Work-Seeker Terms on the First Recruitment Call: UK Guide

When a temp agency's first conversation with a work-seeker happens on the phone, that call carries real legal weight. Under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, an employment business must obtain a work-seeker's agreement to a defined set of terms before it first provides any work-finding service, and it must put those terms in writing before it supplies any service they cover. The call is where that sequence starts, and it is also where it can go wrong: a consultant agrees a rate on the phone, the paperwork follows three days later, and the worker is already on site.

The volume makes this a process question rather than a legal footnote. The REC's Recruitment Industry Status Report 2024/25, published in December 2025, puts the number of temporary or contract workers on assignment on any given day in 2024 at around 872,000, and says temporary and contract placements account for 76.7% of the industry's gross value added. Its previous edition estimated 22.6 million temporary or contract placements across 2023 (REC press release, November 2024). Behind that volume sits a regulation 14 terms agreement for each work-seeker an employment business first supplies, unless the regulation 14(3) exception applies, and this guide assumes the common set-up in which that conversation starts on a call. The latest KPMG and REC UK Report on Jobs, published in October 2026 from data collected 10 to 24 September, found temp billings still expanding, though at the least pronounced pace in five months, while permanent placements rose at a pace that, though marginal, was the strongest in four years.

This guide is written for the Head of Operations or compliance lead at a UK employment business that supplies temporary workers. It covers what regulations 13, 14 and 15 require on and after the first call, which parts a voice AI agent can handle and which must stay in a document, and who enforces the rules since the Fair Work Agency took over in April 2026. It deliberately cedes three neighbouring topics: candidate screening mechanics belong to our candidate screening guide, automated decision law belongs to the employment law and AI decisions post, and right to work and umbrella PAYE belong to the recruitment hub. The 2003 Regulations extend to England, Wales and Scotland, and Northern Ireland has its own regime, so UK here means Great Britain for these rules. Nothing here is legal advice; it is an operating reading of the statutory text, linked throughout so your counsel can check it. It sits in our wider industries collection, alongside the voice AI by industry map.

This guide is shipped by the team behind Dilr Voice, a multi-agent voice AI platform that runs inbound and outbound calls with warm transfer to a human and post-call CRM updates. Or see DATS, our five-stage method for placing AI inside an operating process.

What must a UK employment business agree with a work-seeker before first providing services?

A UK employment business must obtain the work-seeker's agreement to its terms before it first provides any work-finding service. Regulation 14 of the 2003 Conduct Regulations lists what that agreement covers: a statement that it operates as an employment business, the type of work it will look for, and the six regulation 15 terms. All agreed terms must then be recorded in a document given before the services they relate to, unless regulation 14(3) applies.

The distinction between an employment business and an employment agency matters here. An employment business supplies a worker who works under the hirer's control while being engaged by the business, which is the classic temp model. An employment agency introduces a work-seeker to a hirer who then employs them directly, which is the classic permanent model. Regulation 14 applies to employment businesses. Agencies have their own terms duty under regulation 16, but it bites only before the agency provides work-finding services for which regulation 26(1) permits it to charge the work-seeker a fee, so most permanent desks meet it far less often.

For a temp desk, three points sit inside regulation 14 and they are easy to blur on a busy morning (the separate five business day rule for varied terms is covered further down):

• Agreement first. Regulation 14(1) requires agreement to the terms before first providing any work-finding services. Agreement is a state of affairs, and the regulation does not say how it must be captured.
• Document before services. Regulation 14(2) requires every agreed term to be recorded in a single document or, where that is not possible, more than one, with copies given at the same time as each other before the business provides any service those terms relate to.
• One exception. Regulation 14(3) switches off the document duty where the work-seeker already has a written statement of particulars of employment under Part I of the Employment Rights Act 1996, which can apply where the business employs the worker on a contract of employment and has already issued that statement.

The practical reading is that a phone call can be where agreement is reached, but the call alone does not satisfy the document duty. That single sentence drives the design of everything below. For the wider compliance map a voice deployment sits inside, our UK and EU voice AI compliance guide covers recording, consent and disclosure rules that apply to every call, not just recruitment ones.

Which first-call statements does regulation 13 actually require?

Regulation 13 of the Conduct Regulations requires an agency or employment business, on the first occasion it offers a service to a work-seeker, to give notice stating whether that service is a work-finding service for which a fee is prohibited, and the details of any fee for other services or goods. Crucially, regulation 13(2) applies that notice only where fee-bearing extras may actually be provided.

That condition matters. Regulation 13 is not a blanket script every temp call must read. It is triggered when the business, or a third party it introduces, may charge the work-seeker for something other than finding work: training, a uniform, a CV service, transport, accommodation. When it is triggered, the notice must cover the amount or method of calculating the fee, who receives it, what it is for, the right to cancel or withdraw, and any refund or rebate terms. A further notice is due under regulation 13(3) whenever those fees are introduced or varied later.

The background rule sits in primary legislation. Section 6 of the Employment Agencies Act 1973 bars a person carrying on an employment business from requesting or receiving a fee from a worker for finding them work, except in prescribed cases, and section 6(2) makes a breach an offence punishable by a fine. A first call that drifts into "there is a small registration charge" is not a script problem; it is a criminal-law problem.

For a voice agent, this translates into a branch rather than a paragraph. If the role or the agency's offer carries no fee-bearing extras, the agent has nothing to read under regulation 13 and should not invent a fee statement. If it does, the agent should deliver the approved notice wording held in the agency's own knowledge base rather than paraphrase it, and the agency should log that the notice was given and send the written version with the onboarding pack. Dilr Voice agents answer from the customer's own uploaded documents during a live call, which is the right shape for a notice whose wording legal has signed off and nobody on the phone should paraphrase.

What are the regulation 15 terms, and which can a voice call capture?

Regulation 15 lists six terms an employment business must agree with each work-seeker: the type of contract and its terms and conditions, an undertaking to pay for work done whether or not the hirer pays, notice periods for assignments, the rate or minimum expected rate of pay, pay intervals, and holiday entitlement with holiday pay. A voice call can explain all six and confirm understanding, but the document carries them.

Regulation 15 items (a) to (f) are worth laying out against what the call should and should not do, because the failure mode is a call that quietly becomes the contract.

Two design rules follow. First, the agent should state facts the agency has already decided, never negotiate them. Rate is the obvious trap: if a work-seeker pushes back on pay, a voice agent should log the objection and warm-transfer the call to a consultant with the context attached, rather than improvise a number that then has to be honoured. Second, the agent should end every terms section by telling the work-seeker that the written terms will arrive before any assignment starts, and the post-call workflow should write the outcome to the CRM and notify whoever issues the document, so it goes out straight after the call.

Can a phone call count as agreeing the terms?

A phone call can be where an employment business and a work-seeker reach agreement on terms, because regulation 14(1) requires agreement but does not prescribe its form. It cannot replace the written record. Regulation 14(2) separately requires every agreed term to be set out in a document given to the work-seeker before services start, unless the regulation 14(3) exception applies.

The cleanest operating model treats the call as agreement in principle and the document as the record. That gives three checkpoints the agency can evidence later:

1. The call log. Timestamp, the work-seeker's identity as captured, which terms were explained, the explicit yes or no to each, and any objection raised. A call recording helps, subject to the recording and consent rules in our guide to consent capture on AI voice calls.
2. The document send. The terms document generated and delivered, with all copies sent at the same time as each other, as regulation 14(2)(b) requires.
3. The supply gate. No booking confirmed into a shift until the system shows the document was delivered. This is the control that stops the "already on site" failure from the introduction.

The third checkpoint is the most exposed, because supply decisions are often made fast by people who are not looking at the onboarding status. It is a systems question as much as a training one. The same placement logic sits behind our AI placement diagnostic, which maps where in a process an AI step genuinely removes work and where a hard gate is needed instead.

What else should the first call collect for regulations 19 and 21?

Beyond terms, an employment business may not supply a work-seeker until it has confirmed their identity, their experience, training, qualifications and any required authorisation, and their willingness to do the specific role. Regulation 19 sets those gates. Regulation 21 then generally requires role information given orally at offer stage to be confirmed in writing within three business days, which a voice agent's post-call workflow can prompt.

Regulation 19 asks for confirmation, not merely collection, so a first call is the start of the evidence rather than the end of it. A voice agent can ask the work-seeker to state their experience and qualifications, capture their availability, and ask which kinds of work they are willing to do. It cannot verify a forklift licence, a nursing registration or a driving entitlement on its own say-so; those need documents or registers checked by the agency. The same limit applies to right to work. A voice agent can remind a work-seeker to bring a share code and book the check, but the prescribed right to work checks are carried out by the business engaging the worker, not by a phone call.

Roles that involve working with, caring for or attending a vulnerable person add regulation 22: copies of qualifications, two references from people who are not relatives, and any other reasonably practicable step to confirm suitability, with a documented fallback where full compliance proves impossible. Regulation 22 also adds steps where a qualification or authorisation is required by law or a professional body. A voice agent is useful for chasing referees and collecting their contact details, and should hand anything judgement-based to a person.

When a role is later offered, regulation 21 requires the business to pass on the hirer information it holds under regulation 18, such as identity of the hirer, start date and likely duration, location, hours and known health and safety risks. Where that information is not given in paper or electronic form at the time, it must be confirmed that way no later than the end of the third business day, subject to carve-outs in regulation 21(3) to (5), such as a repeat booking in the same position within five business days. An outbound shift-offer call is a natural trigger for that confirmation, and our shift-fill playbook for staffing agencies covers the offer call itself in depth.

How should a voice agent handle a change to agreed terms?

Once terms are documented, regulation 14(4) bars an employment business from varying them unless the work-seeker agrees. Regulation 14(5) then requires the varied terms in writing as soon as possible and no later than the end of the fifth business day after agreement, with the date they take effect. A voice agent can seek that agreement, but cannot make continued work conditional on it.

The conditionality rule is the one an efficiency-minded automated script can most easily break. Regulation 14(6) of the Conduct Regulations says: "An employment business may not make the continued provision of any services by it to a work-seeker conditional on the agreement by the work-seeker to any such variation." In plain terms, an outbound call announcing a change of pay interval cannot end with "if you do not agree, we will not be able to offer you further shifts".

A compliant variation call has four properties:

• it states the proposed change and the date it would take effect;
• it asks for agreement as an open question, with "no" recorded as a valid outcome that changes nothing else about the worker's status;
• it escalates any worker who is unsure or objects to a named person rather than looping back with a second pitch;
• it writes a "yes" to the CRM and notifies whoever issues the regulation 14(5) document, so the five business day clock starts a process rather than relying on a consultant's memory.

Fee changes for extras follow the parallel regulation 13(3) route, which requires a further notice when fees for other services are introduced or varied. Both triggers should sit in the same post-call workflow. Dilr Voice runs post-call automation without code, writing CRM records and sending email, SMS or Slack notifications, which is the mechanism an agency would use to start its document process from an agreed outcome rather than from a consultant's to-do list.

Longer assignments arguably raise the stakes on variation: the longer a worker stays on one assignment, the more room there is for a change of rate, hours or pay cycle to arise mid-assignment, which is why the variation workflow deserves the same design attention as onboarding.

Who enforces the Conduct Regulations in 2026?

Since 7 April 2026 the regulation of employment agencies and employment businesses has sat with the Fair Work Agency, which brought together the Employment Agency Standards Inspectorate, the Gangmasters and Labour Abuse Authority, the Director of Labour Market Enforcement and HMRC's National Minimum Wage Unit. That covers England, Wales and Scotland. Northern Ireland keeps its own Employment Agency Inspectorate.

The launch date and remit are set out on the government's Fair Work Agency employer page, and the four functions it brought together are named in the GOV.UK announcement of the agency's advisory board. For an employment business, the change shows up in the record-keeping duty. Regulation 29 requires records sufficient to show compliance, kept for at least one year from creation, and for work-seeker and hirer particulars at least one year after services to that person last end. Where records are kept away from the business's premises, it must be able to have them delivered to its premises no later than the end of the second business day after a request made under sections 96 or 97 of the Employment Rights Act 2025, wording substituted from 7 April 2026.

That two business day window is the operational point for a voice deployment. If first-call outcomes live in a voice platform, a CRM and an email tool that do not talk to each other, assembling a work-seeker's terms history inside two business days becomes a manual hunt. The obligation binds the employment business, not its software suppliers, so the agency needs its own audit view. Dilr Voice keeps full audit trails on every call by default, and the post-call workflow can write the outcome into a supported CRM such as HubSpot or Salesforce so the evidence sits next to the candidate record. Breaches of regulations made under section 5 of the Employment Agencies Act 1973 are themselves offences punishable by a fine. If you want a second pair of eyes on your own call flows, talk to our team before the next audit cycle rather than after it.

Information handling is the other live thread. Regulation 28 bars disclosure of information about a work-seeker without their prior consent, outside work-finding services, legal proceedings or, where the work-seeker is a member, their professional body. That sits alongside UK GDPR rather than replacing it, and our voice AI data retention guide covers how long call recordings and transcripts should be kept.

The same discipline runs through our AI operating model work, which sets who owns each automated step, what evidence it leaves and who answers an inspector's request, and through the wider DATS consulting method that the team at DILR.AI uses on every regulated deployment.

What is the best way to run first calls for a temp agency in 2026?

The best approach for most UK employment businesses in 2026 is a voice agent that explains decided terms, captures agreement and prompts the written document, with consultants owning negotiation, objections and suitability judgements. It suits high-volume temp desks with stable terms. A consultant-led first call still wins for executive interim, niche clinical and any role where terms are negotiated per worker.

Five criteria separate a compliant first-call design from a fast one:

1. Branching on regulation 13. The agent reads a fee notice only where fee-bearing extras exist, verbatim from approved text.
2. No improvised terms. Every rate, notice period and pay interval the agent states comes from the agency's own data, never from generation.
3. Document before supply. A hard gate in the booking system, not a reminder.
4. Non-conditional variation. "No" is a recorded outcome, never a trigger for withdrawal of work.
5. Two business day retrieval. Call outcomes land in the system of record with the candidate, ready for an enforcement request.

On tools, honest trade-offs apply. Agencies already deep in Bullhorn or Vincere should first check what their own platform's candidate messaging covers for simple confirmations before adding another tool, and a technical team happy to build its own call logic on Vapi or Retell AI keeps full control at the cost of building the compliance branches itself. Enterprise contact centre suites from Genesys or Five9 make sense where recruitment is one queue among many. Dilr Voice fits the middle: a multi-agent platform where a greeter, a qualifier and a knowledge agent can be chained in one call, with business-hours routing, warm transfer to a consultant with full context, per-country recording consent and opt-out handling shipped by default, and 30+ languages for a multilingual temp workforce. Our independent best AI voice agent 2026 guide compares the field on criteria rather than claims, and the enterprise AI voice agents guide explains the architecture choices underneath.

The macro picture argues for starting narrow. McKinsey's State of AI 2025 found 88% of organisations use AI in at least one function but only about a third have it in production. In our view a first-call workflow with a small number of defined checkpoints is the kind of bounded, measurable process that is realistic to take into production, and our voice AI ROI framework shows how to cost it against consultant hours before committing.

Does regulation 14 apply to permanent recruitment agencies?

Regulation 14 applies to employment businesses, the temporary supply model, not to employment agencies that introduce candidates for permanent roles. Permanent agencies have a separate terms duty under regulation 16, triggered before they provide work-finding services for which regulation 26(1) permits them to charge the work-seeker a fee. A permanent desk that charges candidates nothing meets that duty far less often than a temp desk meets regulation 14.

Can a voice agent complete a right to work check on the first call?

A voice agent cannot complete a statutory right to work check, because the prescribed checks are an online Home Office share-code check, a manual check of original documents, or a check through a certified identity service provider, all carried out by the business engaging the worker. On a first call, the agent can explain what is needed, collect a share code if offered and book the check.

Want to see this in production? Try Dilr Voice live, compare the field in our best AI voice agent guide, see the AI execution office that runs a deployment week to week, or read about our approach to placing AI inside regulated workflows.

Written by the Dilr.ai engineering team, practitioners who ship enterprise AI in production. Follow us on LinkedIn for shipping notes, or subscribe via the RSS feed.