Labour Market Enforcement Strategy 2025 to 2026

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 fill gaps in evidence to inform priorities.

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.

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 does not work on communications, gathering and coordination of intelligence, and enforcement mechanisms or investigation methods, including engagement with hard-to-reach groups and different cultures.

I recommend the ODLME prepares a report for the LME Board on methods, additional data sources, research outputs and forecasting techniques the enforcement bodies or FWA might embrace to better identify and monitor emerging risks to the labour market.

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.

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.

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.

I recommend that in advance of the government 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.