News · End-hirers · OPRaaS Platform
The real Living Wage rises to £14.10 an hour across the UK, according to the Living Wage Foundation, and for accredited employers it is a commitment that extends well beyond their own payroll. The Foundation’s guidance says the commitment generally includes long-term temps supplied by recruitment agencies and often paid through umbrella companies, so the employer signs for a rate that another organisation actually pays.
The Living Wage Foundation announced the new rates on 15 October 2026: £14.10 across the UK, up 65p or 4.8 per cent, and £15.45 in London, up 4.4 per cent. According to the Foundation, almost half a million people working for nearly 17,000 accredited Living Wage Employers are due the rise.
Its published guidance asks those employers to implement the rise as soon as possible, and by 1 May 2027 at the latest. That deadline matters above all where the worker is not on the employer’s books. For end-hirers that rely on agency labour, the harder question is not whether the uplift was agreed. It is whether anyone can show it reached the worker.
What the real Living Wage asks of accredited employers
The real Living Wage is voluntary and sits above the statutory floor. According to the government’s published rates, the National Living Wage has been £12.71 an hour for workers aged 21 and over since 1 April 2026. On the Foundation’s figures, the real Living Wage now sits £1.39 an hour above that statutory rate outside London, and £2.74 above it in London.
Accreditation is not limited to directly employed staff. The Foundation’s frequently asked questions describe third-party contracted staff as those who work regularly, for two or more hours a week, for eight or more consecutive weeks a year. Its implementation guide says this generally includes cleaners, security and long-term temporary workers.
Enforcement also works differently from a statutory regime. The Foundation states that it does not carry out annual compliance audits of accredited employers. It does, however, run a compliance check procedure and an anonymous whistleblowing scheme for workers. Where it has reason to believe a licence is being breached, however, it will ask the employer to put things right and may ask for evidence such as anonymised payslips or contract samples.
OPRaaS’s reading, not a position the Foundation has stated, is that this puts the burden of proof on the accredited employer. Yet the payslips in question are produced by agencies and umbrella companies. The evidence sits elsewhere.
Why an agency charge rate is not real Living Wage proof
For recruitment agencies and the clients they supply, the uplift usually starts as a commercial conversation. A new pay rate is agreed, the charge rate is repriced and the assignment schedule is updated. Those documents do not show what the worker was actually paid.
Where a temp is engaged through an umbrella company, the distance grows. In the common umbrella model, the agency pays an assignment rate, and from it the umbrella funds employer National Insurance, the apprenticeship levy where it applies, holiday pay and its own margin before gross pay is set. An assignment rate comfortably above the new real Living Wage does not, on its own, show a basic hourly rate at that level on the payslip.
Blended rates add a further layer. A payslip that shows one combined hourly figure, or rolled-up holiday pay without the hours behind it, can make it difficult to see whether the hourly element meets the real Living Wage at all.
Where real Living Wage evidence tends to go missing
On OPRaaS’s reading, the weak points are more likely to sit in the handoffs between organisations than in the headline rate:
- Uplifts applied to new bookings only. Existing assignments roll over on the old rate because nobody reissued the schedule.
- Temps nobody counted. Workers booked week to week cross the eight-week threshold without ever being added to the register.
- Second-tier suppliers left out. A sub-agency or umbrella was never told about the commitment, so it never reached the payroll.
- Payslips without hours. Where pay varies by hours worked, a payslip that omits them cannot show the hourly rate.
These gaps are not exotic. Each one is a records problem, and each one passes upstream to the accredited employer if the Foundation asks for evidence. For public sector buyers that hold accreditation, and for MSPs managing several supplier tiers on their behalf, the register of qualifying temps is usually the first thing worth checking.
Accreditation is signed by the end-hirer, but the evidence that it is honoured is printed on someone else’s payslip.
What a real Living Wage pay check should contain
For accredited end-hirers and the agencies that supply them, a defensible real Living Wage record usually contains four things:
- A register of qualifying temps. Every third-party worker is logged with a start date and weekly hours, so anyone crossing the Foundation’s two-hour, eight-week threshold is flagged.
- A flow-down clause. Supplier contracts state the accredited rate, the date it takes effect and a right to request anonymised payslip samples.
- A periodic payslip sample. Each supplier provides an anonymised sample at agreed intervals, showing hours paid and a basic hourly rate at least equal to the rates the Foundation reports, currently £14.10, or £15.45 in London.
- A reconciliation. Timesheet hours and rates are matched to payslips, and net pay is matched to what the worker received.
Module 8 of the OPRaaS LSCA Self-Certification Course covers this discipline in its topic Auditing Workforce Payslips. It asks auditors to check that timesheet hours match payslip data, and to use Bacs transfer data to confirm that net pay aligns with the amount the worker actually received. Its red flags include umbrella employer on-costs, such as employer NICs and the apprenticeship levy, being charged to the worker.
The same topic notes that an end-hirer may access workforce data only where it has a lawful basis under UK GDPR and appropriate contractual provisions, applying data minimisation. Sampling is the practical answer. It also matches the Foundation’s own preference for anonymised payslips.
How OPRaaS audits and the OPRaaS VCD support real Living Wage evidence
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, including temps, freelancers, contractors, interims and consultants.
The OPRaaS audit platform puts structured questions to the agencies and umbrella companies in a supply chain, including on payroll, payslips and pay rates, and holds the evidence behind each answer. Answers are scored, and each audit produces a PDF report with that evidence linked, which an accredited employer can keep on file.
Alongside the platform, the OPRaaS Virtual Compliance Director (OPRaaS VCD) runs a quarterly risk-check cycle on umbrella companies on a preferred supplier list, covering payslips, credit scores, director changes and VAT registration, with Companies House used for director and ownership changes and Creditsafe for credit-risk changes.
Payslips reviewed in that cycle give the accredited employer existing evidence to compare against the new rate. Keeping the register of qualifying temps, and deciding what to do about a shortfall, stays with the accredited employer.
OPRaaS is named as a supplier on the UK Government Commercial Agency (formerly Crown Commercial Service) Audit and Assurance Services Two framework (RM6310), Lot 2: External Audit and Lot 4: Other Independent Assurance, and is registered on the RM6219 Learning and Training Services and RM6237 Low Value Purchase System dynamic purchasing systems. The OPRaaS LSCA platform is available on G-Cloud 15 (RM1557.15), Lot 2b: Software as a Service.
What board directors should do before 1 May 2027
For board directors at accredited end-hirers, and at the agencies and umbrella companies that serve them, this work is better done this winter than next spring. Ask each supplier now for a sample of payslips at the new rate, rather than waiting for the deadline to arrive.
The payslip is the proof. Early samples show where the uplift has stalled while there is still time to put it right, and they turn the real Living Wage from a promise in a licence into a record that stands up on its own.
Compliance is your asset. Evidenced daily.
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This article draws on the Living Wage Foundation’s announcement of 15 October 2026, the Foundation’s frequently asked questions and implementation guide, the government’s published National Minimum Wage and National Living Wage rates and Module 8 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.