Twelve-month Legal Timeline

June 2025

• The Low Pay Commission (LPC) launched a consultation seeking evidence to help guide its recommendations on the 2026 National Minimum Wage (NMW) and National Living Wage (NLW) rates. The consultation closes on 30 June 2025.
• On 5th June, HMRC published details of two more tax avoidance promoters and their schemes on GOV.UK. Details of the promoters and the schemes are: 
  • Pure Employment Limited - Employees within the social work sector are among those who have adopted the use of these arrangements. 
  • Arrow Tree Consulting Limited - HMRC has identified that some of the users of these arrangements are employed within the social work and healthcare sectors. 
• HMRC and the Department of Business and Trade has published a National Minimum Wage name and shame list, along with an 'Educational Bulletin' to increase awareness of National Minimum Wage legislation and inform companies on how to make sure they’re paying workers correctly.
• On the 12^th of June, HMRC updated its Current list of named tax avoidance schemes, promoters, enablers and suppliers.
• 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. 
• The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 is due to come into force on 26th June 2025. The Order amendments the Public Interest Disclosure (Prescribed Persons) Order 2014 and amends the list of prescribed persons and matters to which whistleblowers are able to disclose wrongdoing as part of a protected disclosure.
• The Institute for Apprenticeships and Technical Education (Transfer of Functions etc) Act 2025 is due to come into force on 1st June 2025. It transfers the functions of the Institute for Apprenticeships and Technical Education (IfATE), and its property, rights and liabilities, to the Secretary of State, and amends the Apprenticeship, Skills, Children and Learning Act 2009, paving the way for the creation of Skills England, as set out in the Labour government’s manifesto and subsequently in the King’s Speech on 17 July 2024. Skills England will be established as an executive agency within the Department for Education rather than as an independent or cross-government organisation.
• The Data (Use and Access) Bill 2025 received Royal Assent on 19th June 2025. The ICO has since published several guidance documents and a working plan to support this, with the main changes to the law including clarifying how personal information can be used for research and reducing some restrictions on automated decision making, setting out how to use some cookies without consent, allowing charities to send people electronic mail marketing without consent in certain circumstances and requiring organisations to have a data protection complaints procedure and introducing a new lawful basis of recognised legitimate interests.

• The Equality and Human Rights Commission (EHRC) has published a consultation on changes to its Code of Practice for services, public functions and associations (the Code), following the Supreme Court’s judgment of 16 April 2025 in For Women Scotland v Scottish Ministers on the definition of ‘sex’ for the purposes of the Equality Act 2010. A draft of the full Code was consulted on between October 2024 and January 2025 and as such, the latest consultation will focus on the sections of the Code which are affected by the Supreme Court judgment. The consultation closes on 30th June 2025.

  • The EHRC has also updated its interim update on the practical implications of the Supreme Court judgement in For Women Scotland v Scottish Ministers. The update is to clarify the position on separate-sex facilities in the workplace, taking into account requirements of the Workplace (Health, Safety and Welfare) Regulations 1992. However, the update should not be interpreted as a change in its fundamental position on the implications of the judgement. The update was published on 24^th June 2025.

• The Scottish government has published its Disability Equality Plan on the 20th June 2025. The plan was developed in collaboration with core funded Disabled People’s Organisations, setting out a range of actions intended to embed disability competence within the Scottish government and improve outcomes for disabled people through evidence-based policy development and accountability measures.

• The Financial Conduct Authority (FCA) has published its annual report for 2024/25 under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 on 24th June 2025., setting out the whistleblowing disclosures received by the FCA from 1st April 2024 to 31st March 2025. The FCA has received 1,131 whistleblowing reports, which generated 2.684 separate allegations.

• The Employment Rights Bill was concluded in the House of Lords on 25th June 2025. It appears that the Bill will not receive Royal Assent before the summer, although it has now been concluded in the House of Lords.

  • REC Members can watch the REC's Employment Rights Bill webinar, hosted on 26th June 2025, here.