Compliance in July: What the Latest Updates Actually Mean for Your Agency
There's been no shortage of movement this month. The Government is continuing to reshape the employment landscape, and while none of the latest developments demand action today, the direction of travel is clear enough that agencies and umbrella companies should be paying attention now rather than later.
Here's what matters.
Employment Rights Bill – Guaranteed Hours
The Government has released further detail on its proposed reforms to zero-hours contracts. The legislation isn't in force yet, but the shape of it is coming into focus.
Employers will be required to offer qualifying workers a guaranteed-hours contract based on the hours they regularly work over a reference period. In other words, workers can't be left indefinitely on unpredictable patterns.
For umbrella companies, that has real implications for contract design, onboarding and workforce management. Many umbrella employees already benefit from contracts with a minimum annual hours guarantee, but this is one of the most significant employment law changes on the horizon and it needs watching closely.
No action required yet. But it's not something to file away and forget.
Fair Work Agency guidance
The Fair Work Agency has published a collection of guidance for employment businesses and agencies following its launch earlier this year.
Importantly, it introduces no new legal obligations. It pulls together and refreshes guidance previously issued by the Employment Agency Standards Inspectorate, now under the Fair Work Agency banner.
What it does tell you is where the regulator intends to look. The emphasis is on:
clear contractual documentation
compliance with the Conduct of Employment Agencies and Employment Businesses Regulations
transparent information for workers
comprehensive record keeping
appropriate due diligence throughout the labour supply chain
The message for umbrella companies is straightforward. Having a policy isn't the same as being able to prove it works. You need documented processes and accurate records that stand up to scrutiny.
Data (Use and Access) Act 2025
The first provisions of the Act are now coming into force.
The change to know about is a formal process for handling data protection complaints. Organisations are now expected to give individuals a clear route to raise concerns about how their personal data has been handled, before those concerns escalate to the ICO.
Most umbrella companies have a general complaints procedure. Fewer have one that explicitly covers personal data, Subject Access Requests, data accuracy, retention and sharing. Worth reviewing yours.
Holiday Pay consultation
The Government has launched a consultation on holiday pay compliance and enforcement, setting out how the Fair Work Agency will investigate and recover unpaid holiday pay.
No immediate legal changes are proposed. But it signals real scrutiny coming for holiday pay records and calculations. Businesses should be confident they can evidence holiday entitlement, pay calculations and record keeping before the Fair Work Agency becomes fully operational.
The thread running through all of it
Look at these four developments together and the same message keeps surfacing. Regulators are focused on evidence. Not intention, not policy documents sitting in a folder, but demonstrable proof of compliance, governance and worker transparency.
That's a shift in what good looks like. It's no longer enough to say you're compliant. You need to show it.
Where AGPayroll sits in this
This is exactly why we invested in SafeRec certification and FCSA accreditation ahead of the curve. Every payslip we produce is audited in real time and cross-checked against HMRC data. When an agency asks us to evidence our compliance, we don't go looking for it. It's already there.
Joint and Several Liability has been live since April. If a payroll provider in your supply chain underpays PAYE, the liability lands with you. Documented, auditable compliance from your payroll partner isn't a nice-to-have any more. It's the thing standing between you and someone else's tax bill.
The regulators are asking for evidence. We think that's a good thing. It rewards the providers doing the work properly and exposes the ones who aren't.
If you'd like to talk through how any of this affects your agency, we're here.
Call 0333 034 1472 or email customercare@agpayroll.co.uk
