Policies for Recruitment Agencies

Policy Pros writes bespoke, compliance-ready policies for UK recruitment agencies, employment businesses and temporary labour providers. Whether you place permanent staff, run a temp desk or supply workers into regulated sectors, we produce the documents that regulators, hirers and auditors ask to see.

Bespoke, audit-ready policies from £65 + VAT per document. Get a quote or call 020 3951 2875 for a free scoping conversation.

Policies Recruitment Agencies Need

Legally Required

• Terms of business with work-seekers and hirers - required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003 before work-finding services begin
• Key Information Document for temporary workers - regulation 13A of the Conduct Regulations 2003, mandatory since 6 April 2020
• Agency worker equal treatment procedure - Agency Workers Regulations 2010, covering day-one rights and 12-week parity on pay and basic conditions
• Data protection and candidate privacy policy - UK GDPR and the Data Protection Act 2018, covering CVs, vetting records and client data
• Health and safety policy - Health and Safety at Work etc. Act 1974, a written statement is required once you have five or more employees
• Equality and diversity policy - the Equality Act 2010 applies to employment service providers as well as employers
• GLAA licensing standards compliance - Gangmasters (Licensing) Act 2004, where you supply workers to agriculture, horticulture, shellfish gathering or food and drink processing and packaging

Expected by Regulators and Clients

• Right to work checking procedure - preserves the statutory excuse against illegal working penalties under the Immigration, Asylum and Nationality Act 2006
• Umbrella company due diligence policy - manages the PAYE joint and several liability rules in force since 6 April 2026
• IR35 status assessment procedure - expected wherever contractors are supplied through personal service companies
• Modern slavery policy - a statement is compulsory above £36 million turnover, and client supply chains demand one well below that threshold
• Safeguarding and DBS policy - required by hirers when supplying staff into education, health and social care
• Complaints and temporary worker grievance procedure - expected under REC and APSCo compliance audits and most hirer contracts

One Regulator Now Enforces Agency Conduct

On 7 April 2026 the Employment Agency Standards Inspectorate and the Gangmasters and Labour Abuse Authority were absorbed into the Fair Work Agency, a single enforcement body created by the Employment Rights Act 2025. The Conduct Regulations 2003, the Agency Workers Regulations and gangmasters licensing are now policed from one place, with stronger inspection powers and a proactive remit.

The Conduct Regulations set the operating rules for the whole sector. They require agreed terms before services start, ban charging work-seekers fees for work-finding, and oblige you to obtain suitability information from hirers before making a supply.

Enforcement of agency rules was historically under-resourced, so weak paperwork often went unnoticed. That has changed, and our guide to the Fair Work Agency explains the new powers in detail.

GLAA Licensing in Regulated Sectors

If you supply workers to agriculture, horticulture, shellfish gathering or food and drink processing and packaging, you need a gangmasters licence, now issued by the Fair Work Agency. Operating without one is a criminal offence carrying up to ten years in prison, and hirers commit an offence by using an unlicensed provider.

Licence inspections test your documents against the licensing standards, including pay records, terms of engagement, health and safety arrangements and transport and accommodation rules. Written policies that match how you actually operate are the core of passing that inspection.

Umbrella Companies and the April 2026 Liability Rules

Since 6 April 2026, where an umbrella company sits in your labour supply chain, the recruitment agency holding the contract with the end client is jointly and severally liable for any unpaid PAYE, under rules introduced by HMRC. A written umbrella due diligence policy, covering approved supplier lists, payslip checks and contract terms, is now the baseline protection that hirers and insurers expect. Where you supply contractors through personal service companies, an IR35 and off-payroll working policy addresses the parallel status assessment risk.

What Hirers and Auditors Ask to See

Many policy demands on agencies come from clients rather than regulators. Managed service providers, public sector frameworks and REC or APSCo compliance audits routinely ask for terms of business, data protection documents, a recruitment and selection policy and evidence of vetting procedures before releasing vacancies to you.

Agencies placing sponsored workers face extra scrutiny on salary thresholds and role eligibility, which we cover in our Skilled Worker visa guide for 2026. Your own consultants also need the same core HR policies and procedures as any other employer, from disciplinary rules to absence management.

What Policy Pros Delivers

• Bespoke documents written around your desks, sectors and supply chains, not generic templates
• A fixed-price quote before any work starts, with no hourly surprises
• Review rounds included, so the final wording reflects how your agency actually operates
• Finished documents supplied on professionally branded templates, ready to issue to workers and clients

Extremely professional and thorough. The policies were tailored perfectly to our sector and delivered ahead of schedule.

You can read reviews of Policy Pros on Trustpilot.

How to Get Started

Tell us what you place, which sectors you supply into and who is asking you for documents. We will scope exactly what you need and send a fixed-price quote, with most engagements completed within 1-2 weeks. Get a quote or call 020 3951 2875.