Since September 2026, academy trusts in England have been required to use the supply teachers framework when procuring agency supply staff, unless they have a compliant alternative arrangement that meets the Department for Education’s conditions. The framework is the UK Government Commercial Agency (formerly Crown Commercial Service) Supply Teachers and Education Recruitment agreement, RM6376.
The change affects a substantial market. Schools in England spend around £1.4 billion a year on agency supply staff, according to the Department for Education.
The supply teachers framework brings real transparency to agency charges and declared worker pay. It also raises a question for trust boards, finance directors and procurement teams: who verifies what happens to that money after it leaves the framework supplier?
The question is becoming more pressing as the market organises around the agreement. According to a report in Onrec on 8 October 2026, the Association of Professional Staffing Companies (APSCo) has launched a member directory listing recruitment businesses appointed to Lot 1, managed service providers on Lot 2, and members outside the framework who want to work with them. APSCo is clear that a listing is no promise of a contract.
The development highlights an important consideration for academy trusts. Although the supply teachers framework standardises procurement, the businesses involved in delivering supply staff may extend beyond the organisation holding the contract. According to the Government Commercial Agency, a Lot 2 managed service provider may oversee a trust’s staffing using its own staff or a supply chain.
As partnerships develop around the supply teachers framework, understanding who employs, pays and accounts for tax on each worker becomes more important for public sector buyers, agencies and MSPs alike. A framework agreement can establish the commercial terms. It does not remove the need to understand the organisations operating beneath them.
What the supply teachers framework fixes for academy trusts
The Department for Education’s guidance on the supply staff mandate is specific. Trusts must procure agency supply staff through the supply teachers framework unless an alternative route complies with the Procurement Act 2023, meets the relevant thresholds and charges rates no higher than the framework’s. Spend is assessed across the whole trust, not school by school.
According to the Government Commercial Agency’s RM6376 agreement page, Lot 1 has 209 suppliers and Lot 2 has 16, and supplier fees are capped at up to £45 a day for teachers. The department’s buying for schools blog stresses that the cap applies to the agency’s fee, not to what supply staff are paid.
On price and safeguarding, that is real progress. The agreement page states that suppliers must vet workers in line with Keeping children safe in education, and agencies must give trusts a per-candidate breakdown of worker pay, on-costs and fee. Trusts that use the supply teachers framework properly come out ahead on cost visibility.
Why declared pay is not the same as verified payment
The supply teachers framework gives academy trusts greater visibility of the costs associated with each supply worker, including declared worker pay, employment on-costs and agency fees. But a commercial breakdown is not the same as independent verification of payroll.
Where an umbrella company or another intermediary sits beneath the framework supplier, the trust may see the agreed figures without independently knowing whether the worker received the correct payment, whether deductions were calculated correctly or whether the associated payroll liabilities were discharged.
From the declared pay figure, an umbrella typically funds employer National Insurance, the Apprenticeship Levy, holiday pay and its own margin, before PAYE and employee deductions are made. Done properly, that is lawful.
The department has asked trusts to report any agency claiming it must pay workers less because of the mandate. That instruction protects the worker’s rate. Whether the tax on that rate is accounted for is a separate question, and it is where procurement compliance runs head-on into continuing assurance.
How JSL decides who carries the bill beneath the supply teachers framework
The new joint and several liability rules for umbrella arrangements, introduced by Finance Act 2026, which inserts Chapter 11 into Part 2 ITEPA 2003, have effect for payments made on or after 6 April 2026. They are distinct from older PAYE debt transfer powers.
Under Chapter 11, the umbrella company and the relevant party are jointly and severally liable for qualifying PAYE liabilities. According to HMRC’s guidance on PAYE rules for labour supply chains that include umbrella companies, that party is the agency, or the end client where no agency is involved.
In a typical Lot 1 arrangement, the relevant party will usually be the recruitment agency contracting directly with the academy trust. HMRC can therefore pursue that agency for qualifying PAYE liabilities arising from non-compliance by an umbrella company further down the supply chain.
The framework sets the fee. Chapter 11 sets the liability.
Different arrangements, including connected agencies and overseas intermediaries, may place liability on the end client, and a trust that contracts directly with an umbrella would be the relevant party itself. Even where the agency is the one in the firing line, the trust board still answers for whether public money funded a compliant chain.
Three questions every trust should answer for each supply teacher
Chapter 11 makes three facts about each supply worker worth establishing and keeping on record:
- Who is the legal employer, and what is its PAYE employer reference? The agency itself, an umbrella company or another business beneath the framework supplier, identified by legal name and PAYE reference rather than trading name.
- Who actually pays the worker? The organisation making the payment, which may not be the business the trust contracted with. The named Bacs payer on the payslip is useful evidence, not proof.
- Who is the relevant party under Chapter 11? In a typical Lot 1 chain, the agency that holds the contract with the trust.
Those questions sit outside the supply teachers framework order form. They can be answered from evidence a well-run agency should already hold, such as payslips, payroll records and reconciliation statements. Once a trust’s auditors begin to ask, the question moves up the chain quickly.
The framework makes the cost visible. Good governance continues after procurement, with evidence of who paid the teacher and whether the tax was accounted for.
How the OPRaaS VCD supports governance after procurement
OPRaaS, On-Pay-Roll-as-a-Service, is a systemised governance and workforce management partner for organisations that rely on temporary, contractor and contingent labour. The OPRaaS Virtual Compliance Director (OPRaaS VCD) serves end-hirers, recruitment agencies, umbrella companies, MSPs and public sector buyers across temps, freelancers, contractors, interims and consultants.
The OPRaaS VCD provides a structured approach to evidencing the organisations and responsibilities within a labour supply chain. For academy trusts and their framework suppliers, that means identifying the legal employer, the organisation responsible for paying each worker and the relevant party under Chapter 11.
Supporting evidence, including payroll records, payslips, reconciliation statements and available RTI information, can be assessed to identify inconsistencies and potential compliance risks. Payroll documentation alone cannot establish that every corresponding liability has been discharged to HMRC, so effective assurance also depends on continuing scrutiny of the organisations responsible for those payments, with clear escalation when something does not reconcile.
Suppliers can also be monitored between reviews, with Companies House flagging director and ownership changes and Creditsafe flagging credit-risk changes. Findings, owners and resolutions are recorded in the evidence file the platform produces on demand.
The result is a record, not a reassurance. For the agency that usually picks up the tab under Chapter 11, that documented governance matters as much as it does to the trust.
OPRaaS is an appointed supplier on the UK Government Commercial Agency (formerly Crown Commercial Service) agreements RM6310 Audit and Assurance Services Two (Lots 2 and 4), RM6219 Learning and Training Services DPS, RM6237 Low Value Purchase System and G-Cloud 15 (RM1557.15).
What board directors at trusts and agencies should look at next
For trust boards, finance directors and audit committees, the supply teachers framework caps supplier fees and makes the cost of supply far more transparent. For Lot 1 agencies and Lot 2 MSPs, it raises the standard of what they will be asked to show, because the agency holding the trust’s contract is usually the relevant party.
Directories and partnerships around the supply teachers framework may help agencies fill more classrooms. Each new partner is also another organisation to understand. Procurement compliance is now visible; continuing assurance is the next step.
For teams building that evidence, Module 11 of the OPRaaS LSCA Self-Certification Course sets out how to map the legal employer, the payer and the relevant party for every worker.
Compliance is your asset. Evidenced daily.
Read next
This article draws on Onrec’s report published on 8 October 2026, the Government Commercial Agency’s RM6376 agreement page, the Department for Education’s guidance on the supply staff mandate and buying for schools blog, HMRC’s guidance on PAYE rules for umbrella supply chains, Finance Act 2026 and Module 11 of the OPRaaS LSCA Self-Certification Course.
Talk to OPRaaS about your labour supply chain.
Use the contact form alongside this article or email info@opraas.co.uk.
This article is editorial commentary by OPRaaS Limited (On-Pay-Roll-as-a-Service), drawing on published research, legislation and government guidance. It provides general information and does not constitute legal, tax, employment or compliance advice. Obligations vary according to organisation, contractual arrangements and individual engagements. Appropriate professional advice should be obtained before acting on a specific position.