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Navigating Joint and Several Liability: Orbital Payroll Group’s approach to agency compliance

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This is a guest blog from REC Business Partner, Orbital Payroll Group

The introduction of Joint and Several Liability (JSL) represents one of the most significant regulatory shifts the recruitment sector will face ahead of April 2026. Under the new framework, agencies and end clients may become jointly liable for unpaid PAYE and National Insurance within their labour supply chain, increasing the accountability placed on payroll partners and strengthening the need for evidence‑based compliance.

At Orbital Payroll Group, we recognise that agencies need more than reassurance, they need transparent systems, independent verification, and operational clarity that can stand up to HMRC scrutiny. Our approach is built on robust compliance foundations, enhanced visibility, and ongoing validation to help agencies confidently navigate the new landscape.


Orbital Payroll Group's tips

Demonstrate strong due diligence

Protecting agencies under the JSL framework starts with rigorous, independently verified compliance.

Orbital Payroll Group holds FCSA accreditation and SafeRec accreditation, two of the most recognised standards for payroll governance and operational integrity. These accreditations provide:

  • Strict compliance auditing
  • Demonstrable transparency across payroll operations
  • Assurance that PAYE and NIC are handled accurately and in line with HMRC requirements

In addition, agencies can access an added layer of protection via ORBIO insurance, available through SafeRec. This provides further commercial reassurance in situations where liability safeguards are essential.

Utilise independent audits and external validation

Independent oversight is no longer optional — it is essential.

Orbital Payroll Group is Workforce Assured approved, a standard specifically designed to raise compliance and labour‑management expectations within key sectors such as construction.

This additional auditing framework validates:

  • Payroll processes
  • Worker engagement structures
  • Compliance documentation and governance controls

By committing to multiple external assurance routes, Orbital ensures that agencies benefit from a fully audited and independently verified payroll environment.

Ensure full transparency of worker remuneration

Transparency is central to JSL readiness, and agencies must be able to demonstrate that all worker remuneration is processed as employment income.

To enable this, Orbital Payroll Group provides every agency and client with access to The Lighthouse Portal, powered by Octopaye. This portal delivers:

Key benefits:

  • Real‑time transparency of worker tax submissions
  • Full visibility of PAYE treatment and gross-to-net calculation
  • Evidence‑ready compliance trails for agency audit requirements
  • Seamless integration with Octopaye for accuracy and data integrity
  • Immediate visibility of payments made to HMRC

And importantly:

  • This service is completely free of charge to all agency partners.

By providing open access to compliance data, Orbital removes ambiguity and helps agencies demonstrate governance at every stage of the payroll process.

Provide evidence of PAYE and NI payments to HMRC

One of the most important aspects of JSL is the ability to provide proof, not just policy.

In addition to the detailed SafeRec reports agencies receive, Orbital Payroll Group uploads HMRC payment receipts directly into The Lighthouse Portal. This allows agencies to confirm:

  • Liabilities were calculated correctly
  • Submissions were made on time
  • Payments were received by HMRC

This approach replaces retrospective checking with real-time validation — giving agencies confidence that liabilities are not only reported correctly, but also fully settled.

Demonstrating financial stability and long-term resilience

Financial health across the supply chain is a key focus under the JSL framework.

SafeRec’s credit‑checking facility allows agencies to assess the financial standing of providers and conduct additional due diligence where needed. Orbital Payroll Group supports this transparency and encourages agencies to make informed decisions based on factual, independently verified financial data.

Being open to financial scrutiny demonstrates our commitment to stability, resilience, and responsible payroll management giving agencies assurance that we can meet all statutory and payroll commitments reliably.

A more transparent and accountable payroll landscape

Joint and Several Liability is raising the bar for compliance and the recruitment sector must adapt. Agencies that select payroll partners offering real-time visibility, independent verification, and strong financial controls will be best placed to avoid risk and stay compliant.

Compliance must be visible, transparent, and independently validated. We are committed to helping agencies not only meet these expectations, but exceed them as April 2026 approaches.

 

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