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Legal topics affecting recruitment businesses and trends based on REC legal enquiries
The Employment Rights Bill received Royal Assent on 18th December, becoming the Employment Rights Act 2025.
The reforms under the Employment Rights Act will be implemented on a phased basis across 2026 and 2027, and will require employers to update their employment contracts, policies and practices. 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. We recently hosted a webinar on the ERB which included updates for the REC campaigns and legal teams. The recording can be found here. Our most recent publication on changes to statutory payments under the ERB can be found here.
Details on the documents which we will be updating in light of these changes can be found on our Employment Rights Act 2025 planner.
One incoming change is that, as of 1st January 2027, anyone engaged under a contract of employment with six months' service will be protected from unfair dismissal. However, what the new rules mean in practice is that all all employees recruited on or before 1st July 2026 will automatically gain unfair dismissal protection on 1st January 2027 (and a week earlier if they are dismissed without statutory notice). We explore what employers can do to prepare for this change in Part 1 and Part 2 of Unfair Dismissal Series.
Further information can be found on the REC's Legal Timeline.
As of 1 May 2026, the new GCA (previously known as CCS) Supply Teachers and Education Framework has officially gone live. The bidding process for recruitment agencies and businesses seeking a place on the framework closed in December 2025, and GCA has now issued confirmation notices to organisations that have successfully secured a position. As part of the new framework arrangements, GCA has also introduced revised charge rates that all businesses and agencies supplying under the framework will be required to follow. Full details of the updated rates can be found here.
The Department for Education (DfE) is mandating that from September 2026, agencies working with academy trusts must 'not exceed the rates available through the GCA framework.' In relation to existing contracts, the DfE has stated that it "will not force [trusts] to exit an existing contract. We recommend you compare your contracted rates against the GCA framework rates for future planning once your agreement comes to an end, in case the GCA framework provides cheaper rates.”
The Legal Helpline has had an increase of calls regarding Statutory Sick Pay in light of the changes coming in on 6th April 2026. You can find further information on our Legal Guide on SSP.
With increased scrutiny on intermediaries, and tax advisers, HMRC’s latest reforms point clearly towards a requirement for greater transparency, stronger accountability and tougher action on non-compliance across the labour supply chain. In this week’s legal update, we look ahead to April and explore the changes HMRC is implementing and the practical steps employers can take now to prepare for – and stay ahead of – these changes.
For more in depth business support join our in-person, expert-led sessions on tax and legal changes, including umbrella company compliance and PAYE obligations.
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 draft Finance (No. 2) Bill was published on 4th December 2025. It is currently going through the parliamentary process.
In February 2026, the REC will be delivering expert-led sessions on tax and legal changes, including umbrella company compliance and PAYE obligations. In partnership with Qdos, we’ll break down the legislation, highlight the risks, and provide clear, practical steps your business can implement immediately to stay compliant. The sessions will be hosted in London, Birmingham and Manchester. More information, including booking details, can be found here.
On 6th February 2026, the government launched a consultation on bringing umbrella companies within the scope of the Conduct Regulations, as proposed by the ERA 2025. The consultation closes at 11:59pm on 1st May 2026.
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