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RM6376 and RM6238: Education Recruitment Margin Caps Have Arrived. Your Profits Don’t Have To Shrink

RM6376 and RM6238: Education Recruitment Margin Caps Have Arrived. Your Profits Don’t Have To Shrink

RM6376 & RM6238 Margin Caps Are Here. So Where Do Education Recruiters Find Their Profit?

If you’ve recently secured a place on RM6376 or RM6238, congratulations.

It’s a significant achievement and one that doesn’t come easily.

Financial stability, safeguarding, governance, compliance, operational capability and pricing transparency all come under scrutiny. Securing a place on either framework demonstrates that your business can operate at the standard schools, Multi Academy Trusts and public sector organisations expect.

However, for many education recruitment businesses, winning a place on the framework is only the beginning.

The conversation we’re having most often at the moment isn’t about compliance.

It’s about profitability.

The Work Hasn’t Reduced. The Margin Has.

Most agency owners understand why margin caps have been introduced across RM6376 and RM6238.

Schools are under pressure.

Budgets are tighter than ever.

Procurement teams are being asked to demonstrate value and control costs wherever possible.

The challenge is that whilst the frameworks may cap what agencies can charge, they don’t reduce the cost of running a compliant recruitment business.

  • You still need to attract candidates.
  • You still need to manage safeguarding.
  • You still need to support schools.
  • You still need to pay workers accurately and on time.
  • You still need to stay compliant.

The work hasn’t reduced.

The margin has.

It’s no surprise that many agency owners are now asking the same question:

How do we protect profitability without increasing risk?

Is Bringing Payroll In-House The Answer?

One of the first options many businesses consider is bringing payroll in-house.

On the surface, it makes sense.

If margins are being squeezed under RM6376 and RM6238, surely removing third-party costs is the answer?

Sometimes it is.

Often it isn’t.

What many businesses quickly realise is that payroll isn’t just payroll anymore.

When workers are employed directly by the agency, the responsibilities that come with employment sit with the agency too.

That means considering:

  • Payroll governance
  • HMRC reporting obligations
  • Employment rights
  • Compliance monitoring
  • Operational administration
  • Joint & Several Liability considerations for your end clients

With employment legislation continuing to evolve, particularly around day one worker rights, many agencies are understandably cautious about taking on additional responsibility unless the commercial benefit is clear.

For some businesses, bringing payroll in-house works well.

For others, it creates more cost, complexity and risk than expected.

The Conversation Has Changed

Historically, many recruitment businesses selected a payroll model years ago and simply stuck with it.

There was often little reason to review it.

Margins were healthy.

The process worked.

Everyone moved on.

The introduction of RM6376 and RM6238 margin caps is now encouraging agency owners to revisit decisions that may not have been reviewed for years.

Questions such as:

  • Is our current payroll model still the most efficient?
  • Are there alternative worker engagement models available?
  • Could we improve profitability without disrupting operations?
  • Are we carrying unnecessary employment risk?
  • Are we getting the best commercial outcome from our workforce model?

These are exactly the conversations we’re having every day.

There Isn’t A One-Size-Fits-All Solution

At New Red Planet, we’ve worked alongside education recruitment businesses operating on CCS frameworks for more than a decade.

Today, more than 30 suppliers across RM6376 and RM6238 utilise our services.

One thing we’ve learnt during that time is that no two agencies are the same.

That’s why we don’t believe every business should be pushed towards a single payroll solution.

  • Some businesses are best suited to an Umbrella model.
  • Others benefit from PEO PAYE.
  • Some prefer a PAYE Bureau solution.
  • Many operate a combination of different engagement models.

The right answer depends on your objectives, your workforce, and how your business operates.

What often surprises agency owners is how much difference a relatively small change can make.

In many cases, improving profitability isn’t about making wholesale changes to the business.

It’s about reviewing a process that may not have been challenged for years and identifying opportunities that have previously been overlooked.

The Agencies That Thrive Will Be The Agencies That Adapt

The agencies that continue to succeed under RM6376 and RM6238 won’t necessarily be those charging the highest margins.

  • They’ll be the businesses that understand their costs.
  • The businesses that operate efficiently.
  • The businesses that have visibility.
  • And the businesses that are prepared to adapt when market conditions change.

The frameworks have undoubtedly changed the landscape.

But they haven’t removed opportunities.

They’ve simply encouraged agencies to look at areas of their business that may not have needed attention before.

Let’s Have A Conversation

If you’re reviewing how workers are engaged, how payroll is delivered or whether there are opportunities to improve efficiency and profitability within your existing model, we’d be happy to share what we’re seeing across the education recruitment market.

After supporting CCS framework suppliers for many years, we understand the challenges agencies face and the practical solutions many are implementing to adapt successfully.

Your margin may be capped.

Your options aren’t.

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6 April has passed – JSL liability is now real

6 April has passed – JSL liability is now real

6 April has passed – JSL liability is now real

If your payroll partner can’t prove compliance, the risk sits with you

April 6th has now come and gone.

We are officially in the new world of Joint and Several Liability (JSL).

This means one thing very clearly – if an umbrella company in your supply chain cannot prove they are operating correctly and paying the correct PAYE and NIC to HMRC, the liability does not stop with them… it moves up to you!

This is no longer theoretical. It is live.

What you should now be demanding from your payroll partners

Every recruitment business should now have a clear compliance checklist. At a minimum, you should be able to evidence:

  • FCSA Accreditation
  • SafeRec Accreditation
  • Full access to all current and historic payslips for your workers
  • Back-end visibility of PAYE submissions to HMRC (RTI data)
  • Back-end visibility of actual PAYE payments made to HMRC

If you cannot see it, you cannot prove it.

And if you cannot prove it, under JSL, you may be liable for it.

The old model is gone

Gone are the days of choosing an umbrella because:

  • They offer the biggest rebate
  • They take you to the best events
  • They fund nights out or perks for the team

Those things are no longer a deciding factor.

Compliance is now the deciding factor.

Because the cost of getting it wrong is no longer commercial – it is financial liability.

What does that liability actually look like?

Let’s keep it simple.

  • 50 workers
  • £400 per week
  • Over just 12 weeks

That’s £240,000 in gross pay moving through the supply chain.

If PAYE and NIC have not been correctly accounted for, the potential exposure can easily exceed £70,000+ in just that short period.

Now scale that across multiple clients, projects, or months.

This is how JSL risk builds – quickly and quietly.

Early warning signs are already here

We are only days into this new landscape, and we are already seeing umbrella companies entering administration.

That is exactly where the risk begins to surface.

Where New Red Planet fits in

At New Red Planet Limited, everything we do is built around transparency, compliance, and visibility.

Yes, we still enjoy spending time with our partners – whether that’s football, racing, rugby or the odd day out.

But that is a byproduct of strong, compliant relationships – not a substitute for them.

If you would like to understand how we provide:

  • Full payroll transparency
  • Real-time visibility of HMRC submissions and payments
  • A compliant, future-proof payroll structure under JSL

then let’s have a conversation.

Because in this new world, what you can’t see can hurt you.

steve.mcdermott@newredplanet.com

07854 881 220 or 0161 713 1730

Find out more

New Red Planet: providing a flexible choice of FCSA Accredited payroll offerings specially tailored for the Construction Sector.

Get In Touch

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Are Your Self-Employed CIS Workers Exposing Your Business?

Are Your Self-Employed CIS Workers Exposing Your Business?

Are Your Self-Employed CIS Workers Exposing Your Business?

Many construction and civil engineering firms use CIS labour every day. When structured correctly, it works well. However, problems arise when the reality on site does not match the status on paper.

If your business supplies tools, provides vehicles, allocates work, and controls how it is carried out, the engagement may look more like employment than genuine self-employment. As a result, HMRC or an employment tribunal could later reclassify the arrangement as disguised employment.

In practice, this can create serious financial and legal exposure for the business and, in certain circumstances, for directors personally.

Why this matters now

Many business owners only discover the risk when an issue lands on their desk. Typically, that issue appears in one of two ways.

First, a worker challenges their status and claims they were effectively employed.
Second, HMRC reviews the engagement model and questions whether workers were paid correctly under CIS rules.

Both scenarios disrupt operations. Both carry financial consequences. Importantly, both are avoidable when the correct structure and documented audit trail are in place.

The Key Areas of Exposure

1) Employment status and tribunal claims

If a CIS worker is deemed to have operated as an employee, they may pursue:

  • Unpaid holiday pay

  • Statutory rights and entitlements

  • Retrospective employment status claims

Even where a business successfully defends a claim, the time, cost, and management distraction can be significant.

2) HMRC challenges and backdated liabilities

If HMRC concludes that a worker was incorrectly classified under CIS, they can pursue:

  • Backdated PAYE and National Insurance

  • Interest on unpaid sums

  • Financial penalties

  • Broader review of your labour supply model

Consequently, what may appear to be a minor classification issue can escalate into a substantial financial exposure.

    3) Potential loss of gross payment status

    For construction businesses operating under CIS, gross payment status supports both cash flow and credibility within the supply chain. However, incorrect CIS application increases the likelihood of HMRC review. In serious cases, this can result in suspension or loss of gross payment status.

    The “Quick Test” Question

    If your CIS model were challenged tomorrow, would you be able to demonstrate:

    • Why each worker is treated as self-employed

    • What the worker agreed and understood

    • That the engagement structure is consistent

    • That payroll deductions and CIS submissions are handled correctly

    If the answer is uncertain, now is the time to review it.

    Is it time to move CIS labour to an external specialist?

    Increasingly, construction firms are choosing to move their CIS workforce to an external payroll specialist. The aim is not to remove responsibility, but to reduce exposure and introduce documented structure.

    An external model can provide:

    • Independent onboarding

    • Recorded CIS status verification

    • Clear and consistent audit trails

    • Accurate CIS processing and HMRC submissions

    • One consolidated weekly invoice

    • 24/7, 365 support instead of relying solely on internal cover

    In addition, outsourcing reduces reliance on a single internal payroll administrator and improves continuity across holidays, sickness, or staff turnover.

      How New Red Planet supports CIS labour correctly

      New Red Planet works with hundreds of businesses and thousands of workers across the UK. For CIS workforces, we provide:

      • Worker onboarding through our secure portal

      • Recorded and logged CIS status questionnaires

      • Direct worker briefings via Teams or on site

      • CIS verification and compliance checks

      • Fully managed payroll and HMRC submissions

      • Insurance cover included within the margin, including Public Liability Insurance, Professional Indemnity Insurance, and Employers’ Liability Insurance

      As a result, businesses gain a more defensible, structured model that supports genuine self-employment while significantly reducing employment status and HMRC risk.

      What the process looks like

      1. You decide to review or proceed.
      2. You provide a worker list.
      3. We engage workers directly and explain the changes.
      4. We onboard workers onto our portal.
      5. We verify CIS status and complete recorded questionnaires.
      6. You receive one weekly invoice.
      7. We manage payroll, deductions, payments, and HMRC submissions.

      Book a confidential review

      If you would like a confidential discussion to assess your current CIS employment status risk, we can walk through:

      • Where exposure typically sits

      • What documentation you currently hold

      • What a structured transition would look like

      There is no obligation and no pressure.

      Contact Steve McDermott if you would you like to know a little more about the risk and benfit of outsourcing you contractor payroll, and have No-obligation chat:

      steve.mcdermott@newredplanet.com

      07854 881 220 or 0161 713 1730

      Find out more

      New Red Planet: providing a flexible choice of FCSA Accredited payroll offerings specially tailored for the Construction Sector.

      The shake-up has started, and agencies must get their supply chain in order before April.

      The shake-up has started, and agencies must get their supply chain in order before April.

      The post will take around three to four minutes to read. It is important, and will help you understand what is coming and what you may need to prepare for.

      I wanted to give you a straight, honest overview of what is happening across the umbrella and payroll world ahead of the Autumn Budget. There are meaningful changes on the the way that will affect how recruitment businesses manage their supply chains, their payroll models, and their responsibilities to workers. My ain here is simple. I want you to have the facts, the likely timelines and the areas that will need early attention before anything becomes law.

      The shake-up has started, and agencies must get their supply chain in order before April.

      Recently, an umbrella company collapsed owing more than £2 million after advancing money to recruitment clients on extended credit terms. When those clients did not repay the funds, the umbrella could not meet its liabilities. The result was contractors left unpaid and agencies exposed.
      (Source: Freelance Informer)
       

      This is not a one off. It reflects the wider pressure in the market and why the Government is now moving quickly. The direction is clear. The market is being pushed towards financial stability, real transparency, and full compliance. 

      What is happening on 26 November
      The Autumn Budget is expected to set out the next stage of changes to umbrella legislation and the Employment Rights Bill. This will likely be the clearest picture yet of how the new compliance framework will work and how responsibility will be shared, monitored, and enforced.
       

      A first for the industry
      For the first time ever, REC, APSCo, FCSA and HMRC have sat at the same table to help shape this legislation. Together, they are focused on three things:

      • stopping the hundreds of millions lost each year through non-compliant payroll models
      • improving protection for everyday workers
      • removing non-compliant payroll and recruitment businesses from the market permanently

      This level of collaboration has never happened before. It signals a real shift in how the sector will operate in the future. 

      Timescales to implementation
      Current expectations are:

      • The big announcements will be made on 26 November.
      • More detail will follow in the months after.
      • The transition period will run throughout 2025.
      • Full enforcement is expected from April 2026.

      This gives everyone roughly 12 to 16 months to prepare properly. (Would probably leave this information out. If someone gets done, could quote it OR might slow down decision making) 

      What this means for recruitment businesses
      One of the biggest areas under consideration is joint and several liability. Agencies OR end clients will be held responsible for PAYE failures or non-compliance carried out by any umbrella in their supply chain.

      There is also strong expectation that the Employment Rights Bill will introduce day one rights for many workers. This will not only affect umbrella users, it will also impact agencies running their own PAYE. Processes, documentation, internal capacity, and onboarding workflows may all need to change. 

      Changing market behaviour
      Depending on their setup, agencies will respond differently:

      • Many will continue using umbrella providers
      • Some will change how they work with them
      • Some will bring payroll in-house
      • Many will outsource their in-house payroll for extra support and protection

      If you are thinking about changing your payroll structure, especially bringing PAYE in-house, or outsourcing it, the planning needs to start before the Employment Rights Bill takes effect in April. 

      What we will be doing
      Over the next couple of weeks, we will keep a close eye on everything released by Government, HMRC, industry bodies and legal advisers. As soon as confirmed information is available, we will share it in a clear, easy to understand way so you can prepare with confidence.

      In the final days before the Budget, we will also share a five-day countdown. Each message will focus on one key part of the reforms and what agencies should be thinking about ahead of the announcement. 

      New Red Planet holds dual FCSA accreditation for umbrella and PAYE. This means we already work to the standards that will be expected once the new framework is in place. If at any point you want clarity on what the changes could mean for your setup, or you simply want to talk through the likely impact, you are always welcome to reach out. I am here to help where needed.

      Contact Steve McDermott if you would you like to know a little more about the risk and benefit of outsourcing you contractor payroll, and have No-obligation chat:

      steve.mcdermott@newredplanet.com or 07854 881 220 or 0161 713 1730

      Find out more

      New Red Planet: providing a flexible choice of FCSA Accredited payroll offerings specially tailored for the Construction Sector.

      Get In Touch

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      Tackling tax non-compliance — the Brabners article every recruiter should read.

      Tackling tax non-compliance — the Brabners article every recruiter should read.

      Law Specialists Issue Warning Regarding Non-Compliant Umbrella Companies.

      A recent feature in The Recruiter by law specialists Brabners has underlined the growing risks facing recruitment agencies that use non-compliant umbrella companies. As the sector evolves these risks are becoming harder to ignore.

      HMRC estimates that more than £500 million in tax was lost in 2022/23 through umbrella non-compliance. As a result the Government will introduce new joint and several liability rules from April 2026.

      These will allow HMRC to pursue agencies and end clients for unpaid PAYE if any umbrella within their supply chain fails to meet its responsibilities.

      The Autumn Budget is now just 15 days away. By the afternoon of 26 November, we will know the final details of the Umbrella Legislation and the Employee Rights Bill.

      Recruitment agencies should be using this time to review their supply chains and ensure every partner they work with meets the highest compliance standards. 

      At New Red Planet (NRP), we already have those safeguards in place. As one of the UK’s leading FCSA-accredited umbrella organisations, we help recruiters streamline, protect and future proof their businesses through a comprehensive range of compliant workforce solutions.

      Solutions:

      👉 Umbrella PSL
      👉 Bureau (in-house PAYE setup)
      👉 Outsourced payroll bureau (for recruiters who want internal control with external support)
      👉 CIS and Limited Company solutions
      👉 Back Office Support
      👉 PSL and ASL advice and setup
      👉 HR and tax advice
      👉 Full accountancy support

      This means NRP are in the very envious position of being able to manage as much or as little as you wish in the build-up to, during, and after the legislation is passed and becomes a new reality for everyone on 6 April 2026.

      In short our model provides the flexibility agencies need as the industry moves into a stricter compliance era.

      Our integrated approach provides transparency, efficiency and peace of mind at every stage of the labour supply chain. As a result, it protects agencies and end clients well ahead of the 2026 reforms.

      To discuss how NRP can strengthen and future proof your payroll and compliance setup, contact our team today for a no-obligation chat.

      Contact Steve McDermott if you would you like to know a little more about the risk and benefit of outsourcing you contractor payroll, and have No-obligation chat:

      steve.mcdermott@newredplanet.com or 07854 881 220 or 0161 713 1730

      Find out more

      New Red Planet: providing a flexible choice of FCSA Accredited payroll offerings specially tailored for the Construction Sector.

      Get In Touch

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