ALP Publishes Updated Due Diligence Framework

The ALP has published an updated open-source resource, Labour Provider Due Diligence: A Step-by-Step Practical Guide, to support labour providers and labour users in strengthening due diligence across increasingly complex labour supply chains.

The guide is released against a backdrop of intensifying regulatory scrutiny and commercial pressure within labour supply markets. Rising compliance expectations, tighter margins, labour shortages and aggressive procurement practices are continuing to push risk down supply chains, increasing the likelihood of worker exploitation, underpayment, unsafe working conditions and tax evasion where due diligence is weak or treated as a paper exercise. Regulators have repeatedly warned that failures in labour-supply oversight can expose organisations to unpaid tax and National Insurance, VAT loss, modern slavery risk and enforcement action.

In response, the guide sets out a clear, practical five-step framework aligned with UK government guidance, covering capability building, policy and contractual foundations, supply-chain mapping, ongoing monitoring and self-assessment, and optional independent verification. The focus is on robust, risk-based due diligence that operates in practice, rather than reliance on onboarding checks or contractual assurances alone.

A central update within the resource is the release of the 2026 open-source Core Score Checklist, which has been refined to sharpen focus on the areas of highest risk in labour provision. The revised checklist reduces overall requirements, clearly separates statutory obligations from good-practice expectations, and includes direct links to relevant guidance, tools and training. This is intended to help organisations prioritise action, apply proportionate controls and more effectively evidence compliance to clients, auditors and regulators.

The guide emphasises that due diligence is both a two way street and a continuous process, extending well beyond onboarding to ongoing oversight of how workers are recruited, paid, treated and managed, including where subcontractors or umbrella companies are used. It brings together statutory requirements and recognised good practice across employment law, tax, health and safety, modern slavery and labour provider regulation, with practical actions and clear signposting to supporting resources.

Both the guide and the Core Score Checklist are published as open-source documents and are freely available to labour providers, labour users, procurement teams and other stakeholders. The aim is to raise standards across labour supply chains, reduce the conditions in which exploitation and tax non-compliance arise, and support organisations in maintaining robust, defensible due diligence in a challenging operating environment.