• References:  Whilst REC Audited Education requires two written references to be in place, the framework additionally requires that these cover the last two years as laid out in paragraph 4.3.4 in the Framework Schedule 1 (Specification).   As well as carrying out checks in line with the Audited criteria, REC will check when conducting audits that your written reference policy confirms that you will obtain references to cover the last two years.  Where this is not the case, it has been agreed that REC will inform GCA
• Declarations: There are certain clauses within paragraphs 4 and 14 of the framework where the REC will check by asking suppliers to confirm their compliance via a written declaration as part of the audit process.  For clarity these clauses are 4.4/5 and 14.2.4/5/6/7/9/12 and 14.18/19/20.

• Identity/Proof of address/right to work checks – whilst these checks are already embedded within the audit, REC Audited Education has been amended to align with the GCA framework to specify that at least 2 different documents should be seen when carrying out these checks.  GCA have also confirmed that where you use an IDSP for ID checks for DBS purposes, you will not be required to do a separate proof of address check for REC Audited Education
• Employment history – REC Audited Education and the GCA framework both require that a candidate’s full employment history is obtained (via a CV or application form)
• Seeing a worker’s documents – REC Audited Education and the GCA framework both require that all documents provided for validation are current, scanned or copied from originals, clear and legible and held in a format that cannot be subsequently altered as well as being dated and properly validated by electronic means or otherwise.  (You must ensure that you see original, physical documents where required, such as, original, physical DBS certificates when carrying out DBS checks and original, physical documents when carrying out a manual right to work check).

• Continued Suitability - If a worker has not been working with you for a time, such as, 3 or 6 months you should carry out additional checks to ensure the worker’s continued suitability.  We have amended this requirement to say that the 3 or 6 months period is subject to any client requirement
• Reporting to REC – there is also now a requirement in the audit criteria to report promptly to the REC Compliance Team any investigation into a worker that an agency has supplied that may bring the agency, REC or GCA Framework (for GCA suppliers) into disrepute

If you hold REC Audited Education but are not a GCA supplier, please note that the changes outlined in the paragraphs below will apply to you:

• Which areas in the REC Audited Education criteria have been aligned with the framework? (GCA Suppliers and non-GCA Suppliers) and
• Are there any further amendments to the REC Audited Education criteria (GCA Suppliers and non-GCA Suppliers)

If you hold REC Audited only (ie. you do not have the education award), please note that the changes outlined in the paragraphs below will apply to you:

• Which areas in the REC Audited Education criteria have been aligned with the framework? (GCA Suppliers and non-GCA Suppliers) and
• Are there any further amendments to the REC Audited Education criteria (GCA Suppliers and non-GCA Suppliers) with the exception of Continued Suitability which is specific to the education audit

• During the last framework new checks were introduced to the audit where REC checked a sample of payslips against corresponding KIDs to check whether the name of the umbrella company was the same on the KIDs and payslips and whether there were deductions for PAYE/NI on the payslips.  These checks only applied to GCA suppliers during the last framework but these checks will now apply to all REC Audited and REC Audited Education audits (new and renewals).  Please ensure that your umbrella companies allow access to work-seeker payslips for REC audits
• There were major changes to the umbrella company landscape in April 2026 with new obligations for employment businesses. Please ensure that you have reviewed the information in the REC’s Umbrella Hub https://www.rec.uk.com/recruiters/legal/umbrella-companies-what-agencies-need-know If you would like any further guidance on these changes please contact the REC Legal Helpline (REC Corporate Members only).

Ahead of the audit REC agrees a Data Processing Agreement with you.  This agreement requires you to have work-seeker consent for REC to view their files and see their personal data (including special categories of data, such as, health information and DBS checks) and you must then obtain this consent from work-seekers ahead of the audit.  REC has included wording that you must use for this purpose in the REC Audited/REC Audited Education guidance documents.   

So, to assist us in carrying out the audit we will need evidence of work seeker consent to view their files including special categories of data including health information and DBS checks.  This will also enable REC to carry out our reporting obligations to GCA, where required – please see the list of REC’s reporting obligations to GCA.

You should also be aware that REC has agreed with GCA that there will be certain circumstances when REC will automatically refer a matter to GCA.  This is where it comes to the REC’s attention that a worker has been supplied who:

• has been barred from carrying out regulated activity
• has not got a current and valid DBS check
• has been prohibited from working in an education environment or has restrictions placed on them that make it inappropriate to place them
• has not been barred or prohibited from working with children, however references or additional information provided by the police suggest that this is imminent. 
• does not have an overseas police check or letter, a letter of good conduct or a valid DBS
• has no evidence of right to work documentation on their file whatsoever or there are copies but they are illegible or where there are copies of right to work documentation but these have not been made by the agency (or an approved IDSP) and the agency has instead relied on such checks being carried out by a third party
• has changed umbrella companies and the supplier has not issued a new KID to the worker. 
• The REC will also refer to GCA any instances where the REC has checked a payslip for an umbrella company worker against the corresponding KID and the name of the umbrella company is different
• The REC will also refer to GCA any instances where the REC has checked a payslip for an umbrella company worker and there are no deductions showing for PAYE/NI
• The REC will refer to GCA any instances where a supplier has not been able to confirm any of the required declarations in relation to clauses 4.4/5, 4.18/19/20, 14.2.4/5/6/7/9/12

As part of the agreement with GCA, you will also be required to complete a mid audit cycle (12 months) online diagnostic, which will ask you to declare that the amendments outlined during your last audit report have been fully implemented, whether there has been any changes in key staff and to provide further information where necessary.

During the course of the framework, REC and GCA will write to you about any further changes to the audit/framework standards eg. as a result of any DfE amendments to guidance and you must amend your processes accordingly.

We contact all audit holders 6 months ahead of your renewal date to ensure that audits can be completed in a timely fashion.  It’s important that you start the audit process as early as possible as the process from application to award can take approx 12 weeks.

Particularly, all Suppliers on the GCA framework should bear in mind that there is a specific contractual requirement to ensure that the audit is maintained in order to retain the right to supply on the framework.  The REC and the other Accredited Bodies have an obligation to inform GCA when an audit is not renewed at the expiry date.  

GCA have also informed us that they are likely to suspend suppliers from the framework if your audit is not renewed at the expiry date and will only reinstate you once your re-accreditation has been confirmed by the Accreditation Body.

Please see the REC Audited/REC Audited Education guidance, which can be found at the link below:

https://www.rec.uk.com/recruiters/compliance/audited-services

We are here to support you and if you have any questions, please contact audit@rec.uk.com