Temporary Staffing Compliance Checklist for 2025
In today’s fast-evolving employment landscape, temporary staffing remains a flexible and strategic solution for businesses across sectors. However, compliance in temporary staffing is increasingly complex - with updates to employment law, data protection, and ethical standards making it more important than ever for organisations and agencies to stay on top of their obligations.
As we move through 2025, here’s a comprehensive compliance checklist to help ensure your temporary staffing practices are robust, lawful, and future-ready.
✅ 1. Right to Work & Identity Checks
Before any placement, verify that all workers have the legal right to work in the UK. Ensure:
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Valid documentation is checked and copied in line with Home Office guidance.
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Digital ID verification services (where used) are compliant with UK Digital Identity and Attributes Trust Framework (DIATF).
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Rechecks are scheduled for workers with time-limited visas.
✅ 2. Employment Status & IR35 Assessment
With increasing scrutiny from HMRC:
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Review each assignment for IR35/off-payroll working rules, especially in the public sector or medium-large private companies.
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Ensure the correct status determination statement (SDS) is issued and documented.
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Use up-to-date contracts reflecting worker status (PAYE, umbrella, or self-employed).
✅ 3. Agency Workers Regulations (AWR)
Ensure compliance with AWR after 12 weeks in the same role:
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Match pay and basic working conditions to permanent staff.
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Keep accurate records of assignment lengths and roles to track qualifying periods.
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Communicate clearly with clients and workers about rights and entitlements.
✅ 4. Data Protection & GDPR
Temporary staffing means handling a large amount of personal data:
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Have clear privacy policies and obtain informed consent from candidates.
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Ensure all third-party systems and CRMs are GDPR-compliant.
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Train staff on data handling, breaches, and subject access requests.
✅ 5. Health & Safety Obligations
Though temps are not permanent staff, your duty of care remains:
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Conduct joint risk assessments with clients.
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Provide appropriate health and safety training and PPE (where needed).
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Ensure clients have procedures to onboard temps safely and efficiently.
✅ 6. National Minimum Wage & Holiday Pay
All workers must receive at least the National Minimum or Living Wage:
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Ensure accurate timesheet management and prompt payment.
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Provide correct holiday pay (pro-rata) in line with the latest guidance - especially with changes to rolled-up holiday pay allowances for irregular hours (effective from April 2024).
✅ 7. Modern Slavery & Ethical Recruitment
Stay aligned with ethical standards:
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Have a clear Modern Slavery Statement (if required by turnover).
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Audit supply chains and third-party umbrella companies regularly.
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Train consultants on spotting red flags and reporting concerns.
✅ 8. Contracts & Documentation
Every temp should receive:
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A Key Information Document (KID) - clearly outlining pay, deductions, and employment terms.
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A contract for services (or employment contract, where relevant) before the assignment begins.
✅ 9. Equality, Diversity & Inclusion
Ensure your practices don’t discriminate:
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Monitor placements to avoid bias in age, gender, ethnicity, disability, and neurodiversity.
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Provide equal access to opportunities, training, and support.
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Work with clients to build inclusive workplaces for all staff, including temporary workers.
✅ 10. Stay Informed on Legal Changes
Employment law is constantly evolving. In 2025:
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Keep up to date with updates to the Employment Rights Act, Statutory Sick Pay, and AI use in recruitment.
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Subscribe to alerts from ACAS, REC, and GOV.UK.
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Invest in regular training for your internal team to stay legally aware.
Final Thoughts
Compliance isn’t just a box-ticking exercise - it’s critical to protecting your business, your workers, and your clients. In 2025, temporary staffing will play a crucial role in workforce agility. Make sure your compliance practices keep pace.
Need help with compliant temporary staffing solutions? Get in touch with our expert team to ensure you’re covered from every angle.