Preparing for JSL: how Brookson supports compliant supply chains

This is a guest blog by REC business partner, Brookson/People 2.0

With Joint & Several Liability (JSL) coming into force in April 2026, the compliance expectations placed on recruitment agencies are set to rise significantly. Under this new framework, agencies and in some circumstances their clients could be held financially responsible if PAYE and National Insurance obligations are not correctly managed anywhere in their labour supply chain.

For many recruitment businesses, this represents a shift from compliance by assumption to compliance by evidence. Agencies need payroll partners who can demonstrate operational integrity, financial resilience, and end‑to‑end transparency.

At Brookson/People2.0, our approach is built on decades of experience, rigorous compliance frameworks, and a commitment to giving agencies complete visibility into how workers are engaged and paid. Below, we share five top tips to help agencies prepare for this new compliance era.

1. Building confidence through due diligence and transparency

Brookson has long-standing due diligence processes designed to help agencies meet their obligations confidently.

Our FCSA accreditation requires a comprehensive assessment across payroll operations, tax compliance, and worker treatment and provides agencies with independent confirmation that every part of our model meets the highest compliance standards.

Our supply-chain partnership model is built around transparency. Agencies working with Brookson have fully traceable insight into:

• How workers are employed
• How they are paid
• How PAYE and NIC are managed
• How compliance is maintained throughout the chain

This visibility is essential as JSL increases regulatory scrutiny.

2. Independent verification and continuous compliance

Agencies increasingly expect and need independent verification of payroll compliance. Brookson provides this through:

• Ongoing FCSA reassessment
• ISO 27001 certification, ensuring data security and operational controls
• Regular independent reviews of processes
• Comprehensive due‑diligence checks across all supply‑chain partners

These are not one‑off credentials. They reflect a continuous commitment to robust governance and compliance excellence.

3. Ensuring transparent and compliant worker pay

Under the JSL framework, agencies must be able to demonstrate that workers’ pay is treated correctly as employment income.

Brookson’s umbrella employment model ensures:

• All workers are employed directly by Brookson
• All pay is routed through PAYE, with no loan arrangements or third‑party payment structures
• Workers receive fully itemised payslips
• Agencies can access supporting documentation at any time

We are also launching a payslip auditing partnership, giving agencies direct, real-time visibility into payslip detail and payroll calculations.

Together with access to RTI submissions, this provides a clear, transparent record of how tax and NIC obligations are being met pay run by pay run.

4. Real-time payroll verification and compliance

Brookson’s payroll processes are designed to give agencies ongoing evidence, not retrospective confirmation.

We:

• Submit RTI on every payroll cycle
• Ensure PAYE and NIC are calculated and remitted accurately
• Make supporting RTI documentation accessible to agencies
• Provide payslip‑level verification once our auditing partnership goes live

This allows agencies to verify compliance in real time, strengthening internal controls and reducing exposure under JSL.

5. Financial stability and long-term resilience

Financial resilience is a critical consideration under JSL, and Brookson offers exceptional stability.

For over 30 years, we have supported contractors and recruitment agencies across the UK. Today, as part of People2.0 a global workforce solutions provider operating in 130+ countries we bring:

• Deep financial backing
• Global infrastructure
• Mature governance frameworks
• Long-term operational durability

This gives agencies confidence that Brookson has the resources and capability to meet all obligations consistently, now and into the future.

Looking ahead: evidence-led compliance as the new standard

Joint and Several Liability is accelerating a sector‑wide shift toward transparent, independently verified, and operationally robust payroll models. Agencies who prepare early and partner with providers who can demonstrate compliance at every level  will be best placed to manage risk and maintain confidence across their supply chains.

At Brookson / People2.0, our commitment is clear: we provide the visibility, governance, and financial strength agencies need to thrive in the new JSL environment.

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