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Public alignment statement

Labour-Chain Financial Risk, Payroll Funding and Continuity

Episodic ICCE recognises labour-chain financial risk, payroll funding and continuity as a regulatory and assurance area concerned with employer insolvency exposure, statutory worker-claim support, payroll-funding sufficiency, payment-state clarity, regulated payment execution, safeguarding evidence, provider failure and residual shortfall. Across this area, responsible organisations are expected to distinguish what is owed, what is funded, what has been instructed, what has settled, who has failed, what may be recovered and what remains exposed.

Those expectations are practical, financial and evidence-led. For temporary labour activity, they create a need for reliable records showing the worker, employer, Episode, payroll obligation, available capacity, reservation state, payment instruction, external execution response, settlement evidence, reconciliation state, recovery route, insolvency reference, statutory-claim boundary and residual exposure. They also require clear separation between worker payroll and supplier invoices, reservation and protected cash, payment instruction and settlement, safeguarding and guarantee, and financial-risk classification and regulated financial activity.

ICCE aligns with this regulatory area for ICCE-routed temporary-labour activity by preserving controlled evidence relevant to payroll obligation, funding capacity, reservation, payment-state progression, disruption classification, recovery-route evidence and residual-shortfall reporting. ICCE does not lend, insure, guarantee payroll, take deposits, own receivables, act as a payment institution, safeguard client money, replace an authorised payment provider, act as an insolvency practitioner, decide statutory employee claims, direct the National Insurance Fund or create statutory priority, trust protection, security or recovery rights.

Episodic maintains a continued alignment commitment by reviewing this statement where insolvency legislation, statutory employee-claim limits, Insolvency Service guidance, payment-services regulation, financial-services perimeter material, FCA safeguarding rules, external provider arrangements, account structures, funds-flow controls, payment-rail arrangements, UMS continuity controls or ICCE-routed evidence capabilities are amended, replaced, superseded or materially clarified.

Alignment table

Expectation Relevant sources ICCE enforced alignment ICCE evidence / output
Employer insolvency exposure and worker-pay claim evidence Insolvency Act 1986; Employment Rights Act 1996, Part XII; Employment law and insolvency technical guidance ICCE preserves worker, employer, payroll, unpaid amount, payment-state and external insolvency evidence capable of supporting claim and recovery review Employment record, payroll ledger, unpaid wages, holiday or pension contribution evidence, payment failure, insolvency case reference, claim-support pack
Statutory National Insurance Fund claim support Employment Rights Act 1996, Part XII; Claim for redundancy; Rights if an employer is insolvent; Explaining redundancy payments ICCE distinguishes the worker’s actual unpaid amount, potentially recoverable statutory amount, capped statutory category and remaining creditor exposure Pay and service history, weekly-pay evidence, arrears and holiday-pay category, RPS reference, statutory estimate, RPS decision, residual claim
Statutory weekly cap and capped-versus-uncapped exposure Employment Rights Increase of Limits Order 2026; Rights if an employer is insolvent; Explaining redundancy payments ICCE maintains effective-dated statutory limit evidence and keeps capped statutory recovery separate from actual contractual or payroll exposure Official limit source, effective date, weekly-pay input, selected £751 cap where applicable, uncapped amount, capped amount, residual balance
Insolvency-practitioner and official case evidence Insolvency Act 1986; Employment law and insolvency technical guidance; Case setup for insolvency practitioners ICCE preserves authorised office-holder, case setup, worker population, payroll history and evidence-release records without assuming the insolvency-practitioner role Office-holder reference, worker list, pay history export, case reference, data-quality exception, controlled evidence release log
Funding sufficiency, reservation and residual exposure Insolvency Act 1986; Employment Rights Act 1996, Part XII; Financial Services and Markets Act 2000; Regulated Activities Order 2001 ICCE distinguishes approved capacity, reservation state, funding source, available route to value, recoverability and residual shortfall Funding-party record, capacity state, reservation record, exposure classification, recovery route, bridge reference, residual-shortfall record
Payment obligation, instruction and settlement separation Payment Services Regulations 2017; PERG 15; Consider if you provide payment services ICCE separates payroll obligation, payment instruction, external provider execution, settlement and reconciliation so that instruction is not treated as completed payment Payroll obligation, payment instruction, provider response, accepted or rejected state, settlement evidence, reconciliation output, failed-payment record
Payment-services perimeter and external execution Payment Services Regulations 2017; Consider if you provide payment services; PERG 15 ICCE preserves the external provider, account, funds-flow and perimeter evidence required to distinguish ICCE instruction from regulated payment execution Funds-flow map, provider identity, account ownership, regulatory reference, perimeter review, instruction and settlement trail
Financial-services perimeter and regulated-activity boundary Financial Services and Markets Act 2000; Regulated Activities Order 2001 ICCE keeps lending, insurance, deposit-taking, receivables ownership and regulated financial activity outside the ICCE system role and externally attributable where present External funder or insurer identity, FCA or PRA reference, contract role, perimeter review, prohibited-role block, residual-risk report
Safeguarding and payment-provider continuity Safeguarding requirements for payment institutions and electronic money institutions; PS25/12 safeguarding changes; Payment Services Regulations 2017 ICCE preserves externally supplied safeguarding, provider-status, reconciliation, incident and continuity evidence without presenting safeguarding as guarantee protection Provider status, safeguarding arrangement reference, reconciliation data, provider incident, delayed or failed payment event, recovery and alternative-rail record
Worker-pay continuity and disruption classification Insolvency Act 1986; Employment Rights Act 1996, Part XII; FCA safeguarding sources; Insolvency Service guidance ICCE classifies disruption by failing party, affected obligation, payment state, available route to value, bridge position and residual shortfall Failing-party record, affected worker population, payment-state timeline, continuity action, statutory claim route, recovery evidence, closure record
Worker payroll and supplier-payment separation Payment Services Regulations 2017; Insolvency Service guidance; FSMA 2000; Regulated Activities Order 2001 ICCE keeps worker payroll, statutory liabilities, supplier invoices, funding arrangements and commercial recoveries separately attributable Worker payroll record, statutory liability record, supplier invoice reference, funding contract reference, payment rail evidence, recovery and residual-exposure classification
Current regulatory and provider-change control Employment Rights Increase of Limits Order 2026; FCA safeguarding requirements; PS25/12; PERG 15; payment-services perimeter guidance ICCE maintains source-status discipline and triggers review where statutory caps, safeguarding rules, provider status, account control, funds flow or external arrangements change Source-status register, rate or limit update, provider review, funds-flow change record, perimeter reassessment, versioned alignment update

Sources covered

Insolvency legislation and statutory employee-payment sources

Financial and payment-services legislation

Insolvency Service and statutory claim guidance

FCA payment-perimeter and safeguarding sources

Document control

URS-AS-005 - Labour-Chain Financial Risk, Payroll Funding and Continuity

Version
2.1
Status
Public alignment statement
Publication date
10 July 2026

This public alignment statement is an evidence-support and regulatory-area alignment document only. It does not create legal, regulatory, financial, payment-services, safeguarding, insolvency, claims-management or compliance certification authority.

Use is subject to the stated source population, ICCE-routed activity boundary, implementation boundary and controlled public wording retained in the source document.