Episodic.
For.Every.One

Retake control of labour supply chains.

Contractor Introductory Pack

High-visibility framework and transaction
infrastructure for temporary labour chains.
ICCE Contractor Introductory Pack
Episodic. For.Every.One.

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© AUGSCAPE RESEARCH & DEVELOPMENT LIMITED. All rights reserved.

Document title ICCE Contractor Introductory Pack
Version v1.0
Date 31 May 2026
Status Locked
Distribution Controlled
Owner Episodic / Augscape
Engagements (AR)
Limited







ICCE Contractor Introductory Pack
Episodic. For.Every.One.

Table of contents

Document sections and page references

Section Subsection Page
Reader Orientation What ICCE Is 5
Why ICCE Exists 6
How ICCE Responds 6
The Contractor Control Layer 7
Worker Outcomes and Social Value 7
Contractor Launch Position 8
Market Context Market Scale 9
Fragmented Market Truth 9
Why Fragmentation Matters Now 10
The Engagement Routing Problem External Labour Reliance 11
Overlapping Pressure Areas 11
Fragmented Supply-Chain Control 12
What Contractors Are Now Expected to Evidence 13
Route Risk Analysis Route Control and Evidence 14
Agency Worker PAYE Rules 14
IR35 & Off-Payroll Working 15
Umbrella-Company PAYE Reform 15
Construction Industry Scheme (CIS) 16
VAT Supply-Chain Risk 16
Risk Summary 17
Route Risk Heatmap 19
What the Heatmap Shows 20
The Drift Problem 20
Higher-Risk External Routes 21
ICCE Contractor Introductory Pack
Episodic. For.Every.One.
Section Subsection Page
ICCE Operating Model Contractor Control Principle 22
ICCE Controlled Employment 23
Agency Flexibility Inside Controlled Boundaries 24
Excluded Engagement Routes 25
Platform Activity Lifecycle 26
Social Value and Worker Outcomes Worker Clarity as a Design Principle 29
Why Route Boundaries Matter for Social Value 30
Evidence Questions for Contractors 30
From Risk Management to Improvement Story 32
Outcome Areas Supported by ICCE 33
Frameworks, Controls and Project Attribution Frameworks & Controls 34
Scope Boundaries 35
Project Attribution 36
Commercial Value 38
Reporting and Evidence Outputs The Reporting Principle 40
Typical Contractor Outputs 41
Multi-Party Infrastructure Shared Infrastructure 42
Agency & Worker Participation 43
The Agency Experience 44
The Worker Experience 45
Commercial Model 46
Deploying ICCE Starting Point 47
Use Cases 48
Launch Pathway 49
Launch Window Opportunity Launch Window & Intended Scale 50
Suitable Early Adopters 51
Expressions of Interest 52
ICCE Contractor Introductory Pack
Episodic. For.Every.One.

Understanding ICCE and the contractor control layer.

What ICCE Is

Episodic (ICCE) is supply-chain infrastructure technology designed to modernise the UK temporary labour market; focused on improving operational, financial, risk and ethical outcomes. Its purpose is to redefine how temporary labour activity is created, controlled, transacted, understood and evidenced.

For contractors ICCE operates as a framework and transaction layer, providing the free tools to better control labour supply chain activity and enable visibility over every action performed.

Contractors use the ICCE Platform to create Frameworks for a project or package of works, applying Framework Controls that restrict the conditions-of-supply, and then invite preferred agencies to participate.

Agencies then use the ICCE Platform to communicate with workers, form engagements and ultimately fulfil works.

With ICCE routing the resulting agency and worker engagement, payroll and evidence activity through the platform, enforcing the Framework Controls and giving contractors real-time visibility over the downstream data created.

Contractor

creates the Framework → sets the controls → invites preferred agencies.

Agencies and Workers

form engagements → fulfil works → reconcile hours.

ICCE

provides the ecosystem → enforces controls → captures the activity → processes payroll → evidences the outcome.

ICCE Contractor Introductory Pack
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Why ICCE Exists

The foundation and rationale behind ICCE is based on independent research against current 2026-2027 commercial, legislative and workforce-market conditions.

The research identifies a singular structural issue at the heart of temporary labour markets, which currently unaddressed, escalate outwards creating a range of systemic issues for various parties across supply chain.

Modern cohesive markets operate from a singular source of agreed market truth in order to function, project and reconcile cleanly. This truth provides the basis for parties to agree upon units, transactions, actors and timings.

With no singular source of agreed truth for parties to rely upon, report from or make meaningful commercial decisions from; modern markets would collapse into structural chaos where duplication, misapplication and misuse of information creates an environment littered with errors, delays and abuse of trust.

It is a lack of agreed truth within temporary labour markets that is the cause for many resulting issues impacting contractors, agencies, workers, funders, insurers and regulators within the space.

Given the size, scope and significance of flexible working and temporary labour deployment in the UK, it is highly unusual for market of this size to operate in a fragmented manner.

As an environment without the means for internal governance, the market continues to receive increased regulatory intervention and with it, a complex interplay of sector-specific legislative frameworks that create cross-party risk and recovery routes.

At its core, ICCE has been designed as a systematic technological response to this specific, market-wide issue.

Research paper: AMTF-001 [Fragmented Market Truth and Retrospective Data Dependency] is available at augscape.com

How ICCE Responds

By providing the software platform and commercial control mechanisms for contractors, agencies and workers to create Frameworks and manage transactions; ICCE governs the key moments in which temporary labour fulfilment becomes real economic activity, and the rules that surround their creation and processing.

In doing so, ICCE is able to capture individual engagement transactional data points. Creating a golden-thread of evidence and making it available as actionable data throughout the supply chain, which can then support project-level visibility, agency attribution, worker-route clarity, payroll-route assurance, audit reconstruction, financial attribution and social value reporting.

The result is an agreed source of actionable truth for controlled labour activity. Each authorised party accesses the data most relevant to its role, while relying on the same underlying governed record, rather than separate versions of the truth held across separate systems.

That shared record can then be worked from confidently to support commercial decisions, risk review, compliance evidence, financial attribution, audit reconstruction, social value reporting and ESG-related project evidence.

For contractors, this creates a practical control layer.

ICCE Contractor Introductory Pack
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The Contractor Control Layer

Instead of relying only on supplier declarations, periodic audits, invoice summaries or retrospective reconciliation, contractors are able to create defined Frameworks and require agency-supplied activity to operate within those controls.

Preferred agencies can continue to fulfil labour, but the route, evidence and reporting conditions attached to their activities are governed and enforced by the ICCE platform.

ICCE is therefore not an additional labour intermediary joining the supply chain. It is the underlying infrastructure layer through which selected temporary labour activity can be bounded, captured, evidenced and reported with greater clarity, usability, defensibility and consistency.

It does not replace the contractor’s agency relationships. It does not act as a recruitment agency, MSP, umbrella company, labour supplier, payroll bureau for third-party employers, lender, insurer or procurement agent.

Its role is to provide the controlled operating environment through which existing labour relationships and activity can be routed, processed, evidenced and understood.

As a single connected platform for contractors, agencies, workers, and with specialist reporting functions for authorised funders, insurers, auditors and social value teams, ICCE serves different purposes for each party.

Contractors gain stronger project-level assurance and visibility; Agencies can demonstrate clean operating processes; Workers experience transparent finances and simpler understanding of their working-life, and; Funders, insurers, auditors and social value teams can rely on more structured evidence.

For Contractors specifically, ICCE becomes a temporary labour procurement-assistive platform, enabling them to control and oversee temporary labour occurring as a result of their works, on their terms, in real time - providing a simple solution to governance and assurance, whilst operational teams gain flexibility of working directly with preferred agency partners.

As well as providing the guardrails for external labour supply lines; ICCE also creates a direct ethical, social value and ESG opportunity for contractors.

Worker Outcomes and Social Value

Temporary labour in ICCE moves through a clean, non-umbrella engagement and PAYE employment-status route; replacing opaque, umbrella and intermediary-heavy structures.

This improves pay-route clarity, supports fair-work evidence, giving contractors a stronger worker-outcome story to stand behind.

More specifically, since external labour activity is captured at project or works package level; positive worker treatment, experience, transparency and payroll-route outcomes can be quoted, quantified, projected and attributed more clearly to responsible procurement, social value and ESG reporting codes where relevant, supporting tender submissions and milestone reporting.

This document is a structural overview of the ICCE system, a deep dive insight into existing temporary labour supply chains from a contractor’s perspective, the fulfilment routes currently available, the risks and limitations attached to those choices, and the case for using ICCE Frameworks as an overall more practical solution for external, downstream temporary labour governance and oversight.

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Contractor Launch Position

ICCE is currently seeking Expressions of Interest and further closed discussions with select contractors of meaningful size and scope, who are able to identify at least one future project, package of works or supply line where better control, cleaner routing, stronger evidence, financial attribution, positive social value outcomes and/or public-facing assurance would be valuable.

Open-market requests are not accepted during this window. Episodic will review EOI submissions on a case-by-case basis to determine contractor suitability.

Ideal contractor launch partners are those with an aligned ethos and the means and desire to improve outcomes, shape future market-wide standards, and gain early advantage from leveraging ICCE during its initial market launch phase.

The remainder of this pack explains the market conditions, routing risks, operating model and evidence position behind that proposition, before concluding with a contractor-focused summary of the case for ICCE Framework adoption.

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Temporary labour is a major operating environment.

Market Scale

The REC’s 2024/25 Recruitment Industry Status Report states that the recruitment industry contributed £40.6bn to the UK economy in 2025, equal to 1.6% of UK GVA.

It also reports that temporary and contract placements accounted for 76.7% of sector GVA, with around 872,000 temporary or contract workers on assignment on any given day in 2024.

Modern markets of this size have reliable transactional recordkeeping at their core: a shared operating basis from which participants can understand, reconcile, evidence and govern activity.

The vast majority of temporary labour chains in the UK do not.

£40.6bn
recruitment industry contribution to the UK economy in 2025
1.6%
of UK GVA represented by recruitment industry activity
76.7%
of sector GVA from temporary and contract placements
872k
temporary or contract workers on assignment on any given day

Fragmented Market Truth

Despite being significant and strategically meaningful; the market has grown around distributed records, separate parties, disconnected payroll routes, supplier declarations, weekly reconciliation cycles, retrospective evidence formation and fragmented assurance.

The contractor may know the project requirement but lack visibility over secondary and tertiary suppliers. The agency may know the worker booking but lack oversight of payroll activities. A funder may see weekly invoice evidence but lack insight into the underlying exposure.

A social value team may struggle to quantify outcomes based on summaries or second-hand info. A regulator or auditor may later struggle to understand how the whole route connects.

This fragmentation and absence of shared truth has shaped the market.

It has allowed multiple intermediaries and engagement models to develop around the gaps: MSPs, payroll intermediaries, secondary agency layers, umbrella arrangements, outsourced checks, compliance platforms and audit processes.

Some of these may be lawful and useful in the right context. The problem is that none of these “solutions” actually address the primary market issue, and each additional layer can move the contractor further away from the worker, the payroll route, the evidence trail needed to understand the true operating position.

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Why Fragmentation Matters Now

That weakness now matters more because the financial and legislative risk environment has become more significant. Temporary labour chains are no longer exposed only to their own internal failures.

In several areas, parties may become exposed to the actions, omissions, routing decisions or compliance failures of other parties within the chain. Where payroll, worker-status, CIS, umbrella, intermediary, VAT, agency, audit or evidence issues arise downstream, the commercial and evidential consequences may move upstream.

This is especially difficult as modern labour supply involves multiple worker employment-status positions, engagement routes, payroll treatments, intermediary structures and due-diligence standards.

The market is also highly competitive. Agencies are often required to balance speed, flexibility, price, margin pressure and client responsiveness against risk-appetite, route discipline and compliance spend.

Some may deliberately accept greater exposure in pursuit of stronger margins or more work opportunities. Others may become exposed indirectly because a third-party intermediary, payroll provider, secondary supplier or downstream participant introduces risk beneath the approved agency relationship.

The result is a market in which flexibility remains commercially necessary, but uncontrolled flexibility can create material operational, financial, legislative, ethical and evidential weakness.

The Route Risk Analysis section examines these dynamics in detail by mapping the main temporary labour engagement routes against their financial, legislative and labour-chain risk overlaps.

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Contractors rely on external labour, but the route is increasingly difficult to evidence.

External Labour Reliance

Most contractors rely on temporary labour for variable, regional and sequential project delivery.

Labour demand changes by site, package, programme, region, trade and stage of work. Directly sourcing, employing, onboarding, paying and administering every temporary worker directly would give the contractor the highest control position, but it is often too operationally-heavy and cash-flow-restrictive for the flexible labour requirements. Without direct control, contractors are now left trying to manage oversight of external labour activity across departments, projects, regions, agencies, payroll arrangements, intermediaries and downstream records.

Overlapping Pressure Areas

Joint and several liability and “known / should have known” Kittel principle driven legislative frameworks covering employment status, umbrella and purported umbrella companies, VAT and CIS fraud all now bring these supply chain wide issues upstream to contractors.

Public procurement expectations are also moving toward stronger evidence of fair work, fair wages and good working conditions. The PPN 002 Social Value Model identifies fair work as work that offers fair wages and good working conditions, and positions it within the Social Value Model for relevant public procurement activity.

As a result, contractors now face a temporary labour environment shaped by several overlapping categories of pressure and risk.

Operational

Labour must remain available, responsive and project-aligned

Financial

Invoice, payroll, funding, debtor and recovery evidence must be defensible

Legislative

Worker status, agency rules, umbrella reform, CIS, PAYE and off-payroll issues must be understood

Compliance

Supplier assurance, audit trails and downstream checks must be evidenced

Ethical & social value

Worker treatment, fair pay, route transparency and responsible labour-chain claims need support

Reputation & governance

Opaque worker routes can create scrutiny while labour remains scattered across teams and suppliers

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Fragmented Supply-Chain Control

The wider issue, therefore, is not simply that one or more rules have changed. It is that the supplier chains currently used to deliver temporary labour are often disconnected and fragmented, without the capability, visibility, margin or commercial incentives needed to keep the whole route clean.

That weakness now sits alongside tighter, more punitive and more multi-party 2026+ legislative frameworks.

Diligent operators may need to spend materially more time and resource on compliance oversight just to maintain an acceptable baseline. Even then, unreliable, outdated, incomplete or fabricated data passing between primary, secondary and tertiary parties can leave the wider chain significantly exposed.

These burdensome conditions are symptoms of the underlying market issue: a complex and often competing interplay of companies, contracts, legislation, responsibilities, risks and incentives, all stemming from the fact that there is no single reliable record of what occurred, by whom, when, through which route and on what basis.

What Contractors Are Now Expected to Evidence

For contractors, the external labour environment now carries a significant administrative and evidential load, with expectations to understand and evidence:

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Evidence Load

Trying to manage this across multiple projects, sites, regions, agencies and internal functions creates further complexity. Oversight becomes inconsistent, evidence becomes retrospective, and the overall labour-chain position remains structurally weak.

The wide range of worker classification and engagement routes available is perhaps one of the largest risk-factors now impacting how financial risk spreads from party to party.

ICCE undertook a deep-dive review of these routes as part of its pre-formation research. That research considered how each route interacts with contractor oversight expectations, payroll-route evidence, worker treatment, social value and the wider financial, legislative and labour-chain risk environment.

The next section develops this into a route-risk analysis, mapping common engagement routes against their operational, financial, legislative and labour-chain implications.

Research paper: CLCRH-001 [UK Construction Temporary Labour Chain Risk Heatmap] is available at augscape.com

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Contractor risk is now a route-control and evidence problem.

Route Control and Evidence

The contractor risk environment should be understood as a route-control and evidence problem.

The environment has become complex because the same temporary labour supply line can now be tested through, and is subject to; several different legislative frameworks at once.

A single agency-supplied worker may raise questions about the engagement route, worker status, PAYE responsibility, umbrella exposure, CIS boundary treatment, payroll-intermediary usage, worker treatment, pay-route transparency, VAT defensibility, invoice evidence and audit reconstruction.

These are not isolated compliance questions. They overlap around the same issue: whether the contractor can see, control and evidence the route through which the worker was actually engaged, paid, taxed, treated and reported.

The issue is not simply whether a contractor uses a “good agency” or a “bad agency”. A contractor may approve a credible agency and still lack sufficient visibility over secondary agencies, payroll intermediaries, worker status, engagement treatments, worker-facing deductions, invoice reconciliation and audit evidence.

The legislative and regulatory position now gives that problem sharper commercial consequences.

Agency Worker Rules

Agency worker arrangements are already subject to specific PAYE treatment. Where agency legislation applies, the worker is treated as holding employment with the agency for income tax purposes, and the agency must deduct income tax, operate PAYE and remit payment to HMRC through RTI.

In practice, deviation away from agencies operating PAYE directly usually arises through one of two routes.

The first is contractor-influenced status treatment. This may occur where a contractor, client or end user has assessed the role through an IR35 or off-payroll working lens, issued a Status Determination Statement, or otherwise allowed the labour chain to proceed on the basis that a non-employment or non-PAYE route is acceptable.

The second is the introduction of a downstream payroll or worker-paying intermediary. This may include an umbrella company, payroll company, purported umbrella route, CIS-paying intermediary, offshore entity, secondary agency or another party sitting beneath the approved agency relationship.

Either route can affect how the wider labour chain is later understood. A contractor-side status decision may become relevant to what the contractor knew, permitted or should have monitored.

Once worker engagement, payroll operation, tax treatment or payer identity moves away from the agency itself, the contractor may need stronger evidence to show that the route was understood, justified and consistent with the labour-chain position it intended to approve.

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IR35 & Off-Payroll Working

PSC and off-payroll routes create a direct contractor-side status responsibility where the off-payroll working rules apply. The client is responsible for determining the worker’s employment status for tax, must take reasonable care when making that determination, and must issue a Status Determination Statement.

This matters because PSC use is not merely a downstream supplier choice. In ordinary labour-only contexts, the contractor may need to consider whether the worker would be an employee for tax purposes if engaged directly.

If the client fails to take reasonable care, responsibility for tax, NICs, Apprenticeship Levy and payment to HMRC can rest with the client.

A further practical risk arises where the contractor issues an outside-IR35 SDS. The SDS does not itself authorise self-employed or CIS treatment. However, it may evidence that the contractor assessed the role as capable of being performed outside deemed employment for tax purposes.

If the downstream chain then routes the worker through self-employed, CIS, purported umbrella CIS, an umbrella-like payroll company, or another non-PAYE arrangement, the SDS may become relevant to what the contractor knew, should have known, permitted, expected or should have monitored.

The issue is not merely whether the contractor intended that outcome. The issue is whether the contractor has enough route evidence to show that the outcome did not occur.

Umbrella-Company Reforms

Umbrella-company reform adds the next upstream pressure point. As of the 2026 tax year, PAYE rules for labour supply chains involving umbrella companies apply where an umbrella company is used in the chain.

Responsibility sits with the agency that has the contract with the end client, or with the end client where there is no agency in the chain, where the agency is deemed connected with the umbrella company, or where the agency is overseas.

For contractors, the practical issue is that umbrella visibility now matters before the worker is paid, because the recovery question may later turn on whether an umbrella company was present, which party sat above it in the chain, and whether the end client became the relevant recovery party.

This also matters in construction because the highest-risk route is not always a conventional umbrella company openly operating PAYE.

A greater concern may arise where an umbrella-like payroll company, payment intermediary or purported umbrella route is inserted into the chain, but the worker is in fact being paid through CIS, gross payment, self-employed treatment or another non-PAYE route.

In that situation, the contractor may face both sides of the problem: umbrella-chain opacity on the one hand, and CIS / PAYE non-compliance risk on the other.

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Construction Industry Scheme (CIS) Risks

CIS creates its own contractor obligations. Contractors must verify subcontractors, apply the correct deduction status, account for deductions and support monthly CIS reporting.

But CIS should not be treated as a general-purpose route for supplying site labour. It is a construction tax regime that can be appropriate where a subcontractor is genuinely delivering a defined works package, with responsibility for the construction output, supervision, method and delivery risk.

It becomes far more fragile where the purchase is for labour only: where individuals are supplied to work under the contractor’s direction without a genuine subcontracted package of works.

Also from April 2026 onwards, CIS carries a separate supply-chain fraud exposure. A CIS “knew or should have known” framework can apply where a person makes a payment under a construction contract and knew or should have known that a connected party had or would deliberately fail to make or pay a CIS deduction, or deduct or pay an amount due under PAYE regulations.

Where those conditions are met, HMRC may determine that the payer is liable to pay 20% of the payment made.

The commercial economics of a labour supply arrangement may also become part of the warning-sign picture.

Low pricing is not, by itself, proof of CIS fraud, PAYE non-compliance or improper routing. However, where a contractor understands the economics of the arrangement and the apparent margin is not realistically capable of supporting lawful PAYE employment costs, employer NIC, holiday pay, pension contributions, levy exposure where applicable, payroll operation, insurance, overhead and profit, that may raise an obvious route question.

The answer may be that the chain is not operating as PAYE, but through CIS, PSC/off-payroll treatment, purported umbrella CIS, gross payment or another payroll-intermediary route.

The same framework also applies to CIS credit claims. Where the relevant conditions are met, HMRC can charge a penalty, potentially transfer the penalty to a company officer, and immediately cancel Gross Payment Status.

VAT Supply-Chain Risk

VAT risk sits alongside these issues as a separate supply-chain fraud and input-tax defensibility risk. It is not a CIS rule, and it should not be treated as part of the employment-status analysis.

For contractors, the relevance is evidential: opaque labour chains, unusual pricing, unclear paying parties and weak supplier diligence may create tax-risk questions beyond PAYE, CIS and umbrella recovery alone.

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Route Risk Summary

Taken together, these frameworks mean that external temporary labour procurement can no longer be treated as a supplier-trust issue alone. PAYE, NIC, agency legislation, IR35, umbrella-company reform, CIS, VAT, worker-status, invoice evidence, payroll routing and supply-chain fraud rules may each begin from different legal concepts, but in practice they often converge on the same factual questions: who supplied the worker, who paid the worker, what route was used, what tax treatment was applied, what the contractor knew or should have known, and whether the evidence supports the position being relied upon.

In that environment, loopholes, workarounds or margin-driven routing decisions pursued by one party can become another party’s exposure. A route that appears commercially convenient downstream may later create evidential, financial, tax, social value or reputational issues upstream.

This is why contractor-side route control is becoming more important. Even where a contractor keeps a tight PSL, restricts supplier access, receives claims of industry accreditation and relies on periodic audit, that assurance is still only a point-in-time view of supplier presentation. It does not provide a complete, ongoing and objective view of the day-by-day beneath the approved supplier relationship. Bringing into scope the following areas of concern.

Risk area Contractor concern

PAYE / NIC

Whether the correct party has operated PAYE, deducted tax and NIC, reported payroll and paid HMRC where required.

PSC / off-payroll working

Whether labour-only work creates contractor-side status, SDS, fee-payer and PAYE/NIC risk.

Umbrella-company exposure

Whether umbrella arrangements exist, which party sits above them, and whether recovery may move upstream.

Payroll intermediary usage

Whether an apparent payroll or employment route is obscuring worker status, deductions or the true paying party.

CIS

Whether CIS is being used for genuine subcontracted construction work, or incorrectly used for labour-only supply.

CIS fraud / Kittel-style liability

Whether a construction payment or CIS credit is connected to deliberate CIS or PAYE non-compliance.

Risk area Contractor concern

Pricing warning signs

Whether the labour price can realistically support lawful PAYE costs, overhead and profit.

VAT / supply-chain fraud

Whether input tax recovery could be challenged where transactions are connected with fraudulent VAT evasion.

Worker cost treatment

Whether holiday pay, pension treatment, deductions and pay records are clear, defensible and consistent.

Invoice and funding reliance

Whether invoice values can be connected to real project activity and worker-level evidence.

Audit and recovery

Whether the route can be reconstructed later for disputes, failures, audits, funder reviews or regulatory questions.

Reputation and social value

Whether the contractor can defend the labour-chain standard beneath its projects.

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The modern route-control question

The table illustrates why agency approval alone is no longer enough.

A contractor may complete supplier onboarding, approve an agency, obtain contractual assurances and still remain exposed if the actual worker route beneath that agency relationship is not visible, controlled and evidenced.

Not only

Which supplier did we approve?

But also

Which route did the worker actually travel through?

Who paid the worker?

What tax treatment was applied?

Can that be proven later?

That is the route-control problem. Contractors do not need to become employment-law, tax, payroll or audit specialists for every downstream party.

But they do need a practical way to determine which routes are acceptable, exclude routes that create avoidable exposure, and evidence that selected labour activity remained inside the intended structure.

The following heatmap therefore assesses the main engagement routes available in the market and shows why some routes create a stronger contractor position than others.

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Temporary labour route-risk heatmap.

Below is a heatmap summary of the most popular engagement routes, assessed for risk against various legislative arms. A complete breakdown of each individual route including risk severity and likelihoods is available in research paper: CLCRH-001 at augscape.com.

Low risk

Cleanest route profile

Contractor Direct PAYE

The contractor directly employs or engages the worker, owning payroll, tax, records, right-to-work assurance and site-access controls.

Low / medium risk

Controlled if maintained

Agency Direct PAYE

Acceptable where the agency directly employs and pays workers through PAYE, with no umbrella, CIS, PSC or off-chain payroll drift.

Medium risk

Depends on site reality

Contractor Direct CIS Works Package

Viable where a genuine subcontractor delivers a defined construction output and the contractual position matches site reality.

Medium / high risk

Boundary-sensitive routes

Contractor Direct CIS Labour-Only

Simple chain, but the contractor directly owns the employment-status and PAYE/CIS boundary risk.

Umbrella PAYE

Worker is employed and paid through an umbrella company, but recovery exposure may move upstream if PAYE is not operated correctly.

High risk

Visibility and control weaken

Agency CIS Labour-Only

High-risk route sitting directly on the boundary between CIS and agency PAYE rules.

PSC for Labour-Only Work

Ordinary site labour routed through personal service companies creates IR35, status, fee-payer and PAYE risk.

Offshore / Secondary Chains

Offshore payroll or deep secondary agency structures can obscure payer identity, worker rights and route evidence.

Very high risk

Prohibit / avoid route

Mini Umbrella / Disguised Remuneration

Artificial, fragmented or avoidance-led payroll structures hidden beneath secondary agencies or unclear worker-paying arrangements.

Purported Umbrella / Non-PAYE Payroll

Payroll-like entity operating CIS, gross pay or another non-PAYE model while appearing to be payroll infrastructure.

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What the Heatmap Shows

Contractor Direct PAYE gives the strongest traditional assurance because the contractor controls the employment, payroll and evidence position. The contractor knows who the worker is, how the worker is engaged, how pay is calculated, how PAYE is operated, what deductions apply and what records exist.

But it is operationally heavy, and often unsuitable as the default model for flexible, project-led, regional and multi-site temporary labour at scale.

Agency Direct PAYE without umbrella or secondary-chain mechanics can create a more manageable external route. It preserves contractor flexibility and allows agencies to continue fulfilling labour demand.

But it is not risk-free. The contractor remains dependent on the agency maintaining route discipline, operating PAYE properly, keeping worker records, managing holiday and pension treatment, resolving worker queries and producing evidence that the route has not changed.

It can also create commercial pressure for the agency. Where an agency directly operates PAYE employment for flexible labour at scale, it will likely incur additional engagement, payroll, administration, employer-cost management, worker-query and evidence-production burden. That burden can squeeze agency margin, create pressure to increase charge rates, or incentivise the use of alternative downstream routes.

The Drift Problem

Once agencies become involved, the contractor gains flexibility but loses direct control over the worker route. The contractor may intend a clean Agency Direct PAYE route, but the operating reality may later drift into umbrella, purported umbrella, CIS, PSC, secondary-agency, offshore or unknown payroll territory.

The problem is drift.

An agency route that begins as ordinary PAYE can become materially different if umbrella arrangements, secondary agencies, CIS treatments, PSCs, offshore payroll, payroll intermediaries or unknown worker-paying parties enter the chain.

Once that happens, the contractor may be exposed to a risk profile it did not intend to approve.

Contractual assurances no longer provide meaningful protection either. Where legislation allows recovery or liability to move upstream, a clause saying the agency should have operated the route correctly does not stop the contractor being exposed if the chain deviated.

The issue is no longer what the supplier promised. It is what actually happened beneath the approved agency relationship, and whether the contractor can evidence it.

All other labour-only external routes are materially weaker for contractor assurance.

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Higher-Risk External Routes

CIS labour-only, umbrella chains, purported umbrella or payroll-company CIS, PSC labour-only arrangements, offshore payroll, mini umbrella structures and deep secondary agency chains all create high route, payroll, status, worker-transparency, audit or recovery concerns.

Deep secondary agency chains can be especially problematic as they can hide CIS labour-only, umbrella, purported umbrella, mini umbrella, offshore payroll, PSC or unknown worker-paying parties beneath the contractor’s approved agency relationship.

The risk is not only that something goes wrong.

The risk is that the contractor cannot prove, at worker and project level, what actually happened, what it knew, what it should reasonably have known, and what steps it took to prevent the route from drifting away from the position it intended to approve.

That is difficult where labour is spread across multiple agencies, sites, packages, regions, departments and payroll arrangements.

A contractor may negotiate a clean route, but if the operating chain drifts into umbrella, CIS, PSC, secondary-agency, offshore or unknown payroll territory, the contractor’s assurance position changes dramatically.

Public-Sector Procurement Direction

These route risks are now being reflected in formal public-sector procurement expectations.

HM Treasury’s DAO 04/26, published on 10 June 2026, states that central government bodies must procure temporary labour through transparent, commercially viable supply chains. Pricing must reflect employment, tax and supplier costs and margins, while reasonable steps must be taken to assure the tax compliance of both direct and indirect suppliers.

The guidance also warns that employment-tax and VAT liabilities can transfer to the public body where labour suppliers are non-compliant.

Although directed at central government bodies, the implications extend into the contractor and supplier chains supporting public-sector projects. Primary-supplier approval alone may not provide sufficient assurance where worker engagement, payroll operation or tax treatment occurs through indirect parties beneath that relationship.

For contractors delivering public works, the direction is therefore clear: labour-chain assurance increasingly depends on knowing and evidencing the route that actually operated; not only the route that was contractually intended.

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Converting contractor authority into controlled labour-chain infrastructure.

Contractor Control Principle

As the requirement originator; the contractor is the only party with enough practical authority to improve the overall market positioning.

Agencies can comply with requirements. Funders can price risk. Insurers can set conditions. Regulators can intervene. But the contractor controls the project environment and can decide what routes are acceptable beneath it.

ICCE has been developed to close the gap between the contractor’s market authority and the practical difficulty of enforcing that authority across fragmented, financial, operational and compliance-heavy temporary labour chains.

It changes the operating position by controlling the available routes, guard-railing external parties with systematic enforcement, standardising how engagements are formed and transactions are processed, creating consistent downstream operating behaviour, controlling outcomes and improving the available evidence.

ICCE is designed to make operating external labour chains simpler, by empowering contractors to convert what is currently a compliance minefield into a controlled opportunity.

Instead of relying only on supplier declarations, after-the-event checks or fragmented records, contractors can move temporary labour activity onto Frameworks where the route is already structurally controlled, individually worker- and transaction-evidenced and reportable.

This is the basis upon which ICCE was developed. To rethink and rebuild temporary labour from the ground up, with assurance and visibility at the core, providing the infrastructure for temporary labour supply chain activity to flow under consistently-applied, optimal conditions, programmatically processed, evidenced and reported transparently.

In doing so, each party within the chain experiences improved relationships, trust and freedom to focus on their core function and service delivery quality without prohibitive administrative burden.

ICCE is a way to retake control of labour supply chains and enforce operating conditions surrounding operations, risk, compliance and ethical outcomes. It provides a structured way for contractors to improve transparency and defensibility.

To enable delivery at scale, ICCE developed and deploys its own engagement route: ICCE Controlled Employment.

Its sole purpose is to provide a cleaner alternative than existing external routes, whilst preserving agency fulfilment and removing the opportunity for misapplication, misuse, route drift or ambiguity beneath the labour chain.

Operating principle: if temporary labour is to move through a clean external route, the route must be controlled before work proceeds.

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ICCE Controlled Employment

ICCE was developed to provide contractors with the missing external route between the two current imperfect options available.

Engaging temporary workforces directly gives the strongest traditional assurance, but it is unrealistically operationally restrictive.

Conversely, permitting external workforce engagement by agencies preserves operational flexibility, but leaves contractors dependent on downstream route discipline and exposed to changeable, external fulfilment and fragmented supplier records.

ICCE Controlled Employment provides the missing third route: A system-enforced, PAYE-only, external engagement pathway that preserves external flexibilities without drift-risk.

Chain type

ICCE Controlled Employment

Heatmap status

Low risk

The route is deliberately structured around true employment, PAYE-only operation, worker-level evidence, transparency and route exclusion, with worker treatment grounded in recognisable employment protections such as clear pay, holiday pay, statutory sick pay where applicable, pension handling and transparent deductions.

Umbrella, CIS labour-only, PSC, offshore payroll, mini-umbrella, disguised remuneration, worker classified Contracts for Services and other downstream worker-paying routes are all excluded from ICCE delivery by design.

ICCE Frameworks

ICCE Controlled Employment is delivered through ICCE Frameworks.

An ICCE Framework is the contractor-defined operating environment for selected temporary labour activity. It identifies the project or works package brought within ICCE scope, and applies the conditions under which that activity is allowed to proceed.

In ordinary procurement, a framework may define approved suppliers, commercial terms, operating expectations and route requirements. ICCE Frameworks perform a similar organising function, but rather than the relevant conditions being left to contract wording or supplier adherence; they are defined and enforced through the ICCE Platform.

That matters on large projects and supply chains because route discipline can drift quickly. A route agreed centrally may be interpreted differently at regional level, applied inconsistently at site level, weakened through supplier behaviour, or obscured through secondary supply and payroll arrangements beneath the approved agency relationship.

ICCE Frameworks are therefore the mechanism through which contractor intent becomes controlled operating structure. They define the boundary, identify the participating agencies, attach activity to the relevant project or package, apply the permitted engagement route and create the basis for worker-level evidence, payroll-route clarity and structured reporting.

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Agency Flexibility Inside Controlled Boundaries

The value is that ICCE Frameworks can be made operationally-open to any contractor preferred agency, but only within bounded, controlled fulfilment parameters.

That matters because contractor PSL strategy usually involves a trade-off. A wider agency base can improve operational flexibility, regional responsiveness and labour availability, but it can also increase route variability, supplier inconsistency and evidence fragmentation.

A tighter PSL can improve control and relationship discipline, but may reduce choice, resilience and responsiveness when project demand changes.

ICCE is designed to rebalance that trade-off. It allows contractors to preserve agency choice and fulfilment flexibility while applying a consistent controlled engagement route to the activity those agencies fulfil.

Without ICCE, agency selection and approval can remain commercially necessary but evidentially incomplete.

A contractor may select the preferred agency, maintain a tight PSL and receive claims of accreditation or periodic audit comfort, while still lacking a live view of the route, worker, payroll and evidence position beneath that agency relationship.

Inside ICCE Frameworks agency selection becomes largely an operational and relationship decision only, as engagement route and drift concerns are no longer dependent on agency performance alone.

ICCE performs its own agency onboarding process, covering minimum participation requirements, compatibility and evidence expectations, so that the agency’s ability to fulfil through the Framework is assessed before activity is brought into scope.

The preferred agency can still fulfil labour. The contractor can still preserve agency choice, flexibility and day-to-day communications.

The difference is that the engagement, payroll route, evidence and reporting conditions attached to the scoped activity are governed by the ICCE Platform and the ICCE Framework, rather than inferred from supplier approval alone.

The purpose is to give contractors both a commercially controlled, and an operationally practical, way of ensuring downstream external labour chain activity produces the desired outcomes and associated evidence.

Within ICCE Frameworks, activity does not move through the system because a supplier says it is compliant. It moves through ICCE because the engagement, route, evidence and reporting conditions are built into the system itself.

Operating within defined Framework Controls means that the majority of systemic risks are eliminated by design.

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Excluded Engagement Routes

For scoped ICCE-routed activity, the following routes are excluded at system level:

Excluded route Reason
CIS / self-employed treatments, including purported umbrella / payroll-company CIS Creates employment-status, PAYE/CIS boundary and evidence risk, especially where labour-only supply may engage agency legislation, ordinary CIS obligations, or the April 2026 CIS fraud measures. The risk is heightened where a payroll-style intermediary appears to employ or pay workers but in fact operates CIS, gross payment or another non-PAYE treatment instead.
Umbrella payroll chains Create worker-understanding, deduction, pay-transparency and route-opacity concerns, with PAYE recovery risk moving upstream under the 2026 umbrella-company rules where an umbrella company is used in the chain.
PSC routes Create contractor-side worker-status, SDS, fee-payer and PAYE/NIC risk under the off-payroll working rules, particularly where ordinary labour-only work is assessed as outside IR35 or the SDS later supports non-PAYE routing.
Offshore payroll Weakens UK PAYE/NIC visibility, enforcement, worker-route assurance and audit reconstruction where a non-UK payroll, employer or payment entity sits in the chain.
Mini umbrella / disguised remuneration Creates artificial fragmentation, PAYE/NIC avoidance, disguised remuneration, worker-deduction and fraud-risk concerns.
Unknown worker-paying parties Prevents reliable assurance over who employs, pays and taxes the worker, making section 44, umbrella, CIS, PSC, VAT and audit exposure harder to assess.
Uncontrolled secondary agency chains Multiply opacity and can hide CIS, umbrella, purported umbrella, PSC, offshore, mini umbrella or unknown worker-paying routes beneath the approved agency relationship.

This does not mean every excluded route is unlawful in every possible context. It means those routes are not compatible with the clean external engagement position ICCE permits.

The operating logic remains: if temporary labour is to move through a clean external route, the route must be controlled before work proceeds.

That is what makes ICCE different from a PSL audit record, reporting overlay or third party trade association seal of approval. Those are periodic oversight mechanisms which show some of the picture, part of the time.

The following section details how activity within ICCE Platform operates through as a defined lifecycle of deterministic, verifiable events.

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Platform Activity Lifecycle

ICCE and Frameworks govern how activity throughput is allowed to happen, from the point the requirement is created, through the fulfilment process, into payroll, closure and evidence.

The contractor remains able to preserve agency choice. The agency remains able to fulfil labour. ICCE ensures the activity operates through Framework controls.

The lifecycle below shows how temporary labour activity moves from contractor requirement through controlled agency participation, worker engagement, payroll operation and evidence availability.

Each step is designed to reduce ambiguity around who did what, when, through which route and on what basis.

1

Contractor creates a Framework.

2

Agencies are invited & onboarded.

3

Agencies
create worker engagements.

4

Worker
accepts or
declines.

5

Work &
hours are reconciled.

6

Payroll is calculated & executed.

7

Evidence
& reporting
become available.

Each stage is programmatically validated before proceeding to the next stage, then logged and timestamped to create a tamper-proof, auditable data-chain record of the activity.

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Lifecycle stage breakdown

Each stage has a specific role:

Stage What happens Main parties involved
Framework setup The contractor creates the relevant project, package, site, region, trade, labour category or operating segment as an ICCE Framework. Contractor / ICCE
Agency onboarding The contractor invites any preferred agencies intended to fulfil covered labour activity to join the Framework. Contractor / Agency / ICCE
Minimum requirement review Agencies complete onboarding, meeting minimum participation, operational and evidence requirements needed to operate inside ICCE Platform. Agency / ICCE
Agency validation ICCE validates the agency’s ability to operate within the controlled route and communicates the validation outcome to the contractor. ICCE / Contractor
Engagement input The agency loads the worker and engagement details into ICCE against the relevant project or operating context. Agency / ICCE
Engagement validation ICCE checks that the engagement input fits the controlled route before the worker activity proceeds. ICCE / Agency
Worker acceptance The worker receives the work opportunity and can accept or decline the engagement through the ICCE process. Worker / ICCE
Work commencement Where the engagement is accepted and proceeds, the work activity moves into the controlled engagement pathway. Worker / Agency / ICCE
Work completion The engagement concludes and the relevant work record becomes available for hours and payroll handling. Worker / Agency / ICCE
Hours reconciliation Hours are submitted, checked and reconciled so that payroll is based on controlled engagement records rather than scattered downstream evidence. Agency / Worker / ICCE
Payroll calculation Payroll is calculated deterministically from the reconciled engagement and hours position. ICCE
ICCE payroll operation ICCE operates payroll calculation and execution internally instead of relying on an agency, intermediary company or unknown downstream party. ICCE / Worker
Engagement closure The engagement is closed with the relevant route, payroll and activity records attached. ICCE
Evidence and reporting Contractor-facing outputs are available from the controlled activity record, including project, agency, worker, payroll-route and audit evidence. ICCE / Contractor
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From passive oversight to active, ethical control.

This is the central purpose of ICCE: to control, capture and distribute the underlying labour-linked data, making it available as a single source of market truth for relevant, authorised parties.

For contractors, that changes the labour-chain position from passive oversight to active control, and from risk management to operational flexibility.

By leveraging ICCE Frameworks, Framework Controls and data capture for downstream temporary labour chains, contractors turn labour-chain clean-up into an evidence-producing opportunity.

It allows the contractor to demonstrate that selected temporary labour was not merely procured, but purposefully governed to support both commercial and ethical outcomes, stronger supply-chain accountability and more defensible ESG related targets.

As social value is now more important commercially, a cleaner labour chain gives contractors evidence that temporary labour placements originating from their requirement have not been left to opaque downstream arrangements.

Instead, activity is routed through a fairer, more transparent and ethical operating structure, supporting stronger fair-work, responsible-procurement, worker-treatment and supply-chain transparency outcomes.

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Worker clarity as a design principle.

From the outset, ICCE was built around the principle that flexible workforces should be able to understand their engagement, employer, pay route and working life with the same practical confidence as those in more permanent roles.

Many flexible professionals rely on temporary placements as a primary source of income. That makes clarity around engagement, pay, deductions, holiday treatment, employer identity and dispute resolution more than an administrative concern.

Where umbrella, purported umbrella, CIS labour-only, PSC, offshore or opaque payroll routes are permitted inside a labour chain, the worker experience can become harder to explain and harder to evidence.

That can sit uncomfortably beside commitments to fair work, transparency, responsible procurement and positive worker outcomes.

The Route Risk Analysis and ICCE Operating Model sections demonstrate why external engagement routes create financial, legislative and evidential exposure.

This section explains the worker-outcome and responsible-procurement opportunity: where a properly controlled engagement route can create more harmonious conditions for fair work, fair pay, worker transparency and responsible supply-chain behaviour.

The research finding is that opaque, complex umbrella-led payroll chains can create suboptimal worker outcomes where they reduce pay clarity, obscure deductions, confuse employer or payer identity, weaken complaint routes, or make it harder for workers to understand and manage their income.

Removing those routes from scoped activity gives the contractor a clearer, fairer and more defensible worker-outcome position in comparison to alternative labour-chain approaches, and when competing for work.

Research paper: ULESV-001 [UK Umbrella Labour Ethics, Social Value and ESG Assessment] is available at augscape.com

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Why Route Boundaries Matter for Social Value

The permitted downstream workforce engagement boundaries matter, because social value claims are weak when created simply by counting labour hours, worker numbers or local workforce participation.

Conversely, they are materially strengthened when the claimant can evidence the precise nature and quality of the worker-related outcomes: how workers were engaged, paid, informed, supported and protected from opaque downstream arrangements.

Social value, ESG and responsible-procurement claims become comparably more credible where they are supported by both attributable outcome data and a structured assurance process.

A more commercially valuable position is created where the contractor can show not only what outcomes it intends to achieve, but how the relevant labour activity will be scoped, controlled, processed and evidenced.

Having strong and evidenceable answers to these questions is commercially valuable.

Evidence Questions for Contractors

These questions translate the assurance process into practical evidence areas a contractor can use to support social value, ESG and responsible-procurement claims.

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This does not mean every external payroll arrangement is unlawful or improper. It means some arrangements create a heavier evidence burden, especially on public, prominent, infrastructure, regeneration, housing, council, government-linked or social-value-sensitive works.

Where the route is conditional, worker-funded, indirect, difficult to explain, hidden through a secondary chain, or mixed into agency fulfilment without clear worker-level evidence, the contractor’s social value position becomes harder to substantiate.

The issue is not the label attached to the route. It is whether the worker experience remains clearly connected to the project claiming the social value.

If the worker’s engagement, payer identity, deduction position, complaint route or pay calculation is difficult to evidence or explain, the route becomes harder to align with fair-work, worker-dignity and responsible-procurement claims. Creating a weaker social value position if it is worker-funded or reduces pay clarity, worker understanding, complaint access or financial transparency.

The worker-outcomes of ICCE Controlled Employment route are stronger because the workforce is not routed through a “contract for services”, subcontractor agreement, umbrella chain or open-ended zero-hours arrangement. Instead, workers are directly employed by ICCE on a PAYE employment basis for the duration of the engagement.

This is the same Employer of Record arrangement that specialist, perm-hire platforms use to employ thousands of individuals across the globe. That means the route is structured around true employment, payroll clarity and statutory worker protection from the outset, including PAYE operation, payslip visibility, holiday pay, National Minimum Wage / National Living Wage protection, pension auto-enrolment where eligible, employer accountability, and clearer routes for payroll and dispute queries.

The worker is not left to infer their position from a downstream payroll structure. The employment route is simple, understandable, bounded and evidenced.

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From Risk Management to Improvement Story

ICCE turns that issue into a practical opportunity.

The contractor can move away from relying on loose declarations about worker treatment and toward structured evidence of the worker route.

By routing selected temporary labour through ICCE Controlled Employment processed by the ICCE Platform, the contractor can show that it has taken purposeful steps to remove umbrella and other opaque, external arrangements from its supply lines.

This preserves agency fulfilment inside a controlled route, and supports worker-facing fairness, transparency and pay clarity through true PAYE employment.

Instead of claiming that suppliers were approved or compliant, the contractor can evidence how the route is structured, controlled and reported. That is a materially stronger position.

With ICCE-routed activity, contractors can confidently say:

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Outcome Areas Supported by ICCE

By implementing a clean and controlled supply line structure; a contractor is no longer only managing risk. It is taking practical action to improve the standard of the labour chain beneath its projects in a demonstrable way.

This is not a scoring guarantee. Tender and social value scoring will always depend on the wording, weighting and evaluation criteria of the specific opportunity. ICCE should not be presented as an automatic scoring outcome, certification or substitute for procurement, ESG, legal, employment or audit review.

Its practical value is that where a tender, client review or social value assessment asks for evidence of fair work, worker transparency, responsible procurement, supply-chain governance or payroll-route clarity, ICCE Controlled Employment and ICCE Platform gives contractors a stronger evidence base to respond with.

For contractors, that matters commercially. A clean, fair and transparent labour route is no longer just a compliance preference. It can become part of the project’s value story: better worker clarity, stronger supply-chain accountability, more defensible reporting and a clearer explanation of how temporary labour was governed beneath the works.

That is the shift: what was previously a labour-chain weakness can become an evidence-led improvement story.

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Frameworks turn temporary labour activity into a controlled operating environment.

What a Framework Is

Activity inside ICCE is designed to be deployed through ICCE Frameworks.

A Framework is the contractor-defined operating environment for selected temporary labour activity. It gives the contractor a practical way to decide which labour supply lines should move through ICCE, which agencies may participate, control the route conditions, and how the resulting activity should be attributed, evidenced and reported.

The contractor does not need to move every temporary labour arrangement into ICCE at once. A Framework can be created for one defined supply line while other activity remains outside ICCE unless separately adopted.

That makes deployment practical and controlled.

One project may carry higher public scrutiny. One package may involve higher labour volume. One trade may create more route risk. One agency supply line may be suitable for early review. One public-sector-linked programme may require stronger social value evidence.

A Framework allows ICCE adoption to begin where controlled routing, worker-level evidence, financial attribution, social value evidence and project-linked reporting matter most.

This makes adoption clearer for contractors, agencies and internal teams, because the Framework establishes where ICCE applies, where it does not, and which labour activity is intended to produce controlled evidence.

Framework Controls

Framework Controls are the conditions that allow the structure to operate.

They are not policy statements, contractual assurances or supplier promises. They are the practical, systematically-enforced restrictions applied to scoped activity inside ICCE.

Preferred agencies can continue to fulfil labour, but the activity they fulfil must operate through the ICCE Platform and Framework Controls.

The worker engagement, route, payroll and evidence conditions are programmatically processed rather than inferred from supplier approval alone.

This is the difference between approving an agency and controlling a labour supply line.

Agency approval confirms which supplier the contractor is prepared to work with. A Framework controls how selected activity is allowed to happen once that supplier participates.

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Framework elements

At its simplest, the Framework defines:

Framework element Function
Scope Identifies the project, package, site, region, trade, agency supply line or PSL subset brought into ICCE.
Agency participation Identifies which agencies may fulfil labour through the controlled route. Agencies can be added at procurement or PSL level, or invited at regional, site, project or package level where permitted.
Route control Requires activity to move through ICCE Controlled Employment rather than external umbrella, CIS labour-only, PSC, offshore, unknown payroll or uncontrolled secondary-chain routes.
Worker engagement process Ensures agencies create and communicate engagements through the ICCE Platform, and workers accept, decline or interact with those engagements through the worker-facing process. The contractor does not manage individual worker engagement; ICCE captures the agency and worker activity as it occurs.
Payroll route Connects scoped activity to ICCE’s PAYE employment and payroll process. ICCE operates payroll directly, including RTI reporting through FPS and EPS submissions to HMRC, rather than relying on an umbrella company, payroll intermediary, downstream paying party or third-party payroll software.
Attribution Links activity to the relevant project, package, trade, site, region,or agency supply line, so that labour usage, worker-route evidence and outcome data can support financial review, risk and compliance oversight, audit reconstruction, social value reporting and ESG-related project evidence.
Evidence Captures the data created inside ICCE as activity happens, including agency participation, worker engagement, worker acceptance, commencement, completion, hours handling, employment-status route, payroll values, statutory deductions, exception handling, closure records and reporting outputs.
Reporting basis Creates the structured record from which contractor-facing outputs can be produced, using project-linked attribution, controlled route evidence and captured activity data to support reporting across labour usage, agency fulfilment, payroll values, risk and compliance oversight, audit reconstruction, social value outcomes and ESG-related project evidence.

The preferred agency can still communicate with workers, form engagements and fulfil labour demand. The contractor can still preserve established agency relationships.

The difference is that scoped activity moves through ICCE Controlled Employment, with the engagement, payroll, route evidence and reporting conditions attached to that activity captured inside the system.

This gives the contractor a practical control position without requiring a change to normal commercial and contractual relationships.

Scope Boundaries

A Framework can be narrow or broad depending on the contractor’s preference. It may apply to: one project; one package of works; one site or region; one trade category; one labour category; one agency supply line; one PSL subset; one social-value-sensitive programme; one high-risk or high-volume labour supply chain.

Anything not brought into the Framework remains outside of scope.

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Project Attribution

For contractors, labour activity needs to connect back to the level at which the work is already managed, priced, governed and reviewed. ICCE uses project and package attribution to give temporary labour activity a defined commercial and operational home inside the Framework.

That attribution allows worker engagement, agency fulfilment, PAYE employment, payroll-route evidence, project reporting, social value outputs and audit records to connect back to the context in which the labour was required.

Agencies cannot create engagements in isolation. Each engagement must be created inside an existing contractor-created Framework.

The agency may be invited into that Framework directly by the contractor, or may enter the relevant Framework ID when creating the engagement, where that method is enabled and permitted.

This is what ties each engagement, worker record, payroll event and evidence output back to the wider contractor requirement, regardless of which authorised agency supplied the labour.

Where multiple agencies fulfil against the same Framework, ICCE can aggregate and filter the resulting activity by project, package, site, trade, region, labour category, agency supply line, worker route or reporting purpose.

This gives the contractor one controlled view of downstream labour-linked data, usage, spend and outcome evidence without removing agency flexibility or diluting oversight.

This matters because temporary labour information often becomes separated between what the contractor can see internally and what the agency later reports back.

A contractor may understand the project, package, requirement, approved agency, expected labour usage, budget position and headline spend.

The agency may then provide timesheets, worker lists, invoice summaries, payroll confirmations or compliance evidence about the activity it fulfilled.

The difficulty is that even well-run contractors can struggle to connect those two views at worker and project level.

Contractor-side project visibility may show the requirement and spend, but not the worker-level route. Agency-side evidence may show fulfilled activity, but not tie each engagement, payroll value, route position or worker outcome back to the exact project, package, trade, site or labour category that created the requirement.

Framework attribution changes that structure. It allows temporary labour activity to be understood through the same commercial and operational lens as the work itself.

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Framework-linked answers

Framework attribution gives contractor questions a clearer worker, route and project-linked answer.

Contractor question Framework-linked answer
Which project, package or workstream did the labour relate to? Labour activity is attached to the relevant Framework and project context.
Which agency fulfilled the requirement? Agency participation is linked to the scoped Framework.
Which workers were engaged? Worker-level engagement records connect to the Framework and project context.
Which employment route was used? ICCE Controlled Employment and payroll-route evidence are attached to the scoped supply line.
What did the labour cost relate to? Payroll-linked activity can be attributed to the relevant project, package, trade, site, region, labour category or agency supply line.
What period did the labour support? Engagement records can be linked to the relevant project duration, phase, package period or workstream timeline.
What social value evidence is available? Worker-route, PAYE employment, project attribution and route-exclusion evidence can be reported from the same controlled activity record.
What activity is outside ICCE? Anything not brought into the Framework remains outside ICCE unless separately adopted.

This attribution has financial, operational and evidential commercial value.

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Commercial Value

Temporary labour is often one of the more variable elements of project delivery. Demand can shift by location, trade, programme stage, agency availability, regional labour pressure, delay, acceleration requirement or recovery need.

Where that activity is spread across multiple agencies, site communications, invoice cycles and downstream payroll records, the full position may only become clear after cost has already formed.

A Framework gives that activity visibility. Ith does not replace estimating, procurement, commercial management or project controls, but it gives those functions clearer underlying labour data, sooner.

Commercial control improvement

Framework-linked records create a clearer relationship between temporary labour activity, project context and downstream evidence.

Commercial control issue Framework-linked improvement
Temporary labour cost appears late through invoices or agency summaries. Labour activity is attached to project context as it is created and fulfilled.
Agency spend is visible, but worker-level activity is harder to connect to packages or trades. Worker engagement can be linked to project, package or supply line.
Multiple agencies fulfil the same project through separate records. Activity can be viewed through one Framework-linked reporting structure.
Labour demand changes because of delay, acceleration or recovery pressure. Labour usage can be attributed to the project context in which the demand arose.
Project teams, commercial teams, finance teams and social value teams need different views. The same activity can support cost, audit, route, worker and social value reporting.
Labour usage is difficult to compare against planned assumptions. Framework-linked records support clearer variance review and internal explanation.
Temporary labour routes drift through downstream arrangements. Scoped activity remains controlled by the ICCE route.
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Using a Framework fits temporary labour into the project and package structures contractors already use.

Labour is not only seen as agency spend, payroll total or weekly timesheet volume. It becomes financially attributable, operationally visible, socially reportable and evidentially connected activity.

The activity carries identifiable workers, known agency participation, clean engagement, payroll-route evidence, route exclusions and structured outputs.

That matters across the contractor environment.

Commercial teams can understand where labour cost arose. Project teams can see which labour supported which package or phase. Finance teams can connect payroll-linked activity to the relevant project context.

Social value teams can evidence worker-route and fair-work outcomes by project or supply line. Compliance and audit teams can review route, worker and payroll evidence without relying only on supplier-level summaries.

A Framework gives the contractor a bounded way to apply ICCE to a preferred, defined scope of works. Once that scope is set and activity begins to move through the controlled route, the value is generated by the evidence created from it. That is where ICCE reporting begins.

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Reporting is created from controlled lifecycle activity.

The Reporting Principle

ICCE reporting value is driven from system-performed lifecycle activity, with the data-chain created as the activity moves through the system rather than assembled after the event.

Each output connects back to controlled events inside the ICCE platform: Framework creation, project attribution, agency participation, worker engagement, worker acceptance, commencement and completion, PAYE employment, payroll processing, engagement closure and related evidence.

The underlying record is created as the activity happens. At each relevant lifecycle stage, information is submitted, validated, logged and connected to the wider engagement record.

This creates a real-time, multi-party golden thread of trusted, labour-linked evidence.

Instead of being assembled after the event from various sources in various formats at different times, the data-chain is created at the point the activity becomes commercially and evidentially meaningful.

Each event becomes part of the record. Timestamped and stored as tamper-proof evidence, so historic data cannot be silently rewritten.

The purpose is to give contractors and other authorised parties confidence that reporting is not simply a later narrative about what happened.

It is a representation of controlled system activity in action.That matters when different parties rely on different parts of the same labour transaction.

A contractor may need project-level visibility. An agency may need fulfilment and worker-treatment records. A worker may need pay, engagement and route clarity.

A funder may need payroll-linked activity evidence. An insurer may need route and dispute evidence. An auditor or regulator may need reconstructible records. A social value team may need worker-route and fair-work evidence.

ICCE does not give every party every piece of data.

Each party has access to the information that is relevant and authorised for its role. The value is that those different views are drawn from the same underlying record, rather than from separate versions of the truth held by separate parties.


This is where the data-chain becomes the agreed source of truth. Framework scope, project attribution, agency participation, worker engagement, PAYE employment, payroll activity and evidence outputs are connected in one governed record.

For scoped activity, that record allows contractors and authorised parties to understand what happened, evidence the route, support commercial review, and report from with greater confidence.

Without ICCE, temporary labour reporting can remain fragmented, retrospective and incomplete.

The purpose is not to produce more data. It is to produce clearer, trusted and usable evidence.

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Typical Contractor Outputs

Typical contractor-facing output areas may include:

Reporting area Contractor use
Project labour usage Understand labour volume by project, package, trade, site, region or agency supply line.
Agency fulfilment See which authorised agencies fulfilled work through the scoped route.
Worker-level evidence Link worker engagement to project context, agency participation and PAYE employment route.
Payroll-route evidence Evidence that activity moved through the ICCE PAYE employment and payroll rail.
Route exclusions Evidence that umbrella, CIS labour-only, PSC, offshore and unknown payroll routes were excluded.
Financial attribution Connect labour activity, payroll-linked values and evidence to the relevant project or package context.
Social value support Produce worker-route, fair-work, pay-transparency and project-level evidence for review.
Employment numbers Evidence meaningful PAYE employment participation, volumes and project-linked labour activity.
Audit support Preserve attributable evidence for later reconstruction.
Exception reporting Surface gaps, rejected routes, blocked activity or unresolved items.
Cross-agency view Aggregate activity across multiple authorised agencies within the same project-coded scope.
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Shared infrastructure.

Multi-party benefits

This document covers ICCE from the perspective of contractors, but ICCE is not contractor-only infrastructure.

Temporary labour involves multiple parties relying on different parts of the same activity. Contractors need project visibility and route control. Agencies need a fulfilment pathway. Workers need clear employment, pay and engagement information.

Finance teams need payroll-linked values. Social value teams need worker-route evidence. Funders and insurers need stronger underlying evidence. Auditors and regulators need records that can be reconstructed.

ICCE gives each party a permissioned view of the same controlled activity.

Primary parties

Contractor | Internal Teams

Defines the Framework scope, route controls, agency participation and project attribution. Gains project-coded visibility, route control, fixed-term PAYE employment assurance, worker-level evidence and reporting.

finance, commercial, compliance, ESG, social value and project teams can use the same underlying record for cost attribution, route assurance, audit support, social value evidence and internal review.

Secondary parties

Agencies | Workers

Agencies continue to fulfil contractor demand where onboarded and authorised, while operating inside a cleaner, controlled and evidence-producing route.

Workers receive clearer fixed-term PAYE employment, pay-route visibility, employer accountability and worker-linked evidence.

Tertiary parties

Funders | Insurers | Auditors

Funders can review clearer evidence of the labour activity.

Insurers can review route discipline, worker engagement, payroll treatment and dispute context.

Auditors can reconstruct activity from controlled, timestamped, tamper-proof records rather than fragmented after-the-event submissions.

Primary parties define the requirement, controls and reporting need. Secondary parties operate within the platform under those controls. Tertiary parties benefit from the structured evidence, improved visibility and indirect assurance created by the controlled route.

That is why ICCE is multi-party framework and transaction infrastructure.

It operates the controlled transaction layer beneath activity that would otherwise be held in separate systems, separate records and separate interpretations.

The parties are not each relying on separate declarations about what happened. They are working from the same data-chain source of agreed truth, with access limited to the data relevant and authorised for their role.

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Agency & Worker Participation

ICCE improves the operating experience and outcomes for agencies and workers as active secondary participants. It does not force them into a structure that removes their existing relationships, role or autonomy.

The same operating principle applies to both groups: ICCE does not decide who works with whom, interfere with existing commercial or working relationships, or replace normal agency coordination.

It provides the infrastructure through which selected work can flow, with onboarding, suitability and compliance processes used to confirm that each party can participate properly inside the system.

The aim is to create a standardised minimum gate before activity proceeds, then give agencies and workers a clearer, more useful experience once they are inside the platform.

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The Agency Experience

ICCE does not change, restrict or interfere with the contractor’s existing agency relationships or contractual arrangements.

Contractors remain free to work with their preferred agencies, maintain existing PSL structures and decide which agencies may be invited to participate in a Framework. ICCE’s role is to control the route through which selected activity is processed once that activity is brought within scope.

Agency onboarding means the agency forms its own platform relationship with ICCE.

Before an agency can fulfil through Frameworks, ICCE carries out suitability, participation and compliance checks to confirm that the agency can operate inside the controlled route.

This includes KYB/KYC, director checks, VAT and financial checks, contract and policy review, insurance evidence, funding support and payment-clearing requirements where relevant.

For contractors, this creates a minimum platform-level assurance position before agency participation begins.

An agency may be invited by the contractor to participate in a Framework, but it must be onboarded before it can fulfil activity through the ICCE Platform.

Contractors can manage agency participation centrally, through procurement or PSL-level control, or allow regional and site-level teams to invite agencies where desired, and where that permission has been enabled within the system.


This allows agency selection to remain aligned with the contractor’s internal operating model while ensuring that only onboarded agencies can supply through the controlled route.

Agencies also gain value from participation. ICCE provides desktop and mobile access to work communication, engagement and scheduling tools, allowing agencies to coordinate activity and communicate with workers through the platform.

Agencies also receive their own financial, compliance, risk and activity reporting, with audit-grade evidence available to support contractor assurance, agency review, insurer discussion, funder visibility, audit response or regulatory review where applicable.

The result is not a system imposed on agencies solely for contractor oversight.

ICCE gives agencies a practical route to continue fulfilling contractor demand through a standardised, demonstrable, non-umbrella, PAYE-only employment pathway that reduces route ambiguity, improves evidence quality and gives workers a clearer flexible-working experience.

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The Worker Experience

In the same way contractors can invite agencies to participate in a Framework, agencies can invite workers to register with ICCE and participate in ICCE-routed engagements.

The ICCE Platform does not recommend, introduce, select, filter or rank workers. It does not replace the agency’s existing worker relationships or interfere with ordinary agency-to-worker communication and fulfilment.

Agencies remain responsible for sourcing and coordinating workers where they are authorised to fulfil through a Framework.

Worker onboarding allows ICCE to complete the checks and processes needed to support lawful engagement, PAYE employment, payroll operation, worker communication and route understanding inside the controlled pathway.

The purpose is not to create a digital recruitment or matching service. It is to ensure that workers moving through ICCE Controlled Employment are engaged, employed, paid, informed and evidenced through a clear PAYE process.

ICCE Platform provides the controlled environment once a worker is invited into an ICCE-routed engagement, supporting worker onboarding, engagement communication, acceptance, route controls, evidence capture and worker-facing records.

Then for each engagement, ICCE directly employs the worker, operates payroll, provides payslip visibility, creates worker-facing evidence, giving workers clearer routes for pay, payroll or engagement dispute and queries.

Workers receive clearer information about the engagement, employer position, pay route, deductions, payslip visibility and query pathway.

They are not left to infer their position from an opaque downstream payroll structure or navigate multiple worker-paying parties.

This supports the wider contractor proposition by making the worker experience part of the controlled activity record.

The route is clearer for the worker, more evidenceable for the contractor, and easier for authorised parties to understand where worker-route, pay transparency, fair-work or responsible-procurement evidence is required.


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Commercial Model

ICCE’s funding model follows from the controlled employment route.

ICCE employs the worker for the engagement and operates PAYE directly. Payroll is therefore not a separate downstream service sitting outside the system.

It is part of the infrastructure that creates the worker pay record, tax treatment, deduction evidence, employment evidence and reporting truth.

ICCE is designed to operate PAYE payroll processing directly with HMRC through FPS and EPS API connectivity, rather than relying on third-party payroll software, an umbrella company, payroll intermediary or downstream worker-paying party.

That direct payroll position matters. If ICCE is intended to provide cleaner worker outcomes, stronger payroll-route evidence and better contractor assurance, the payroll route has to be controlled at source.

ICCE therefore avoids worker-funded payroll operation.

Workers routed through ICCE do not fund the payroll infrastructure through umbrella-style deductions, intermediary payroll charges or worker-facing payroll costs.

They are employed through the ICCE route, paid through the ICCE payroll process, and given clearer visibility over pay, deductions, payslips and query pathways.

That position is central to the model. A system designed to improve pay-route clarity, worker understanding and produce ethical outcomes should not depend on charging workers for the machinery that creates that assurance.

The ICCE commercial model is therefore positioned around agency-funded participation.

Agencies already operate within commercial environments built around charge rates, pay rates, margin control, fulfilment cost, payroll administration and client-service delivery.

Agencies are therefore the party most naturally placed to factor ICCE platform fees into the commercial structure of the labour they fulfil through the platform.

This also reflects the service position. Agencies are the direct users receiving the operational fulfilment services: engagement creation, worker communication, scheduling support, controlled employment routing, payroll processing, reporting, evidence and platform visibility.

Without ICCE, agencies would either need to operate more of that engagement and payroll burden themselves, or rely on downstream third parties and lose control, consistency and oversight in the process.

ICCE therefore supports agencies as the service recipient and paying participant, while preserving the contractor’s agency choice and giving contractors the benefit of a controlled, reportable route.

For contractors, that matters commercially.

ICCE is not designed to create a large ongoing labour-linked implementation cost for contractors simply to obtain better visibility. It gives contractors route control, Framework assurance and reporting value without ICCE sitting between the contractor and agency as an MSP, labour supplier, recruitment agency or procurement intermediary.

Contractors

Keep agency choice.

Agencies

Keep fulfilment activity.

Workers

Avoid unethical payroll opacity.

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Deployment starts with one defined future labour requirement.

Starting Point

Adopting ICCE as controlled Framework infrastructure does not require whole-business implementation from the outset.

The suitable starting point is one defined future labour supply requirement. That requirement may be a project, package, site, region, trade category, agency supply line, PSL subset or social-value-sensitive programme.

The objective is simply to identify a bounded area of future activity where ICCE can be assessed on its own merits before wider adoption is considered.

Bounded launch

Begin with one project, package, supply line or programme rather than whole-business rollout.

Evidence-led

Assess ICCE where better route control, reporting or worker evidence has clear value.

Low disruption

Existing agency relationships and project structures can remain in place during review.

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Use cases

ICCE is most suitable for consideration where a contractor can identify a future supply requirement that is operationally important, commercially meaningful, evidentially exposed, or attached to a large, visible or public-facing scheme where better labour-chain assurance could support risk, social value, reporting or reputational outcomes.

Use case Why ICCE may help
Public-sector-linked project Provides stronger evidence for fair work, responsible procurement, worker-route transparency and social value reporting.
Infrastructure programme Supports project-level labour visibility where volume, scrutiny, audit sensitivity and programme delivery pressure are high.
Multi-agency project Creates one controlled route and reporting structure across multiple authorised agencies.
Umbrella-heavy supply line Gives the contractor a practical way to move selected activity away from umbrella dependency and into controlled PAYE employment.
CIS-sensitive trade Helps avoid labour-only CIS ambiguity for scoped temporary labour activity.
High-volume labour package Creates worker-level evidence, project attribution and payroll-route reporting at meaningful scale.
Social-value-sensitive tender Supports evidence around fair work, worker transparency, PAYE employment and responsible procurement.
Commercially variable labour supply line Improves visibility where labour demand, cost or agency usage may shift due to programme pressure, delay, acceleration or regional availability.
Selected PSL agency group Preserves agency preference while improving route discipline and evidence quality for selected, familiar suppliers.
Audit-sensitive project Creates attributable evidence during the activity rather than relying only on later reconstruction.
Regional pilot Allows bounded adoption without disrupting the wider business.

Each use case should be assessed on its own facts.

ICCE is most relevant where the contractor is already asking whether a defined labour supply line can be made cleaner, more visible, more attributable or easier to evidence, without becoming the direct employer for all temporary labour.

The point is not to adopt ICCE everywhere immediately.

It is to identify the supply requirements where the current or intended route is weakest, the risk is highest, the evidence need is strongest, or the improvement opportunity is most valuable.

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Launch Pathway

A controlled launch pathway allows the contractor to move from interest to suitability decision without disrupting existing operations, preferred agency relationships or wider procurement structures.

Step Contractor action Purpose
1 Review the ICCE proposition Understand the controlled external PAYE employment route and how it differs from agency supply, MSP, umbrella, CIS, PSC and ordinary supplier reporting models.
2 Assess route and evidence needs Consider whether existing supply lines or upcoming requirements create umbrella, CIS, PSC, secondary-chain, audit, financial visibility, worker-outcome or social value concerns.
3 Review deeper ICCE materials under NDA Examine system workflow, route boundaries, agency participation, reporting outputs, risk materials, funding model and legal or tax materials where available.
4 Identify one suitable future labour requirement or supply line Select a project, package, trade, region, agency supply line or PSL subset where controlled routing may be valuable.
5 Map agency participation Identify which preferred agencies currently supply, or may supply, the selected requirement.
6 Review outputs and outcomes Confirm what project, agency, worker, payroll-route, financial attribution, risk, audit and social value reporting would be useful.
7 Decide whether deployment is suitable Proceed only where the scope, agencies, internal stakeholders, operating requirements and controlled launch conditions are aligned.

Existing agency relationships, project control and procurement preferences can remain in place while one selected supply requirement is assessed for controlled routing. That allows ICCE to be considered on a bounded, evidence-led basis before wider rollout is considered.

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ICCE is intended to support a new national standard.

Launch Window Purpose

ICCE has been developed for a market that is larger than any single contractor, agency, payroll route or compliance workflow. Temporary labour is now a recurring operating dependency across major sectors, projects and supply chains.

The question is no longer whether temporary labour can be sourced. It is whether temporary labour can be routed, evidenced, paid, attributed and reported in a manner that is strong enough for modern contractor governance, public accountability, financial scrutiny, audit review, ESG reporting and worker-outcome expectations.

ICCE is intended to support that next operating standard.

operating scale

5,000

engagements per week
controlled launch throughput

Initial market phase
intentionally controlled and limited.
Six-year milestone

100,000

engagements per week
next operating milestone

Nationally meaningful scale
recurring, project-linked and multi-agency.

The immediate launch intention is to support a controlled throughput of 5,000 engagements per week. Subject to speed of contractor adoption, agency participation, partner alignment and launch progression, the longer-term operating ambition is to reach a next-milestone of 100,000 engagements per week within a six-year period.

Those figures define the intended direction and operating scale of the infrastructure: a controlled rail capable of supporting recurring, project-linked, multi-agency and evidence-sensitive temporary labour activity at nationally meaningful scale.

The initial market phase is intentionally controlled. ICCE is not being launched as an open-market product for unrestricted adoption.

Episodic is seeking engagement with a limited number of contractors of meaningful size, scope or strategic relevance.

Suitable contractors are those capable of assessing ICCE against real future labour activity and aligned with the wider ambition of improving operational, financial, risk and ethical outcomes across the UK temporary labour market.

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Suitable Early Adopters

Suitable early contractors may gain the opportunity to assess ICCE through a defined, practical and commercially relevant route.

Launch partner relevance Contractor significance
Defined project or package application ICCE can be assessed against a real operating environment rather than abstract policy language.
Project-coded labour visibility Temporary labour activity can be attributed to the correct site, package, region, agency and reporting context.
Agency-compatible supply Existing agency relationships can be preserved where agencies are onboarded and authorised for the relevant scope.
Controlled employment route Scoped activity can move away from opaque or fragile labour-only payroll routes into a cleaner PAYE employment structure.
Worker-level evidence Engagement, employment, payroll-route and reporting evidence can exist at the level of the individual worker and engagement.
Social value and public-facing assurance Contractors may be able to evidence fairer, clearer and more responsible temporary labour-chain governance.
Future standard influence Early participants may help shape how the controlled route is understood, evidenced and adopted across the wider market.
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Expressions of Interest

ICCE is currently seeking Expressions of Interest and further closed discussions with select contractors during its initial market launch phase.

An Expression of Interest is an early, non-committal exploratory step.

Its purpose is to determine whether there is a credible basis for further review, including whether the contractor has a suitable operating environment, relevant internal stakeholders, sufficient potential labour requirements, aligned values and a practical reason to consider ICCE during its initial market launch phase.

This initial phase is expected to operate through a limited launch group rather than unrestricted market access.

Contractors progressed beyond EOI may form part of the first closed operational review cohort, helping assess ICCE against live labour activity before wider market adoption is considered.

Ideal contractor launch partners are those with an aligned ethos and the means and desire to improve outcomes, shape future market-wide standards, and gain early advantage from leveraging ICCE during its initial market launch phase.

The wider ambition is to materially improve how temporary labour operates, driving improved operational, financial, risk and ethical outcomes across the UK.

Contractors submitting an EOI should therefore be capable of engaging with ICCE as more than a software review.

Episodic recognises that EOI submissions and initial discussions may come from individuals working within, or close to, procurement, commercial, risk, compliance, social value, ESG, contract management, agency management or project delivery.

It is not expected that one individual will have complete knowledge or authority across every matter required to assess, approve or adopt ICCE.


A relevant internal stakeholder with specialist knowledge in one or more areas may be sufficient to begin the conversation, provided they are capable of recognising where ICCE may be relevant and distributing the opportunity to the appropriate internal stakeholders.

Where further review is appropriate, later discussions may involve procurement, commercial, finance, compliance, legal, tax, ESG, social value, project teams and agency-facing contacts.

Open-market requests are not accepted during this initial window. Episodic will review EOI submissions on a case-by-case basis to determine whether further discussion is appropriate.

Submission of an EOI does not create approval, onboarding, participation, partnership, exclusivity, deployment or any commitment by either party.

Further discussion may remain subject to suitability review, confidentiality arrangements, internal stakeholder engagement, agency participation assessment, system readiness, legal and tax review, operational review, commercial agreement and controlled launch planning.

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Review Materials

A contractor reviewing ICCE may need more detail than this access pack can reasonably contain.

Further materials can be made available under appropriate confidentiality arrangements so that the contractor and its advisers can assess the route properly before any deployment decision is made.

Those materials may include:

Material Contractor relevance
ICCE model overview Shows how the wider infrastructure model operates.
Classification-safe positioning summary Explains why ICCE is infrastructure rather than labour supplier, MSP, umbrella, lender, insurer or payroll bureau for third-party employers.
Contractor workflow overview Shows how project codes, contractor access and agency routing work.
Project-code and Labour Requirement Notice examples Shows how temporary labour demand can be structured before fulfilment.
Sample reporting outputs Shows the project, agency, worker, payroll-route, financial attribution and social value outputs a contractor may receive.
Agency participation model Shows how existing agencies can fulfil through ICCE rails.
Worker experience summary Shows how worker engagement, fixed-term PAYE employment and route information are handled.
Fixed-term PAYE employment evidence examples Shows how ICCE-routed activity excludes umbrella, CIS labour-only, PSC and unknown payroll routes.
Funding model summary Explains why ICCE avoids worker-funded payroll and how agency-funded participation supports the model.
Financial and labour-chain risk materials Supports review of current route risk, legislative pressure and evidence gaps.
Social value and ESG materials Supports review of fair work, worker transparency and responsible procurement evidence.
Funder and insurance materials Shows how controlled labour evidence may support wider financial and risk review.
System status materials Explains current implementation status, target architecture and controlled launch requirements.
Legal and tax review materials Supports adviser review where available and appropriate.

Availability of review materials may remain subject to confidentiality arrangements, suitability review, adviser involvement, and the stage of contractor engagement.

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Boundary Statement

ICCE is infrastructure for selected routed activity.

What ICCE is not

  • ICCE is not legal advice.
  • ICCE is not tax advice.
  • ICCE is not employment-status advice.
  • ICCE is not insurance advice.
  • ICCE is not funding advice.
  • ICCE is not procurement advice.

Operational exclusions

  • ICCE does not supply labour.
  • ICCE does not select workers for contractors.
  • ICCE does not guarantee labour availability, worker suitability or worker performance.
  • ICCE does not replace contractor agency relationships.
  • ICCE does not certify historic labour chains.

Role exclusions

ICCE does not act as an MSP, recruitment agency, umbrella company, payroll bureau for third-party employers, labour supplier, lender, insurer, receivables owner or procurement agent.

ICCE controls only activity brought within ICCE scope. Activity outside ICCE remains outside ICCE unless separately adopted.

What ICCE does control

For scoped activity, ICCE provides a controlled route through which contractor-approved scope, onboarded agency fulfilment, fixed-term PAYE employment through ICCE Controlled Employment, worker-level evidence, payroll processing and reporting can be connected.

That route does not remove the contractor’s need for legal, tax, employment-status, procurement, ESG, insurance, audit or operational review.

Any deployment of ICCE in relation to a contractor project, package, region, trade category or agency supply line would remain subject to further discussion, legal review, tax review, operational review, agency participation review, system readiness, appropriate documentation and controlled launch planning.

The boundary is part of the value. ICCE does not create assurance by widening the chain. It creates assurance by narrowing the governed route for selected activity.

For selected activity, the contractor can require a cleaner operating position: approved scope, authorised agency fulfilment, ICCE Controlled Employment, worker-level evidence, payroll-route clarity and structured reporting.

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Appendix: Source Basis

This document is supported by external public sources and supplementary research materials.

The sources below provide the factual basis for the market context, labour-chain risk environment, worker-route concerns, public procurement relevance and social value opportunity discussed in this pack.

1. Market Scale and Temporary Labour Context

Source Relevance to this document
REC - Recruitment Industry Status Report 2024/25 Supports the position that temporary and contract labour is a major UK operating environment, not a marginal procurement category. REC reports that the recruitment industry contributed £40.6bn to the UK economy in 2025, representing 1.6% of UK GVA, with temporary and contract placements accounting for 76.7% of sector GVA and around 872,000 temporary or contract workers on assignment on any given day in 2024.

2. Construction Temporary Labour Route Risk

Source Relevance to this document
CLCRH-001 - UK Construction Temporary Labour Chain Risk Heatmap Provides the route-risk research basis for distinguishing between Contractor Direct PAYE, Agency Direct PAYE, controlled non-umbrella PAYE employment, genuine CIS works packages, labour-only CIS, umbrella PAYE, purported umbrella or payroll-company CIS, mini umbrella / disguised remuneration, PSC labour-only work, offshore payroll chains and deep secondary agency chains.
CLCRH-001 - Contractor Direct PAYE analysis Supports the position that Contractor Direct PAYE gives the strongest legal and evidential control because the contractor owns the employment relationship, payroll route, worker onboarding and evidence trail. It also confirms that the main downside of Contractor Direct PAYE is operational burden rather than route ambiguity.
CLCRH-001 - Agency Direct PAYE analysis Supports the position that Agency Direct PAYE is the cleanest existing external labour route where the agency directly engages and pays workers through PAYE, while confirming that the contractor still owns supplier approval, labour-chain assurance, site access, right-to-work oversight, invoice reconciliation and evidence that the route remains Agency PAYE.
CLCRH-001 - Higher-risk route classifications Supports the treatment of labour-only CIS, agency CIS labour-only, umbrella PAYE, purported umbrella / payroll-company CIS, mini umbrella / disguised remuneration, PSC labour-only work, offshore payroll chains and deep secondary agency chains as routes requiring heightened caution or exclusion from clean contractor-controlled temporary labour flows.
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Appendix: Source Basis

3. Agency PAYE, PAYE Reporting and Employment Route Treatment

Source Relevance to this document
HMRC Employment Status Manual - Agency and temporary workers, ESM2039 Supports the explanation that where ITEPA 2003 section 44 applies, the worker is treated as holding employment with the agency for income tax purposes, and the agency must deduct income tax, operate PAYE and remit payment to HMRC via RTI.
HMRC Employment Status Manual - Agency legislation introduction, ESM2030 Supports the wider position that agency worker arrangements sit within defined legislative treatment and cannot be understood simply as informal labour-supply arrangements.
GOV.UK - Running payroll: reporting to HMRC Supports the position that payroll reporting and RTI evidence are formal statutory payroll processes, not merely internal supplier records.
GOV.UK - What payroll information to report to HMRC Supports payroll reporting context, including employee pay, deductions and reporting through FPS / EPS.

4. Umbrella Company Reform and Payroll-Chain Accountability

Source Relevance to this document
HMRC / GOV.UK - Umbrella company market changes to Income Tax rules Supports the position that umbrella-company reform is moving PAYE recovery accountability up the labour supply chain. The source states that legislation will introduce a new Chapter 11 into Part 2 of ITEPA 2003 to make employment agencies or end clients jointly and severally liable for PAYE amounts where an umbrella company forms part of a labour supply chain.
GOV.UK - Government response to umbrella non-compliance consultation Supports the position that umbrella-market non-compliance is treated by government as a material labour-market issue affecting worker outcomes, competition and tax compliance.
GOV.UK - Working through an umbrella company Supports the worker-understanding and pay-route transparency discussion, including the need for workers to understand who employs them, who pays them, what deductions apply and how the umbrella route operates.
GOV.UK - Key Information Document guidance for agency workers paid through umbrella companies Supports the worker-transparency discussion around pay, deductions, holiday entitlement, benefits and the worker’s understanding of the proposed arrangement.
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Appendix: Source Basis

5. CIS, PSC, Mini Umbrella and Other Route-Risk Frameworks

Source Relevance to this document
HMRC / GOV.UK - Construction Industry Scheme guide for contractors and subcontractors, CIS340 Supports the position that CIS is a defined construction tax regime and that contractors must consider status and verification requirements when making payments to subcontractors.
GOV.UK - Understanding off-payroll working / IR35 Supports the position that PSC and off-payroll arrangements can create client-side status assessment responsibilities and should not be treated as a clean default route for ordinary labour-only site work.
GOV.UK - Off-payroll working for clients Supports the position that clients may have responsibilities to determine employment status and take reasonable care where off-payroll working rules apply.
HMRC / GOV.UK - Mini umbrella company fraud Supports the position that artificial payroll-chain fragmentation and disguised remuneration structures are recognised risk patterns in labour supply chains.

6. Social Value, Fair Work and Responsible Procurement

Source Relevance to this document
Cabinet Office / GOV.UK - PPN 002: The Social Value Model Supports the position that fair work, fair wages and good working conditions are recognised public procurement social value themes.
Public Services (Social Value) Act 2012 Supports the wider public procurement context in which economic, social and environmental wellbeing are relevant to public services contracting.
GOV.UK - PPN 003: Public Services (Social Value) Act 2012 Supports the public procurement framing that relevant authorities should consider how what is procured may improve social, environmental and economic wellbeing.
GOV.UK - Modern Slavery Act transparency in supply chains guidance Supports the position that larger organisations are expected to consider supply-chain due diligence, worker protection and meaningful action in relation to labour supply chains.
GOV.UK - PPN 009: Tackling modern slavery in government supply chains Supports the heightened public-sector supply-chain scrutiny context for government-linked procurement.
Local Government Association - Modern slavery in supply chains Supports the construction and built-environment relevance of labour exploitation risk, particularly where temporary labour, agency labour and subcontracting are present.
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Appendix: Source Basis

7. Umbrella Labour, Worker Transparency and ESG

Source Relevance to this document
ULESV-001 - UK Umbrella Labour Ethics, Social Value and ESG Assessment Provides the supplementary research basis for treating umbrella payroll and payroll-route opacity as worker-experience, ethical procurement, social value and ESG issues where work is public, prominent, contractor-linked or social-value-sensitive.
ULESV-001 - Framework basis Supports the position that umbrella payroll concerns map into recognised social value and ESG categories including fair work, fair pay, good working conditions, pay transparency, worker understanding, worker voice, grievance access, ethical procurement, supplier monitoring and labour rights risk.
ULESV-001 - Route scoring and interpretation Supports the position that Contractor Direct PAYE and controlled non-umbrella PAYE employment can produce stronger social value and ESG alignment where they improve worker clarity, accountability and pay transparency.
GRI 414 - Supplier Social Assessment Supports the ESG supplier-social-assessment context, including supplier screening, employment practices, wages, compensation, working hours and negative social impacts in the supply chain.
EcoVadis Ratings and methodology Supports the broader ESG and supplier sustainability context, including labour and human rights, ethics and sustainable procurement themes.
MSCI ESG Controversies methodology Supports the broader ESG controversy context in which labour rights and supply-chain labour standards can affect reputational and investor-facing assessments.

8. ICCE Source Basis

Source Relevance to this document
ICCE Unified Model Specification / UMS-001 Supports ICCE’s core system identity as a unified employment, payroll, participation-control, controlled-disbursement and reporting model.
UMS-101 - Legal and Structural Positioning Specification Supports ICCE’s classification-safe position as infrastructure rather than labour supplier, recruitment business, MSP, umbrella company, lender, insurer, receivables owner or payroll bureau for third-party employers.
UMS-501 - Reporting and Reconciliation Specification Supports the distinction between reporting as a derived representation of controlled system activity and reporting as an independent source of legal, tax or operational authority.
ICCE market-entry and contractor demand materials Support the project-coded deployment model, Labour Requirement Notice concept, governed open agency participation and contractor-led demand pathway.
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Appendix: Source Basis

9. Interpretation and Reliance

The sources above support the factual and research basis of this document. They do not replace contractor-specific legal, tax, employment-status, procurement, ESG, insurance, financial or operational advice.

The external sources establish the market, legislative, procurement and social value context.

The supplementary research materials support the construction-specific route-risk and worker-outcome analysis.

The ICCE source materials support the classification, system-boundary and operating-model position of ICCE.

ICCE controls only activity brought within ICCE scope. Activity outside ICCE remains outside ICCE unless and until it is separately adopted.

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Legal Notice and Intellectual Property