Who checks references when a contractor uses an umbrella company?
The umbrella runs payroll. The agency supplies the worker. In almost every case, the agency is the one who has to have checked them.
Do umbrella companies check contractor references?
Usually not. An umbrella company employs the contractor for payroll, but the agency that introduces or supplies the worker to the client carries the vetting duties under the Conduct of Employment Agencies and Employment Businesses Regulations 2003. So umbrella company references are normally the agency's job. RefAssure lets the agency collect consent, chase referees and keep a signed PDF for each contractor.
Why the agency still owns the check
Three parties sit in an umbrella arrangement. The client wants the work done. The agency (in law, usually an employment business) finds the contractor and contracts with the client. The umbrella company employs the contractor and runs PAYE. Because payroll moves to the umbrella, it is easy to assume vetting moves with it. It does not.
The Conduct Regulations place their checks on the agency or employment business that introduces or supplies the work-seeker. Regulation 19 requires it to confirm identity and that the person has the experience, training and qualifications the client considers necessary. Where the work involves vulnerable people, Regulation 22 adds two references from people who are not relatives and who have agreed the reference can be shared with the client. None of that is passed to an umbrella just because it pays the worker.
What the umbrella usually does
A well-run umbrella will check right to work as an employer and handle tax, pension and holiday pay. Some ask for basic employment history. Very few take references in the way a client expects, and the client contract is with you, not with them.
Changes in 2026 and 2027
Since April 2026, HMRC rules make agencies jointly liable for unpaid PAYE by the umbrella companies they use, and the Fair Work Agency now enforces employment agency standards. The government has said umbrella companies will be brought into regulation from 2027. The direction is clear: agencies are expected to know who sits in their supply chain. Check GOV.UK for the current position.
What to cover for umbrella contractors.
The same reference you would take for a PAYE temp, plus a little context on how they have worked.
Engagement history
Dates, end clients and the agency or umbrella for each recent contract, so gaps are explained.
Conduct and reliability
Ask the end client manager, not the umbrella payroll team, how the contractor actually performed.
Skills claimed
Confirm the tickets, systems or experience the client is paying for were used on the job.
Vulnerable settings
For care, health or education work, add the suitability questions those sectors expect.
Would they rehire?
A simple yes or no that tells you a lot about a contractor who moves between clients.
Signed and dated
Each referee signs, so the reference stands up if a client or auditor asks later.
One record, whoever pays them.
Add the contractor once. RefAssure gets their consent online, then contacts each referee and chases until they reply.
- Consent with signature before any referee is contacted
- 5 emails and up to 2 texts over 12 days, stopping on reply
- A PDF with timestamps for consent, requests, reminders and completion
- Unlimited team members on shared credits that never expire
Umbrella reference questions
More in the full FAQs.
Is the umbrella company the employer?
Yes, for employment and tax purposes the umbrella usually employs the contractor. That does not make it responsible for the agency's checks before supply. Those sit with the agency under the Conduct Regulations.
Can I ask the umbrella company for a reference?
You can, but it will often confirm dates of employment and little else, because it never saw the work. A reference from the end client manager tells you far more about conduct and skill.
Who is liable if an umbrella contractor was not checked?
If the agency supplied the worker, it is the party with the regulatory duty and usually the contractual promise to the client. Our guide to agency reference liability explains where the risk sits.
Do limited company contractors need references too?
Clients often expect them, and the Conduct Regulations can still apply unless the contractor has opted out where that is allowed. See contractor reference checks for the detail.
What if the contractor has worked through several umbrellas?
Ask for each engagement with dates and the end client. Use the end client managers as referees and treat the umbrella names as payroll detail, not as the employment history itself.
How much does it cost?
Your first reference is free. Credits then cost from 99p down to 80p each with no monthly fee and no VAT added. See pricing.
Related guides
Check every contractor, whoever runs payroll.
Your first reference is free. Two minutes to send, and RefAssure chases the rest.