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.png "APSCo September Legal Updates")
The latest APSCo legal updates for September 2025.
W/C 22nd September
1. HMRC Webinar - Labour supply chains featuring umbrella companies - Are you ready for April 2026?
HMRC is running a webinar for labour supply chains, featuring umbrella companies. It covers the proposed changes from April 2026 and looks at:
• when the new rules apply
• who the new rules apply to
• how the new rules apply to agencies, end clients, umbrella companies and workers employed by umbrella companies.
Sign up here
2. HMRC Guidance on the umbrella reforms
HMRC has published guidance on what you need to know about the new rules if you're in a labour supply chain which includes an umbrella company, or any third person supplying labour. These rules are based on draft legislation and the government’s approach to tackling non-compliance in the umbrella company market. They’ll be updated if there are any changes before it becomes law.
W/C 15th September
W/C 8th September
APSCo Update - Keeping Children Safe in Education 2025 Table of Changes
Following the updated version of Keeping Children Safe In Education (KCSIE) 2025 available since the 1 September 2025, APSCo has created a table of changes allowing you to easily identify the changes made from KCSIE 2024 to KCSIE 2025.
You can access the table of changes on our What's New page here.
GOV Call for Evidence – Adoption of Trust Services
The government is seeking views on the use of digital trust services (e-signatures, seals, timestamps, secure delivery) under UK eIDAS rules.
Currently no UK-registered providers exist, meaning firms rely on EU services. Recruitment companies who manage contracts and compliance digitally may wish to respond, particularly on digital ID verification and secure contracts.
W/C 1st September
1) Update on Umbrella Company Reforms
We’ve been working hard on your behalf since the umbrella company reforms were announced in last year’s Autumn Budget, and which comes into force in April 2026 our focus remains on making sure your views are heard.
Over the past year we’ve held a number of roundtables with members and Trusted Partners to obtain your input and feedback, represented you directly with government departments including DBT, HMT and HMRC, run member events on the reforms, and issued legal updates to give clarity and guidance. We’ll also be responding to the draft legislation consultation on 15 September 2025, and our final submission will be shared on our website next week. Further events are scheduled throughout Q3 and Q4 please keep an eye out on our Events page.
Our message to government is clear: the recruitment sector needs statutory protection and practical support. We’re pressing for a clear roadmap with HMRC engagement, access to real-time tax data to protect compliant supply chains, proper licensing of the umbrella market with fit and proper tests, and more resources for regulators to shut down rogue operators. To help reinforce this, we have prepared a pro-forma letter for members to send to their MPs setting out these key concerns and recommendations.
2) GOV - Technical guide to neonatal care leave and pay
The Government issued a technical guide for employers on neonatal care leave and pay. This guidance follows the statutory entitlement to Neonatal Care leave and Pay for babies born on or after 6 April 2025 which is now available to employees in England, Scotland and Wales.
The guide provides employers with details about the eligibility criteria, information employees must provide, how to calculate how much Neonatal Care Leave and Pay the employee has accrued, amongst other things.
You can access this technical guide here.
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