FWA-ready: the 12-point compliance health check for recruitment agencies

Last reviewed: 23 July 2026 · Reading time: 4 minutes

Use this as a 30-minute self-audit. Score each item yes, partly, or no. Anything that isn't a clean yes is your action list — and if more than four items score "no", make FWA-readiness a board agenda item this month.

1. Named owner. One named person owns employment-rights compliance, and it is recorded — not assumed.
2. Terms with work-seekers. Your terms of engagement for permanent candidates and temps are current, issued before services begin, and match how you actually operate.
3. Key information documents. Every temp receives a compliant KID before terms are agreed, including accurate pay illustrations through any umbrella.
4. Advertising accuracy. Every live advert reflects a genuine, current vacancy with accurate terms — no evergreen adverts for expired roles.
5. Fees and transparency. All fees and charges to clients are disclosed before work begins; no fees are charged to work-seekers for work-finding services.
6. Payroll chain due diligence. You can name every umbrella and intermediary in your chain, you hold current due-diligence evidence on each, and you would be comfortable showing it to an inspector tomorrow.
7. SSP and rates. Your temp charge rates reflect the April 2026 SSP changes, and your payroll (or provider) is applying day-one SSP correctly.
8. Day-one rights. Contracts and onboarding reflect day-one paternity and unpaid parental leave entitlements.
9. Harassment duty. You have assessed harassment risk for workers you place — including third-party risk at client sites — and your client terms allocate responsibility for it. From 30 October 2026 the duty to take "all reasonable steps", including against third-party harassment, is in force.
10. Documentation discipline. Client briefs, candidate consents, CV submission permissions and the recruitment process are documented end to end and retrievable within a day.
11. January 2027 plan. You know which of your own staff pass six months' service before 1 January 2027, your probation and review documentation is fit for the new regime, and you can brief clients on theirs. The ERA timeline for recruiters has every date.
12. Horizon watch. Someone reads the guaranteed-hours consultation outcome when it lands — the consultation closes 25 August 2026, and if you run a temp desk, 2027 planning starts there.