The recruitment sector is preparing for a significant change with the introduction of Joint and Several Liability (JSL) legislation in April 2026. At SmartWork, we understand that this reform brings important considerations for our agency partners, which is why we’re taking clear steps now to ensure full compliance and protect your business from potential risks.

Our Existing Compliance Framework

The good news is that our current compliance frameworks already meet the anticipated requirements of the JSL legislation. In many areas, we exceed them. We’ve built our operations on a foundation of independent verification, transparent processes, and continuous auditing that gives our partners genuine peace of mind.

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.

What We’re Doing to Prepare

Strong Governance and Regular Audits

We maintain a comprehensive compliance framework that keeps us aligned with both current and upcoming legislation. Our credentials include:

• Full FCSA membership with annual independent audits covering operational, tax, and anti-avoidance controls
• ISO 27001 certification for information security
• APSCo Trusted Partner status
• SafeRec certification for real-time payroll compliance verification
• Internal compliance reviews conducted twice yearly to maintain best practice standards
• Registration with the FCSA Diligence Hub, giving transparent access to all our compliance documentation

Our SafeRec certification enables real-time payroll compliance verification, adding another layer of assurance for agencies partnering with us.

Complete Transparency in Tax and National Insurance

We believe transparency builds trust. That’s why we maintain full visibility across all PAYE and National Insurance processes:

• Daily and monthly reconciliation of PAYE and NIC payments, verified through external audits
• Real-time payslip auditing via SafeRec, which cross-checks RTI submissions directly with HMRC data
• Full payslip visibility for both workers and agencies, showing all deductions and contributions in detail
• Secure payment systems operated exclusively through UK-based bank accounts in SmartWork’s name

This approach removes ambiguity and ensures every payment is correct, compliant, and fully accountable.

Rigorous Due Diligence

To guarantee proper tax treatment and ethical management of all workers, we conduct thorough due diligence and audit procedures:

• Annual independent compliance and payroll audits through FCSA, ISO 27001, and SafeRec
• Ongoing real-time due diligence via the FCSA Diligence Hub for continuous documentation verification
• Automated monitoring systems that detect irregularities, including mini-umbrella and VAT evasion schemes
• Comprehensive worker verification and identity checks before onboarding

These continuous checks safeguard your business from financial exposure and reputational damage that can come from non-compliant supply chains.

Open Access to Certifications

We provide formal assurances and easy access to all relevant certifications and documentation, including:

• Certificates of FCSA accreditation, ISO 27001 certification, and SafeRec compliance verification
• Full access to current certificates, audit reports, and documentation via the FCSA Diligence Hub
• Quarterly compliance updates to keep agencies informed
• Formal compliance statements available on request

This transparency allows you to demonstrate your own compliance diligence with confidence.

Ongoing Enhancements

We’re not standing still. To prepare for the JSL reforms, we’re continuing to strengthen our operational and technological frameworks:

• Leveraging our SafeRec certification for real-time payroll auditing and compliance verification
• Updating agency and client contracts to include JSL provisions (Q1 2026)
• Enhancing payroll systems to support live reconciliation and automated compliance reporting
• Conducting quarterly supply chain reviews to ensure continuous JSL compliance
• Centralising documentation through the Diligence Hub for on-demand access

Comprehensive Insurance Protection

We maintain comprehensive insurance coverage to protect our partners:

• Professional Indemnity Insurance
• Employer’s Liability Insurance
• Public Liability Insurance

We’re also reviewing and updating our indemnity provisions to ensure full alignment with the JSL framework. Written confirmation of our coverage is available on request.

What This Means for Agencies

As we move closer to April 2026, it’s essential for agencies to ensure their supply chains are transparent, compliant, and independently verified. The JSL legislation will make this more important than ever.

By partnering with SmartWork, agencies are working with a provider that combines FCSA accreditation, ISO certification, and SafeRec verification to deliver independent, real-time compliance assurance.

Including SmartWork on an approved supplier list helps agencies mitigate the risks associated with JSL while demonstrating their commitment to ethical practice, governance, and worker protection.

Moving Forward with Confidence

Our continued investment in compliance technology, auditing, and supply chain transparency means our partners can operate with confidence, both today and beyond April 2026.

We’re here to support agencies through this transition. If there are any questions about our compliance measures or how we’re preparing for the JSL legislation, please get in touch with our team.

For more information about SmartWork’s compliance framework or to access our certification documents via the FCSA Diligence Hub, please contact us.