The introduction of Joint and Several Liability (JSL) legislation has fundamentally changed how agencies assess compliance within their labour supply chains. With JSL now in force, agencies can be held jointly liable for certain unpaid PAYE and National Insurance liabilities where non-compliance exists within the supply chain.
As a result, due diligence is no longer simply a matter of good practice. Agencies must be able to demonstrate that they have taken reasonable steps to work with compliant partners and actively manage supply chain risk.
At SmartWork, we understand the importance of giving our agency partners confidence that they are working with a compliant, transparent umbrella company. That’s why we’ve built our operations around independent verification, robust auditing, and full supply chain transparency.
Our Established Compliance Framework
The good news for agencies is that SmartWork’s existing compliance framework already aligns with the requirements introduced under the Joint and Several Liability regime. In many areas, our controls exceed industry expectations.
We’ve built our operations on independent verification, transparent processes, and continuous auditing, giving agencies confidence that they are partnering with a provider that takes compliance seriously.
When you work with SmartWork, you’re partnering with a fully accredited umbrella company that actively manages risk at every stage of the employment supply chain.
How SmartWork Supports Agencies Under JSL
Strong Governance and Independent Auditing
We maintain a comprehensive compliance framework designed to meet current legislative requirements, including the obligations introduced under the Joint and Several Liability framework.
Our credentials include:
- FCSA Accreditation with annual independent audits covering operational, tax, and anti-avoidance controls
- ISO 27001 certification for information security management
- APSCo Trusted Partner status
- SafeRec certification for real-time payroll compliance verification
- Internal compliance reviews are conducted twice yearly to maintain best-practice standards
- Registration with the FCSA Diligence Hub, providing transparent access to compliance documentation
Our SafeRec certification enables real-time payroll compliance verification, providing agencies with an additional layer of assurance and independent oversight.
Complete Transparency in PAYE and National Insurance
Transparency is at the heart of our compliance approach.
To ensure every deduction and payment is processed correctly, we maintain full visibility across all PAYE and National Insurance processes, including:
- Daily and monthly reconciliation of PAYE and National Insurance payments
- Independent verification through external audits
- Real-time payslip auditing via SafeRec, which cross-checks payroll data against HMRC submissions
- Full payslip visibility for contractors and agencies, showing deductions and contributions clearly
- Secure payment systems operated exclusively through UK-based bank accounts held in SmartWork’s name
This approach removes ambiguity and helps ensure every payment is accurate, compliant, and fully accountable.
Rigorous Due Diligence and Worker Verification
Protecting agencies from supply chain risk requires ongoing monitoring and robust verification processes.
To support this, SmartWork operates comprehensive due diligence procedures, including:
- Annual independent compliance and payroll audits through FCSA, ISO 27001, and SafeRec
- Continuous verification of compliance documentation through the FCSA Diligence Hub
- Automated monitoring systems designed to identify irregularities and potential indicators of mini-umbrella fraud
- Comprehensive worker identity verification and onboarding checks
- Ongoing reviews of operational processes to maintain compliance standards
These measures help protect agencies from the financial and reputational risks associated with non-compliant supply chains.
Open Access to Certifications and Compliance Documentation
We believe compliance should be transparent and easily verifiable.
That’s why we provide access to key certifications and supporting documentation, including:
- FCSA Accreditation certificates
- ISO 27001 certification
- SafeRec verification documentation
- Compliance statements and supporting information on request
- Access to current compliance documentation through the FCSA Diligence Hub
- Regular compliance updates for agency partners
This transparency helps agencies demonstrate their own due diligence processes with confidence.
Ongoing Enhancements
Although JSL is now in force, compliance expectations continue to evolve.
SmartWork remains committed to strengthening its systems and processes through:
- SafeRec-powered real-time payroll auditing and compliance verification
- Enhanced payroll reconciliation and automated compliance reporting
- Quarterly supply chain reviews and risk assessments
- Continuous monitoring for emerging threats, including mini-umbrella fraud and identity-related risks
- Centralised compliance documentation through the Diligence Hub for easy agency access
- Ongoing investment in technology and compliance infrastructure
By continually reviewing and improving our processes, we help ensure our agency partners remain supported in an increasingly complex compliance environment.
Comprehensive Insurance Protection
SmartWork maintains comprehensive insurance coverage to provide additional protection and reassurance to our partners.
Our cover includes:
- Professional Indemnity Insurance
- Employer’s Liability Insurance
- Public Liability Insurance
Written confirmation of our insurance arrangements is available on request.
What This Means for Agencies
With JSL now in force, agencies must be able to demonstrate that they have undertaken appropriate due diligence when selecting umbrella partners.
Independent verification, transparent payroll processes, and ongoing compliance monitoring are no longer simply best practices; they are essential risk-management measures.
By partnering with SmartWork, agencies work with a provider that combines FCSA Accreditation, ISO 27001 certification, APSCo Trusted Partner status, and SafeRec verification to deliver independent, real-time compliance assurance.
Including SmartWork on your approved supplier list can support your due diligence processes and demonstrate your commitment to ethical practices, governance, and worker protection.
Moving Forward with Confidence
Our continued investment in compliance technology, auditing, and supply chain transparency enables our partners to operate with confidence in today’s regulatory environment.
As agencies adapt to the realities of Joint and Several Liability, having independently verified compliance processes has never been more important.
SmartWork remains committed to providing the transparency, assurance, and support our partners need to manage supply chain risk effectively and meet their ongoing due diligence obligations.
If you have any questions about our compliance measures or would like to discuss how SmartWork can support your agency under the Joint and Several Liability framework, please get in touch with our team.
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