The new rules will require end hirers to pass details of their employment status determination and the reasons for that decision directly to each party in the contractual chain (which could include one or more agencies as well as the PSC, the contractor). They will therefore need a procedure in place to make status determinations and to pass that information to the worker and the fee-payers in that chain. It will be important for companies to consider how they deal with any data privacy issues arising from this new process.

End hirers have an obligation to respond to representations from workers where there is a disagreement over determination. End hirers that fail to respond will be liable for the tax and NIC in point.