You may have seen recent updates on changes to the UK’s Right to Work legislation, due to take effect from 1 October 2026 (subject to Parliamentary approval).
Following extensive engagement between the Association of Labour Providers (ALP) and the Home Office, clarification has now been provided on how these changes will apply to a standard temporary agency labour supply chain.
We wanted to reassure our clients that Pure Staff’s operating model already aligns with the arrangements confirmed by the Home Office. That means there should be no additional Right to Work obligations for clients when engaging agency workers supplied by us.
What this means
The Home Office has confirmed that, in a standard agency supply arrangement (like ours):
- Responsibility for carrying out Right to Work checks remains with the labour provider (the recruitment agency)
- The end client is not expected to undertake duplicate Right to Work checks on agency workers supplied through the agency
This only applies where:
- The agency employs the temporary worker directly
- There are no substitution rights within the worker’s contract
- The worker performs their duties under the supervision, direction and control of the end client
How Pure Staff operates
For complete clarity, Pure Staff already operates in accordance with the above.
We can confirm that:
- 100% of our temporary workforce is employed directly by Pure Staff on PAYE
- We do not outsource payroll or employment responsibilities
- We do not use umbrella companies or intermediary payroll providers
- Our contracts do not contain substitution clauses allowing workers to send a replacement
- Workers supplied by Pure Staff carry out their assignments under the supervision, direction and control of our clients
- We remain responsible for carrying out compliant Right to Work checks and obtaining the statutory excuse before any worker starts an assignment
In short: direct engagement, PAYE all the way, and compliance built into how we work, not bolted on afterwards.
Our commitment to you
Compliance has always been at the heart of how we operate.
We continue to invest in robust compliance processes, in-house payroll, direct employment and regular auditing to ensure both our workers and our clients remain fully protected.
While the new legislation introduces additional considerations for more complex labour supply chains, including outsourced service models, umbrella companies, second-tier suppliers and substitution arrangements, our operating model remains straightforward, transparent and fully aligned with the Home Office’s intended approach for standard agency labour supply.
Talk to us
If you have any questions about these changes, or would like confirmation of our compliance processes, please get in touch with your Pure Staff account contact, or call our Head Office on 0121 237 4840.
Thank you for your continued partnership.
