5 Employment Law Changes on April 6 — What Every UK Employer Must Do

Five significant employment law changes take effect on Friday, 6 April 2026. Every UK employer is affected by at least two of them — and most haven't reviewed all five.

This checklist covers each change, who it affects, and the specific action you need to take before Friday.

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Table of Contents

1. Statutory Sick Pay from Day One
2. Mandatory 6-Year Holiday Records
3. Protective Award Doubles to 180 Days
4. Making Tax Digital for Income Tax
5. CIS Director Liability Changes
6. Fair Work Agency Launches Monday April 7
7. Your April 6 Action Checklist

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1. Statutory Sick Pay from Day One {#ssp}

What's changing: The three-day waiting period for Statutory Sick Pay (SSP) is abolished from 6 April 2026. Employees are entitled to SSP from their very first day of illness — and the qualifying earnings threshold has been removed.

Who's affected: All UK employers. This is particularly significant for hospitality, retail, care, and cleaning — sectors with high staff turnover and frequent short-term absences.

The impact: Previously, you only paid SSP from day four. Under the new rules, a single one-day absence now triggers SSP entitlement. If you have 10 employees and each has one short-term absence per month, your sick pay liability increases substantially.

What you must do:

• Update your HR software and payroll settings to remove the 3-day waiting period
• Brief your line managers — they cannot tell employees to "wait it out" before reporting illness
• Update your staff handbook and sickness policy
• Check your employment contracts don't reference the old waiting period rule

Source: GOV.UK — SSP reform 2026

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2. Mandatory 6-Year Holiday Records {#holiday-records}

What's changing: From 6 April 2026, employers must retain detailed holiday pay records for a minimum of six years. Failure to maintain adequate records is a criminal offence under the Employment Rights Act, as amended.

Who's affected: All UK employers. The Fair Work Agency (launching 7 April — see below) can request these records retroactively during inspections.

The impact: This isn't just a paperwork rule. The six-year window means records going back to April 2020 are in scope. If you've had staff on irregular hours, zero-hours contracts, or variable pay in that period, your historic holiday calculations may be challenged.

What you must do:

• Audit your holiday pay records back to April 2020
• Ensure your payroll software exports and retains holiday pay data (not just absence dates)
• Confirm records include: dates, hours worked each week, pay rate, holiday taken, holiday pay paid
• If records are incomplete, document the steps you're taking to reconstruct them
• Store records securely for at least six years from the date they were created

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3. Protective Award Doubles to 180 Days {#protective-award}

What's changing: If an employer fails to follow proper collective consultation procedures when making 20 or more redundancies, the Employment Tribunal can award a "protective award" to each affected employee. From 6 April 2026, this award doubles from 90 days' pay to 180 days' pay per employee.

Who's affected: Any employer with 20+ employees who is considering, planning, or in the process of restructuring or redundancies.

The impact: If you have 20 employees and the average weekly wage is £500, the maximum liability for getting collective redundancy wrong just increased from £90,000 to £180,000 overnight.

What you must do:

• If you're planning any redundancies involving 20+ employees, begin the 45-day collective consultation period immediately
• Brief your HR team and legal advisors on the new award maximum
• Review your redundancy procedures — incomplete or rushed consultations are the most common trigger
• If consultation has already begun, ensure you can demonstrate full compliance

🚨 If you're planning redundancies and haven't started consultation: you have days, not weeks.

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4. Making Tax Digital for Income Tax (MTD ITSA) {#mtd}

What's changing: Making Tax Digital for Income Tax Self Assessment (MTD ITSA) goes live on 6 April 2026 for sole traders and landlords with income over £50,000 per year. These businesses must now use HMRC-compliant software to keep digital records and submit quarterly updates to HMRC.

Who's affected: Sole traders and landlords with turnover/income above £50,000. Around 860,000 people in the UK are in scope for this first wave.

The impact: The quarterly submission deadline for the first period (April–June 2026) falls in August 2026. But the switch to compliant software must happen from 6 April — not August.

What you must do:

• Check if your income is above £50,000 (sole traders, property landlords, or both combined)
• Sign up for MTD ITSA via your HMRC Government Gateway
• Choose and migrate to HMRC-compatible software (e.g., QuickBooks, Xero, FreeAgent)
• Ensure your accountant is aware and enrolled as your agent in the MTD system
• Set up quarterly submissions starting from this tax year (6 April 2026 – 5 April 2027)

Accountants: Up to 860,000 of your clients are affected. Those earning £30,000–£50,000 come into scope in April 2027.

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5. CIS Director Liability and the Kittel Principle {#cis}

What's changing: Under new HMRC guidance applying from April 2026, the "Kittel principle" — originally an EU tax law concept — is being applied to the Construction Industry Scheme (CIS). This means directors can be held personally liable for CIS tax fraud committed by their supply chain if they "knew or should have known" fraud was involved.

Who's affected: Construction companies, subcontractors, property developers, and civil engineering firms.

The impact: HMRC can now recover lost CIS tax from the director personally — not just the company. The penalty can reach 30% of the lost tax on top of the principal liability.

What you must do:

• Verify every subcontractor through CIS before making payments
• Document your due diligence on each subcontractor (registration, UTR, business legitimacy)
• Submit monthly nil returns even if no payments were made — missing returns trigger full penalty regimes
• Brief your finance director and contracts manager on the new liability exposure
• Review any subcontractors who have been flagged by HMRC or had irregular payment patterns

Source: HMRC CIS guidance — GOV.UK

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6. Fair Work Agency Launches Monday 7 April {#fwa}

The Fair Work Agency (FWA) launches the day after these five changes take effect. It merges the enforcement powers of HMRC (National Minimum Wage), the Gangmasters and Labour Abuse Authority (GLAA), and the Employment Agency Standards Inspectorate (EASI).

Key powers:

• Unannounced inspections — no complaint required
• Checks wages, sick pay, and holiday records in a single visit
• Civil penalties for holiday pay underpayment (for the first time)
• Can inspect retroactively using the six-year holiday records from point 2 above

Priority sectors for FWA enforcement: hospitality, retail, care, cleaning, construction.

If you haven't reviewed your compliance across the five points above, do it before Monday.

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7. Your April 6 Action Checklist {#checklist}

Print this and work through it before Friday:

Statutory Sick Pay

• Updated payroll to pay SSP from day 1 (not day 4)
• Line managers briefed on new rules
• Staff handbook updated

Holiday Records

• Records audited back to April 2020
• Payroll system retaining full holiday data
• 6-year retention confirmed

Redundancy / Protective Awards

• If 20+ redundancies planned: collective consultation started
• Legal advice obtained if mid-process
• Tribunal liability reviewed under new £180-day maximum

MTD ITSA (sole traders/landlords over £50k)

• HMRC registration completed
• Compatible software selected
• Accountant enrolled as MTD agent

CIS (construction only)

• All subcontractors verified via CIS
• Monthly nil returns submitted
• Director liability reviewed

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Don't Try to Monitor All of This Manually

Between SSP, holiday records, MTD, CIS, the new protective award rules, and a brand-new enforcement agency starting Monday, staying on top of UK compliance has become a full-time job.

ComplianceAlert monitors all 16 UK regulators and sends you plain-English alerts the moment something changes — so you find out about it before enforcement starts, not after.

Start your free 7-day trial at compliancealert.co.uk — no credit card required.

Not sure if your business is already at risk? Take our free 3-minute Compliance Score quiz — instant results, no sign-up required: compliancealert.co.uk/compliance-score

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Summary: What Changes on 6 April 2026

Change	Who's Affected	Action Needed By
SSP from day one	All employers	Update payroll today
6-year holiday records	All employers	Audit records now
Protective award → 180 days	Employers planning redundancies	Start consultation now
MTD ITSA	Sole traders/landlords £50k+	Register + migrate software
CIS director liability	Construction	Verify subs, submit nil returns

April 7: Fair Work Agency launches — enforcement begins.

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Published: 1 April 2026 | Author: ComplianceAlert Editorial Team | Sources: GOV.UK, HMRC, ACAS

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