Navigating the new compliance landscape: NumberMill

This is a guest blog by REC business partner, NumberMill

As April ushers in a significant shift in the recruitment compliance landscape, the introduction of Joint and Several Liability (JSL) marks one of the most important regulatory steps the sector has seen in recent years. For staffing businesses, payroll providers and umbrella companies, it raises a clear question: How do we protect our workers, customers and supply chains with confidence?

At NumberMill, we believe that strong governance is not something to “add on” in response to legislative change—it’s something that must be embedded long before regulatory risk arrives. As the new regime comes into force, our role as a PAYE employer remains unchanged, but the accountability across the supply chain is evolving. That’s why we’ve taken proactive steps to ensure complete transparency, robust risk safeguards and a compliance-first operational model for every agency we partner with.

Below, we outline the principles at the heart of our approach.

1. Strengthened due diligence to protect agencies from JSL risk

Under JSL, HMRC can pursue liabilities up the supply chain even when NumberMill remains the PAYE employer. That reality demands an enhanced due‑diligence strategy.

Our governance framework includes:

• GLAA licensing
• FCSA accreditation
• Strengthened supply‑chain due‑diligence checks
• Segregated client accounts with full audit trails
• SafeRec accreditation in progress ahead of April 2026

This structured approach means agencies can rely on a partner that has already built the right safeguards into daily operations—not one that is scrambling to catch up.

2. Independent validation for continued assurance

Our compliance processes are not only internally governed they are independently verified.

We complete external audits of payroll and tax compliance, supported by our GLAA and FCSA credentials. We’ve also partnered with SafeRec to offer live payslip audits and monthly confirmations of RTI submissions.

In addition, our payroll software partners have built a dedicated Agency Portal, giving clients real‑time visibility of:

• Payslips as they’re produced
• RTI submissions each pay day
• Confirmation of tax reporting

These layers of independent review give agencies confidence that the standards we promise are the standards we consistently deliver.

3. Full transparency of worker pay and employment income

Trust in the supply chain starts with crystal‑clear pay processes.

Every worker receives transparent contracts and payslips, but visibility doesn’t stop there. Through our Agency Portal, clients can access:

• Worker‑specific payslips
• Payroll submissions
• Monthly P32 summaries
• A breakdown of statutory deductions and net pay

Our accreditations with SafeRec and the FCSA require ongoing scrutiny of our payroll processes—providing agencies with continual, independent validation that workers’ pay is treated correctly as employment income.

4. Demonstrating accurate, timely PAYE & NI payments to HMRC

Ensuring payroll taxes are paid accurately and on time is critical in a JSL environment.

We submit RTI filings on or before payment dates, complete full PAYE/NIC reconciliations, and remit funds within HMRC deadlines. Agencies can view upload evidence—such as payment screenshots—directly within the Portal.

This is supported by three separate verification sources:

1. FCSA
2. SafeRec
3. My Digital Accounts (our payroll software provider)

Together, these ensure RTI and tax data is checked, confirmed and evidenced from multiple angles.

5. Financial stability and responsible credit management

Financial resilience is one of the sector’s top concerns - and rightly so. In the new regulatory landscape, an unstable payroll partner becomes a direct risk to recruiters.

As an accountancy and back-office provider ourselves, we maintain financial controls and cash flow processes that exceed what is typical for similar-sized organisations. We encourage agencies to credit-check any payroll partner regularly, and we remain committed to:

• Avoiding large, unsecured or uninsured credit lines
• Protecting recruiters from exposure to high-risk funding models
• Ensuring our operations remain fully resourced and responsibly managed

As part of a wider, well‑funded group, we are in a strong financial position and well‑equipped to meet the industry’s evolving demands.

Looking ahead: a safer, more transparent future for the sector

Compliance should not be an obstacle to growth—it should be the foundation that enables it. At NumberMill, we welcome the higher standards introduced by JSL, because they help to elevate the entire industry and protect the reputation of responsible agencies.

We are committed to staying ahead of regulatory change, investing in technology, strengthening our governance and offering transparency at every step.

As the landscape shifts in 2026 and beyond, our message to the industry is simple:

With the right systems, accreditations and governance in place, compliance becomes a competitive advantage, not a compliance burden.

Learn more about Numbermill