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Recrutiment & Employment Confederation

Trending topics

Legal topics affecting recruitment businesses and trends based on REC legal enquiries 

Umbrella Company Hub: What agencies need to know on the upcoming changes

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.

Employment Rights Bill

The amendments to the Employment Rights Bill were announced on 4th March 2025. Further information on the amendments can be found here. Our most recent publication on changes to statutory payments under the ERB 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. 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.

DBS

The DBS have clarified their Update Service guidance to add that before carrying out a status check, employers must see the applicant's original paper certificate in person.

At the end of April 2025, the DBS had also updated their ID checking guidelines for Standard/Enhanced DBS check applications. You can find further information in our Legal Hot Topics July 2025.

Additional DBS Digital Identity Verification Guidance issued on 6th October states that using a Digital Verification Service (‘DVS’) is an alternative to following one of the routes set out in the ID checking guidelines, provided that you are following the DBS guidance on how to use Digital Identity Verification. If you are not going to use one of the certified DVS, you must manually check the candidate’s original identity documents as set out in Routes 1, 2 or 3 of the ID checking guidelines.

Decision on the charging of VAT for the supply of locum doctors

The judgment in Isle of White NHS Trust v HMRC was published on 16th September 2025. The case involved an NHS Trust appeal against a VAT notice relating to the supply of locum doctors to the First Tier Tax Tribunal arguing that an exemption applied.

You can find our recent publication on The Tax Tribunal's Decision on VAT: What does this mean for REC members supplying Locum Doctors here.

This is due to be addressed at the upcoming Health and Social Care Sector meeting on 21st October 2025. The REC's Health & Social Care Sector Meeting is designed for REC members to hear the latest sector news and developments and discuss these with your peers. With regular updates from the REC’s legal and campaigns teams, you’ll be kept informed of the big issues impacting your business.

 

 

EAS Inspections

Guidance on what to expect during an EAS inspection can be found here.

The aim of the EAS’ routine inspections is to ensure employment businesses and agencies remain compliant with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (the Conduct Regulations). We recommend that REC members are familiar with these obligations, and you can find information on this on our Legal Guide or in our Conduct Regulations Factsheet.

 

Contact our legal helpline, available exclusively to REC Corporate members

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