APSCo UK November Legal Updates

W/C 3 November

HEART Academies Trust Supply Agency Staff Framework Reopening Now Live

The HEART Academies Trust Framework for the Provision of Supply Agency Staff Services has officially reopened, providing an opportunity for recruitment businesses to apply for the supply of temporary staffing services.

The framework is open for applications across three lots:

• Lot 1 - Direct Provision;
• Lot 2 - Master Vendor; and
• Lot 3 - Neutral Vendor.

Existing framework suppliers do not need to take any action unless they wish to apply for an additional lot, as their current framework appointments will remain in place.

New suppliers and existing suppliers wishing to apply for additional lots must submit their applications through the CIMPLE procurement portal.

Key deadlines include:

• 13 November 2026 at 12:00pm - Deadline for clarification questions; and
• 27 November 2026 at 12:00pm - Deadline for tender submissions.

APSCo members interested in applying should review the tender documentation and ensure their submissions are completed ahead of the deadline. All clarification questions must be submitted through CIMPLE.

You can access the tender opportunity on CIMPLE and the official tender notice on Find a Tender.

Further information can be found through our What’s New page.

APSCo Update - HMRC Enforcement Against Non-Compliant Umbrella Companies

APSCo has published a new legal update highlighting HMRC's increasing enforcement action against non-compliant umbrella companies, including compulsory winding-up petitions where significant tax liabilities remain unpaid.

With Joint and Several Liability (JSL) now in force, recruitment businesses and in certain circumstances end clients, could be held liable for unpaid PAYE liabilities where an umbrella company fails to meet its tax obligations.

The update highlights that traditional due diligence checks and umbrella company accreditations alone do not provide protection against JSL, reinforcing the importance of ongoing monitoring and financial checks such as:

• conducting regular payroll audits and financial due diligence on umbrella companies;
• monitoring PAYE deductions and tax reporting to identify potential non-compliance;
• identifying contractors and assessing financial exposure where an umbrella company faces winding-up proceedings;
• considering alternative compliant payroll arrangements for affected contractors; and
• communicating with contractors and encouraging them to check their HMRC Personal Tax Accounts for discrepancies.

You can access the full APSCo Update through our What's New page.