APSCo UK December Legal Updates

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By APSCo United Kingdom December 02, 2025 4 minutes read time

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The latest APSCo legal updates for December 2025.

W/C 15th December

Employment Rights Bill has now received Royal Assent

The Employment Rights Bill completed its passage through Parliament on 16 December 2025, and has now received Royal Assent today, Thursday 18 December 2025, becoming the Employment Rights Act 2025.

Certain provisions will come into force as soon as the Bill becomes law. APSCo UK is working closely with members to support them through early changes, including reforms to industrial action rules and enhanced protections for striking workers, while ensuring member representation during consultations.

You can access our blog on the next steps to expect for more information.

ICO updates SAR guidance under Data (Use and Access) Act 2025

The ICO has updated its Subject Access Request (SAR) guidance following the Data (Use and Access) Act 2025 and published a new SAR template for small businesses.

The template is optional for individuals to use but may help recruitment businesses better understand and manage SARs by clarifying the data requested, date ranges and contact preferences.

The ICO has also confirmed that its existing SAR bitesize guidance is under review and may be updated. Organisations must continue to respond to SARs within one calendar month, subject to limited extensions and fees in certain circumstances.

You can access the updated guidance and template through our What’s New page.

DBT Consultation – Options for Reform of Non-Compete Clauses in Employment Contracts

The Department for Business & Trade (DBT) has published a working paper exploring reforms to non-compete clauses in employment contracts, driven by concerns around job mobility and innovation.

Options under consideration include a statutory cap on the length of non-competes, a full ban, a ban below a certain salary threshold, or a combination of salary thresholds and time limits.

This consultation closes on 18 February 2026, details of which can be found on our What’s New page.

W/C 8th December

GOV - Finance (No 2) Bill

The Government published the Finance (No. 2) Bill on 4 December 2025, which includes the proposed umbrella company provisions in Chapter 11.

Here are the key points for members to note:

Section 61Y – joint and several liability remains broadly the same as the earlier draft.
Section 61Z1 - has been rewritten and expanded, with additional scenarios where liability can transfer.
Explanatory notes – make it clear the Government wants to change behaviours by ensuring businesses have a financial incentive to only work with compliant umbrella companies.

Although this remains draft legislation, it is significant. If an umbrella company fails to account for PAYE/NICs, the agency or hirer may be exposed. Strong due diligence and robust PSL management will be essential.

APSCo will continue to monitor the progress of the Bill and support members as further details become available.

If you haven’t come across it already, we have recently updated our Umbrella Company Supplier Questionnaire which can be accessed through our What’s New page.

APSCo Update - Employment Rights Bill - Unfair Dismissal

The Employment Rights Bill (the Bill), which introduced new workplace rights to end unfair employment practices and help deliver economic growth, is still in its ping pong phase and is now back to the House of Lords for further scrutiny.

One of the key reforms introduced by the Bill aimed to extend employee's protections against unfair dismissal to day one of their employment, instead of the current two years. However, following pushback from the House of Lords, the House of Commons agreed to amend the Bill and to replace the day-one right with a 6-month qualifying period instead.

The reform on unfair dismissal is not expected to come into force before 2027.

APSCo has produced an update to help you understand these changes. You can access it directly on our Employment Rights Bill hub.

CCS - Maximising value for pupils

The Department for Education (DfE) issued a Policy paper on Maximising value for pupils, aiming to guide schools and trusts through resource planning for next year and the years ahead.

Within the policy paper, the DfE invited schools and trusts to source agency staff through the framework, unless they are able to achieve better value for money through another route.

The policy paper is available here, and members can find further information on joining the CCS framework on our APSCo Update here.

W/C 1st December

Guidance Update on Day 1 Unfair Dismissal: Following the recent government announcement we've updated our guidance on Day 1 rights. Find out more.

Other legal updates:

APSCo Update - Supply Teachers and Education Recruitment RM6376

The Crown Commercial Service (CCS) has published its Tender Notice for the new Supply Teachers & Education Recruitment framework, replacing the previous RM3826 agreement. This framework covers the supply of temporary, fixed-term, and permanent education staff into state-funded schools across the UK.

The new agreement is scheduled to begin on 29 May 2026 and will run for an initial three-year term, with the option to extend to May 2030. The deadline for tender submission is set on 19 December 2025 at 3:00pm. APSCo has drafted an update to provide you with all the necessary information for the tender here.

APSCo Compliance+ Accreditation - A mark of trust in Education Recruitment

APSCo has created a one-page summary of APSCo’s Compliance+ Accreditation for the Education sector.

This summary is designed to support your conversations with your clients, helping you articulate the benefits of Compliance+, how it goes beyond statutory safeguarding requirements, and why partnering with an accredited member provides additional peace of mind. You can access this one pager here.