APSCo UK March Legal Updates

• Engaging and paying subcontractors,
• Reporting requirement to HMRC,
• Payment and deduction statements,
• Record-Keeping obligations.

Updated APSCo Guidance on the Key Information Document (KID)

In light of the Fair Work Agency becoming the new enforcement body for worker rights from 7 April 2026, APSCo has updated its Key Information Document (KID) guidance and templates to reflect the new Fair Work Agency contact details.

Members should ensure they include the correct contact information for the relevant enforcement authority in their KIDs from 7 April onwards, as this is a mandatory requirement.

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

APSCo Virtual Roundtable - Modernising the Agency Work Regulatory Framework and Fair Work Agency

This is a kind reminder that APSCo will be holding a member roundtable on Thursday, 9 April 2026, from 11:00 am to 12:30 pm with the Department for Business and Trade (DBT) focused on the Modernising the Agency Work Regulatory Framework and Fair Work Agency consultation.

This is your opportunity to hear from the DBT and provide your feedback on how the regulatory framework could be amended to streamline rules and processes, and reduce administrative burdens for businesses and to enable the effective regulation of umbrella companies.

You can reserve your place today here!

HMRC and APSCo Guidance - Umbrella reform

The Finance Bill 2025-26 received Royal Assent on 18 March 2026, effectively becoming the Finance Act 2026.

The Act contains several key measures, including the introduction of a new Chapter 11 Part 2 of ITEPA 2003, which creates a new Joint and Several Liability (JSL) for unpaid PAYE and National Insurance Contributions (NICs) in umbrella company supply chains.

HMRC has updated its guidance and Employment Status Manual in readiness for the reform coming into force on 6 April 2026. You can also access their recorded webinar on labour supply chains featuring umbrella companies, designed to support implementation requirements for agencies in labour supply chains.

• APSCo Update on the new Umbrella reform - providing you with an overview of the reform and the introduction of the JSL;
• 10 Steps towards Umbrella Compliance - providing you with clear steps to help you comply with your due diligence checks;
• Umbrella Compliance Questionnaire - Which provides you with a useful set of questions and documents to be provided by any new umbrella company joining your PSL;
• APSCo Umbrella contract template and our guidance on the Key JSL protection clauses - which will help you identify all the provisions in our contract that support protection against JSL exposure.

APSCo Update – The Employment Rights Act Implementation Timelines

We have recently produced an overview of the implementation for the Employment Rights Act 2025, outlining the key reforms and what they mean for recruitment companies.

Some of the changes include expanded day one rights, Statutory Sick Pay reform, increased enforcement, and greater exposure to Employment Tribunal claims, alongside updates to unfair dismissal and fire and rehire practices.

Members should begin reviewing policies, contracts and processes to prepare for the phased introduction of these reforms.

You can access the APSCo update through our What’s New page.

GOV Guidance for Employers – Action Plans for Gender Pay Gap and Menopause

From April 2026, employers with 250 or more employees will have the option to produce and publish a voluntary action plan alongside their gender pay gap data. These action plans are expected to become mandatory from spring 2027, subject to secondary legislation.

Action plans will show the steps organisations are taking to:

• reduce their gender pay gap
• support employees experiencing menopause
  

Employers will also be able to highlight work already being carried out to improve workplace gender equality.

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

GOV Statement of Changes to Immigration Rules

On 5 March 2026, the Government published a Statement of Changes to the Immigration Rules introducing a number of updates across several visa routes that may be relevant to businesses engaging overseas workers.

Key changes include:

• Temporary pause on Skilled Worker visa applications from Afghan nationals;
• Refugee and humanitarian protection leave reduced from five years to 30 months;
• Visit visa requirements introduced for nationals of Nicaragua and St Lucia;
• Skilled Worker route updates, including tailored provisions for Prison Service officers and new pay period compliance requirements;
• Ukraine Permission Extension (UPE) scheme extended for a further 24 months;
• Appendix Visitor updated, including changes to the Permit Free Festival List;
• Global Business Mobility – Secondment Worker route updated, reducing the qualifying overseas employment requirement from 12 months to 6 months; and
• English language requirement for settlement increased to B2 level.

You can access the policy paper through our What’s New page.

DBT Engagement Meetings – Amending the Regulatory Framework

The Department for Business and Trade (DBT) will be arranging a series of engagement meetings over the coming months to discuss their approach to amending the regulatory framework. We would very much welcome your involvement.

If you are interested in taking part in the meetings with the DBT please notify shaziaimtiaz@apsco.org and we will be in touch shortly with further details.

• Teaching - Thursday 19 March at 10:00-11:00
• Construction - Friday 20 March at 10:00-11:00

DBT Consultation - Threshold for triggering collective redundancy obligations

The Department for Business and Trade (DBT) has launched a consultation on the new organisation-wide threshold for triggering collective redundancy obligation under the Employment Rights Act 2025.

Under the new rules, the Trade Union and Labour Relations (Consolidation) Act 1992 (TULRCA) will be amended to introduce an additional alternative threshold based on the total umber of redundancies across the whole business. This means that the new threshold could trigger collective consultation obligations even where fewer than 20 redundancies are proposed at any single establishment.

The consultation is seeking views on how this new rule should be implemented.

Members can answer the consultation online until 21 May 2026.

APSCo Update - Key Umbrella protection clauses in APSCo Model Umbrella Terms

In readiness for the upcoming reform introducing a new Chapter 11, Part 2 of the Income Tax (Earnings and Pensions) Act 2003, which will be coming into force on 6 April 2026, and to assist members in protecting themselves against the newly introduced Joint and Several Liability (JSL), APSCo has undertaken a review of its current Model Agreement for Umbrella Companies.

This APSCo Update has been prepared to assist members in identifying the key clauses within our APSCo Model Agreement for Umbrella Companies that support protection against JSL exposure and to help members understand how these provisions operate in practice.

You can access it through our What’s New page here.