The Finance Bill 2019-20 was not passed into law before parliament was dissolved on 6 November 2019. The new rules for IR35 (see below for a recap) are therefore NOT law and so it is you or your accountant who continue to make the IR35 judgement on each contract.
The timings now make it highly unlikely that the IR35 changes can be implemented for 1 April 2020. The election is on 12 December and therefore the winner and the new Government will not be announced until 13 December. In previous years the Christmas recess has commenced on or around the 18th December with MPs returning around the 7 January. The next Brexit deadline is 31 January 2020 so the Finance Bill will not be a priority. Even in a normal year with a spring Budget in March, it takes a further 4 1/2 months to become enacted as the Finance Act. In our view the timing is too tight.
In addition, the new Government may have different priorities and drop the legislation entirely as part of keeping a flexible workforce in the face of business and economic changes.
Your end client(s) should be encouraged to defer making any decision on employment status at this time.
As a reminder the rules on IR35 have not changed. However the Finance Bill 2019-20 was to introduce new legislation to change the person/body/company that makes the IR35 assessment; instead of being you (the contractor) or me (your accountant) it would be the end client. These new rules were to mirror the rules brought in to the public sector in 2017.