APSCo UK October Legal Updates

APSCo UK October Legal Updates

The latest APSCo legal updates for October 2026.

W/C 21 October 

APSCo Update - Prevent Sexual Harassment
APSCo has published an APSCo Update on preventing sexual harassment, outlining employers’ strengthened legal obligations and the practical steps recruitment businesses should take to protect their employees and workers placed with clients.
 
The update covers the strengthened duty to take all reasonable steps to prevent sexual harassment from 30 October 2026, the importance of assessing risks across internal teams and client placements, and practical measures such as reviewing policies, providing regular training, establishing clear reporting channels and keeping records of preventative action.
 
Our Legal Update is available on our What's New page.
 
APSCo Contracts Update - Right to Work changes
APSCo has updated its contract templates for Umbrella and Personal Service Company (PSC) engagements to reflect the changes to Right to Work checks and the extended liability introduced by the Border Security, Asylum and Immigration Act 2025.
 
The review of our remaining contract templates is still ongoing. Members are encouraged to keep an eye on our What's New page for further updates as additional contract reviews are completed and published.
 
Further guidance on the changes introduced by the Act can also be found here.
 
APSCo Quarterly Board Briefing – Q4 2026
As part of our service to members, APSCo has produced the latest edition of our Quarterly Board Briefing Q4 2026.
Quarterly Board Briefing 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.

 

 

W/C 12th October

Further Employment Rights Act 2025 Reforms to Take Effect from 30 October

The Government has published the Employment Rights Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026, confirming that the next phase of Employment Rights Act 2025 reforms will come into force on 30 October 2026.

 

The latest changes include:

  • strengthening the employer duty to take "all reasonable steps" to prevent sexual harassment in the workplace;
  • extending protection against harassment by third parties, such as customers and clients, where employers have failed to take all reasonable steps to prevent it; and
  • introducing new rights for trade unions to request physical and digital access to workplaces and workers, together with further changes relating to facilities for trade union representatives.

 

The Government has also confirmed that the requirement for employers to provide workers with a statement of their right to join a trade union has been deferred until January 2027.

 

APSCo members should review their workplace policies and procedures ahead of the changes taking effect on 30 October 2026.

 

You can find out more about the ERA 2025 through our website here.

 

Government Publishes Consultation Outcome on Bereavement Leave

The Government has published its response to the consultation on bereavement leave, including pregnancy loss, as part of its wider Make Work Pay reforms. The changes will introduce a new day one right to unpaid bereavement leave for employees from April 2027, including those who experience pregnancy loss before 24 weeks.

 

The new entitlement will include:

  • leave following the death of a spouse or partner, parent, adult child or sibling, including certain step, adoptive and foster relationships;
  • up to two weeks of unpaid leave for pregnancy loss before 24 weeks, including miscarriages, terminations and unsuccessful IVF embryo transfers;
  • flexibility to take leave within 56 weeks of the bereavement; and
  • protection from dismissal or detriment for exercising the right to bereavement leave.

 

You can read the Government's response through our What's New page.

 

W/C 5th October

Education sector - GCA - Clarification on employment cost guidance

Following the GCA’s recent RM6376 guidance on pricing, employment costs and worker compliance, APSCo raised serious concerns with the GCA about the practical implications of the guidance and shared the valuable feedback we had received from members.

We are pleased that the GCA engaged constructively with APSCo and the sector, revisited its guidance, and has now promptly issued an updated clarification.

Recruitment companies have been advised to continue operating as previously, using assumed employment costs of up to 18.5%. The GCA has also confirmed that where a supplier does not make Apprenticeship Levy contributions, the 0.5% Levy cost should not be passed on to the hirer.

We welcome the GCA’s prompt response and this clarification, following the concerns raised by APSCo and our members.

Importantly, the GCA has also committed to developing ways to capture market feedback on future changes to the agreement, which we welcome as a positive step towards ensuring that the practical implications for suppliers are considered as future changes are developed.

APSCo - Updated APSCo Compliance+ Standards for Education
APSCo has published the latest version of the Compliance+ Education Standards, together with a summary of the changes made to the standards.

 

The updates ensure the standards continue to reflect current legislation, regulatory requirements, Keeping Children Safe in Education (KCSIE) versions, and best practice for education recruitment.

 

The latest version of the standards, together with the summary of changes, can be accessed through our What’s New page.