Policy Talks Q1 January 2026

2025 Review – The End of the Beginning…. For the Employment Rights Act 

It was a year a lot of recruiters were happy to see the back of, with fresh hopes for 2026. The Government finished with the Employment Rights Act, but much of the hard graft is yet to come, as set out in summer’s roadmap. The consultation timetable has slipped, but recruitment companies should assume that go live dates continue to apply.  

Before the New Year kicks off in earnest here’s a quick round up of what we achieved in public policy over the year: 

Maintaining a consistent and effective cadence of stakeholder meetings is key to raising APSCo and the sector’s profiles and securing political influence. 

Our series of briefing papers for parliamentarians on the Employment Rights Bill across the year caught the attention of MPs and peers cross party, leading to meetings with the Conservative and Liberal Democrat peers so influential in the amendments including on day one dismissal rights.  

Face to face engagement with Labour ministers Conservative shadow ministers and Reform on the economy, IR35, umbrella reform and Employment rights. 

We held a series of successful parliamentary dinners with roundtable discussions on AI, skills and the employment rights bill leading to subsequent activity.  

We also engaged with the regional mayoral offices, DWP, DfE and Skills England on skills initiatives and apprenticeships. 

As a permanent member of HMRC and HMT’s Intermediaries Committee, we were involved in policy discussions on umbrella reform and IR35. 

Dealing with member challenges 

• DHSC’s policy has led to dramatic reductions and in some cases the ban on the use of temporary staffing across the NHS ecosystem, which has been catastrophic for many of our healthcare members. 
  
  
• In addition to a series of member events we have engaged with our member NHS Professionals, written on several occasions to ministers and responded to consultations on NHS workforce strategy.  
  
  
• Similarly, in Education we are proactively engaging with CCS on their proposed framework and have written to the relevant DfE minister asking for a review on the impacts of the new statutory code for engaging temporary social workers in children's services. 
  
  

Ensuring the professional sector is heard and represented 

• We submitted recommendations to HMT ahead of both the Spring Statement and Autumn Budget. 
  
  
• The language and tone of the submissions were also developed to reflect the balance between the Government's key missions and the requirements and concerns of APSCo members.   
  
  
• Parliamentary Questions on the Employment Rights Bill were made by Baroness Verma, following our meeting with her. 
  
  

Keeping our Members Informed and Providing Clarity 

• We continued to produce our bi-weekly Political Monitor and expanded it to include more legislative information, particularly on the Employment Rights Act. 
  
  
• We produced a presentation on the UK parliamentary process mapping a bill’s progress from initial calls for evidence through the Commons and Lords to Royal Assent and secondary regulation.  
  
  
• We also published a review of the government’s performance against the King’s Speech 2024. 
  
  

Being Impactful 

Concessions were made on the Employment Rights Act, particularly the 6-month probationary period and changes to fire and rehire.  We remain hopeful that the government has listened to us on zero-hours contracts and that draft regulations will be limited in scope to protect the genuine low paid, at-risk workers it is intended to protect and not adopt a broad-brush approach. The government has published a much more detailed impact assessment on the ERA, but much more is needed in respect of cost and behavioural impact of the zero hour contract changes. 

Rules on apprenticeships have been simplified with shorter apprenticeships and reduced administration. The first tranche of short modular training, covered by the levy, will be launched by Skills England in April 2026. 

Coming in 2026.... 

• A review of employment status, which will include a review of genuine self-employment which we have long called for. 
• Some form of review of the Conduct of Employment Agencies and Employment Businesses Regulations 2003, considering umbrella companies are coming within scope of regulation. 
  
  
• The launch of the Fair Work Agency led by Matthew Taylor, in April 2026. 
  
  
• The focus on the Employment Rights Act will continue, given all the secondary regulations coming downstream. 
  
  
• We may start to see action and some results as the government starts to implement the strategies and policy papers published in 2025, ahead of a fresh Kings Speech in early summer.  Delivery of some of the missions set out in the Industrial Strategy could be positive for hiring.  However, will this all be set offtrack by a leadership battle after the May election, or even by geopolitical events?