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.png "APSCo UK July Legal Updates")
The latest APSCo legal updates for July 2026.
W/C 27th July
Changes to Right to Work Checks from 1 October 2026
Significant changes to the UK's right to work regime will come into force on 1 October 2026, extending the requirement to carry out right to work checks beyond employees to a wider range of working arrangements.
The changes will require right to work checks to be carried out for certain workers (such as casual and zero hours workers), individual contractors and sub-contractors, and some individuals providing services through online matching platforms.
The new regime also introduces "extended liability", meaning organisations higher up the contractual chain could, in some circumstances, be held liable for illegal working where services have been subcontracted. Employers that fail to comply with the new requirements could face civil penalties of up to £60,000 per illegal worker, as well as potential director disqualification or criminal sanctions in the most serious cases.
To support the changes, the Government has published draft updates to its Code of Practice on Preventing Illegal Working and its employer guidance on right to work checks.
APSCo members may wish to review their onboarding processes and contractual arrangements ahead of 1 October 2026 to ensure they are prepared for the expanded right to work requirements.
You can access the updated guidance through our What's New page.
APSCo Inside Legal and Compliance - Q3 2026
As part of our service to members, APSCo has produced the latest edition of our Inside Series: Legal & Compliance - Board Briefing Q3 2026.
Inside Legal and Compliance aims to provide members’ boards, legal and compliance teams with a steer on upcoming legal changes and guidance affecting the professional recruitment sector to enable a proactive response and potentially competitive advantage.
The latest Legal and Compliance Inside Series is available on our website in the Inside Legal and Compliance section and on our What's New page.
W/C 20th July
Employment Rights Act 2025 Implementation Timelines Updated
Following the Government's publication of an updated implementation timetable for the Employment Rights Act 2025, APSCo has updated its guidance on Employment Rights Act 2025 Implementation Timelines.
The updated version reflects the latest confirmed commencement dates, including the separation of measures due to take effect on 1 October 2026 and 30 October 2026, together with other changes announced by the Government. The update continues to provide practical commentary on what each stage of implementation is likely to mean for recruitment businesses and the steps members should be considering ahead of the reforms.
You can access the update through our What’s New page.
DBT Consultation - Reforms of zero hours and similar contracts
The Government launched a consultation on implementing new rights under the Employment Rights Act 2025 aimed at ending one-sided flexibility in zero hours and similar contracts.
The proposals include a right to guaranteed hours based on regular working patterns, reasonable notice of shifts and shift changes, and compensation for shifts cancelled, shortened or moved at short notice. The consultation focuses on how these rights will work in practice and will help shape future regulations.
The consultation is open until 25 August 2026 and can be answered online here or using the following email address zerohours.consultation@businessandtrade.gov.uk.
W/C 13th July
DfE Publishes Statutory Allergy Safety Guidance
The Department for Education (DfE) has published new statutory guidance setting out the measures schools in England must take to support pupils with allergies. The guidance will apply from 1 September 2026 and is accompanied by a model allergy safety policy and Individual Healthcare Plan template.
The guidance requires schools to:
- create and publish an allergy safety policy;
- provide allergy safety training for all staff;
- identify pupils who require Individual Healthcare Plans (IHPs) and ensure these are in place; and
- record, review and learn from serious incidents and near misses.
The new requirements are particularly relevant for education members who may wish to ensure that supply staff are aware of schools' allergy safety procedures and that clients are prepared for the new statutory obligations ahead of the 2026/27 academic year.
You can read the guidance and access the templates through our What's New page.
DBT Consultation - Holiday Pay Compliance and Enforcement
The Department of Business and Trade (DBT) has launched a consultation seeking views on proposals to give the Fair Work Agency (FWA) new powers to enforce statutory holiday pay rights.
The consultation explores how the FWA should investigate holiday pay compliance and take enforcement action where employers have failed to meet their statutory obligations. Proposals include limiting enforcement to statutory holiday entitlement, introducing a six-year enforcement period, and publicly naming organisations found to have underpaid holiday pay.
The proposals form part of the Government's wider employment law reforms and the expansion of the Fair Work Agency's enforcement role.
The deadline to responds to the consultation is 11:59pm on 22 September 2026, you can access the consultation through our What's New page.
W/C 6th July
ACAS - Tips to help employers manage hot weather at work
With warmer weather expected again, ACAS is reminding employers to take practical steps to keep staff safe and comfortable at work. There is no legal maximum workplace temperature in the UK, but employers have a duty to ensure working conditions are reasonable.
Key actions include providing drinking water, encouraging regular hydration, using fans or air conditioning where possible, considering more flexible dress codes, and allowing extra breaks if needed. Employers should also assess risks for employees who may be more vulnerable to heat and consider reasonable adjustments where appropriate.
Read the full ACAS guidance on managing hot weather at work here and additional recommendations on extreme workplace temperatures here.
ICO - New data protection complaints law now in force
Since 16 June 2026, a new legal requirement for handling data protection complaints is in force. This new requirement mandates that all organisations that process personal data must have a clear complaints process in place. Organisations must provide an accessible way for individuals to raise complaints, acknowledge them within 30 days, investigate them without undue delay, and communicate the outcome.
The ICO published practical guidance to help organisations review or integrate these requirements into their existing complaints procedures and ensure staff know how to manage complaints effectively. Read the ICO's guidance on preparing to handle data protection complaints here.
W/C 29th June
DBT Consultation: Reforms of zero hours and similar contracts
The Government launched a consultation on implementing new rights under the Employment Rights Act 2025 aimed at ending one-sided flexibility in zero hours and similar contracts.
The proposals include a right to guaranteed hours based on regular working patterns, reasonable notice of shifts and shift changes, and compensation for shifts cancelled, shortened or moved at short notice. The consultation focuses on how these rights will work in practice and will help shape future regulations.
The consultation is open until 25 August 2026 and can be answered online here or using the following email address zerohours.consultation@businessandtrade.gov.uk.
APSCo Model Registration Terms for work finding services
With the Fair Work Agency (FWA) currently undertaking compliance audits across the recruitment sector, now is a good time to review your candidate registration processes.
Recruitment businesses are required under Regulations 14 and 15 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 to provide candidates with written Registration Terms before any work-finding services commence. These Registration Terms are distinct from the Terms and Conditions that apply once an assignment has been secured, and both documents serve different legal purposes.
The Registration Terms must be provided before work-finding services begin and the obligation applies even where no assignment has yet been identified. Review your processes now to ensure compliance and access the latest version of the APSCo Model Registration Terms here.
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