Does a limited company contractor need a key information document?

Yes. Regulation 13A applies to work-seekers that are companies whether or not they have opted out of the Conduct Regulations under regulation 32. The opt-out removes other protections, not this one. The KID goes to the company as the work-seeker and shows the rate, pay intervals, deductions and fees between agency and company, holiday and an example.

Can an umbrella company issue the key information document instead?

No. GOV.UK guidance says the employment business must provide it and cannot defer it to a third party such as an umbrella company. You can rely on written information the umbrella gives you about itself, and if the worker asks for that information you must give them a copy within five business days.

How long can a key information document be?

Regulation 13A and GOV.UK guidance require it to be clear, succinct and no more than two sides of A4, with the title Key Information Document at the top of the first page. Where an accessible format makes that impossible, a summary can be given with a reference to where fuller details can be found.

Do we need a new key information document for each assignment?

Not automatically. A revised KID is needed when the facts in it change, such as a new deduction, a change in pay intervals or a new paying party, and a new one if the umbrella or intermediary changes. A change in assignment pay alone may not need one, though keeping it up to date is best practice.

What happens if an agency does not give a key information document?

It breaches regulation 13A of the Conduct Regulations, which is enforced by the Fair Work Agency in England, Scotland and Wales from 7 April 2026. GOV.UK guidance for employment businesses says the inspectorate can close businesses and ban directors. No penalty amount for this rule was confirmed, so none is stated.

Answers

What is a Key Information Document and when must an agency give one?

A key information document is a separate document, no more than two sides of A4, that an employment business must give a work-seeker before they agree terms. It states whether they are employed or self-employed, who pays them and how often, the rate, every deduction and fee, holiday entitlement and a worked example from gross to net pay. Regulation 13A of the Conduct Regulations has required it since 6 April 2020, and it applies to limited company contractors even after an opt-out.

Written by the Vayora team. Updated 28 October 2026.

Regulation 13A of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 was inserted from 6 April 2020. Its purpose is simple. Before someone agrees to work through an employment business, they should be able to see in one place what they will be paid, who pays them, and what will come off the money between the client's rate and their bank account.

The duty belongs to the employment business. GOV.UK guidance for businesses says you cannot hand it to a third party such as an umbrella company. If you use an umbrella, you gather the figures from it and put them in your document. If someone shows you a figure that proves wrong, the regulation lets you rely on written information from the person it relates to, but only if you have it in writing.

A KID is not the contract. It comes first and is meant to be read before terms are agreed, and it is not a full statement of the terms that follow. That makes accuracy the whole point: a KID that says one thing while the payslip says another is the problem the rule was written to prevent. The sections below cover who gets one, what goes in it for each route, when to issue a new one and what changed in 2026.

Who must be given a key information document, and when?

Every work-seeker an employment business signs up. Regulation 13A requires it to give the work-seeker a KID before obtaining their agreement to terms under regulation 14, which is before it first provides work-finding services. In practice it is one of the first things you send. The regulation also applies to work-seekers that are companies, whether or not an opt-out is in place under regulation 32, so a limited company contractor must have one even after opting out.

Where the person to be supplied is not the work-seeker, for example a worker supplied through an umbrella company or another intermediary, the KID goes to the work-seeker and to that person, and it follows a different content list. The duty to provide revised documents after agreement only applies where the employment business first provided work-finding services on or after 6 April 2020.

What must the document contain?

It must be separate from other documents, headed Key Information Document at the top of the first page, with a statement beneath the title saying what it covers, where to find related information and the contact details of the officers appointed under section 90 of the Employment Rights Act 2025, whom the work-seeker may contact about breaches. GOV.UK guidance says it should be no more than two sides of A4 and written clearly.

For a direct work-seeker, regulation 13A(3) lists the content: whether they are under a contract of service or apprenticeship or a contract for services; the identity of the employment business; who normally pays them if different; the rate or the minimum rate you reasonably expect to achieve; the pay intervals; the nature of costs and deductions required by law; other costs and deductions with the amount or method of calculation; any fees for services or goods with the amount or method; non-monetary benefits; and holiday entitlement and holiday pay.

It must end with a representative example statement, item by item, for a single prospective pay period: gross pay, legal deductions, other deductions, fees, and net pay. Amounts can be reasonable estimates. Our existing glossary entry on the Conduct Regulations sets this in the wider rules.

What does it show for PAYE, umbrella and limited company routes?

The content changes with how the person is paid. The table compares the three routes. Typical deductions are a guide to what the document lists, not a calculation, and amounts depend on the individual.

Engagement route	What the KID must show	Typical deductions listed
PAYE, paid directly by the agency	Contract of service or for services, the rate or minimum rate, pay intervals, deductions and fees, holiday and benefits, and the example	Income Tax, employee National Insurance, pension and any fees for services
Umbrella company	The umbrella's identity, any connection between parties, the assignment rate the agency pays the umbrella, the worker's rate, deductions from each, and the example for the worker	Employer National Insurance, employer pension, Apprenticeship Levy, holiday pay and umbrella margin, then tax, employee National Insurance and pension
Limited company (PSC) controlled by the worker	The company is the work-seeker, so the content list for a direct work-seeker applies: rate, pay intervals, deductions and fees between agency and company, holiday, and the example	Often none at this stage; deductions inside the company are paid by it and are not shown to the extent it pays them

What does a worked example look like?

GOV.UK publishes an umbrella example worth copying in style. A £750 weekly assignment rate is paid to the umbrella. From it come employer National Insurance of £65.61, employer pension of £15.76, Apprenticeship Levy of £3.23 and holiday pay of £69.51, then a £20 umbrella margin. That leaves £575.89 gross pay. After Income Tax of £75.48, employee National Insurance of £55.37 and an employee pension contribution of £26.27, take-home pay is £418.77 a week. These figures are printed as HMRC and GOV.UK give them; yours will differ.

For a limited company the example is shorter. A contractor on £550 a day working five days has gross remuneration of £2,750 for the week. If the agency makes no deduction and charges no fee, net remuneration to the company is £2,750 before VAT, and that is what the statement says. This illustration is arithmetic, not an official example, so state the VAT position as it applies to the company.

When do you need to issue a new key information document?

Three situations. First, if the contents change before terms are agreed, a revised KID must be given, and a finalised one before agreement. Second, if details change after agreement, a revised KID must be given by the end of the fifth business day after the change, stating when the revisions take effect. Third, the 2019 guidance says a new KID must be issued if the intermediary or umbrella company engaging the worker changes.

Not every change qualifies. The guidance says a new KID is not needed every time a worker starts a new assignment, and that a change in assignment pay alone may not need one, although keeping it accurate is best practice. A new deduction, a change in pay intervals or a change of paying party does need one. The 2019 guidance also says a worker who signed with the same employment business before 6 April 2020 did not need a KID, but a worker who signs with a new employment business does.

Before terms are agreed: revised KID if anything changes, finalised KID before agreement.
After terms are agreed: revised KID by the end of the fifth business day after a change.
New umbrella or intermediary: a new KID.
New assignment on the same terms: no new KID needed.

What changed in 2026?

On 7 April 2026 the Fair Work Agency took over from the Employment Agency Standards Inspectorate, and regulation 13A was amended from that date so the statement beneath the title carries contact details for officers appointed under section 90 of the Employment Rights Act 2025. Update any template that still names the old inspectorate.

From 6 April 2026 there are new PAYE rules for labour supply chains that include umbrella companies, which GOV.UK describes on its umbrella guidance pages. Nothing in regulation 13A or the GOV.UK guidance changes the contents of the KID because of those rules, but they make the umbrella figures in your KID matter more, because the agency is now closer to the umbrella's compliance. GOV.UK also says the government plans to bring umbrella companies within the legal definition of an employment business; That has not been confirmed as in force. Our answer on PSC versus umbrella covers the routes.

What should you keep to prove you gave one?

Employment businesses already have to show compliance with the Conduct Regulations by keeping records, and the 2019 guidance says that includes evidence the finalised and any revised KID reached the worker. A saved email showing what you sent and when is enough; nobody has to sign. Keep it for at least 12 months after you last provided work-finding services, and keep any messages with an umbrella or intermediary about their deductions and margins, because you must be able to show the details are as correct and up to date as possible.

Where Vayora fits

Vayora is software, not legal advice, and it does not generate a key information document. There is no KID template, no check that one was sent before terms were agreed, and no prompt for a revised one. That stays in your process, and the page above is the checklist.

What Vayora does hold is the data you draw a KID from. A contractor's record states how they are engaged (limited company, umbrella, sole trader or PAYE inside IR35), their company name and number, VAT registration and Conduct Regulations status, and the placement holds the pay rate, bill rate or fee percentage. Documents you create elsewhere, such as the KID and your saved email, can be filed on the contractor's record next to the signed opt-out and self-billing agreement. See contract finance, the Conduct Regulations answer, or start a free trial.

Common questions

Does a limited company contractor need a key information document?: Yes. Regulation 13A applies to work-seekers that are companies whether or not they have opted out of the Conduct Regulations under regulation 32. The opt-out removes other protections, not this one. The KID goes to the company as the work-seeker and shows the rate, pay intervals, deductions and fees between agency and company, holiday and an example.
Can an umbrella company issue the key information document instead?: No. GOV.UK guidance says the employment business must provide it and cannot defer it to a third party such as an umbrella company. You can rely on written information the umbrella gives you about itself, and if the worker asks for that information you must give them a copy within five business days.
How long can a key information document be?: Regulation 13A and GOV.UK guidance require it to be clear, succinct and no more than two sides of A4, with the title Key Information Document at the top of the first page. Where an accessible format makes that impossible, a summary can be given with a reference to where fuller details can be found.
Do we need a new key information document for each assignment?: Not automatically. A revised KID is needed when the facts in it change, such as a new deduction, a change in pay intervals or a new paying party, and a new one if the umbrella or intermediary changes. A change in assignment pay alone may not need one, though keeping it up to date is best practice.
What happens if an agency does not give a key information document?: It breaches regulation 13A of the Conduct Regulations, which is enforced by the Fair Work Agency in England, Scotland and Wales from 7 April 2026. GOV.UK guidance for employment businesses says the inspectorate can close businesses and ban directors. No penalty amount for this rule was confirmed, so none is stated.

Sources

Checked 28 October 2026

Terms

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