Compliance conversations in this industry tend to arrive as rumour, usually the week before something lands. The dates below are fixed and published. An agency that reads them once and shapes its records accordingly meets each one as an administrative change rather than a scramble.
Joint and several liability for umbrella payroll failures
Enacted in Finance Act 2026 s.24, inserting Chapter 11 into ITEPA. Where an umbrella in the chain fails to account for PAYE, the liability can land on the agency. It is strict: there is no due-diligence defence written into it, and the liability sits with the agency that holds the contract with the end client ESM2420.
What your records must show: that assessment of each umbrella was ongoing rather than a one-off at onboarding. Accreditation, payslip samples, RTI evidence, insurance and the contract, each with a date and an expiry, tied to the placements actually running through that company.
LiveRight-to-work reform
Under SI 2026/700, identity service providers become RtW DVSPs, and facial-image records and supply-chain statements join the check. The civil penalty for illegal working is up to £60,000 per worker at the repeat-breach level in force since 13 February 2024, so the statutory excuse is the whole point of getting the check right.
What your records must show: the route each check took, and from this date the new evidence alongside it. A check recorded before the date is not retrospectively wrong; a check after it that omits the new evidence does not establish the excuse.
Six weeks outUmbrella company regulation under the Employment Rights Act 2025
Agencies answer for the umbrella companies they pay through. The direction of travel has been one-way for two years: the umbrella chain stops being someone else's problem and becomes part of the agency's own compliance surface.
What your records must show: the same file the JSL position already needs, which is why an agency that treats each umbrella as a first-class record now meets 2027 with nothing new to build.
ComingThe Fair Work Agency takes over enforcement
The Employment Rights Act 2025 consolidates enforcement that previously sat across the Employment Agency Standards Inspectorate, the Gangmasters and Labour Abuse Authority and HMRC's national minimum wage teams. One body, wider powers, and a single view of an agency.
What your records must show: the same things, to one inspector instead of three. Consolidation raises the cost of a gap because the gap is now visible from more angles.
In progressMake Work Pay reopens the Conduct Regulations, AWR and the EAA
The rules this industry runs on are being rewritten in the open. Nobody can tell you the outcome, and anyone who does is selling something. What can be said is which records the rewrite will touch: qualifying periods, the information a worker gets before terms are agreed, and what an agency may and may not do between a worker and a hirer.
What your records must show: whatever the outcome says. The defensible position is holding the underlying facts, so a change in a threshold is a change in a number rather than a change in what you collect.
UnknownThe pattern behind all five
Every entry above asks the same underlying question in a different costume: can you evidence what you did, when, and why you believed it was right at the time. That is not five compliance projects. It is one records problem with five deadlines attached.
BookKept holds the rules as dated configuration
Every compliance threshold in the system is a versioned pack carrying an effective date and the source that establishes it. The October 2026 right-to-work duties are already in the product, dated 1 October 2026, and switch on when that date arrives rather than when someone remembers to update software. Records are never edited, so the position on a past date stays reconstructable, which is the question an inspector actually asks.