The umbrella company landscape is entering a period of major change. With new and changing obligations on the horizon for recruitment businesses, including critical changes to legislation coming into force in April 2026, now is the time to prepare. To support you through this transition, the REC has launched an Umbrella Company Hub: your go-to source for updates on these changes as more details emerge, with clear and insightful information and guidance on what these changes mean for your business and what you can do to prepare for them. Watch our recent webinar on demand to understand what the new obligations on the horizon mean, how Umbrella Companies are legally defined and how to prepare your business accordingly.

The amendments to the Employment Rights Bill were announced on 4th March 2025. Further information on the amendments can be found here. Our most recent publication on changes to statutory payments under the ERB can be found here. We recently hosted a webinar on the ERB which included updates for the REC campaigns and legal teams. The recording can be found here. On 1st July 2025, the government published the Roadmap on Implementing the Employment Rights Bill which sets out when different provisions contained in the Bill are scheduled to come into force. On 7th July 2025, several amendments were made to the Bill, details of which can be found here.

The DBS have clarified their Update Service guidance to add that before carrying out a status check, employers must see the applicant's original paper certificate in person.

At the end of April 2025, the DBS had also updated their ID checking guidelines for Standard/Enhanced DBS check applications. You can find further information in our Legal Hot Topics July 2025.

Additional DBS Digital Identity Verification Guidance issued on 6^th October states that using a Digital Verification Service (‘DVS’) is an alternative to following one of the routes set out in the ID checking guidelines, provided that you are following the DBS guidance on how to use Digital Identity Verification. If you are not going to use one of the certified DVS, you must manually check the candidate’s original identity documents as set out in Routes 1, 2 or 3 of the ID checking guidelines.

On 19th November, the Crown Commercial Services (CCS) released their Invitation to Tender Notice for the upcoming framework agreement for Supply Teachers and Education Recruitment (RM6376). The information provided within the Bidder Engagement Slides from the 17th September 2025 (available under 'Supplier Engagement') remains correct, with the exception of a few updates: 

• Slide 6: Number of suppliers to be awarded a place on Lot 1 of the agreement. CCS will now be awarding up to 150 suppliers. 
• Slide 9: Pricing Model and Role Types
• Category Line 1: Teacher (SEND and non-SEND). This will not be split into STEM teacher and non-STEM teacher, so there will be an additional role type as part of the commercial pricing template. 
• CCS will be implementing a maximum 'bid ceiling' pricing strategy. This means that bidders will be required to tender Employment Business pricing that falls within a maximum 'bid ceiling', set for each role type. If the tender pricing exceeds the maximum 'bid ceiling' for any of the role type for the lot(s) for which they are bidding, then the bid will be deemed non-compliant and will be excluded from the procurement (though this will still not guarantee bidders a place on the framework agreement). 

The tender enquiry deadline is on 3rd December at 3:00pm, and the tender submission deadline is on 19th December at 3:00pm. 

For further information, you may wish to review Part 1 of the November issue of our Legal Hot Topics. 

We have seen an increase of queries surrounding holiday pay, including members looking to move from the accrual method to rolled up holiday pay. You may wish to see our Legal Guide on Holiday Pay and our Frequently Asked Questions on the amendments to the Working Time Regulations 1998.

As the year comes to an end, it may also be the end of the leave year for many businesses. You should ensure that you are reminding employees/workers of their entitlement to take leave and that any accrued but untaken leave at the end of the leave year may be lost. For further information on this, you may wish to see our Legal Guide on Holiday Pay or contact the REC Legal Team.