Confidential · Mace Group · WFA-PROP-2026-0509
Prepared 09 May 2026 · v1.0

Supply chain
due diligence,
re-engineered.

A structured response to the legislative shift now bearing on Tier 1 contractors — the Criminal Finances Act 2017, the Economic Crime & Corporate Transparency Act 2023, the Employment Rights Act 2025, the Finance Act 2026, and HMRC's evolving supply-chain due diligence guidance.

Operating since
2018
Pre-CFA accreditation regime
Tier 1 mandates
09+
Active programme partners
Live regimes
5
Converging on labour supply
Stage 1 fee
£0
Risk Assessment · 3 weeks
§ 0Executive Summary

The position, plainly.

Five pieces of legislation now converge on Mace's labour supply chain. Three have already commenced. One commences mid-cycle. The standard is no longer "did you know" — it is "should you have known."


The exposure

The Criminal Finances Act 2017 (CFA) has applied since September 2017 — yet most Tier 1 contractors still cannot evidence the "reasonable prevention procedures" defence in respect of their indirect labour. The Economic Crime & Corporate Transparency Act 2023 (ECCTA) extended the same logic to fraud on 1 September 2025, with senior-manager attribution under the new identification doctrine. The Fair Work Agency, established under the Employment Rights Act 2025, became operational on 7 April 2026, consolidating EAS, GLAA and (from April 2027) HMRC NMW enforcement into a single body. The Finance Act 2026 introduced joint and several liability for PAYE umbrella shortfalls, effective 6 April 2026 — first impacted payday 17 April 2026. HMRC's supply-chain due diligence guidance, long-standing but rarely tested at scale, has materially hardened.

Every one of these regimes turns on the same evidential question: what did Mace, as the principal, know — or what should it have known — about the people, structures and money flows in its labour chain.

Our proposal

A three-stage engagement:

  1. Risk Assessment — a structured exposure map across the five legislative pillars, delivered free of charge within three weeks of kick-off.
  2. Procurement Process Review — independent examination of Mace's onboarding, due-diligence, and ongoing assurance procedures against the "should have known" standard. Scope-driven, costed separately following Stage 1.
  3. Engagement options — including the new Workforce Assured Desktop Assessment, full WFA accreditation pathway, or a bespoke advisory mandate. Selected at Mace's election.
The outcome

An evidenced, defensible position — capable of withstanding scrutiny by HMRC, the Fair Work Agency, or a Crown Prosecutor — across the agency, umbrella, and PSC populations engaged on Mace projects. Demonstrable "reasonable prevention procedures" under both CFA s.45–46 and ECCTA s.199. A documented baseline against which improvements can be measured.

§ 0.1Independent Standing

Why Workforce Assured.

An independent, construction-specialist assurance regime, operated since 2018, currently embedded in the supply-chain governance of nine Tier 1 UK contractors.

Operating since
2018
Pre-CFA accreditation regime
Tier 1 mandates
09+
Active programme partners
Sector specialism
UK C&CE
Construction & civil engineering
Position
Independent
No agency or sub-contractor interest

§ 0.1.1Programme partners — UK construction sector

Workforce Assured is currently embedded in the supply-chain governance, accreditation, or due-diligence programmes of:

Balfour Beatty
GRAHAM
P.J. Carey
John Sisk & Son
Skanska
Kier
Lendlease
Multiplex
Sizewell C

§ 0.1.2What "independent" means here

Workforce Assured is owned and operated by Nutral Solutions Ltd, a construction-specialist neutral vendor managed service provider. Workforce Assured itself supplies no labour, holds no agency interest, and earns no margin from worker placement. This is a deliberate structural choice. It allows the assurance regime to function as a credible third-party determination — distinct from a self-attestation by an agency or in-house procurement function, and capable of supporting the reasonable-prevention-procedures defence in a way self-assessment cannot.

§ 0.1.3What Workforce Assured does not do

Workforce Assured does not advise on, draft, or sign off the underlying tax positions of the suppliers it assesses; that remains the supplier's own responsibility. Workforce Assured does not indemnify Mace against tax or employment liability — its role is to evidence the diligence on which any defence to those liabilities will turn. The boundary is deliberate, and the engagement should be understood with that boundary in clear sight.

§ 1Risk Assessment

Five regimes, one principle.

Each statute below imposes a distinct corporate liability on Mace as principal. Each shares the same evidential threshold: actual or constructive knowledge of irregularity in the supply chain.

Exposure map · five legislative pillars
Critical High
§ 1.1 CFA 2017 · Facilitation of tax evasion
Critical
Live · 30 Sep 2017
§ 1.2 ECCTA 2023 · Failure to prevent fraud
Critical
Live · 01 Sep 2025
§ 1.3 ERA 2025 · Fair Work Agency
High
Live · 07 Apr 2026
§ 1.4 FA 2026 · PAYE umbrella JSL
Critical
Live · 06 Apr 2026
§ 1.5 HMRC SCDDG · Supply chain due diligence
High
Continuing
The principal need not have known of the specific wrongdoing. It is sufficient that, on the facts available to it, a reasonable corporate body in its position should have known — and failed to take the steps that knowledge would have required. Synthesis · Kittel-line authorities · CFA 2017 explanatory notes · ECCTA 2023 s.199(4) defence · HMRC Supply Chain Due Diligence Guidance
§ 1.1

Criminal Finances Act 2017 — facilitation of tax evasion

CFA 2017 ss. 45–46 · Strict-liability corporate offences · Defence: reasonable prevention procedures

A Tier 1 contractor commits the UK facilitation offence (s. 45) where any associated person — including agencies, umbrellas, payroll providers, and labour-only sub-contractors — criminally facilitates tax evasion in connection with the contractor's business. The foreign equivalent (s. 46) follows the same logic across border. Liability is corporate and strict, mitigated only by demonstrable reasonable prevention procedures aligned to HMRC's six guiding principles.

Mace exposure: mini-umbrella fraud, disguised remuneration schemes, false self-employment under CIS, undeclared cash payments, and abusive intermediary chains all sit squarely within this offence — irrespective of whether Mace contracted with the offending entity directly.

Critical
Live since30 Sep 2017
§ 1.2

Economic Crime & Corporate Transparency Act 2023 — failure to prevent fraud

ECCTA 2023 s. 199 (failure to prevent) · s. 196 (senior-manager identification) · Live for large organisations from 1 Sep 2025

ECCTA imports CFA-style strict liability into the wider fraud landscape. A large organisation commits an offence where an associated person commits a specified fraud offence intending to benefit (directly or indirectly) the organisation. The defence — again — is reasonable prevention procedures.

Compounding the position, s. 196 broadens corporate criminal attribution: the acts and intentions of senior managers (not only the directing mind) are now the company's own. A regional procurement director acting fraudulently — or recklessly — binds the corporate.

Mace exposure: false invoicing through tiered agencies, inflated headcount or hours claims, fraudulent CIS deductions retained at intermediary level, and ghost-worker scams all engage s. 199 where Mace stands to benefit.

Critical
Live since01 Sep 2025
§ 1.3

Employment Rights Act 2025 — Fair Work Agency

ERA 2025 · Fair Work Agency operational from 07 Apr 2026 · Consolidates EAS, GLAA and (from Apr 2027) HMRC NMW enforcement

The Fair Work Agency is now the single state enforcement body for agency worker rules, modern slavery indicators in labour markets, holiday pay, and (from April 2027) the National Minimum Wage. It inherits the GLAA's licensing reach into construction labour suppliers and the EAS's investigatory powers, and applies a unified case-management approach across all three.

Mace exposure: a single FWA inspection now triggers cross-checks against agency licensing, AWR rights, NMW compression in CIS rates, and modern slavery red flags simultaneously. Findings are shared inter-agency by design.

High
Live since07 Apr 2026
§ 1.4

Finance Act 2026 — Joint & Several Liability for PAYE umbrella

FA 2026 · Chapter 11 ITEPA 2003 · Effective 06 Apr 2026 · First impacted payday 17 Apr 2026

Where workers are supplied through a PAYE umbrella in the chain, joint and several liability for unpaid PAYE and NIC now sits with the agency or end-client (or, in the absence of an agency, the end-client directly). The provisions are CIS-exempt — but every PAYE umbrella worker on a Mace project is now a direct fiscal-recovery vector.

Mace exposure: any PAYE umbrella default — mini-umbrella, phoenixed entity, or mere insolvency — converts to a Mace liability if no compliant agency stands between Mace and the umbrella.

Critical
Live since06 Apr 2026
§ 1.5

HMRC Supply Chain Due Diligence Guidance

HMRC manual SPCONNECT 50000 et seq. · MSC legislation s. 61B–D ITEPA 2003 · Off-payroll Chapter 10 ITEPA · Construction Industry Scheme

HMRC's supply-chain due diligence guidance is not legislation — but it is the framework against which Mace's "should have known" position will be tested in any of the regimes above. It expects principal contractors to know who is in their chain, to check their compliance posture, and to act on adverse findings. The Managed Service Company legislation, the Off-payroll rules, and the CIS verification regime each layer additional specific tests.

Mace exposure: the absence of evidenced supplier checks is itself evidence of constructive knowledge. Procurement files that say nothing are louder than ones that say something difficult.

High
Live sinceContinuing

§ 1.6The "knew or should have known" principle, in operation

Across MTIC VAT (the Kittel line), the MSC legislation, modern slavery enforcement, and now the failure-to-prevent regimes, the same evidential test recurs: would a competent principal, with the information reasonably available to it, have identified the irregularity? The corollary is that a contemporaneous, structured due-diligence record is itself the defence. Workforce Assured exists to produce that record.

Note on terminology

This proposal interprets "EFA 2025" in your brief as the Employment Rights Act 2025, which received Royal Assent in 2025 and established the Fair Work Agency in April 2026. If you intended a different statute, we will revise on notice.

§ 2Procurement Process Review

What we examine, and why.

The risk assessment in § 1 establishes where exposure lies. A procurement review establishes how Mace's existing controls perform against that exposure — and what is missing.


§ 2.1Scope of examination

An eight-domain review covering the full life-cycle of a labour-supplier engagement:

RefDomainEvidence sought
2.1.1Supplier onboarding gatewayPre-qualification questionnaire, ownership and beneficial-owner checks, financial health screening, sanctions and PEP checks, bona-fides of payroll arrangements.
2.1.2Tax status determinationIR35 SDS process and quality, CIS verification, VAT reverse-charge controls, evidence of off-payroll Chapter 10 ITEPA discipline.
2.1.3PAYE umbrella governanceApproved umbrella list, KID issuance evidence, FA 2026 JSL exposure mapping, audit-trail to first impacted payday (17 Apr 2026).
2.1.4Contractual architectureUpper-tier MSA, lower-tier flow-down (PSC, CIS, PAYE umbrella), indemnity and step-in rights, cooperation clauses for HMRC and FWA inquiry.
2.1.5Worker-level data integrityRight-to-work, identity, qualifications and competence records, and the data-protection regime around them (post the Requidex sector-wide lessons of Q1 2026).
2.1.6Time, attendance, payWorking-time records, NMW compliance against the April 2026 threshold, holiday-pay calculation, evidence of timesheet reconciliation against billing.
2.1.7Ongoing assurance cadenceRe-audit frequency, trigger-based review, supplier exit and remediation procedures, board-level reporting cadence.
2.1.8Reasonable prevention proceduresDocumented policy under CFA 2017 ss. 45–46 and ECCTA 2023 s. 199, evidenced training, risk assessment refresh cycle, escalation routes.

§ 2.2Common gaps observed in Tier 1 contractors

Drawn from Workforce Assured engagements across Balfour Beatty, GRAHAM, P.J. Carey, John Sisk & Son, Skanska, Kier, Lendlease, Multiplex, and Sizewell C — patterns recurring with material frequency:

Gap · 01

Onboarding stops at financial & H&S checks

Tax-status interrogation is delegated to the supplier's own attestation. There is no independent verification of payroll model, umbrella relationships, or sub-tier population.

Gap · 02

The chain disappears below Tier 2

Principal contractors typically have visibility of their direct agency, partial visibility of the umbrella, and effectively none of the worker-level reality. The "should have known" test bites here.

Gap · 03

SDS processes are templated, not reasoned

Status determinations are produced at scale with insufficient role-by-role analysis — vulnerable to reasonable-care challenge under Chapter 10 ITEPA.

Gap · 04

Assurance is annual or one-off

A static onboarding pack does not refresh against material change at the supplier — phoenixing, ownership change, payroll-model switch.

Gap · 05

Reasonable-prevention policies exist on paper only

CFA-aligned policies are commonly drafted, but training, risk assessment refresh, and live escalation are absent. This is the single most common defence failure.

Gap · 06

Worker personal data flows are unmapped

Sector-wide breach incidents in Q1 2026 evidenced indemnity exposure under standard MSA clauses where data flows through the chain were never documented.


§ 2.3Output

A written findings report addressed to Mace's Office of Tax, Compliance & Procurement, comprising:

§ 3Engagement Options

How Mace can act on the findings.

Three pathways are offered. They are not mutually exclusive — a typical engagement combines Option A across the supplier population with Option B for a critical-tier subset.


Option B · established pathway

Workforce Assured Full Accreditation

Per-supplier
standard schedule of fees

The established Workforce Assured pathway: on-site audit, document interrogation, worker-interview sampling, and full controls testing. Recommended for the highest-risk Tier 2 suppliers identified through Stage 1 risk assessment, or where prior findings warrant in-person verification.

  • Full audit field-work plus worker interviews;
  • Compliance review across all eight domains in § 2.1;
  • Findings, remediation period, and (where remediated) accreditation award;
  • Two-year cycle with annual surveillance check.
Option C · embedded advisory

Bespoke Advisory Mandate

Day-rate
scope-driven

Direct engagement of Nutral / Workforce Assured personnel into Mace's procurement function for a defined transformation period — typically when the procurement review identifies controls gaps that warrant redesign rather than supplier-side action.

  • Procurement policy and PQQ redesign;
  • Reasonable-prevention-procedures statement drafting and board adoption;
  • Internal training programme for procurement and project teams;
  • Quarterly board-level risk reporting framework.

When to pick A first

  • You need a defensible position across the whole supplier base, fast
  • You don't yet know which suppliers warrant deeper scrutiny
  • You're preparing for a board, audit committee, or HMRC dialogue

When to pick B (alongside A)

  • A supplier has been flagged Conditional or Fail under Option A
  • A supplier carries disproportionate spend or worker volume
  • Prior incident history justifies on-site verification
§ 4Ten-Week Linear Process

From kick-off to remediation roadmap.

A ten-week structured engagement covering Stages 1 and 2 (risk assessment FOC; procurement review costed). Stage 3 mobilisation runs from Week 9 where elected. Step through each week below — or use the arrow keys.

Kick-off
W 01
Within 5 working days of mandate
Risk Assessment delivered
W 03
FOC · Stage 1
Interim findings
W 07
Stage 2 mid-point
Final report
W 09
Recommendations + roadmap
Ten-week engagement · step through
Stage 1 · FOC Stage 2 · costed Stage 3 · option / click
W01 / W10
Stage 1 · FOC
Week 01
Output
Engagement charter

Mandate & kick-off

Mandate confirmation, NDA execution, kick-off workshop with Mace Office of Tax, Compliance & Procurement. Stakeholder mapping and engagement-charter sign-off within five working days.

  • NDA and engagement letter executed
  • Mace SPOC + procurement-operations lead confirmed
  • Stakeholder map across legal, tax, procurement, project delivery

§ 4.1Resourcing & access requirements

Assumptions stated for this proposal

  • Scope confirmed as UK construction labour supply chain only — agency, umbrella, PSC, and CIS populations engaged on Mace UK projects. International supply chain, materials and consultancy supply outside scope.
  • Stage 1 (Risk Assessment) is delivered free of charge. Stage 2 (Procurement Process Review) is costed at scoping following Week 4. Stage 3 commercials are option-dependent.
  • "EFA 2025" interpreted as the Employment Rights Act 2025 (see § 1.6). Subject to revision on instruction.
  • This proposal is addressed at corporate level pending introduction of named Mace stakeholders.
§ 5 · Commercials & Next Steps

The standard has moved.
The defence is contemporaneous evidence.

Stage 1 — the Risk Assessment — is offered free of charge and can be delivered within four weeks of Mace's instruction. It will give the Office of Tax, Compliance & Procurement a defensible baseline before the next reporting cycle, and a clear basis on which to scope Stage 2 and elect Stage 3.

We propose an introductory call within the next ten working days to confirm scope, agree the Mace-side single point of contact, and book the kick-off workshop.

Workforce Assured Operated by Nutral Solutions Ltd
Construction-specialist neutral vendor MSP
Engagement enquiries Office of the Chief Executive
Nutral Solutions Ltd · Leeds
Document control WFA-PROP-2026-0509
Issued 09 May 2026 · v1.0
Confidential — Mace Group
Nutral Solutions Ltd × Workforce Assured
WFA-PROP-2026-0509 · Issued 09 · 05 · 2026
Confidential — Not for redistribution