Labour Market Enforcement Strategy 2025 to 2026 Published

The recently published Labour Market Enforcement Strategy outlines 4 main themes: improving the radar picture, improving focus on effectiveness, better joined-up thinking, and better engagement and support with business and workers.

The strategy makes 8 recommendations to be taken forward by the director’s office, the Department for Business and Trade, Home Office and by the 3 labour market enforcement bodies:

• Gangmasters and Labour Abuse Authority (GLAA)
• Employment Agency Standards Inspectorate (EAS)
• HMRC National Minimum Wage and National Living Wage team (HMRC NMW)

Recommendation 1: resources
I recommend government ensures that the FWA has resources commensurate with its task and the Make Work Pay ambition – both on the front line and as regards strong core functions to support its work.
This should include:
(a) a substantial communications budget to enable the development of a strong, recognisable brand and ongoing proactive external communications.
(b) a team with strong analytical functions to understand labour market trends and risks, with responsibility for horizon scanning to monitor labour market developments and identify emerging threats to employment rights and enforcement.
(c) a research budget to fll gaps in evidence to inform priorities. This should build on the outputs and learnings from the research project, ‘the scale and nature of labour
market non-compliance’.
Timeframe for delivery: April 2026
Lead: DBT
Supporting: Home Office

Recommendation 2: transparent governance
I recommend the Framework Agreement required between DBT and the FWA is in line with best practice.
This should include:
(a) ensuring the Framework Agreement between DBT and the FWA includes sufficient focus on transparency.
(b) identifying metrics that assess impact and creating a baseline for reporting to the FWA Advisory Board.
(c) developing a system of regular performance reporting on efficiency and cost-effectiveness through quarterly reports to the FWA Advisory Board.
(d) promoting transparency of the FWA by developing a clear mechanism, such as a dashboard, that internal and external stakeholders can access.
Timeframe for delivery: By April 2026
Lead: DBT
Supporting: EAS, GLAA, HMRC NMW and ODLME

Recommendation 3: building on experience
I recommend DBT lead a project to identify the learnings from the enforcement bodies as well as my office in terms of what works and doesn’t work on the following priority areas.
1. Communications – an effective communications strategy will be key to ensuring the FWA achieves its objectives, setting out how the FWA will engage with workers, modern slavery victims and survivors, employers, stakeholders (such as NGOs, trade unions, academics) and partners (such as the Advisory, Conciliation and Arbitration Service (Acas), police, NCA, local authorities). To inform this I recommend:
(a) Mapping the stakeholders for the 3 enforcement bodies and the ODLME.
(b) Identify learnings from the four organisations on what engagement works (including method, timing, format) and what doesn’t work, to inform next steps for the FWA.
2. Gathering, processing and coordination of intelligence
(c) Mapping the intelligence stakeholders (including responsibilities) and processes for the 3 enforcement bodies and the ODLME.
(d) Identify learnings on what works and doesn’t work for the 3 enforcement bodies and ODLME and their relationships with their law enforcement partners to inform the
development of the FWA.
3. Enforcement mechanisms/investigation methods – the 3 enforcement bodies employ different methods to enforce and investigate exploitation. I recommend:
(e) Mapping the enforcement mechanisms/investigation methods for each of the 3 enforcement bodies
(f) Identifying learnings on what works and doesn’t work.
(g) Looking specifcally at engagement with hard-to-reach groups and different cultures, including training for staff.
Timeframe: The FWA strategy, due April 2026, to indicate how this recommendation was
actioned.
Lead: DBT
Supporting: EAS, GLAA, HMRC NMW and ODLME

Recommendation 4: emerging threats
I recommend the ODLME prepares a report for the LME Board17 on methods, additional data sources, research outputs and forecasting techniques the enforcement
bodies/FWA might embrace to better identify and monitor emerging risks to the labour market.
Timeframe for delivery: December 2025
Lead: ODLME

Recommendation 5: payslips
I recommend ODLME collates evidence on the provision of payslips and presents a paper to the LME Board making recommendations on what further measures
might strengthen compliance with the Employment Rights Act 1996 in relation to the provision of payslips.
Timeframe for delivery: March 2026
Lead: ODLME

Recommendation 6: achieving compliance and providing support through others
I recommend DBT considers how the FWA can make best use of other agencies, community groups, NGOs and industry led initiatives to both support and encourage
compliance.
Timeframe for delivery: The FWA strategy, due April 2026, to indicate how this recommendation was actioned.
Lead: DBT

Recommendation 7: hand car washes
ODLME supports the planned regional pilot into the compliance of hand car washes, and I recommend the evaluation of the pilot is combined with an evaluation of the
activities undertaken by HMRC NMW and other stakeholders. This joint evaluation should be used by the FWA to determine what solutions are required to mitigate the
risks in the sector.
Timeframe for delivery: Evaluation by April 2026
Lead: GLAA (with other stakeholders)
Joint evaluation lead: DLME/ Strategic Coordination Group (SCG)26

Recommendation 8: construction
I recommend that in advance of the government’s proposed housebuilding programme, law enforcement stakeholders produce an engagement, coordination
and action plan with central government, local authorities and industry, expanding on current initiatives to mitigate the risks of exploitation.
Timeframe for delivery: Review engagement plan by October 2025 with a report to
LME Board
Lead: Enforcement bodies, coordinated through the ODLME Strategic Coordination
Group (SCG)

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