First annual public stakeholder consultation

Consultation (2026)

A public consultation giving stakeholders the opportunity to review, challenge and help shape ICCE while there is still time for external input to improve the system, reporting, commercial approach and launch plans.

Participants may also receive a controlled early preview of ICCE. This gives relevant organisations and specialists the chance to experience the system before general release and respond to what they see, not just what they read.

Opens

24 August 2026

Closes

16 October 2026

Format

Discussion + written input

Why consultation, why now

A chance to shape a system for a market that matters.

Consultation (2026) is ICCE’s first annual public stakeholder consultation. It brings expert knowledge, commercial reality and worker experience into development before launch, while external challenge can still improve the system, reporting, adoption plans and stakeholder experience.

ICCE is being developed as controlled infrastructure for UK temporary labour. It brings together ICCE-controlled PAYE employment, work activity, integrated payroll, the Payment Trust Centre and evidence-based reporting in one operating environment. ICCE does not find or supervise work, replace the commercial role of agencies or contractors, or act as a funder or insurer.

This is not an exercise in seeking product endorsement. Participants do not need to understand the whole market or every part of ICCE. Buyers, agencies, workers, advisers, funders, insurers, regulators, researchers and other specialists can focus on the questions closest to their own experience.

Collaborative-Open Enterprise

Annual consultation is part of how Episodic intends to operate.

Episodic has classified itself as a Collaborative-Open Enterprise: open by default, protected where necessary and commercial by design. Annual public consultation is part of that commitment. It creates a visible way to challenge our work while protecting legitimate intellectual property, privacy, security and commercial interests.

Read the public COE standard →
Collaborative-Open Enterprise
Who we want to hear from

We want to hear from more than potential customers.

Successful adoption depends on more than interest in the product. We want views from the people and organisations that buy, operate, finance, insure, scrutinise, regulate, research and advise across the areas ICCE may affect.

Type Stakeholders

Academics & researchers

Independent challenge and views on evidence quality, employment, procurement and policy.

Agencies & labour providers

Practical views on adoption, worker relationships, commercial fit and day-to-day processes.

Auditors & assurance professionals

Views on control evidence, tracking responsibility, monitoring, reconciliation and audit.

Buyers & contracting authorities

Views on procurement, commercial needs, contract management and public accountability.

Contractors & delivery organisations

Views on project delivery, workforce governance, supply-chain visibility and implementation.

Framework operators

Views on framework design, supplier participation, call-off, reporting and assurance.

Funders & finance partners

Views on financial checks, transaction visibility, operating risk and participation requirements.

Insurers, brokers & risk advisers

Views on evidence quality, controls, risk transfer and assurance.

Investors & strategic capital

Views on market size, competitive strength, adoption, the commercial model and delivery risk.

Legal, tax & employment professionals

Challenge and guidance on classification, contracts, employment, tax and regulation.

Regulators & public bodies

Views on policy, enforcement, the public interest and how the market is governed.

Technology & delivery partners

Views on integration, data, implementation and controlled service delivery.

Current topics of concern

Forty live questions for specialist discussion.

These questions reflect the policy, procurement, employment, payroll, funding, payment and insurance issues covered in the Consultation (2026) Briefing Pack. They guide the discussion; they are not a legal checklist. Participants should focus on the questions closest to their knowledge and practical experience.

Questions 01–10 Procurement, social value and enforcement
01

Temporary labour within the Good Jobs agenda

When should temporary workers form part of Good Jobs and contract-workforce assessment?

02

Framework and call-off social value

Where should social-value commitments and evidence sit across framework and call-off?

03

Compliance versus added social value

What should count as added social value beyond ordinary legal compliance?

04

Worker-level evidence behind KPIs

What transaction evidence is enough to support labour-related social-value KPIs?

05

Fair pay beyond the statutory minimum

How should fair pay be defined and evidenced for temporary workers?

06

Open frameworks and wider supplier participation

How can frameworks widen agency participation without weakening labour-chain control?

07

Supplier payment versus worker payroll

How should buyers distinguish supplier-payment performance from worker-payroll performance?

08

The Fair Work Agency

What records should parties be able to produce quickly in a more coordinated enforcement environment?

09

State enforcement of holiday pay

Are current records sufficient to evidence entitlement, calculation, payment and correction?

10

Modernising agency-work regulation

What responsibilities and information should sit with the agency, hirer, employer, umbrella or other intermediary?

Questions 11–20 Employment status, umbrellas and alternative routes
11

Guaranteed hours and predictable shift information

How can genuine flexibility coexist with protection against one-sided uncertainty?

12

Employment-rights status versus tax status

How should status be explained so tax treatment is not mistaken for employment-rights status?

13

PAYE, limb (b) and deemed employment

What should people be told when employment-style tax treatment does not create the same rights position?

14

Longer claims and evidence horizons

Are labour records complete and durable enough for longer enforcement and dispute periods?

15

PAYE accountability higher in the labour chain

What checks and ongoing evidence are reasonable now that parties higher in the chain can carry PAYE risk from umbrella use?

16

Umbrella regulation beyond tax

What standards of conduct, transparency and worker protection should apply when umbrella regulation takes effect?

17

Worker understanding of the payroll route

Can workers identify employer, payer, rate basis, deductions, rights and challenge route?

18

CIS is not an employment-status determination

How should labour chains distinguish genuine subcontracting from labour-only work needing another route?

19

PSC and IR35 deemed employment

How should status decisions, deductions, worker information and challenge processes connect?

20

Direct engagement and PEO-style descriptions

Does the legal and operational substance match the route description when responsibility is tested?

Questions 21–30 Funding, capacity, payment and disputes
21

Working-capital availability

What evidence would improve access to working-capital funding for responsible labour growth?

22

Infrastructure workforce demand

Can finance, insurance and payroll capacity scale with the infrastructure pipeline?

23

Rapid mobilisation after award

How should funders assess fast payroll growth after framework or contract award?

24

Reliance on a small number of buyers

How should heavy reliance on major buyers affect funding and insurance decisions?

25

Credit-limit reduction events

How should future labour activity respond when insured or funded credit support is reduced?

26

Use of funding and remaining capacity

Would earlier visibility of active labour demand and financial exposure improve funding decisions?

27

Actual payment time versus terms

Where is the real payment delay, and who bears the cost?

28

Invoice disputes as a working-capital problem

Which disputes can be prevented by better engagement, time, rate and approval evidence?

29

When disputes are raised

How early should genuine disputes be raised before they affect funding and collection?

30

Making labour invoices easier to finance

What minimum evidence makes a temporary-labour invoice clear enough to finance?

Questions 31–40 Insurance, claims and commercial advantage
31

Credit limits as a live trading constraint

Should customer credit limits influence workforce mobilisation earlier?

32

Funding and insurance together

How should funders, insurers and agencies share relevant risk information while preserving separate roles?

33

Claims-ready evidence

Can normal labour activity produce insurer-ready evidence without post-failure reconstruction?

34

Claims timing and interim liquidity

How is payroll continuity maintained while non-payment and claims are being resolved?

35

Collections and recoveries

Who manages collections, how are recoveries attributed, and what evidence is required?

36

Evidence and funding confidence

Which data actually changes a funder's confidence, funding limit, advance rate or review speed?

37

Controls and insurance confidence

Which controls and evidence could meaningfully improve an insurer's understanding or willingness to provide cover?

38

Reducing commercial friction

Where does poor transaction evidence create avoidable cost across funding, insurance, audit and disputes?

39

Financial readiness as supplier capability

Should workforce financial readiness form part of supplier capability or tender assessment?

40

Growth without proportional risk

What controls allow agencies to scale workers, projects and customers without risk rising at the same rate?

The briefing pack explains the context, limits and source references behind these questions.

ICCE-specific consultation topics

What we are building, and what should still be challenged.

The wider questions look at changes across temporary labour. These six topics focus on ICCE itself: its role, how different parties take part, the controls built into the system, its approach to evidence, the proposed framework route and priorities before launch.

ICCE topic 01 Purpose and market role

ICCE is being developed as controlled infrastructure that connects PAYE employment, work activity, payroll, payment evidence and reporting. It does not replace the existing commercial or professional roles in temporary labour.

Primary consultation question

Is controlled infrastructure the right role for ICCE, and does it strike the right balance between worker, compliance and commercial goals?

ICCE topic 02 Participation and visibility across the labour chain

Temporary labour involves several parties. ICCE is intended to let authorised parties add, confirm and receive the information relevant to their role through the same controlled process.

Primary consultation question

Who should add, confirm and see each type of information? Where could shared visibility create privacy, authority or confidentiality concerns?

ICCE topic 03 System controls and boundaries

ICCE is designed to put important activity through defined checks and controlled routes, rather than relying only on declarations, informal coordination or corrections made later.

Primary consultation question

Which activities should the system restrict, which exceptions need human review, and where could strict controls create unnecessary friction?

ICCE topic 04 Transaction evidence, reporting and accountability

ICCE aims to create evidence as activity happens, so reports can draw directly from controlled work, payroll and payment records instead of being rebuilt later.

Primary consultation question

What must be recorded for each engagement, what should be combined into summary reporting, and what do buyers, workers, funders, insurers and auditors each need?

ICCE topic 05 Supply-chain frameworks and project reporting

ICCE is exploring a flexible, contractor-led route in which authorised agencies can take part in a project-coded environment. Evidence could then be linked to the relevant project or supply chain.

Primary consultation question

Would contractors and framework operators use this route? What should they be able to see, and where should the line sit between shared oversight and agency confidentiality?

ICCE topic 06 Current development and pre-launch priorities

The core model and planned system design are defined. Product development, partner discussions, external testing and preparations for adoption are continuing.

Primary consultation question

What capabilities, partner relationships, reporting, evidence and testing must be in place before a credible pilot or wider launch?

The framework approach is a flexible, proposed contractor-led option. It is not a requirement of the current ICCE model.

Early ICCE preview

Understand and experience ICCE ahead of general release.

Where appropriate and technically possible, consultation participants may receive a controlled, guided preview of ICCE before release. This lets stakeholders see how the idea works as a real system, understand the user and evidence experience first hand, and give more practical feedback.

Preview access within the consultation

Respond to the system you can see, not only the proposition you can read.

Understand

Receive a guided explanation of the relevant ICCE features, stakeholder roles and the parts of the system that can be shown publicly.

Experience

Where suitable, see current screens, demonstration environments and pre-release features relevant to your consultation topics.

Challenge

Use that first-hand experience to identify difficult processes, missing evidence, unclear behaviour, integration needs or opportunities to improve the system.

Preview access is controlled and may vary by participant and development stage. It does not provide access to the live system or unrestricted access to protected ICCE materials.

How the consultation works

A simple route from registering interest to a focused discussion.

We will use your registration and an introductory discussion to make sure the main session includes the right people, focuses on where your organisation can add the most value, and is supported by useful introductory material.

  1. 01

    Complete the consultation form

    Tell us who you are, why the consultation is relevant to you, and the areas where you or your organisation are best placed to contribute.

  2. 02

    Short introductory call and ICCE preview

    We will explain the relevant parts of ICCE, understand your perspective and, where appropriate, provide a guided pre-release preview. This means your feedback can be based on first-hand understanding.

  3. 03

    Define the right attendees

    Together we will identify the relevant people within your organisation or professional network whose experience is most useful for the topics being considered.

  4. 04

    Schedule the consultation meeting

    The consultation can then be held in person or by video call, focused on the agreed areas for input, challenge and feedback.

Useful contributions

You do not need to endorse ICCE to contribute.

The consultation is intended to test ICCE, not to seek support for a position already decided. The most useful contribution may identify a flaw, a missing stakeholder, an integration barrier, a weak assumption, an unclear KPI, a procurement restriction, a commercial objection or a reason ICCE would not be adopted in practice. Positive interest is useful, but critical evidence matters just as much.

Contributions can be practical or specialist. Buyers, framework operators and contractors may be best placed to comment on procurement, governance, reporting and implementation. Agencies may identify process, adoption and commercial realities. Legal, tax, employment and academic contributors may challenge assumptions or highlight areas needing stronger evidence. Funders, insurers, auditors and investors may help define the evidence, controls and checks they would need before relying on or participating in the system.

We are particularly interested in specific examples: information that is currently hard to obtain, decisions that are difficult to prove, reporting that arrives too late, KPIs that would meaningfully improve oversight, likely integration points, practical barriers to taking part, and the minimum conditions needed for a credible pilot or commercial launch. If you support an objective but think there is a better way to achieve it, we want to understand that alternative.

Feedback can also focus on the consultation material itself. We want to know what needs a clearer explanation, what evidence should support particular claims, which parts of ICCE need expert review before wider release, and where stakeholder expectations differ from our current assumptions. This includes terms, controls, reporting measures or commercial positions that may be technically sound but difficult to understand or use in practice.

A contribution does not need to produce a formal document or commercial commitment. It may lead to a short written observation, an expert review, suggested evidence requirements, KPI or reporting ideas, implementation or integration needs, a second discussion, or simply a clear statement that part of ICCE does not yet work. Where genuine interest exists, the conversation may later develop into an expression of interest, letter of intent, formal review or pilot discussion. None of these outcomes is required for a contribution to be useful.

Stakeholder briefing materials

Consultation (2026) Briefing Pack

The briefing pack explains the purpose of the consultation and brings together the forty Current Topics of Concern and six ICCE-specific topics in one concise document.

Open Consultation Pack