How Much Do You Really Know About Your Recruitment Supply Chain?

Your agency has paid the umbrella company. The worker has received their wages. But how confidently could you explain everything that happened in between?

For recruitment agency leaders, that gap in visibility can carry significant consequences. A supplier relationship may appear to be working smoothly while leaving important questions unanswered about deductions, tax payments and how workers are treated.

At Recruitment Agency Expo London 2026, Chris Bryce, Chief Executive of FCSA, challenged delegates to examine how well they understood the organisations supporting their business.

Speaking on the Discovery Stage on 17 March, his session, Navigating What Comes Next: Practical Risk-Mitigation for the Changing Contingent Labour Market, explored how agencies can protect their businesses, workers and clients through stronger checks and greater transparency.

Bryce described a “360-degree circle of trust”: a network in which agencies, umbrella companies, intermediaries and end clients support confidence through evidence and collaboration.

His central message was straightforward. Knowing who your suppliers are is only the beginning. Understanding how they operate requires continuing attention.

Looking beyond a supplier’s reassurance

An established relationship can make a supplier feel like a safe choice. Familiar contacts, responsive service and a completed questionnaire can all provide reassurance.

Bryce encouraged agencies to look more closely at what supports that confidence.

A supplier saying it is compliant is different from providing independently assessed evidence. Equally, collecting documents at the start of a relationship does not establish what happens throughout it.

He highlighted independent accreditation as an important part of supplier assessment, explaining FCSA’s use of external professional firms to assess its members.

The wider lesson for agency leaders is to understand what has been checked, what evidence is available and how that information remains current.

Why the PAYE changes make visibility more important

Speaking ahead of the April 2026 changes, Bryce highlighted joint and several liability as a significant development for agencies using umbrella companies.

Those rules now apply to payments made on or after 6 April 2026. Broadly, the agency with the contract to supply workers to the end client is jointly and severally liable alongside the umbrella company for relevant PAYE amounts. Where there is no agency involved, responsibility can fall to the end client.

That makes the operation of an umbrella company’s payroll a direct concern for the relevant agency.

Bryce’s practical point was that a reassuring relationship does not remove financial exposure. Agencies need to understand the arrangements they are using and the evidence available to support them.

Due diligence helps agencies assess and manage risk; it should not be mistaken for a guarantee that liability cannot arise.

Following the worker’s pay

One of Bryce’s most useful distinctions was between checking a payslip and understanding the wider payroll journey.

A payslip can show whether the figures presented at a particular moment add up. It does not, by itself, explain the full history of a payment, subsequent corrections or whether the relevant amounts reached HMRC.

Bryce encouraged agencies to seek greater visibility of payment structures, including deductions, expenses and holiday pay.

He also discussed FCSA’s Diligence Hub and VeriPay as tools intended to support the exchange of due diligence information and payroll verification.

The broader question extends beyond any particular platform: can the agency explain what happens between paying its supplier and the worker receiving their money, and what evidence supports that explanation?

Understanding the whole chain

Bryce’s circle of trust extended beyond umbrella companies.

He urged agencies to consider the other organisations involved in their arrangements, including managed service providers, neutral vendors, end clients and finance providers.

Each relationship contributes to how the supply chain operates. Understanding those connections helps agencies identify where responsibilities sit, where information is missing and which questions need to be asked.

Bryce also challenged the assumption that a shorter preferred supplier list automatically means lower risk.

Working with fewer suppliers may make detailed assessment easier, but it can also concentrate exposure. His point was to consider the balance between oversight and dependence, rather than treating the number of suppliers as a measure of safety.

Keeping workers at the centre

Supply-chain compliance is also about the experience of the people being placed.

Bryce highlighted the importance of correct contracts, understandable payment arrangements and proper routes for workers to raise concerns.

For agencies, those issues are closely connected to service quality. Confusion over deductions or holiday pay can undermine a worker’s confidence, even when another organisation handles their employment and payroll.

Asking how workers are treated therefore belongs alongside questions about supplier processes and financial controls.

It also helps agencies judge whether the standards promised during onboarding are reflected in day-to-day practice.

Making compliance part of everyday operations

Bryce recognised the competing demands on recruitment businesses. Winning clients, filling vacancies and onboarding candidates can make compliance reviews feel like something to return to later.

His advice was to build the checks into normal operations.

That includes reviewing supplier evidence, keeping due diligence processes current, checking contracts and documenting relevant employment-status assessments.

Clear ownership matters too. Information has limited value if nobody is responsible for reviewing it, identifying concerns and following up.

The aim is a process that continues after a supplier has been approved, with a practical way to recognise and respond when something changes.

Turning confidence into a commercial advantage

Bryce also saw an opportunity for agencies that can demonstrate strong standards.

Clients want confidence in the businesses supplying their workers. An agency that can explain its checks, show supporting evidence and answer difficult questions has something useful to bring to that conversation.

He argued that investing in compliance can strengthen trust and support opportunities with end clients, managed service providers and neutral vendors.

That gives agency leaders a reason to look beyond the administrative workload. Greater supply-chain visibility can help protect the business while making its service easier for clients to trust.

Starting with better questions

Bryce closed with practical actions: audit existing partners, examine due diligence processes, ask for transparency around payment arrangements and review contracts.

For agency leaders, a useful starting point is to identify where confidence rests on evidence and where it rests mainly on assumption.

Who has checked the supplier? What was assessed? How are workers paid? What happens when something goes wrong? And who in the agency is responsible for finding out?

A circle of trust becomes stronger when every organisation within it can answer those questions.

Key takeaways

• Support supplier confidence with evidence and independent assessment.
• Understand how the umbrella-company PAYE rules affect your agency’s position in the chain.
• Look beyond a single payslip to the wider payroll journey.
• Consider both supplier oversight and the risks of concentrating exposure.
• Include worker treatment, contracts and payment transparency in supplier reviews.
• Make compliance an ongoing process with clear responsibility.
• Use demonstrable standards to strengthen client confidence.