Fair Work Agency 2026/27 Delivery Plan: What It Means for Recruitment Supply Chains

The Fair Work Agency has published its first delivery plan, setting out its priorities for 2026/27.

For recruitment agencies, MSPs, end clients and umbrella providers, the key theme is the development of more joined-up, intelligence-led labour market enforcement.

The plan does not create new umbrella company rules or announce a specific enforcement programme for the umbrella market. It explains how the Fair Work Agency intends to improve its use of information, technology and partnerships while preparing for additional responsibilities.

What is the Fair Work Agency?

The Fair Work Agency launched on the 7th of April 2026. It brings together functions previously carried out by the Employment Agency Standards Inspectorate, the Gangmasters and Labour Abuse Authority and the Office of the Director of Labour Market Enforcement.

Its responsibilities include regulating employment agencies and employment businesses, administering the gangmasters licensing scheme and taking action against serious labour exploitation. The agency also has statutory responsibility for National Minimum Wage enforcement. HMRC will continue to deliver this work under contract during 2026/27, before approximately 500 colleagues transfer to the Fair Work Agency in April 2027.

What will happen during 2026/27?

The delivery plan is organised around three goals: Deliver, Build and Innovate.

The Fair Work Agency intends to maintain existing enforcement activity while improving its website, guidance, contact centre and referrals with Acas and other partners. It will also build the workforce, governance and systems needed for its future responsibilities. This includes preparing for the transfer of National Minimum Wage enforcement and for holiday pay enforcement, which the government expects to begin during 2027, subject to consultation, and not before April 2027.

Technology and data are central to the plan. The agency intends to develop open-source data-scraping capability, design a unified case-management system with integrated AI capability and improve access to intelligence and management information. It also plans to introduce an online payslip explainer and holiday pay calculator.

A more joined-up enforcement environment

The delivery plan confirms the Fair Work Agency’s intention to make enforcement more coordinated, risk-based and informed by intelligence.

It plans to combine insight from its predecessor organisations, strengthen relationships with partners and improve its understanding of higher-risk sectors. Social care and construction are identified as examples. The plan does not require recruitment businesses to adopt a particular compliance system. However, government guidance recommends that employers review their compliance with existing employment rights and maintain appropriate records to demonstrate that they are meeting their legal obligations.

For recruitment supply chains, the practical priority is understanding how workers are engaged and paid. Contracts and onboarding checks remain important, but organisations also need reliable information about what is happening throughout the relationship.

Although the plan does not refer specifically to umbrella companies, its work on National Minimum Wage enforcement, holiday pay, payslips and employment rights can be relevant where an umbrella company employs workers.

What should recruitment businesses review?

The delivery plan does not prescribe specific controls for recruitment supply chains. However, its focus on coordinated enforcement may prompt agencies, MSPs and end clients to consider:

• Which labour providers operate within their supply chains
• Whether contractual arrangements accurately reflect how workers are engaged
• Whether relevant employment records are maintained
• How potential employment rights concerns are handled

Any action will depend on the organisation’s role, contractual arrangements and legal responsibilities.

What happens next?

The Fair Work Agency plans to hold its first Assembly in October 2026.

It also intends to publish its first three-year Enforcement Strategy and its 2027/28 Business Plan in April 2027. These publications should provide further detail about its longer-term enforcement priorities and planned activity.

For now, the delivery plan is best understood as a statement of direction. It explains how the Fair Work Agency intends to maintain existing enforcement work while developing the technology, systems, intelligence and partnerships required for its future responsibilities.

Recruitment agencies, MSPs, end clients and umbrella providers should continue to monitor developments as the agency’s enforcement strategy takes shape.