Conduct Regulations
The Conduct of Employment Agencies and Employment Businesses Regulations 2003 govern how UK recruiters deal with candidates and clients: terms before work, checks before introductions, limits on transfer fees, no withholding of pay. They cover limited company contractors unless opted out.
The Regulations, SI 2003/3319 made under the Employment Agencies Act 1973, distinguish two roles. An employment agency introduces people for permanent employment with the client. An employment business supplies people who work under the client's control, such as contractors. Most contract agencies are both. The 1973 Act also bars charging work-seekers a fee for finding them work, with narrow exceptions.
The core duties are procedural. Terms must be agreed with work-seekers and with clients before services are provided. Since 6 April 2020 an employment business must give a work-seeker a key information document, covering pay, deductions and who pays them, before agreeing terms. Before an introduction or supply, the agency must obtain information from the client about the role and confirm the work-seeker's identity, their experience and qualifications and any authorisation the role requires, and that they are willing to do the work. Regulation 12 bars withholding pay because the client has not paid or has not signed a timesheet. Records of work-seekers and clients must be kept for at least a year after the agency last provided services to them.
Regulation 10 governs transfer fees when a client hires a supplied contractor permanently. A transfer fee is only enforceable within the relevant period, which ends 14 weeks after the first day of supply or 8 weeks after the last day worked, whichever is later, and only if the terms gave the client the option of an extended period of hire instead. A contractor supplied from 3 March and offered a permanent job in week ten is inside that period, but if the terms quoted a fee with no extended-hire option, the agency cannot enforce it.
The Regulations apply to a work-seeker that is a company, with some modifications, unless the company and the individual opt out under regulation 32(9). Enforcement in England, Scotland and Wales passed in April 2026 from the Employment Agency Standards Inspectorate to the new Fair Work Agency; Northern Ireland has its own inspectorate. Breaches can be criminal offences and can lead to a prohibition order.
How Vayora handles it
Vayora shows each contractor's Conduct Regulations status on their record, in scope by default, and can send the regulation 32(9) opt-out notice for signature. Client terms of business are sent and signed electronically, and the signed date is stamped on the client. Vayora does not generate a key information document, check that the regulation 19 confirmations were obtained before a submission, or apply the transfer-fee rules; your terms and your process still carry those.
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