The Fair Work Agency: a foundation year, but not a quiet one

The Fair Work Agency has published its first Delivery Plan for 2026/27—and although this is being described as a “foundation year”, there is plenty for employers and labour supply businesses to take note of.

The FWA brings together the Employment Agency Standards Inspectorate, the Gangmasters and Labour Abuse Authority and the Office of the Director of Labour Market Enforcement into one enforcement body.

National Minimum Wage enforcement remains with HMRC under contract during this transitional year, before around 500 NMW colleagues transfer into the FWA in April 2027.

Some of the key priorities for the year ahead include:

🔹 Maintaining existing enforcement activity while developing a more joined-up, intelligence-led approach

🔹 Improving guidance, digital access and the way workers and businesses contact the FWA

🔹 Making greater use of shared data, technology and AI—including open-source data scraping and a unified case-management system

🔹 Developing practical compliance tools, including an online payslip explainer and holiday pay calculator

🔹 Preparing to begin holiday pay enforcement during 2027

🔹 Developing a three-year Enforcement Strategy for 2027–2030

🔹 Using new powers, including Fraud Act powers, to take action against serious non-compliance

The plan also specifically refers to developing a deeper understanding of higher-risk sectors, including construction and social care.

For the umbrella and recruitment supply chain, the overall direction is clear: enforcement is becoming more connected, more data-led and increasingly focused on the complete picture rather than individual issues viewed in isolation.

The FWA has said it wants to make compliance simpler for responsible businesses while taking tougher action against those that exploit workers or undercut legitimate operators.

That is a positive ambition, but businesses should not mistake a “foundation year” for a quiet year.

With National Minimum Wage and holiday pay enforcement coming together from 2027, now is the time to make sure pay calculations, processes, records and supply-chain controls will stand up to much greater scrutiny.

The foundations are being laid, but so is the enforcement infrastructure.