19 March 2026
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Employment: To the Point (March 2026)

To The Point
(5 min read)

This March 2026 edition focuses on compliance issues and what businesses can do to prepare for changes being implemented in April.  Our HR Checklist will take you through the employment law changes in April, we also take a look at IR35 and off-payroll working scrutiny and with the Home Office having access to payroll data, what it means for immigration sponsors and the increased risk of enforcement action. We report on a case in Germany on personal accountability for whistleblowing failures and what it means for international HR and compliance teams and we have our usual round-up of news, our UK and EU horizon scanners, our Employment Rights Act tracker, our EU Pay Transparency Hub and information on forthcoming events.

Spring into compliance

It may be an understatement to say that employment law is facing a time of significant change.  It is also true that the enforcement of rights is about to embark on a new era, with the establishment of the Fair Work Agency (FWA), commencing next month.  Initially the FWA with be responsible for NMW, regulating employment agencies, licensing standards for gangmasters and enforcing tribunal awards.  Its powers will extend to enforcing holiday pay and SSP, with a view to expanding its remit to determine other employment law rights.  The FWA will be asked to audit employers' compliance in respect of some of the most complex areas of employment law. 

The FWA will have extensive powers, including an ability to issue fines and bring claims on behalf of workers.  Bringing the enforcement bodies under one organisation and extending the remit to other areas, appears to mark a shift in approach to compliance. This approach may be far more time consuming and costly than litigation.  Arguably, more worrying for employers, it can be less consistent and transparent, as there is little precedent to follow. 

If you are concerned about your organisation's compliance, now may be the time to act. 

Editorial – by Andrew Moore

Spring into compliance: April 2026 brings new obligations for UK employers

Our April HR Checklist will take you through all the employment law changes being implemented this April and what employers can do to comply.

Find our April HR Checklist here

IR35 and Off-Payroll Working – HMRC scrutiny at pace

With an increase in HMRC enforcement activity focusing on off-payroll working, we look at what this means and what businesses should be doing now.

Read more about it here

UK Business Immigration – Home Office access to payroll data – increased risk of enforcement action for immigration sponsors

With effect from April 2026, the Home Office will have access to payroll data from HMRC.  This will impact immigration sponsors as the Home Office will be able to use the data for compliance checks and to support enforcement action.

Find out what it means for employers here.  

Germany: Local Labour Court confirms personal accountability for whistleblowing failures

A recent whistleblowing case in Germany highlights the personal accountability of senior legal and compliance leaders for effective whistleblowing governance. 

We take a look at what it means for international HR and compliance teams here.  

Upcoming Events:

Our Dublin team are holding their annual Ireland Employment and Immigration Training Day on 22 April 2026 at The Merrion Hotel, Merrion Street Upper, Dublin 2.  The team will be covering all the latest developments in employment law and business immigration with a special focus on the EU Pay Transparency Directive.  Spaces are limited but for more information, please contact Fiona Boland.

Our Warsaw team are running a series of webinars on different aspects of the EU Pay Transparency Directive.  Forthcoming topics include gender pay gap reporting and enforcement measures.  For more information, please contact Warsaw@aglaw.com.

For our Employment and Immigration Training Calendar 2026 listing all our client training events, please visit our website page here.

What else you should know

CMA advocates curbs on non-compete clauses
  • Legislation giving the State Labour Inspectorate the power to reclassify civil law contracts as employment contracts is expected to come into force in June 2026.  Find out more in our article Reclassification of civil law contracts by decision of the State Labour Inspection getting closer: bill passed. 
  • For all the latest information on employment law reforms and implementation of the Employment Rights Act 2025, please visit our Employment Rights Act 2025 Tracker which you can find on our website page here
  • Keep track of the latest developments on the EU Pay Transparency Directive by visiting our Pay Transparency Hub on our website here
  • For all the latest legislative developments, see our latest UK Employment Horizon Scanner and our Employment Horizon Scanner for Ireland, France, Germany, Spain and Poland.  by visiting the resources section of our website page here

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