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The National Living Wage of £12.71 per hour puts umbrella payroll construction under scrutiny, with HMRC enforcing and JSL raising the stakes for agencies.
NMW compliance becomes enforceable for umbrella firms from April 2027 under the Fair Work Agency — audit deductions and holiday pay now.
The duty to inform workers of trade union rights starts on 1 January 2027, with government-set wording agencies and umbrellas must issue to staff.
Guaranteed hours for agency workers would strip out the flexibility people choose agency work for. FCSA sets out why the model does not fit the reform.
IR35 enforcement in 2026 now runs on HMRC’s AI detection, and small-company threshold changes have handed status decisions back to many contractors.
From 1 October 2026, right to work checks apply to agency workers, subcontractors and platform staff, with penalties up to £60,000 per worker.
