Key Employment Law Changes for Temporary Workers from April 2026

From 1 April 2026, a series of important employment law reforms came into force, significantly impacting temporary workers and the businesses that engage them. These changes strengthen worker protections, increase compliance obligations for businesses, and signal a broader shift toward stricter enforcement.

Here’s a practical breakdown of what has changed and what businesses should have done / should be doing in response.

1. Statutory Sick Pay (SSP): Now a Day-One Right

• SSP is now payable from day one of sickness absence (removing the previous 3-day waiting period); and
• The lower earnings limit is abolished, meaning more workers qualify.

What this means in practice:

Temporary workers can now access sick pay immediately, which may lead to increased short-term absences.

Recommended actions for businesses:

• Tighten your sickness procedures, especially in respect of reporting and recording absences;
• Use self-certification forms for the first 7 days;
• Require fit notes from day 8; and
• Ensure your sickness policy is clear, documented, and consistently applied and consider whether training for your managers on this policy is needed.

2. Family Leave Rights Become Day-One Entitlements

Both paternity leave and unpaid parental leave are now available from the first day of employment.

Potential challenges:

Workers may request extended leave shortly after starting, creating operational disruption, especially in temporary or short-term roles.

How to manage it:

• Continue enforcing notice requirements, such as 15 weeks for paternity leave and 21 days for parental leave;
• Where notice cannot realistically be met (e.g. new hires), consider discussing alternative arrangements;
• Request appropriate supporting documentation (e.g. proof of pregnancy/birth/adoption).

3. New Bereaved Partner’s Paternity Leave

A new and sensitive entitlement has been introduced allowing employees to 52 weeks’ leave if a partner dies within the child’s first year.

Business approach:

This requires careful, compassionate handling.

Best practices:

• Ask employees to notify you as soon as reasonably practicable;
• Request confirmation of:
  • The partner’s death; and
  • Their relationship to the child;
• With that in mind, avoid overly intrusive processes – balance compliance with empathy.

4. Agency Worker PAYE Responsibility Shift

Responsibility for PAYE and National Insurance is shifting:

• Recruitment agencies are now primarily responsible for correct tax deductions
• However, “end clients” (i.e. the company where the worker actually works) can still be pursued by HMRC if errors occur (e.g. if a worker should be taxed via PAYE but is not)

Impact:

• Reduces tax avoidance; and
• Creates greater accountability across the labour supply chain.

What businesses should consider:

• Review how you engage temporary workers (direct vs agency vs umbrella companies);
• Conduct due diligence on agencies and intermediaries; and
• Ensure contracts clearly allocate responsibility.

5. Introduction of the Fair Work Agency (FWA)

A new enforcement body launched on 7 April 2026:

• The Fair Work Agency (FWA) will oversee rights such as:
  • Holiday pay;
  • Sick pay; and
  • Minimum wage compliance.

Why this matters:

Enforcement is expected to become significantly more proactive and robust.

Preparation steps:

• Conduct regular internal audits of:
  • Pay practices
  • Holiday calculations
  • SSP processes
• Pre-empt and identify risks and fix issues, where necessary, before they are identified externally

6. Stronger Whistleblowing Protections

A key legal shift:

• Sexual harassment complaints now qualify as protected disclosures

Implications:

• Cases may trigger whistleblowing protections, not just HR grievance procedures
• Increased risk of:
  • Automatic unfair dismissal claims; and
  • Detriment arising from whistleblowing claims.

What to do:

• Update or implement a Whistleblowing Policy;
• Explicitly include sexual harassment within its scope; and
• Provide managers with training to avoid retaliation (even unintended actions like reducing shifts).

7. National Minimum Wage Increases (Effective 1 April 2026)

New hourly rates:

• £12.71 (age 21+)
• £10.85 (age 18–20)
• £8.00 (age 16–17 and apprentices)

Business responsibilities:

• Notify affected workers in writing;
• Clearly explain their new pay rate and the effective date; and
• Update payroll systems to ensure compliance.

Final Thoughts

The April 2026 reforms mark a clear move towards stronger worker protections and stricter enforcement. For businesses relying on temporary or flexible labour, the key to staying compliant is proactivity. Review your policies, train your managers, and audit your processes now, because once these changes take effect, enforcement will only become more rigorous. If you would like support reviewing your current setup, our employment team would be happy to help.

If you would like support assessing how these reforms will impact your organisation, please contact our employment law team.