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Public alignment statement

Labour Provider Due Diligence, Fraud and Intermediary Risk

Episodic ICCE recognises labour-provider due diligence, fraud-risk and intermediary-risk assurance as a regulatory area shaped by tax, corporate-transparency, labour-market, agency, fraud-prevention, tax-avoidance and enforcement sources. The area creates expectations for accountable counterparty identification, route transparency, worker-paying-entity clarity, payroll and RTI evidence, payment traceability, corporate identity review, risk monitoring, escalation, remediation and source-aware evidence retention.

Those expectations are practical, source-sensitive and evidence-led. For temporary labour activity, they require responsible organisations to distinguish due diligence from approval, risk indicators from findings, Companies House records from complete integrity assurance, identity verification from wider operational substance, payslip or RTI artefacts from HMRC payment evidence, and internal route blocks from external regulator, prosecutor, court or tribunal decisions.

ICCE aligns with this regulatory area for ICCE-routed temporary-labour activity by preserving controlled evidence across counterparty intake, engagement route, worker-paying route, employer identity, payroll, RTI, worker artefacts, payment instructions, external-source references, risk indicators, review actions and remediation records. ICCE supports responsible due-diligence, monitoring and fraud-risk review by making parties, routes, changes, anomalies and evidence gaps attributable. ICCE does not approve labour providers, certify suppliers, determine fraud, determine tax evasion, make criminal findings, perform regulator investigations, verify Companies House identities, certify prevention procedures or replace HMRC, Companies House, the Fair Work Agency, law-enforcement bodies, courts, tribunals or professional advisers.

Episodic maintains a continued alignment commitment by reviewing this statement where umbrella-company law, HMRC labour-chain guidance, organised labour-fraud materials, corporate prevention guidance, Companies House identity-verification requirements, tax-avoidance materials, DOTAS sources, agency-reform sources, Fair Work Agency material or ICCE-routed evidence controls are amended, replaced, superseded or materially clarified.

Alignment table

Expectation Relevant sources ICCE enforced alignment ICCE evidence / output
Umbrella-company route transparency and liability awareness ITEPA 2003 Part 2 Chapter 11; Social Security Contributions (Umbrella Companies) Regulations 2026; Finance Act 2026 section 24; HMRC umbrella PAYE rules; HMRC umbrella good-practice guidance ICCE keeps ICCE-routed PAYE employment distinct from umbrella-company worker-paying arrangements and preserves the actual employer, agency, end-client and payer position Employer and payer identity, agency and end-client linkage, worker-paying route, external umbrella reference, exception and escalation record
Labour-chain assurance cycle and due-diligence evidence HMRC GfC12; GfC12 Recommended approach to assurance; GfC12 Tax risks ICCE supports counterparty intake, risk assessment, monitoring, review, action and remediation through attributable worker-level and transaction-level evidence Counterparty register, chain map, engagement-to-payroll-to-payment lineage, due-diligence reference, risk and action record, review pack
Worker-paying route and payroll-integrity monitoring HMRC umbrella PAYE rules; outsourced labour payroll fraud guidance; organised labour fraud collection; GfC12 Tax risks ICCE preserves employer, payroll, RTI, payslip and payment evidence and makes unexpected employer, payer or payroll-route changes visible Employer-change record, payroll authority record, RTI evidence, worker artefact, payer-change alert, payment reconciliation and remediation history
Mini umbrella, outsourced payroll and organised labour-fraud indicators HMRC mini umbrella company fraud guidance; outsourced labour payroll fraud guidance; organised labour fraud collection; construction labour fraud guidance ICCE identifies and preserves reviewable indicators associated with fragmented employers, unusual payer changes, missing payroll evidence, company-pattern anomalies and labour-chain opacity Company-pattern evidence, worker-to-employer history, officer and address references, payroll and payment gaps, risk indicator, reviewer decision, escalation record
Corporate identity, control and Companies House evidence Companies Act 2006; Economic Crime and Corporate Transparency Act 2023; Companies House identity-verification guidance ICCE preserves corporate identity, officer, PSC, filing, verification and change evidence as external due-diligence inputs with source status and limitations Companies House profile, officer and PSC reference, identity-verification state, filing and status record, discrepancy alert, review and action log
Corporate tax-evasion prevention procedures Criminal Finances Act 2017; HMRC failure-to-prevent facilitation of tax evasion guidance ICCE supports risk assessment, due diligence, monitoring, review, escalation and remediation evidence relevant to organisation-owned prevention procedures Risk assessment reference, associated-person and counterparty record, transaction evidence, training or communication reference, alert, action and review evidence
Failure-to-prevent-fraud procedures Economic Crime and Corporate Transparency Act 2023; failure-to-prevent-fraud guidance ICCE supports the labour-chain component of fraud-prevention controls by preserving counterparty, associated-person, benefit-pathway, transaction and anomaly evidence Fraud-risk register, counterparty and associated-person mapping, control record, anomaly evidence, investigation reference, remediation and closure record
Disguised remuneration and third-party reward-route exclusion Finance Act 2011 Schedule 2 — employment income through third parties; HMRC disguised remuneration guidance ICCE preserves ordinary PAYE remuneration as the ICCE-routed worker-payment route and records external references where loans, third-party rewards or disguised forms are identified PAYE payroll item, worker payment record, proposed third-party reward reference, HMRC or adviser reference, route block, worker warning and remediation evidence
Marketed tax avoidance, DOTAS and named scheme screening Finance Act 2004 Part 7 — DOTAS; HMRC named avoidance schemes and promoters list; DOTAS guidance ICCE preserves external scheme, promoter, DOTAS and HMRC references for review and escalation while keeping notifiability and tax treatment externally determined Scheme or promoter reference, DOTAS number where supplied, HMRC list match, legal-review record, affected transaction population, block or escalation record
Employment-business and agency responsibility with umbrella companies Employment-business responsibilities with umbrella companies; HMRC umbrella PAYE guidance; Make Work Pay agency-work regulatory consultation ICCE provides route, employer, payer and worker information capable of supporting agency-owned due diligence and information duties Agency and employment-business record, umbrella or non-umbrella route evidence, worker information source data, external agency review, action and remediation
Fair Work Agency and labour-market enforcement readiness Fair Work Agency enforcement statement; Employment Rights Act timeline; Make Work Pay agency-work regulatory consultation ICCE preserves labour-chain, worker, pay, complaint, exception and remediation evidence capable of supporting accountable engagement with authorised enforcement activity Worker and engagement records, payroll and payment evidence, complaint chronology, regulator request reference, controlled evidence release log, external outcome
Current-law, reform and source-status control Finance Act 2026 section 24; Economic Crime and Corporate Transparency Act 2023; Companies House identity-verification guidance; Employment Rights Act timeline; Make Work Pay agency-work consultation ICCE maintains source-status discipline and distinguishes enacted law, phased requirements, active guidance, regularly updated lists, closed consultations and future reforms Source-status register, commencement record, list retrieval date, company-data update, consultation status, review trigger, versioned alignment update

Sources covered

Umbrella and tax legislation

Corporate fraud and transparency legislation

HMRC labour-chain assurance and fraud guidance

Corporate prevention, avoidance and tax-risk sources

Corporate identity, agency and labour-market reform sources

Document control

URS-AS-006 - Labour Provider Due Diligence, Fraud and Intermediary Risk

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, fraud-investigation, tax, labour-market, supplier-approval 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.