Consultation (2026) · Public briefing material
A defined consultation period for stakeholders to review, challenge and inform ICCE as the model moves through final specification and pre-launch development.
Part one · Why this consultation exists
Consultation (2026) is ICCE's first annual public stakeholder consultation. It is designed to bring specialist knowledge, commercial reality and worker experience into pre-launch development while meaningful decisions can still be influenced.
ICCE is being developed as controlled infrastructure for UK temporary labour. Its intended public-facing role brings together ICCE controlled PAYE employment, engagement activity, integrated payroll, the Payment Trust Centre and evidential reporting within one connected operating environment.
ICCE does not source or supervise work, replace the commercial role of agencies or contractors, or become a funder or insurer. The model and target architecture are specified, while implementation and external adoption preparation remain pre-launch. Public material should therefore distinguish intended capability from live operating capability.
Episodic, the enterprise behind ICCE, has classified itself as a Collaborative-Open Enterprise. This is an Episodic-defined operating category, not a statutory status or certification. It means openness, transparency and meaningful stakeholder collaboration are intended to be normal operating conditions, while legitimate intellectual property, privacy, security, legal and commercial protections remain in place.
Annual public consultation is one of the commitments attached to that position. Consultation is intended to create a visible route for challenge, including criticism, before development decisions become harder to change.
734 planned projects across private and public investment over the next decade.
Estimated value owed to UK businesses in late payments at any given time.
Funding provided at any one time by UK Finance invoice-finance and asset-based-lending members.
Material direction and impact should normally be visible where it can responsibly be published.
Restriction should have a legitimate reason and should be no wider than necessary.
Openness does not remove IP ownership, commercial advantage, private capital or responsible confidentiality.
Temporary labour should not require a choice between flexibility and proper treatment. Better compliance should not have to prevent growth. Better worker outcomes should not have to weaken labour availability. Greater transparency should not have to create another retrospective reporting burden.
ICCE is intended to operate as an enabling infrastructure layer between policy intent, commercial reality and worker outcomes. It should support better implementation and evidence without claiming the authority of regulators, buyers, legal advisers, funders, insurers or other specialist decision-makers.
Different expertise · one shared discussion
The consultation is designed so that expertise from different parts of the market can be combined without asking any one participant to speak for everyone.
| Perspective | What we want that perspective to test |
|---|---|
| Buyers, contracting authorities and framework operators | Procurement fit, contract performance, social value, supplier participation, supply-line visibility and adoption requirements. |
| Agencies, contractors and labour providers | Workflow, labour availability, operating friction, commercial fit, mobilisation, payment and implementation realities. |
| Workers and worker representatives | Employment clarity, pay understanding, treatment, flexibility, security, worker voice, challenge routes, skills and progression. |
| Legal, tax, employment and payroll specialists | Status, responsibilities, PAYE routes, evidential sufficiency, interpretation risks and areas needing further professional review. |
| Funders, insurers, brokers and credit professionals | Financial readiness, receivable quality, credit-limit events, payment timing, claims evidence, continuity and sustainable growth. |
| Academics, regulators, auditors and assurance professionals | Independent challenge, public-interest effects, evidence quality, auditability, unintended consequences and market-level implications. |
How should temporary-labour systems respond to changing expectations around employment rights, tax, agency work, procurement, social value and enforcement?
How can organisations grow and mobilise labour while maintaining reliable funding, payroll, payment and risk controls?
What should good temporary work look like across status clarity, working conditions, pay, information, voice, skills and progression?
What information must exist so that buyers, agencies, workers, regulators, funders and insurers can distinguish evidenced outcomes from unsupported claims?
The annual consultation does not transfer decision authority. Episodic may reject or defer recommendations, but the Collaborative-Open position requires material feedback to be considered and the response to be explained.
Policy, procurement, employment and payroll routes
These questions identify live areas where specialist input may materially improve ICCE's assumptions, evidence requirements or implementation approach. Participants should concentrate on the questions closest to their own expertise.
When should temporary workers form part of Good Jobs and contract-workforce assessment?
Where should social-value commitments and evidence sit across framework and call-off?
What should count as additional social value beyond ordinary legal compliance?
What transaction evidence is sufficient to support labour-related social-value KPIs?
How should fair pay be defined and evidenced for temporary workers?
How can frameworks widen agency participation without weakening labour-chain control?
How should buyers distinguish supplier-payment performance from worker-payroll performance?
What records should parties be able to produce quickly in a more coordinated enforcement environment?
Are current records sufficient to evidence entitlement, calculation, payment and correction?
What responsibilities and information should sit with the agency, hirer, employer, umbrella or other intermediary?
How can genuine flexibility coexist with protection against one-sided uncertainty?
How should status be explained so tax treatment is not mistaken for employment-rights status?
What should people be told when employment-style tax treatment does not create the same rights position?
Are labour records complete and durable enough for longer enforcement and dispute periods?
What due diligence and continuing evidence are proportionate now upper-chain parties can carry PAYE exposure?
What conduct, transparency and worker protections should apply when umbrella regulation becomes operational?
Can workers identify employer, payer, rate basis, deductions, rights and challenge route?
How should labour chains distinguish genuine subcontracting from labour-only work needing another route?
How should status decisions, deductions, worker information and challenge processes connect?
Does the legal and operational substance match the route description when responsibility is tested?
Current policy context includes PPN 026, the Employment Rights Act 2025 implementation programme, Fair Work Agency enforcement, the 2026 umbrella-company PAYE rules and continuing agency-work reform. Supporting guidance remains subject to change in several areas. See sources S02-S10 on page 9.
Funding, capacity, payment, insurance and growth
These questions invite agencies, buyers, funders, insurers, brokers and credit professionals to discuss the practical conditions that determine whether labour can be mobilised, paid, financed, insured and scaled responsibly.
What evidence would improve access to working-capital funding for responsible labour growth?
Can finance, insurance and payroll capacity scale with the infrastructure pipeline?
How should funders assess fast payroll growth after framework or contract award?
How should concentrated exposure to major buyers affect funding and insurance decisions?
How should future labour activity respond when insured or funded credit support is reduced?
Would earlier visibility of active labour demand and exposure improve funding decisions?
Where is the real payment delay, and who bears the cost?
Which disputes can be prevented by better engagement, time, rate and approval evidence?
How early should genuine disputes be raised before they affect funding and collection?
What minimum evidence makes a temporary-labour receivable clear and financeable?
Should customer credit limits influence workforce mobilisation earlier?
How should funders, insurers and agencies share relevant risk information while preserving separate roles?
Can normal labour activity produce insurer-ready evidence without post-failure reconstruction?
How is payroll continuity maintained while non-payment and claims are being resolved?
Who manages collections, how are recoveries attributed, and what evidence is required?
Which data actually changes a funder's confidence, facility size, advance rate or diligence speed?
Which controls and evidence could materially improve insurer understanding or appetite?
Where does poor transaction evidence create avoidable cost across funding, insurance, audit and disputes?
Should workforce financial readiness form part of supplier capability or tender assessment?
What controls allow agencies to scale workers, projects and customers without risk rising at the same rate?
Commercial context: NISTA Infrastructure Pipeline, Office of the Small Business Commissioner late-payment research and UK Finance invoice-finance / asset-based-lending data. See S11-S13 on page 9.
What we are building · what should still be challenged
What is ICCE intended to provide, and what should stakeholders help refine before launch? The descriptions below are intentionally public-safe and do not disclose protected ICCE mechanics.
| ICCE topic | What it means at public level | Primary consultation question |
|---|---|---|
| 1. Purpose and market role | ICCE is being developed as controlled infrastructure connecting PAYE employment, engagement activity, payroll, payment evidence and reporting without replacing existing market roles. | Is controlled infrastructure the right role for ICCE, and are worker, compliance and commercial objectives balanced appropriately? |
| 2. Multi-party participation and visibility | Temporary labour is multi-party. ICCE is intended to let authorised parties contribute, confirm and receive information appropriate to their role from the same controlled activity. | Who should contribute, confirm and see which information, and where could shared visibility create privacy, authority or confidentiality concerns? |
| 3. System-enforced controls and boundaries | ICCE is designed to process important activity through defined checks and controlled pathways rather than relying only on declarations or retrospective correction. | Which activities should the system constrain, which exceptions need human review, and where would rigid control create unnecessary operating friction? |
| 4. Transaction evidence, reporting and accountability | ICCE aims to create evidence as activity occurs so reporting can be derived from controlled engagement, payroll and payment records rather than reconstructed later. | What must be evidenced at engagement level, what should be aggregated, and what do buyers, workers, funders, insurers and auditors each need? |
| 5. Supply-line frameworks and data attribution | A configurable contractor-led route is being explored in which authorised agencies can participate within a project-coded environment and resulting evidence can be attributed to the relevant project or supply line. | Would contractors and framework operators use this route, what visibility should it provide, and where should the boundary sit between shared oversight and agency confidentiality? |
| 6. Development position and pre-launch priorities | The core model and target architecture are specified, while product implementation, partner alignment, external validation and adoption preparation continue. | What capabilities, partner relationships, reporting, evidence and validation must be in place before a credible pilot or wider deployment? |
Frameworks are presented here as a configurable/proposed contractor-led route, not as a universal requirement of the current locked ICCE model. Public descriptions remain subject to the project's protected-language controls.
A focused discussion · not a questionnaire marathon
A useful consultation may concentrate on one issue only. The process is designed to identify the right topic, the right people and the right level of discussion before the main meeting takes place.
Tell us who you are, why the consultation is relevant to you, and the areas where you or your organisation are best placed to contribute.
We explain the relevant parts of ICCE, understand your perspective and agree the primary areas where input or feedback would be most useful.
Together we identify the relevant people within your organisation or professional network whose experience is most useful for the topics being considered.
The main consultation can take place in person or by video call, structured around the agreed areas of evidence, challenge, practical experience and feedback.
Participants do not need to endorse ICCE. A useful contribution may identify a weak assumption, a missing stakeholder, an impractical control, an unsuitable KPI, a worker consequence, a commercial objection, an evidential gap or a reason why an organisation would not adopt the proposed approach. A clear explanation of why something does not work can be more valuable than general support.
Stakeholders should be able to contribute candidly without being required to make their identity or sensitive evidence public. Individual submissions, contributor identities and raw consultation notes remain protected by default unless publication is specifically agreed or otherwise required. Material themes may still be reported in aggregate.
The process does not end when submissions close
Consultation (2026) should leave a public record of the main themes raised, including material criticism, the conclusions reached and the action Episodic intends to take.
| What the public response should show | Why it matters |
|---|---|
| Who participated | Stakeholder categories and participation volume provide context for what the consultation can and cannot reasonably represent. |
| Principal themes | Supportive feedback, critical feedback, material concerns, emerging risks and unresolved questions should all be visible. |
| Accepted and partly accepted actions | Where consultation changes ICCE, the relationship between feedback and intended action should be understandable. |
| Matters requiring more evidence | Some issues should remain open rather than being forced into a premature decision. |
| Recommendations not adopted | Collaboration does not create stakeholder veto. Material non-adoption should be explainable where possible. |
| Future consultation | Consultation (2026) is intended to begin an annual practice informed increasingly by operating evidence, stakeholder outcomes and changes in the market. |
A clearer view of material market problems, adoption conditions, worker outcomes, evidence expectations, areas requiring specialist review, and the capabilities or partner relationships that should be prioritised before deployment.
Consultation does not mean every recommendation will be accepted, every topic will be resolved or protected ICCE mechanics will be disclosed. It means the organisation commits to listening, considering, responding and changing where the evidence justifies change.
Selected source register
Positions are stated as at 9 August 2026. Policy, regulation and market practice may change. This pack is general information and consultation material only; it is not legal, tax, employment, procurement, funding or insurance advice.
24 August - 16 October 2026. Register your interest, identify the areas where you can contribute, and arrange a focused consultation discussion.
episodic.co.uk/icce-consultation-2026.php