Can you prove your agency temps actually receive the new £14.10 real Living Wage?

Accredited employers have until 1 May 2027 to apply the £14.10 real Living Wage to qualifying temps. Whose payslips will show it happened?
Real Living Wage concept: a yellow ribbon runs down three navy tiers and across a pale blue payslip form, the evidence at the end of the chain

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:

  1. 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.
  2. A flow-down clause. Supplier contracts state the accredited rate, the date it takes effect and a right to request anonymised payslip samples.
  3. 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.
  4. 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.

Read next

“Payslip verification is what tells you whether the tax shown was ever paid to HMRC.“

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.

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LSCA Glossary of Terms

Glossary of Terms

Comprehensive definitions for Labour Supply Chain Assurance compliance terminology

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Acronym Full Term Definition
CFA 2017 Criminal Finances Act 2017 UK legislation introducing Corporate Criminal Offence (sections 45/46): failure to prevent the facilitation of tax evasion. Requires businesses to implement 'reasonable prevention procedures' (RPP). The only defence is having adequate RPP or showing it was not reasonable to expect such procedures.
MSA 2015 Modern Slavery Act 2015 UK legislation mandating supply chain transparency and worker safeguarding. Section 54 requires commercial organisations with ≥£36m turnover to publish annual modern slavery statements (board-approved, signed by director, published on website with prominent homepage link).
IR35 Off-Payroll Working Rules Tax legislation determining whether a contractor should be treated as employed or self-employed for tax purposes. Since April 2021, medium and large private sector clients must determine contractor status and deduct employment taxes if inside IR35. Requires Status Determination Statement (SDS).
JSL Joint & Several Liability 2026 legislation imposing strict liability on agencies and end-hirers for umbrella company tax debts, even where due diligence checks have been undertaken. Makes supply chain participants jointly responsible for unpaid PAYE taxes.
AWR Agency Workers Regulations 2010 UK regulations giving agency workers the right to the same basic working and employment conditions as permanent employees after 12 weeks in a qualifying assignment (12-week parity rule).
Good Work Plan Good Work Plan 2020 UK employment law reforms requiring written 'section 1 statement' of employment particulars to be given to employees and workers on or before day 1 of engagement (effective 6 April 2020). Sets out key terms but is not itself the contract.
Construction Act Housing Grants, Construction and Regeneration Act 1996 UK legislation governing payment practices in construction contracts. Section 113 renders "pay when paid" clauses ineffective (except where upstream payer is insolvent). Requires clear due dates, final dates for payment, and compliant payment/pay less notices.
Pensions Act 2008 Pensions Act 2008 UK legislation establishing workplace pension auto-enrolment requirements. Employers must automatically enrol eligible workers into qualifying pension schemes and make minimum contributions.
Acronym Full Term Definition
HMRC HM Revenue & Customs UK government department responsible for tax collection, payment of tax credits and benefits, and enforcement of tax law. Operates PAYE, CIS, RTI systems and conducts compliance audits. Business Tax Account provides reconciliation data.
GLAA Gangmasters and Labour Abuse Authority UK government body regulating labour providers in certain sectors (agriculture, horticulture, shellfish gathering, food processing/packaging) and investigating worker exploitation. Operates licensing regime and has criminal investigation powers. Hotline: 0800 432 0804 (03000 718234 out of hours).
ICO Information Commissioner's Office UK independent authority upholding information rights. Enforces UK GDPR and Data Protection Act 2018. Personal data breaches must be reported to ICO within 72 hours where there's risk to individuals' rights. Provides guidance on lawful bases, DSARs, and data-sharing.
CITB Construction Industry Training Board Industry body that collects levy from construction employers (payroll ≥£80k in PAYE in last tax year, or ≥£80k net CIS payments) and provides training grants. CITB levy compliance is audited in construction-focused compliance audits.
Acronym Full Term Definition
PAYE Pay As You Earn HMRC's system for collecting Income Tax and National Insurance Contributions from employees' wages. Employers deduct tax before paying employees, then remit to HMRC. Operates under Real Time Information (RTI) reporting requirements.
CIS Construction Industry Scheme Tax deduction scheme for payments to subcontractors in construction industry. Contractors must verify subcontractors with HMRC before first payment and make deductions (20% for verified, 30% for unverified) on labour element only (excluding VAT and allowable materials). CIS300 returns due by 19th following tax month.
GPS Gross Payment Status CIS status allowing subcontractors to be paid without deductions. Must apply to HMRC and meet compliance tests (business test, turnover test, compliance test). Contractors must verify GPS and keep evidence; continue to file CIS300 but make no deduction.
CIS300 CIS Monthly Return HMRC return submitted by contractors detailing total payments made to each subcontractor and CIS tax deductions applied. Must be filed by the 19th following the tax month (6th–5th). Should reconcile to subcontractor statements and bank payments.
CIS340 CIS340 Guidance HMRC's official guidance document defining what constitutes 'construction operations' for CIS purposes. Only work qualifying under CIS340 can legitimately be paid through the Construction Industry Scheme. Includes site preparation, construction, alteration, repairs, demolition.
RTI Real Time Information HMRC system requiring employers to report PAYE information at or before each pay run. Consists of Full Payment Submission (FPS) for regular pay data and Employer Payment Summary (EPS) for adjustments/recoveries. Must reconcile to payslips and Business Tax Account.
FPS Full Payment Submission RTI submission reporting gross taxable pay, Income Tax, and NICs for each employee on each payday. FPS values must match payslips. Should not be used to mask under-deductions.
EPS Employer Payment Summary RTI submission used only for adjustments, such as recoveries, statutory payments, employment allowance claims, or apprenticeship levy. Should not be used to mask PAYE under-deductions.
Bacs Bankers' Automated Clearing Services UK electronic payment system used for direct debits and credits, including salary payments. Net pay on payslip must match Bacs transfer to worker's bank account. Never use "BACS" (incorrect).
UTR Unique Taxpayer Reference 10-digit number issued by HMRC to identify individuals and businesses for tax purposes. Required for CIS verification and self-assessment tax returns. Note: UTR alone isn't proof of CIS verification; contractor must verify with HMRC before first payment.
NIC / NICs National Insurance Contributions UK social security tax paid by employees (via PAYE), employers (as on-costs), and the self-employed (Class 2/4 via self-assessment). Funds state benefits including state pension, statutory sick pay, and maternity allowance. CIS deductions are payments on account of Income Tax and Class 4 NICs.
NMW National Minimum Wage Legal minimum hourly rate employers must pay workers in the UK. Rates vary by age band. Post-deduction pay (after deductions for employer's own use/benefit) must not fall below NMW. Records must be kept for 6 years.
NLW National Living Wage Higher rate of National Minimum Wage for workers aged 21 and over. Often referred to together as "NMW/NLW". Different from voluntary Real Living Wage calculated by Living Wage Foundation.
AE Auto-Enrolment (Pensions) Workplace pension scheme where employers must automatically enrol eligible workers (aged 22+ to state pension age, earning ≥£10k annually) into a qualifying pension. Minimum contributions, opt-out rights, and re-enrolment (every 3 years) required.
P45 P45 (Leaving Employment) HMRC form given to employees when they leave employment, showing pay and tax details for the year to date. New employer uses P45 to operate correct tax code. Emergency codes (e.g., 1257L W1/M1) apply without P45/P6.
Acronym Full Term Definition
DRC Domestic Reverse Charge (VAT) VAT mechanism for construction services where the customer accounts for VAT instead of the supplier. Applies to most construction services under CIS340. Designed to combat missing trader fraud in construction supply chains.
Kittel Kittel Principle EU/UK legal principle that a taxpayer who knew or should have known their transaction was connected to VAT fraud may be denied the right to deduct input VAT. Creates due diligence obligations for supply chain participants.
DR Disguised Remuneration Tax avoidance arrangements designed to pay individuals while avoiding income tax and NICs, often involving loans, offshore entities, or trusts. HMRC actively targets such schemes. Loan charge applies to outstanding loans.
Acronym Full Term Definition
SDC Supervision, Direction or Control Key factor in determining employment status under agency rules (ITEPA 2003 s44). If a worker is under supervision, direction or control by any person (client, agency, end-hirer) over how they work, PAYE must be operated. SDC alone is not the general CIS status test—apply usual status tests (control, substitution, mutuality).
MOO Mutuality of Obligation Employment status indicator examining whether the employer is obliged to provide work and the worker is obliged to accept it. Absence of MOO suggests self-employment; presence suggests employment.
SDS Status Determination Statement Document required under IR35 reforms (April 2021) where medium/large clients must provide written reasons for their determination of a contractor's employment status for tax purposes. Must be given before contract starts or worker begins work.
CEST Check Employment Status for Tax HMRC's online tool for determining whether a worker should be classified as employed or self-employed for tax purposes. Results are binding on HMRC if information provided is accurate and not relating to highly complex arrangements.
PSC Personal Service Company Limited company through which a contractor provides their services. Often used by contractors working outside IR35, but subject to IR35 rules if the underlying relationship is one of employment. Requires SDS from medium/large clients.
KID Key Information Document Plain-English factsheet (not a contract) that agencies must give to workers before they agree to an assignment (Conduct of Employment Agencies and Employment Businesses Regulations 2003). Includes worked pay illustration, deductions, who pays the worker, benefits. Must be updated within 5 working days of any change.
ITEPA 2003 Income Tax (Earnings and Pensions) Act 2003 UK tax legislation governing employment income. Section 44 contains agency rules requiring PAYE where worker is under SDC. Section 61N–61R cover off-payroll working (IR35) for public sector and (from 2021) medium/large private sector.
DBS Disclosure and Barring Service UK government service providing criminal record checks for employment purposes (particularly roles working with children or vulnerable adults). Processing DBS data requires DPA 2018 Schedule 1 condition and appropriate policy document.
Acronym Full Term Definition
Umbrella Umbrella Company Employment intermediary that employs agency workers and contractors. Handles PAYE, pension, and employment administration while the worker performs assignments for end-clients arranged through agencies. Employer NICs/apprenticeship levy must be funded from assignment rate, not charged to workers as deductions.
MUC Mini Umbrella Company Fraudulent scheme where multiple small umbrella companies are created to exploit employment allowances and avoid tax obligations. Often phoenixing after accumulating tax debt. A significant compliance risk that supply chain audits help detect.
Phoenix Phoenix Company Scheme Fraudulent practice where a company accumulates tax debts, is dissolved, and re-emerges as a new entity to escape liabilities. A key risk factor in supply chain due diligence. Tolerance of phoenix suppliers by end users enables fraud cycle.
Purported Purported Umbrella Company Entity presenting itself as a legitimate umbrella company but failing to meet compliance standards, potentially operating tax avoidance schemes or misclassifying workers.
Hybrid Hybrid Payment Model Pay arrangement combining different payment methods (e.g., PAYE + CIS, or PAYE + PSC). Requires careful status assessment to avoid disguised remuneration or employment status breaches.
Acronym Full Term Definition
UK GDPR UK General Data Protection Regulation UK data protection law (retained EU law post-Brexit) governing processing of personal data. Requires lawful basis (Art 6), data minimisation, security, transparency (Arts 13-14), and respect for data subject rights. Works alongside Data Protection Act 2018.
DPA 2018 Data Protection Act 2018 UK legislation supplementing UK GDPR. Schedule 1 sets conditions for processing special category data (health, biometric, union membership) and criminal offence data (e.g., DBS checks). Provides exemptions (crime prevention, tax collection, legal professional privilege).
DSAR Data Subject Access Request Individual's right under Art 15 UK GDPR to obtain copy of their personal data. Must respond within one month (extendable by 2 months for complex requests). Usually no fee. Must verify identity proportionately.
DPO Data Protection Officer Required role for public authorities or organisations conducting large-scale systematic monitoring or processing special category data (Art 37). Oversees data protection compliance, advises on DPIAs, and acts as contact point for ICO and data subjects.
LIA Legitimate Interests Assessment Assessment required when relying on legitimate interests (Art 6(1)(f)) as lawful basis. Three-part test: identify legitimate interest → demonstrate necessity → balancing test (interests vs individual rights). Appropriate for audit/assurance; avoid consent for audits.
DPIA Data Protection Impact Assessment Required assessment where processing is likely to result in high risk to individuals (Art 35). Must complete for large-scale, systematic monitoring or extensive special category data processing. Documents risks, mitigation measures, and necessity/proportionality.
RoPA Records of Processing Activities GDPR requirement (Art 30) documenting all personal data processing activities. Must include purposes, lawful bases, data categories, recipients, retention periods, security measures, and international transfers. Must be available to ICO on request.
IDTA International Data Transfer Agreement UK mechanism for lawfully transferring personal data outside the UK (replacing EU Standard Contractual Clauses post-Brexit). Required unless recipient country has adequacy decision or other derogation applies. Alternative: UK Addendum to EU SCCs.
SCCs Standard Contractual Clauses EU Commission-approved contract templates for international data transfers. For UK data exports, use UK Addendum to EU SCCs or UK IDTA.
Art 28 DPA Article 28 Data Processing Agreement Mandatory contract between controller and processor (Art 28 UK GDPR). Must cover: subject matter, duration, data types, processing instructions, confidentiality, security, sub-processors, data subject rights assistance, breach notification, data deletion/return, audit rights.
Art 26 Article 26 (Joint Controllers) UK GDPR provision for parties who jointly determine purposes and means of processing. Requires arrangement setting out respective responsibilities, data subject rights, and contact points. Different from controller-processor (Art 28) or controller-controller data-sharing.
Controller Data Controller Organisation that determines the purposes and means of processing personal data. Bears primary GDPR obligations. Agencies, umbrellas, and end-hirers usually act as independent controllers for their own audit/compliance purposes.
Acronym Full Term Definition
LSCA Labour Supply Chain Assurance Due diligence framework ensuring compliance with tax, employment, and ethical standards throughout the labour supply chain. Covers PAYE/CIS compliance, modern slavery, CFA 2017, worker rights, and IR35. Aims to detect exploitation, fraud, and phoenixism.
PSL Preferred Supplier List Vetted list of approved suppliers (typically umbrella companies or agencies) that meet compliance standards. Key governance control for managing supply chain risk. Should be reviewed regularly and require re-certification.
End-Hirer End-Hirer / End Client The organisation where agency or contract workers ultimately perform their work. Under current regulations, medium/large end-hirers have IR35 status determination responsibilities and supply chain due diligence obligations.
CCO Corporate Criminal Offence CFA 2017 offence: failure to prevent facilitation of tax evasion by an associated person. Three-stage liability: (1) taxpayer evades tax, (2) associated person criminally facilitates it, (3) organisation failed to prevent. Only defence: reasonable prevention procedures (RPP).
RPP Reasonable Prevention Procedures The only defence to Corporate Criminal Offence under CFA 2017. HMRC's six principles: risk assessment, proportionate procedures, top-level commitment, due diligence, communication (training), monitoring & review. Must be risk-based and documented.
SRO Senior Responsible Owner Senior person accountable for CFA 2017 compliance, risk assessments, and implementation of reasonable prevention procedures. Provides top-level commitment and board oversight.
MSAT Modern Slavery Assessment Tool UK Government tool (Home Office/Cabinet Office) for assessing modern slavery risks in supply chains. Free to organisations registered on UK Government Supplier Registration Service.
Acronym Full Term Definition
ASCA Agency Self-Certification Audit Most comprehensive audit form with 174 questions across 18 sections. Enables recruitment agencies to self-assess compliance with tax, employment, and supply chain obligations including PAYE, CIS, Modern Slavery, CFA 2017.
AUCIS Agency Umbrella CIS Audit Audit evaluating recruitment agencies' compliance with CIS requirements when engaging umbrella companies, ensuring proper tax treatment and supply chain integrity.
AUPAYE Agency Umbrella PAYE Audit Audit assessing recruitment agencies' oversight of umbrella companies' PAYE compliance, including tax deductions, National Insurance contributions, and payroll accuracy.
EHUCIS End-Hirer Umbrella CIS Audit Audit evaluating end-hirers' due diligence when engaging umbrella companies under CIS, ensuring supply chain compliance and proper contractor treatment.
EHUPAYE End-Hirer Umbrella PAYE Audit Audit assessing end-hirers' oversight of umbrella PAYE arrangements, covering payroll transparency and worker rights compliance.
EHSA End-Hirer Self-Assessment Audit Audit enabling end-hirers to self-assess their compliance with supply chain, tax, and employment obligations.
EHAA End-Hirer Assurance Audit Audit providing end-hirers with an independent assessment of their supply chain compliance, risk management, and due diligence practices.
UMBCIS Umbrella CIS Audit Audit evaluating umbrella companies' compliance with CIS requirements, including proper contractor treatment, tax deductions, and verification processes.
UMBPAYE Umbrella PAYE Audit Audit assessing umbrella companies' PAYE compliance, payroll integrity, and worker protection standards. Contains 21 sections (Section 1 info-only, Sections 2-20 audit, Section 21 declaration) vs 18 for most other audits.
Self-Cert Self-Certification Audit Generic term for labour supply chain compliance audits where organisations self-assess against tax, employment, and ethical standards. Provides documented evidence of due diligence for HMRC inspections.
Acronym Full Term Definition
Instance Audit Form Instance Individual audit submission. Users can create unlimited instances, each stored as WordPress custom post type with responses in wp_opraas_audit_responses table. Assigned to logged-in user via post_author field.
Completion Completion Score Frontend metric showing percentage of questions answered (any answer counts). Includes ALL sections: Section 1 checkbox, Section 2 (8 fields), Declaration (7 fields), and all audit questions. N/A responses count as answered.
Compliance Compliance Score Backend metric measuring quality of compliance. Scoring: Yes=5 points, No=0 points, N/A=0 points (excluded from maximum), Don't Know=1 point. EXCLUDES Sections 1, 2, and Declaration entirely. ≥80% = Compliant, 60-79% = Partially Compliant, <60% = Non-Compliant.
Evidence Evidence Files Supporting documents uploaded to substantiate audit responses. Stored in AWS S3 via WP Offload Media plugin, with Evidence Table providing S3-aware ZIP downloads that temporarily download from cloud before adding to archives.
Red Flags Red Flags Warning indicators in audit questions identifying practices that may indicate non-compliance, fraud risk (phoenixism, MUCs, disguised remuneration), or regulatory breaches requiring immediate attention and remediation.