SSP and Shared Liability: Why Compliance Now Matters More Than Cost

From 6th April 2026, a major change to Statutory Sick Pay (SSP) came into force, extending sick pay rights from day one of employment. Alongside this, strengthened Joint & Several Liability rules fundamentally shifted risk within labour supply chains.

For aviation businesses relying on agency workers, particularly across airport jobs and operational aviation roles, this is a direct, financial and reputational risk that now sits much closer to home. And high-performing HR teams are now placing an emphasis on compliance in their tendering and RFQ processes.

What do the SSP and Joint & Several Liability changes mean?

Under the new SSP legislation, employees will be entitled to Statutory Sick Pay from the first day of absence, removing the three waiting days entirely. The removal of the Lower Earnings Limit means many more workers will qualify, including agency staff who were previously outside the scope. In practical terms, this means higher payroll costs, short absences triggering SSP where they never did before, and increased complexity in workforce planning.

At the same time, Joint & Several Liability is making one thing clear: if tax or National Insurance is unpaid anywhere in your labour supply chain, HMRC can pursue not just the payroll provider or recruitment agency, but potentially the end client as well.

Your starting point when considering your own circumstance should be: who is actually paying our people, and how?

Working with a recruitment agency that prioritises compliance, invests in governance, and has dedicated compliance leadership is now the only way to mitigate the risk that comes with this new legislative change.

Aviation recruitment

In aviation recruitment, thorough compliance has never been optional. Our industry operates under intense scrutiny from both the Civil Aviation Authority and Airport ID Centres. Because of this, our team at Aviation Recruitment Network have always approached payroll with the same rigour and auditable quality as our recruitment and vetting services.

For over 25 years, our clients have been able to reply on our compliant PAYE payroll, SSP handling, and robust due diligence to protect their businesses to potential risk factors. Our commitment to compliance is further reinforced by our company structure, as our payroll team is overseen by our dedicated Head of Compliance; a position which many of other recruitment agencies do not have.

Reputable and compliant aviation staffing agencies, such as Aviation Recruitment Network, should be comfortable with scrutiny, audits and transparency. That should come as standard as part of any responsible partnership.

If you would like to talk through what these changes mean for your workforce or simply sense-check your current agency arrangements, we’re always happy to have an informed, practical conversation.

What to look out for

Many low-cost or low-margin recruitment agencies who offer short-term savings can do so because they do not invest in the expertise needed for compliant aviation recruitment. 

Warning signs to look out for can include ultra-low margins without explanation, overly complex payslips, unfamiliarity with payroll auditing, constant changes in payroll providers and promises to workers of 'higher take-home' pay.

A simple review of contracts, payroll structures and compliance documentation can quickly highlight gaps. Even a short conversation with a compliance-led recruitment agency such as Aviation Recruitment Network can provide clarity and reassurance.

The reality is simple: you can't afford to partner with the lowest cost agency. Instead, successful talent acquisition leaders must prioritise compliance as an equally critical decision-making factor. Tender and RFQ processes should not be about eliminating cost, but about avoiding far larger liabilities later.

SSP FAQs

Does day-one SSP apply to agency workers and temporary staff?
Yes. From 6th April 2026, Statutory Sick Pay is payable from the first day of sickness absence, and the removal of the Lower Earnings Limit means more workers qualify. This includes many temporary, contract and agency workers who were previously excluded, depending on their employment status and payroll arrangement.

Will this increase our costs as a client?
In many cases, yes. SSP costs may be reflected in agency charge rates, particularly where short-term absences previously fell outside SSP eligibility. What matters most is transparency: you should understand how SSP is calculated, applied and funded within your agency’s payroll model.

If we use a recruitment agency, aren’t they responsible for payroll compliance?
A recruitment agency plays a critical role, but responsibility does not stop there. Under Joint & Several Liability rules, if tax or National Insurance is unpaid anywhere in the supply chain, HMRC can pursue multiple parties, including the end client. Assurance alone is no longer enough; visibility and due diligence are essential.

What is Joint & Several Liability in simple terms?
It means that if HMRC cannot recover unpaid tax or National Insurance from the payroll provider or umbrella company, they can seek recovery from other parties in the labour supply chain, potentially including you as the hirer.

How can we tell if a payroll arrangement is non-compliant?
Red flags include promises of higher take-home pay, pay structures involving loans or advances, unclear payslips, frequent changes in payroll providers, or a lack of clarity over who the legal employer is. Low charge rates without clear explanation can also indicate risk. A simple review of contracts, payroll structures and compliance documentation can quickly highlight gaps. Even a short conversation with a compliance-led recruitment agency can provide clarity and reassurance.

What should we be asking our recruitment agencies right now?
You should be asking who employs and pays the worker, whether pay is processed under standard PAYE, and whether compliance evidence can be provided. Responsible agencies will expect these questions and be comfortable answering them.

Looking for recruitment support? Start the conversation today.