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.png "APSCo November Legal Updates")
The latest APSCo legal updates for November 2025.
W/C 24th November
APSCo Update – HMRC Tax Fraud Warning
HMRC has issued a warning about tax fraud in umbrella, PEO, joint employment and co-employment models. If a provider claims to reduce PAYE or NIC through “tax credits” or similar mechanisms, HMRC classifies these schemes as high-risk and agencies can be held jointly liable. We have created an APSCo update summarising what the risks are, the red flags to watch for, and what recruitment companies must do to stay compliant and protect their businesses. You can access the update through our What’s New page.
APSCo toolkit - Umbrella Supplier Compliance Questionnaire
APSCo updated its Umbrella Supplier Compliance Questionnaire to assist members conducting their due diligence checks before onboarding with an Umbrella company, in readiness for the changes coming into force on the 6th of April 2026. This questionnaire is intended to collect as much information as possible for agencies to be able to make an enlightened decision before engaging with an Umbrella company, and consequently reduce the risk of the joint and several liabilities binding the agency to its umbrella's actions.
W/C 17th November
Supply Teachers and Education Recruitment RM6376
Crown Commercial Service has published its Tender Notice for the agreement for the provision of temporary and permanent staffing for use by schools and educational establishments (excluding independent/for profit schools.)
Important Dates:
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Enquiry Deadline 3 December 2025, 3:00pm
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Tender submission deadline 19 December 2025, 3:00pm
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Award decision date (estimated) 18 May 2026
Useful Bidder information:
Independent Review of Social Work Regulation: Call for Evidence
The Government has issued a call for evidence which provides you our valued social work members, with an opportunity to share your views with the people conducting an Independent Review of Social Work Regulation.
The deadline is 26 November 2025 and you can respond here.
Social Work England - Annual Registration 2025
The registration renewal period, running from 1 September 2025 to 30 November 2025, is open.
It is a legal requirement that all social workers apply to renew their registration on an annual basis if they wish to continue practising and use the protected title of ‘social worker’. Social workers must renew their registration before 30 November 2025, or they risk being removed from the register.
Social Work England created a guidance to assist your candidates in renewing their registration here.
W/C 10th November
ERB Consultation - Leave for bereavement
The Government is seeking views on the new day one right to unpaid bereavement leave for employees who experience the loss of a loved one, including pregnancy loss before 24 weeks.
The consultation consists of three sections:
- Part One - Eligibility
- Part Two - When and how the bereavement leave can be taken
- Part Three - Notice and evidence requirements.
The consultation is open until 15 January 2026 and can be answered online.
Upcoming change to the RM6397 Clinical and Non Clinical Temporary and Permanent Staff Agreement
Thank you to everyone who joined the Crown Commercial Services July 2025 webinars and shared feedback. As a result, the NHS Workforce Alliance will merge the RM6281 Clinical and RM6277 Non-Clinical staffing frameworks into a single new framework, RM6397 Clinical and Non-Clinical Temporary and Permanent Staff, which will replace the current agreements by mid-2027. https://www.workforcealliance.nhs.uk/news/rm6397-clinical-and-non-clinical-temporary-and-permanent-staff/
The unified framework will allow the NHS and public sector to recruit all staff types, including via managed service provision, simplifying procurement for customers and bidding for suppliers. https://www.workforcealliance.nhs.uk/news/rm6397-clinical-and-non-clinical-temporary-and-permanent-staff/
APSCo will share the CCS webinar dates in our newsletter as soon as they are confirmed for this month.
Independent Review of Social Work Regulation: Call for Evidence
The Government has issued a call for evidence which provides you our valued social work members, with an opportunity to share your views with the people conducting an Independent Review of Social Work Regulation.
The deadline is 26 November 2025 and you can respond here.
W/C 3rd November
GOV - DBT names and shames 491 employers failing to pay minimum wage
The Department for Business and Trade (DBT) has named 491 employers for failing to pay national minimum wage to around 42,000 workers in its 22nd naming round. Defaulting employers have received fines totalling £10.2m.
From April 2026, the Employment Rights Bill will establish a new Fair Work Agency with more powers to tackle employers underpaying workers and failing to pay holiday and sick pay.
You can access the GOV names and shames list here, and access APSCo Fair Work Agency factsheet here.
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