There are now a lot of responsibilities and potential liabilities for agencies over the way in which individuals are paid especially if they are ‘off-payroll’.
If an agency engages individuals on a self-employed basis, whether it be directly or indirectly, it is exposed to the risk of HMRC challenging the position under the agency legislation (ITEPA 2003 s44).
If they supply personal service companies, from April 2020 they may be responsible for IR35 if they are deemed the “fee payer” by HMRC and will have an obligation to provide information down the chain.
There are also quarterly reporting requirements for all agencies which must confirm (among other things) who has been paid, how much and why PAYE was not deducted.