Number of newly blacklisted tax avoidance schemes appears to slump, just as JSL bites

The number of tax avoidance schemes being 'named and shamed' by HMRC appears to have plummeted, just as Joint and Several Liability (JSL) takes effect.

Experts quizzed by ContractorUK were unable to pinpoint a technical reason for the taxman adding considerably fewer firms to his 'naughty list' on the cusp of JSL coming into force.

Coming the closest, however, was Andy Chamberlain, head of policy at the Freelancer & Contractor Services Association (FCSA).

What should Joint & Several Liability drive?

Chamberlain told ContractorUK that because JSL "should drive stronger due diligence" and "reduce activity at the market's non-compliant end," avoidance operators were now on the back foot.

And if fewer companies are being blacklisted by HMRC, it may "indicate that the market is beginning to improve," he said.

However, "many" of the names that get added to the Revenue's tax avoidance list relate to "historic" schemes or arrangements, observes Tom Wallace, a former tax inspector.

What's the difference between JSL and HMRC's tax avoidance list?

Wallace told ContractorUK that whereas the list is effectively an "early warning system" to taxpayers, Joint and Several Liability (JSL) is a "recovery mechanism" for HMRC.

And given that Joint and Several Liability only took effect a few days ago (Monday, April 6th 2026), JSL "will not immediately change the numbers being added by HMRC [to the list]."

"It should also be remembered that JSL covers much more than Disguised Remuneration (DR) schemes," Wallace, tax investigations director at WTT Group, said in his statement.

"So it's possible for Joint and Several Liability to [now] be in play and the [affected] umbrella company not to be a Disguised Remuneration scheme."

Will umbrella companies be hit by JSL as well as on the avoidance blacklist?

However, Wallace conceded that there may, in future, be an "overlap" between those blacklisted by HMRC and pursued by it under JSL.

Rob Sharp, chief executive of Orca Pay Group, has also been distinguishing JSL from the list of abusive tax arrangements.

"Tax avoidance operators run schemes whereby they, by and large, all pay HMRC liabilities.

"What they don't do, however, is pay the correct liabilities; they normally only pay the National Minimum Wage and the secondary payment is never disclosed to HMRC," he says.

What interpretation of JSL is being widely challenged?

Sharp made the distinction as part of his finding fault with the following statement:

"It seems to me the biggest concern with JSL is not whether the tax and NI have been calculated correctly, but whether it has been paid to HMRC."

A version of that statement has been challenged by SafeRec, too, here and exclusively for ContractorUK.

How many avoidance arrangements did HMRC 'name and shame' in March 2026?

In March 2026 — the month prior to JSL coming into force — only five new schemes were added by HMRC to its "Current list of named tax avoidance schemes…".

The five were Finsgate Contracting Ltd; Oak Umbrella Ltd, Pro Act HR Ltd, KHRP Group Ltd and Umbrella Requirements Ltd.

How many avoidance arrangements did HMRC blacklist in February 2026?

In February 2026, only three new schemes were added by HMRC to the avoidance list.

The three were HR Liquid Ltd, Signature Contracting Ltd and Outsource Ltd.

By contrast to the handful of new schemes blacklisted in January and February 2026, in December 2025, HMRC freshly added (or updated the entries of) some 18 tax avoidance schemes.

By how much has HMRC's 'naming and shaming' seemingly reduced?

So, compared to December last year, February this year saw a six-fold decrease in the number of avoidance schemes 'named and shamed' by the taxman.

HMRC explained that its approach to publishing the names of tax avoidance schemes is not impacted by the umbrella company market's new JSL rules.

The tax authority also pointed out that the number of schemes blacklisted per month can fluctuate due to legal and governance processes which each one is subjected to before listing.

Such a process is understood to include HMRC approaching the promoters or directors due to be named so that they can respond in advance of the effective blacklisting.

Is a lack of HMRC resources behind fewer companies being named and shamed?

Resources at HMRC have long been a problem for the government department.

Tax body AAT warned on the eve of the 2023/24 tax year that a "lack of resources lies at the heart of HMRC's problems."

To provide taxpayers with guidance for the new tax year (which began on Monday), HMRC had to publish almost 30 pages of multi-faceted updates and extensive guidance for 2026/27.

What's the fear behind HMRC's avoidance list naming fewer new operators?

The FCSA's Andy Chamberlain sounds hopeful that the 'naughty list' doesn't get deprioritised at a resource-scarce organisation contending with a heavy publishing workload.

He told ContractorUK: "The published list of named tax avoidance schemes, promoters, enablers and suppliers from HMRC is an invaluable tool. It enables taxpayers and businesses to identify non-compliant providers and avoid liabilities that often crystallise months or even years after engaging with them.

"Tax avoidance schemes continue to evolve, and new operators will emerge to exploit gaps where they can. And so it's therefore critical that HMRC continues to update the list promptly, while using all available means to identify and expose rogue actors. For contractors and other taxpayers, vigilance remains essential."