Ministers have signed the Employment Rights Act 2025 (Enforcement) (Consequential Amendments) Regulations 2026 (SI 2026/302). Made on 16 March 2026, laid before Parliament on 17 March 2026 and commencing on 7 April 2026, the instrument realigns secondary legislation with Part 5 of the Employment Rights Act 2025 on labour market enforcement.
The Regulations displace references to the Gangmasters and Labour Abuse Authority (GLAA) and substitute the Secretary of State across the Gangmasters (Appeals) Regulations 2006 and the Northern Ireland equivalent. Definitions covering decision documents, immediate‑effect decisions, disputed decisions and licences are amended so that decisions are taken by, and appeals are answered by, the Secretary of State.
Procedural machinery for appeals is retained but re‑badged. Acknowledgement, amendment and withdrawal of appeals, replies, contents of replies and Secretariat actions now refer to the Secretary of State rather than the GLAA, ensuring continuity for licence‑holders while changing the decision‑maker.
The Gangmasters (Licensing Conditions) Rules 2009 are updated so that applications, licence conditions and fees are administered by the Secretary of State. Inspection and information‑gathering provisions are amended to recognise enforcement officers appointed under section 90 of the Employment Rights Act 2025, replacing previous references to GLAA compliance officers.
Amendments to the Conduct of Employment Agencies and Employment Businesses Regulations 2003 update cross‑references for the work‑seeker key information document and record‑keeping duties. References move from the Employment Agencies Act 1973 to section 90 and sections 96–97 of the Employment Rights Act 2025.
Within investigatory powers, the Regulation of Investigatory Powers regime is adjusted. The 2007 Order on authorisations extending to Scotland omits the GLAA, and the 2010 Order on directed surveillance and covert human intelligence sources lists, within the Department for Business and Trade, an enforcement officer appointed under section 90 of the 2025 Act at or above Senior Executive Officer grade. The GLAA entry is removed.
The Legislative and Regulatory Reform (Regulatory Functions) Order 2007 and the Economic Growth (Regulatory Functions) Order 2017 are also updated. The former omits GLAA from its schedule, while the latter adds “The Secretary of State under or by virtue of the labour market legislation listed in Part 1 of Schedule 7 to the Employment Rights Act 2025”, recognising the reformed enforcement functions in the growth duty framework.
Extensive amendments to the Proceeds of Crime Act 2002 (References to Financial Investigators) Order 2021 reposition powers. For England and Wales, DBT is recognised for restraint orders, authorisations, civil recovery, search of cash, listed assets, account freezing and forfeiture of cryptoassets, with GLAA references omitted. Where a “senior officer” is specified, the Regulations require a DBT officer at or above Senior Executive Officer level.
Parallel changes apply in Northern Ireland. DBT is inserted into provisions for restraint orders, authorisations and appeals, civil recovery, search and seizure, account and cash powers, and cryptoasset forfeiture, again with senior roles defined at Senior Executive Officer grade or higher. This ensures POCA designations reflect the new enforcement structure across jurisdictions.
Consequential removals extend beyond enforcement and POCA. GLAA is omitted from the Register of Overseas Entities (Disclosure and Dispositions) Regulations 2023, the Trade Union (Facility Time Publication Requirements) Regulations 2017 and the Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017, reflecting the cessation of GLAA as a listed public authority for those purposes.
Taken together, the changes centralise labour market enforcement under the Secretary of State and the Department for Business and Trade. DBT enforcement officers are expressly positioned within the statutory authorisation schemes for surveillance and financial investigation, with an internal grade threshold for decisions that require a “senior officer”.
Employers, employment businesses and labour providers should refresh compliance documents ahead of 7 April 2026. Key information documents and record‑keeping frameworks should cite the Employment Rights Act 2025 provisions, references to the GLAA in templates and privacy materials should be updated, and licence‑holders should prepare for correspondence, inspections and information requests from DBT enforcement officers or the Secretary of State.
The instrument is signed by Kate Dearden, Parliamentary Under‑Secretary of State at the Department for Business and Trade, dated 16 March 2026. The Explanatory Note confirms no separate impact assessment for this SI; assessments for the Employment Rights Bill, introduced on 10 October 2024, are available at: https://bills.parliament.uk/bills/3737/publications.
Policy Wire analysis: the transfer consolidates labour market enforcement within DBT, replacing GLAA listings across surveillance and proceeds‑of‑crime gateways. Legal thresholds are unchanged, but governance, sign‑off and contact points move to the Secretary of State and DBT, with UK‑wide effect including Northern Ireland.