HMRC has published its latest update to the list of named tax avoidance schemes, promoters, enablers and suppliers (the “HMRC avoidance list”). The October 2025 update names the following organisations:
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T.U Paye Limited
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Echo Pay Limited
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Temp Contracting Limited
These additions reflect HMRC’s ongoing crackdown on umbrella-company structures and payroll arrangements that raise significant tax and NIC risk for contractors, agencies and end-clients.
What does being on the HMRC avoidance list mean?
When a company is listed on the HMRC avoidance list, it does not necessarily mean a criminal finding has been made. Rather, HMRC is signalling that it suspects the organisation is promoting or facilitating arrangements designed to avoid Income Tax or National Insurance contributions.
For contractors and agencies this means:
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If payments have been structured via an umbrella company within a named scheme, the contractor may face unexpected tax bills, interest or NIC liabilities.
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Agencies and end-clients involved in referring workers into the scheme may also face reputational or financial risk.
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Names on the HMRC avoidance list are often associated with split-pay or disguised remuneration models: part of income processed via PAYE, part styled differently to minimise tax.
Contractors should therefore treat inclusion on the list as a serious warning signal and review any current arrangements without delay.
What you should do now
If you are currently working via one of the newly named companies (T.U Paye Limited, Echo Pay Limited, Temp Contracting Limited) or have done so recently:
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Cease using the company immediately while you investigate the situation.
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Check your payslips and contracts to verify that 100% of your income has been taxed correctly through PAYE.
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Seek independent tax advice to assess possible exposure and options for exit or remediation.
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Consider moving to a fully compliant umbrella company. For trusted, transparent providers, see our Top 10 Umbrella Companies.
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Alert HMRC if you believe you’ve been involved in a promoted avoidance scheme.
Agencies and end-clients should:
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Cross-check any umbrella provider against the HMRC avoidance list.
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Ensure they only work with umbrella companies offering clear PAYE taxed income, visible payslips, and evidence of audit/compliance accreditation.
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Document their due-diligence and adopt a “stop list” policy of providers named by HMRC.
Pattern and context
This update continues HMRC’s regular monthly naming cycle of umbrella-related operators:
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In September 2025 the list was updated adding Endeavour Services Ltd.
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In August 2025 four companies were added.
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In July 2025 five companies were named.
Such consistency reinforces that umbrella arrangements remain a high-risk area for tax avoidance scrutiny. Inclusion on the HMRC avoidance list typically remains live for 12 months or longer, unless legally challenged or removed.
Final thoughts
The October 2025 update to the HMRC avoidance list is a clear signal to contractors, recruiters and end-clients alike: check who you’re working with, ensure fully compliant payroll arrangements, and stay vigilant. The potential tax and NIC liability for using a named scheme—plus the agency referral risks—is real.
If you require confidence in your umbrella company, please refer to our guide of the Top 10 Umbrella Companies.
