29/09/2026
September has been a significant month for contractors and agencies.
Here is a brief summary of the key developments heading into October.
1. Right to Work expansion takes effect on 1 October.
The Border Security, Asylum and Immigration Act 2025 extends Right to Work liability up the supply chain. Agencies and umbrella companies can now face civil penalties of up to £60,000 per worker if they fail to meet prescribed compliance requirements.
Digital verification via DVSP providers is now mandatory for many checks. If you have not reviewed your Right to Work processes, speak to your agency business manager.
2. Mid-tax-year checkpoint.
We are now halfway through the 2026/27 tax year. September was the time to review your tax code, check pension contributions, verify the new 55p mileage rate is being applied, and assess holiday pay accrual.
If you have not completed a mid-year financial check, your SmartWork business manager can walk you through your payslip.
3. HMRC holiday pay consultation closed on 22 September.
HMRC reviewed holiday pay compliance and enforcement across the umbrella sector. The Fair Work Agency will begin enforcement from 2027, with penalties up to 200% of arrears for non-compliance.
Compliant holiday pay should be clearly itemised on every payslip, calculated at 12.07% of gross pay, and never withheld or rolled into your hourly rate.
4. Umbrella company selection criteria.
With September's "back to work" season, many contractors reviewed their umbrella providers. The five key criteria are: FCSA accreditation, SafeRec certification, transparent payslips, a designated business manager, and fast, reliable payments.
SmartWork meets all five. If you are reviewing your current provider, we are here to help.
For detailed info on any of the above, head to our blog. Link in the comments. 👇
Follow us for monthly updates, and if you have questions about any of these developments, your business manager is here to help.