FCSA has submitted its response to the Labour Market Enforcement (LME) Strategy consultation 2025-26, emphasising the importance of smarter enforcement, collaborative regulation, and clear legislative definitions to protect workers and support compliant businesses in the temporary labour market.
The strategy, which focuses on tackling non-compliance and improving worker protections, comes at a critical time for the industry. In its response, FCSA outlines the need for enforcement approaches that prioritise targeting ‘payroll pirates’ while supporting firms striving to meet their obligations.
Chris Bryce, FCSA’s Chief Executive, said: “We welcome efforts to improve compliance across the labour market, but enforcement must be proportionate and well-targeted. Too often, compliant businesses bear the brunt of poorly implemented policies, while bad actors slip through the cracks. Recognition of compliant umbrellas, who invest heavily in achieving and demonstrating their compliance, simply has to come into the mix. Smarter, data-driven enforcement is key to creating a fairer, more sustainable industry.”
In its submission, FCSA calls for:
- Smarter, targeted enforcement to identify and penalise bad actors without hindering compliant businesses.
- Clear definitions for terms such as “inherently temporary workers” and umbrella companies to avoid ambiguity and displacement into non-compliant models.
- Collaborative partnerships between regulators, industry bodies, and firms themselves to share knowledge and improve outcomes.
- Streamlined regulation to align overlapping rules and avoid unnecessary burdens on temporary labour markets.
As trusted representatives of the sector, FCSA continues to work closely with government and enforcement bodies to ensure legislative changes are fair, effective, and realistic for businesses and workers alike.
Read the full consultation below:
Addendum to FCSA’s Response to the LME Strategy Consultation 2025-26
Following the publication of FCSA’s response to the Labour Market Enforcement Strategy 2025-26 consultation in December, an important update has been released. The addendum reflects further insights and feedback gathered after a roundtable discussion with Margaret Beels, Director of Labour Market Enforcement, which took place shortly after the initial submission deadline.
This addendum builds upon our original response by addressing critical points raised during the roundtable, including challenges surrounding “Mini-Umbrella non-compliance,” gross payment fraud, and the enforcement landscape. The supplementary feedback reinforces FCSA’s commitment to effective collaboration with government bodies to ensure a more transparent and compliant labour market. You can read the full addendum below.
