Our research in SLTE-002 identified a clear convergence across temporary labour governance. Employment treatment, tax treatment, worker protection, responsible procurement and social value are increasingly dependent on the same underlying facts being visible, attributable and capable of evidence. Together, these requirements are creating a tighter operating net around the market, with aligned compliance depending less on isolated supplier assurance and more on a coherent understanding of how labour is engaged, treated, paid and evidenced across the chain.

For upper-chain parties (buyers, framework operators and major contractors), achieving that level of control is exceptionally difficult. Their direct commercial relationships often extend only to mid-chain parties (subcontractors & MSPs), while lower-chain organisations (agencies and payroll companies) involved in engagement, payroll or payment can sit beyond immediate visibility and can change over time. Establishing which parties are participating, under what terms, through which employment and tax treatment, and with what supporting evidence requires continuous governance across organisations that the upper chain may not directly control. The conventional response is either to increase audit, assurance and administrative reconciliation across the chain, or to reduce the supplier population until it becomes easier to manage. Both approaches carry a commercial cost through higher governance overhead, reduced competition, lower labour availability and less delivery flexibility.

More recently, the publication of PPN 026 as the successor to PPN 002 has reinforced that direction and the ICCE theology. Its increased emphasis on good jobs, fair working conditions, fair pay and measurable contract performance brings worker outcomes more firmly into responsible procurement and social value, further aligning procurement policy with the wider regulatory movement toward stronger labour-chain visibility, evidence and accountability.

The diagram below brings conventional mapping and assurance together. Selecting a party reveals its connected downstream chain: mapped parties can receive the assurance request, while unmapped parties interrupt it at the same point. It demonstrates the direct consequence of an incomplete chain map: upper-chain responsibility remains, but governance cannot reliably extend across every participating organisation.

Our original August 2025 research identified a single structural weakness at the centre of temporary labour: the market lacked a sufficiently current, attributable and authoritative account of the individual worker transaction on which multiple parties could safely rely. Employment terms, working activity, payroll treatment, deductions, payment, funding, project attribution and supporting evidence are routinely held across different organisations and systems, leaving the market with many records but no dependable shared transactional position. In a large, economically important and worker-relevant market, that level of fragmentation creates avoidable uncertainty around rights, obligations, commercial exposure and accountability.

The same fragmentation weakens the way governance requirements move through the chain. Conventional controls are typically passed downstream through contracts, policies, supplier instructions and assurance requests, with each organisation responsible for forwarding, interpreting and enforcing them at the next tier. As the chain deepens or changes, requirements can be diluted, partially communicated, reinterpreted or fail to reach the parties performing the underlying activity at all. Upper-chain organisations can therefore retain responsibility for standards and outcomes they cannot directly enforce, while lower-chain participants may operate without a complete or consistent understanding of the requirements against which their activity will later be assessed.

The consequences are systemic. Different parties can form different views of the same engagement; employment and tax treatments diverge from the underlying activity; worker pay and deductions become difficult to trace; funders lack timely visibility of the activity supporting their exposure; and upper-chain parties inherit legal, procurement, financial or reputational consequences without direct access to the facts that created them. The same discontinuity that weakens downstream governance also makes evidence harder to move back upstream in a complete and attributable form. Where the underlying transaction is assembled retrospectively by lower-chain parties, treatment and outcome are largely fixed before the wider chain can see or test them. Control therefore occurs after exposure has been created, while obtaining and reconciling the necessary data becomes administratively difficult, commercially costly, or both. Meaning even where mapped chain entities are visible, the data within may not be reliable.

Regulatory and policy development through 2026, with further changes applying from 2027, has materially strengthened this dynamic. Employment-status and worker-protection reform, umbrella PAYE accountability, CIS fraud measures, Fair Work Agency enforcement, public-sector tax assurance, responsible procurement and the revised Social Value Model increasingly connect workforce treatment, tax exposure, recovery mechanisms and contract performance to the same underlying labour activity. The operating net around temporary labour is becoming tighter and more aligned, making reliable transactional data more important to compliance, fair treatment, assurance and commercial decision-making than at any earlier point in the project’s development.

The diagram below shows how conventional chain structures obstruct that visibility and separate upper-chain responsibility from the transaction data required to discharge it.

As supply chains increasingly need to be governed at the level of the individual transaction. That requires the wider organisational chain to be understood as a collection of distinct supply lines, with each line identifying the parties involved, the route through which the worker is engaged and paid, the governance conditions applying to that activity, and the specific project, lot, call-off, site or works package to which the resulting transaction belongs.

Once mapped at that level, the chain needs a mechanism for capturing the activity generated within each supply line in a form that is separable, attributable and capable of aggregation. Worker, engagement, payroll, payment, treatment and compliance evidence can then remain linked to its source transaction while also being combined into wider project, supplier, framework and contract-level metrics.

This marks a material shift in supply-chain governance. Traditional models primarily send obligations downstream through contracts, policies, supplier mandates, declarations and periodic assurance. Modern governance increasingly requires evidence to travel in the opposite direction: lower-chain activity must produce attributable, measurable and quantifiable data that can be passed upstream and assessed against regulatory, responsible-procurement, social-value and commercial requirements.