access and data were constrained. That proxy was understandable in a world of static documents, monthly checks and fragmented systems. It is less persuasive when modern software can expose the live workings of payroll, employment and statutory controls.

Regulators and agencies care less about logos and more about whether PAYE has been applied correctly to each worker, on each pay run, with correct RTI alignment and timely downstream payments to HMRC and pension providers. They want to see right to work evidence that maps to active assignments, employment contracts that match payment records, and policies that are version controlled and demonstrably in force. When these artefacts are current, dated and audit ready, ambiguity falls and the reliance on third party accreditation as a substitute for oversight reduces materially.

Evidence-led compliance in practice

Modern umbrella focused platforms now allow companies to generate and retain a complete compliance evidence pack on demand. At a minimum this includes PAYE records, RTI submissions, payslips, gross to net reconciliation reports, pension enrolment and contribution files, right to work documentation, and proof of tax payments. The strongest systems link these items to the worker, the pay period and the payment event so that each fact can be verified against a traceable audit trail. That design supports both internal governance and external scrutiny.

The goal is not to assemble documents after the event, but to operate processes that produce evidence as a natural output.

This is where software enablement providers such as MYUHUB play a central role. MYUHUB gives umbrella companies access to specialist systems designed for the sector, acting as a hub for governance, transparency, operational control and evidence led compliance. Agencies can review how software supports compliance readiness in practice by visiting My Umbrella Hub, which outlines how platforms are deployed and how data flows support verification.

When accreditation turns to software

Some accreditation bodies are now signalling an intention to introduce or mandate their own software solutions as a way of evidencing compliance under JSL. That shift itself is an acknowledgement that assurance based models are no longer sufficient and that live operational data is required. The question for umbrellas and agencies is, why duplicate capability through an accreditation layer when specialist umbrella platforms already generate this evidence as part of day to day operations. Systems such as Distinction by MYUHUB already capture the worker data payroll logic, RTI alignment, and payment records that accreditation schemes are now seeking to surface. Adding parallel tools risks cost complexity and fragmentation without improving visibility where robust systems are already in place.

Distinction and the mechanics of readiness

Distinction, available through MYUHUB, is a Windows based CRM built specifically for umbrella companies. It is designed to manage the complexity of thousands of workers while maintaining accuracy, traceability and governance. Within Distinction, worker records, assignment details and payroll configurations are structured so that PAYE calculations are consistent, auditable and aligned with RTI reporting. Gross to net outputs can be reconciled to source inputs and statutory parameters, while payment records demonstrate that net pay is made directly by the umbrella to the worker, with onward remittances to HMRC and pension schemes evidenced.

Distinction enables umbrellas to store, validate and surface compliance information across payroll, employment and statutory obligations in a consistent manner. Right to work checks can be retained with date stamps and reviewer identities. Contracts, Key Information Documents and assignment schedules can be linked to payroll cycles. Policies covering holiday pay, expenses and grievances can be version controlled so that an auditor can see what applied to whom and when. The result is an integrated evidence pack that is current, searchable and easy to share with agencies and regulators.

Distinction is not the only platform capable of enabling this approach. Other specialist umbrella software providers can also support evidence led compliance when configured and governed well. The key differentiator is not a badge on a website, but the umbrella’s proven ability to surface records that match the worker, the period and the payment. Under JSL, that capability will define trust.

What agencies will expect next

As April 2026 approaches, agencies will move from assurance to verification. Expect requests for data extracts, reconciliation proofs and RTI alignment checks as standard engagement conditions. Umbrellas that use platforms like Distinction through enablement providers such as MYUHUB will be able to supply real time evidence, not retrospective narratives. Next steps for compliance leaders include mapping current evidence gaps, assessing software readiness and aligning processes so that every compliant action creates an auditable record.

Contractor News view

Contractor News expects the JSL framework to accelerate a market-wide shift towards proof based compliance. Accreditation will still have a place, but it will no longer carry the weight it once did when agencies lacked visibility. Transparent systems, robust documentation and operational control will set the standard. Software led evidence offers a practical route to that outcome, giving umbrellas and agencies confidence grounded in verifiable data rather than promise alone.