From 6 April 2026, changes are in force to the UK umbrella company sector that substantially alter how tax risk is allocated across labour supply chains.

Joint and Several Liability means that if an umbrella company fails to pay the correct PAYE or National Insurance Contributions, HMRC can go after recruitment agencies and end clients for the full unpaid amount. Every party in the labour supply chain becomes jointly and severally liable for tax obligations that stem from an umbrella company’s failure.

Two points are critical to understand from the outset. First, liability is joint and several, meaning HMRC can pursue any party in the chain for 100% of the unpaid amount, regardless of where the failure originated. Second, and perhaps most importantly, there is no reasonable care defence — even if an agency carried out thorough due diligence, it can still be held fully liable.

The new rules aim to combat tax non-compliance, protect workers, and level the playing field by eliminating rogue umbrella providers. The security sector is directly in scope.

How Does the Liability Chain Actually Work?

Understanding the mechanics matters because your position in the chain determines your direct exposure.

Umbrella companies remain employment intermediaries and the PAYE employer in the standard model, but they are no longer the only party potentially liable for payroll taxes where things go wrong. Where a worker is supplied via an umbrella company and there is a UK recruitment agency in the chain, the agency will generally be the party that HMRC can pursue for any PAYE and Class 1 NIC shortfall.

If the client contracts directly with the umbrella, or the agency is offshore or connected to the umbrella, the end client may instead be exposed.

Liability for the taxes occurs from the moment that a payment is due to HMRC. The liability falls on both the umbrella company and the other liable party at the same time — so technically the amount the umbrella has to pay is an amount the other liable party also owes, even though they are not the ones reporting to HMRC.

The practical implication: if your staffing agency uses an umbrella model and that umbrella fails — through insolvency, fraud, or simple non-compliance — HMRC can pursue the agency first, or you directly if the agency is offshore, connected to the umbrella, or otherwise unavailable. HMRC is under no obligation to warn you that a non-compliant umbrella is in your supply chain, and no one should rely on receiving a warning before enforcement begins.

Critically, insolvency does not extinguish the liability: HMRC can pursue you for unpaid taxes even after the umbrella company has collapsed or gone into administration. The most likely scenario in which security companies face a JSL demand is not an investigation into a live umbrella — it is post-insolvency pursuit once the umbrella itself cannot pay.

Does Joint and Several Liability Apply to Security Companies?

Yes, if umbrella companies are present in your labour supply chain — and in the security sector, they frequently are.

The reforms are primarily focused on arrangements involving umbrella companies. Where umbrella companies are used to employ and pay temporary workers, liability for unpaid PAYE and National Insurance may extend beyond the umbrella itself.

In practical terms, this applies to you if you:

• Use a staffing agency that places officers through an umbrella or third-party employment arrangement
• Use subcontractors whose payroll model you have not verified
• Have not mapped the employment structure behind every person currently filling your shifts

The security industry’s reliance on subcontracting to manage demand spikes, fill last-minute absences, and mobilise new contracts quickly makes this an active risk, not a theoretical one. The operational model that has served the industry for decades now carries a direct tax compliance dimension it did not have before April 2026.

It is worth being precise about scope: JSL applies specifically where an umbrella company is involved. Direct subcontracting between two security companies — where workers are direct employees of the subcontractor on a standard PAYE payroll — is a different arrangement. The critical question is not whether you use subcontractors, but how the people in your supply chain are actually employed and paid.

What Happens If You Are Found Liable?

The financial exposure is straightforward: HMRC can pursue any party in the chain for 100% of the unpaid amount, regardless of where the failure originated. There is no apportionment, no cap tied to your share of the relationship, and no good faith defence.

The reputational consequences in a regulated sector are arguably more damaging. If HMRC issues a recovery notice, the issue rarely remains private. It may appear in financial disclosures, auditor commentary, or media coverage. Stakeholders do not distinguish between deliberate avoidance and structural failure. Investors see unmanaged risk. Clients see instability.

For a security company, add the sector-specific consequences: ACS accreditation reviews, client contract compliance clauses triggered by tax enforcement action, and reputational damage in a relationship-driven market where your next contract win often depends on a reference from your last one.

One important misconception to address: HMRC publishes a list of known tax avoidance schemes and non-compliant umbrella operators, and some security companies assume that checking this list is sufficient protection. It is not.

JSL is a separate enforcement mechanism from the avoidance blacklist — it is a recovery tool that applies regardless of whether the umbrella in your supply chain appears on any published register. A non-compliant umbrella can generate a JSL liability without ever having been named by HMRC. Do not treat the absence of a name on the list as confirmation of compliance.

The Employment Rights Act 2025 received Royal Assent in December, and the Fair Work Agency launched on 7 April 2026 with a remit to enforce workers’ rights across the labour market. The Fair Work Agency is expected to take on direct regulation of umbrella companies from 2027, further consolidating supply chain oversight under a single enforcement body. The direction of travel is clear: the government intends to hold every party in the supply chain accountable. Security companies that treat this as a one-time compliance exercise rather than a standing operational discipline are misjudging the trajectory.

What Should Security Companies Do Now?

There is no published government checklist and no single accreditation that eliminates JSL exposure. HMRC has made clear that it expects agencies and end-clients to conduct regular, documented checks on their umbrella suppliers. Those that cannot demonstrate a reasonable process for verifying compliance may find themselves exposed.

For security companies, that translates into five concrete actions.

1. Map your supply chain in full. Identify every staffing agency and subcontractor you currently use. For each one, establish how their workers are employed — specifically, whether an umbrella company sits anywhere in the arrangement. If you cannot answer this today, that is your first priority.
   
2. Request documented PAYE compliance evidence. Ask your labour suppliers to confirm in writing that workers are employed on PAYE and that Income Tax and National Insurance are being correctly remitted to HMRC. Consider what processes are necessary to obtain comfort — potentially in real time — that PAYE and NIC have been calculated, reported through Real Time Information, disclosed on workers’ pay slips, and paid correctly and on time. Document everything you request and everything you receive.
   
3. Prefer FCSA-accredited suppliers where possible. FCSA accreditation provides independent assurance of payroll and tax compliance. Ensure umbrella partners are financially secure and consistently meeting PAYE and NIC obligations. Accreditation is not a complete defence under JSL, but it is evidence of a documented compliance process if HMRC investigates.
   
4. Review your BS7858 vetting exposure simultaneously. If you are using agency-supplied staff whose vetting status you cannot verify, you have a compliance problem that runs alongside — and compounds — your JSL exposure. An officer who is not properly vetted and whose employment arrangement is not clean creates regulatory and tax risk at the same time.
   
5. Rethink how you meet flexible demand. The operational pressure that drives subcontracting in security does not go away. What changes is the risk calculation. PAYE-employed flexible staffing, where the employment relationship is direct and the audit trail is complete, removes the JSL exposure that umbrella or agency arrangements create.

How Does JSL Interact With Other 2026 Compliance Pressures?

JSL does not sit in isolation. Security companies in 2026 are managing several concurrent compliance obligations, and they interact with each other.

BS7858 vetting remains the baseline for every security hire. The 2025 tightening of SIA criminality criteria means the standard your vetting process must meet has moved, and any agency-supplied worker whose vetting you have not verified independently represents a gap in your compliance posture.

Martyn’s Law, which received Royal Assent in April 2025 and enters enforcement no earlier than April 2027, subject to the Home Office’s implementation timeline, will require venues above 200-person capacity to demonstrate compliant security arrangements. Security companies supplying those venues will face increased scrutiny of their staffing documentation — including employment status.

The Fair Work Agency, launched on 7 April 2026, has a remit that overlaps with how security workers are employed and paid. Its enforcement focus on labour market compliance means the supply chain questions JSL raises are being examined from multiple regulatory angles simultaneously.

The companies that will navigate this period well are those that treat compliance as an integrated operational discipline — not a series of separate box-ticking exercises.

Frequently Asked Questions

Does JSL apply to all subcontracting in the security sector?

No. The reforms are primarily focused on arrangements involving umbrella companies. Direct subcontracting between two security companies, where the subcontractor’s workers are on a standard PAYE payroll, is a different arrangement. The key question is whether an umbrella company is involved anywhere in the supply chain.

Is there a due diligence defence against JSL?

No. There is no reasonable care defence. Even if an agency carried out thorough due diligence, it can still be held fully liable. Documentation of your compliance process may be relevant to how HMRC prioritises enforcement in practice, but it does not eliminate the liability itself.

Who does HMRC pursue first — the agency or the end-client?

Where a worker is supplied via an umbrella company and there is a UK recruitment agency in the chain, the agency will generally be the party HMRC pursues. If the client contracts directly with the umbrella, or the agency is offshore or connected to the umbrella, the end client may instead be exposed.

What is the scale of the legislation?

Approximately 30,000 recruitment agencies, 400 umbrella companies, and 700,000 umbrella workers fall within scope. The legislation is projected to protect £715 million in tax revenue in 2026–27 alone.

When did JSL come into force?

Joint and Several Liability for umbrella companies officially took effect on 6 April 2026. If you have not yet reviewed your supply chain arrangements, you are already operating under the new rules.

Does JSL change anything about IR35?

No. There are no changes to the way IR35 is currently assessed. JSL applies to workers employed by an umbrella company via PAYE — a separate employment model from IR35 determinations.

Does JSL apply to self-employed or limited company contractors?

No. Freelancers operating as genuinely self-employed sole traders, or through their own limited companies, are not caught by JSL. The rules apply only where an umbrella company is acting as the employer in the supply chain. Security companies that use a mix of directly contracted self-employed individuals and agency-supplied workers should note that JSL exposure applies to the latter category only — but this makes it more important, not less, to know precisely how each category of worker in your supply chain is engaged.

How GuardPass Can Help

JSL exposure doesn’t start with a compliance failure — it starts with not knowing how the people filling your shifts are actually employed. The security companies most at risk are those operating with gaps in their supply chain visibility, relying on agency arrangements they haven’t audited, and treating staffing as an operational question rather than a compliance one.

If that’s where you are, GuardPass gives you the tools to close those gaps — from licence verification and vetting through to how you source and manage your security workforce.

The direction of travel from HMRC, the Fair Work Agency, and the SIA is consistent: every party in the labour supply chain will be held accountable. The security companies that come through this period without disruption won’t be the ones that got lucky — they’ll be the ones that made deliberate decisions about how they staff.

Disclaimer: This blog is for informational purposes only. Please verify details independently before making decisions.

The post Joint and Several Liability: What Security Companies Need to Know in 2026 appeared first on GuardPass Resources.

For the last 4 weeks, I’ve been helping a company prepare for its ACS Approval renewal, and an audit is imminent. It isn’t a simple job, and although initially achieving SIA Approved Contractor Scheme membership may not be difficult, getting a good score takes time, effort, and a genuine corporate desire to adapt its culture and achieve excellence in a wide range of areas.

Within the UK private security industry, Security Industry Authority (SIA) Approved Contractor Scheme (ACS) status remains one of the most recognisable indicators of organisational quality. Although participation is voluntary, many buyers of security services somewhat naively regard ACS approval as evidence that a company has invested in governance, compliance, staff development, and operational standards.

For businesses considering ACS approval, or preparing for an upcoming assessment, the process can appear daunting. The documentation is extensive, the evidence requirements are demanding, and the assessment itself examines far more than simple regulatory compliance. Yet organisations that approach the ACS audit methodically often discover that the exercise improves the overall effectiveness of their business.

Why ACS Approval Is Desirable

ACS approval can provide several commercial advantages.

Many procurement departments, local authorities, public-sector bodies, and major corporate clients either prefer or actively encourage suppliers to hold ACS approval. In competitive tender situations, it can help differentiate a contractor from competitors that operate solely with the minimum legal requirements.

The scheme is also designed to encourage continual improvement rather than mere compliance. Companies are assessed against a range of business management criteria covering leadership, strategy, service delivery, people management, financial controls, and customer relationships.

For many businesses, ACS status becomes a useful marketing tool. It demonstrates that an independent assessor has reviewed the organisation and confirmed that required standards are being met.

The Cost of ACS Membership

One reason some companies hesitate before applying is cost.

There are SIA application and registration fees, together with assessment fees payable to approved assessing bodies. The total cost varies depending upon company size, the scope of approval sought, and the assessor selected. The SIA periodically reviews and adjusts ACS fees, and organisations should budget not only for the direct charges but also for the internal administrative effort required to prepare for assessment.

At the time of writing, ACS fees were as follows:

The initial application fee varies depending on the number of licensable staff in your organisation and is non-refundable.

• Up to 10 licensable staff: £400
• 11 to 25 licensable staff: £800
• 26 to 250 licensable staff: £1,600
• Over 250 licensable staff: £2,400

The registration fee is the same for everyone: £25 per every licensable individual deployed as of the 1st June 2026. It is worth noting that this has just gone up from £15 per officer, a raise of 66% with very little notice or consultation, and the industry is universally unhappy.

Read the Government’s explanation for the huge increase in fees here.

For a larger business, these costs may be regarded as a routine overhead. For a smaller security company employing only a handful of officers, the financial commitment can appear much more significant.

The 104-Page Self Assessment Workbook

Preparation normally begins with the ACS Self Assessment Workbook.

The current workbook runs to approximately 104 pages and requires organisations to assess themselves against the ACS standard before the external assessment takes place.

In principle, the workbook is a valuable preparation tool. It forces management teams to examine their procedures, identify weaknesses, and gather supporting evidence.

In practice, however, many users have experienced difficulties when attempting to complete the workbook electronically using Adobe Acrobat. Depending upon software versions, security settings, and local IT configurations, users have reported problems with data retention, embedded functions, validation fields, saving progress, and transferring information between different computers.

Such technical frustrations can waste valuable preparation time. Organisations are therefore advised to start work on the workbook well in advance of their assessment date and maintain multiple backup copies throughout the process.

The key point is that completing the workbook is not the objective. The objective is ensuring that every answer can be supported by evidence when the assessor arrives.

Policies and Procedures Required

One of the most common misconceptions is that ACS compliance is primarily about producing documents.

Documentation is important, but assessors are looking for evidence that policies are actually being followed.

Typical documents expected during an assessment include:

• Recruitment and screening procedures.
• Vetting and right-to-work processes.
• Health and safety policies.
• Equality, diversity and inclusion policies.
• Data protection and GDPR procedures.
• Complaints management procedures.
• Disciplinary and grievance policies.
• Training and competency frameworks.
• Lone worker arrangements.
• Incident reporting procedures.
• Business continuity plans.
• Environmental and sustainability policies.
• Quality management procedures.
• Customer feedback processes.

Just as important as the policies themselves, however, are the records that demonstrate implementation. Training records, management meeting minutes, customer surveys, corrective action reports, supervisor site visit records, and employee consultation evidence all help support compliance claims and boost the achieved score.

Site Visits and What Auditors Want to See

The site visit is often the point at which reality meets documentation.

Assessors want to confirm that what appears in policies and procedures is genuinely happening on operational sites.

During site visits, they typically examine:

• Assignment instructions.
• Site risk assessments.
• Occurrence books and incident records.
• Patrol records.
• Welfare facilities.
• Uniform standards.
• Licensing compliance.
• Training records.
• Emergency procedures.
• Health and safety arrangements.
• Management and supervisory oversight.
• They will normally speak directly with security officers and supervisors.

Staff should understand their site instructions, know how to report incidents, understand emergency procedures, and be familiar with company reporting lines. Assessors are generally not conducting examinations, but they do expect staff responses to align with documented procedures.

How to Score Additional Points

Under the ACS assessment model, organisations must meet the required achievement level for every indicator. Beyond that, additional points are awarded for evidence of good practice and continuous improvement.

Some relatively straightforward ways of improving scores include:

• Conducting regular employee engagement surveys.
• Recording customer satisfaction feedback.
• Implementing structured management reviews.
• Demonstrating environmental initiatives.
• Maintaining formal training and development programmes.
• Operating documented welfare and wellbeing initiatives.
• Recording lessons learned from incidents and complaints.
• Establishing measurable business objectives and reporting against them.

Many organisations leave potential points on the table simply because good practices exist but are not formally documented.

How Many Points Are Needed to Pass?

A common misunderstanding concerns scoring.

What do you actually need to score to pass your ACS audit: Zero.

Zero, however, is the baseline figure obtained if you meet the absolute minimum standard in all 78 required “indicators” across 7 assessment criteria. All points above this are earned for going further, achieving more, and being better.

In practical terms, failing to meet a mandatory indicator is likely to be far more serious than missing out on extra improvement points.

The maximum possible score is currently 145 points, so there is a huge gulf between a company that just scrapes through and only ticks the required boxes, and one of the compliance powerhouses that obtains ACS Pacesetters (A private membership organisation for top-scoring companies) qualification level, being the top 15% of all ACS-approved companies, with a score above 110!

Adding a New Category of Approval

Existing ACS-approved companies sometimes decide to expand into additional sectors such as door supervision, security guarding, key holding, or CCTV operations.

When this occurs, businesses should engage with the SIA well in advance. Extending the scope of approval is not something that should be left until the last minute. The continuation and approval extension processes require planning, supporting documentation, and sufficient time for review.

Early communication with the SIA can prevent delays and avoid unnecessary complications during renewal or reassessment.

Challenges for Smaller Businesses

Smaller companies often face the greatest difficulties.

Many owner-managed businesses already operate effectively but lack the administrative infrastructure expected by the ACS framework. Producing management reports, documenting staff consultations, conducting formal reviews, and maintaining comprehensive records can be challenging when the same individual is responsible for sales, operations, recruitment, and payroll.

The cost of external consultancy, assessment fees, and management time can also place significant pressure on limited resources.

As a result, some excellent operational businesses struggle with ACS preparation despite delivering high-quality security services.

Why Some Businesses Do Not Seek ACS Approval

Given the advantages, it may seem surprising that some companies choose not to pursue ACS status.

The reasons are varied.

For some, the cost outweighs the perceived commercial benefit. Others operate within niche markets where clients rarely ask about ACS approval. Some business owners simply prefer to focus on operational delivery rather than compliance administration.

There are also organisations that conclude the return on investment does not justify the considerable effort required to maintain approval year after year.

Ultimately, ACS approval is a business decision rather than a legal requirement. However, for companies seeking larger contracts, stronger market credibility, and structured business improvement, the scheme continues to provide a recognised framework for demonstrating professionalism within the UK security industry.

The Future of the Approved Contractor Scheme

The ASC is not perfect, and the regulator has been looking at modifying the entire system for the last few years. The industry has also been crying out for mandatory security business licensing, and a new system would be required to allow this to be successful.

To that end, a new Business Approval Scheme (BAS – because they love acronyms) is not far over the horizon. Is it just a case of change for change’s sake? Well, until the Home Office finally relents and implements mandatory business licensing, many people think so.

Will the new BAS genuinely bring the improvements in public safety and better industry standards that the SIA claim?

We can only wait and see.

Keeping Compliance Practical

ACS preparation is ultimately about proving that the systems in the business work in practice, not just on paper. For security companies trying to make that easier, GuardPass brings hiring, training and compliance tools into one platform, while GuardCheck helps simplify BS7858 screening when evidence and speed both matter.

Build the habits before the ACS audit arrives, and the assessment becomes much less painful.

The post SIA ACS Audit Preparation: What Security Companies Need to Know appeared first on GuardPass Resources.

The UK private security industry stands on the edge of what may prove to be its most significant structural reform since the introduction of individual licensing under the Private Security Industry Act 2001. For over two decades, regulation has focused almost entirely on the individual operative. Now, attention is shifting, decisively, towards the businesses that employ them.

At the centre of this shift sits the proposed Business Approval Scheme (BAS), the successor to the long-standing Approved Contractor Scheme (ACS). To understand its significance, we must first understand why it exists at all.

How We Got Here

The current regulatory framework, overseen by the Security Industry Authority (SIA), was built on a simple principle: license the individual, and you regulate the industry. That approach has striven to deliver a baseline of competence. Today, hundreds of thousands of licensed operatives work across the UK under that system.

But there has always been a gap, one that seasoned professionals have known about for years. The SIA licenses people, not companies. There is no legal requirement for a security business itself to be approved, registered, or even inspected before trading.

The Approved Contractor Scheme was introduced to fill that gap. It is, and remains, a voluntary quality mark. Companies that opt in are assessed against standards of service delivery, management and compliance.

And therein lies the problem.

Voluntary schemes attract the willing, the better operators, the established firms, those already invested in compliance. Meanwhile, a significant proportion of the market operates entirely outside that framework. Currently, only around 750 businesses are approved, representing a small fraction of the total industry.

The result is a two-tier market: one regulated by choice, the other only by minimum legal obligations.

The Case for Change

The SIA has been candid in its assessment. The existing model is no longer sufficient to deliver consistent standards or robust public protection. The consultation launched in 2024 made that clear, seeking views on a new approach that would place “public protection at the heart” of business approval.

What followed was not a minor tweak, but a recognition that the ACS, in its current form, has reached the limits of what a voluntary scheme can achieve.

The proposed Business Approval Scheme represents a fundamental redesign. It is intended to shift the focus from process-driven audits to the outcomes that security companies actually deliver on the ground.

This is more than semantics. It signals a move away from annual, tick-box assessments towards a more intelligence-led, risk-based, model of oversight. Higher risk businesses will face greater scrutiny, and specialist providers will be expected to demonstrate sector-specific competence.

In short, the regulator is attempting to become more agile, more targeted, and more aligned with real-world risk.

How BAS Differs from the ACS

At first glance, BAS may appear to be a rebranded ACS. That would be a mistake.

The ACS was built as a quality assurance scheme, an optional badge of credibility. BAS is being designed as something closer to a regulatory framework in waiting.

Key differences are already emerging:

1. From Voluntary Badge to Strategic Lever

The ACS has always been optional. BAS, while initially likely to remain voluntary, is clearly being positioned as a stepping stone to something more formal. The language of “public protection” and “outcomes” reflects a regulatory mindset rather than a purely commercial one.

2. Risk-Based Assessment

Under the ACS, companies undergo periodic assessments, often three-yearly. BAS proposes a more dynamic model, focusing regulatory effort where the risk is greatest. This is a more modern approach, aligned with how other regulators operate.

3. Sector Specific Standards

The new scheme is expected to introduce enhanced requirements for specialist sectors, events, healthcare, and critical infrastructure, recognising that one-size-fits-all standards are no longer adequate.

4. Greater Emphasis on Service Delivery

There is a clear intention to shift assessment time towards how services are actually delivered, rather than purely how systems are documented.

Taken together, these changes represent a move from compliance on paper to performance in practice.

The Impact on Security Companies

For reputable operators, the direction of travel will feel familiar, perhaps even overdue. Many already operate to standards that exceed those currently required by the ACS.

However, BAS will raise the bar in several important ways.

First, it will demand greater transparency. Companies will need to demonstrate not just that they have policies, but that those policies are effective. That means better data, better reporting, and stronger governance.

Second, it will increase scrutiny on labour models. Issues such as subcontracting, use of labour providers, and employment practices will come under closer examination. For those operating on razor-thin margins, that scrutiny may prove uncomfortable.

Third, it will widen the gap between compliant and non-compliant businesses. Those already invested in quality will adapt. Those relying on minimal compliance, or worse, will find it increasingly difficult to compete in a market where clients are encouraged to look beyond price.

The Link to Mandatory Business Licensing

We cannot discuss BAS without addressing the larger question: is this a precursor to mandatory business licensing?

The honest answer is yes. At least in principle….

The SIA itself has acknowledged that any move to mandatory licensing would require government approval and legislative change. But the direction of travel is unmistakable. The development of BAS sits alongside wider consultation on business licensing, described by many as a “defining moment” for the industry.

Why does this matter?

Because mandatory licensing would fundamentally change the industry landscape. For the first time, every security business, not just individuals, would need to meet defined standards to operate legally.

That would address one of the sector’s most persistent weaknesses: the ability of poor or unethical operators to enter the market with minimal oversight.

BAS, in this context, can be seen as both a testing ground and a bridge. It allows the SIA to refine standards, develop assessment models, and build industry consensus before any legislative step is taken.

Risks and Realities

There are, of course, risks.

If BAS remains voluntary, it may struggle to achieve the scale required to drive meaningful change. The same structural limitation that affects the ACS could persist.

If it becomes mandatory, the challenge shifts to proportionality. Over-regulation could stifle smaller, legitimate businesses, particularly in a sector already under intense commercial pressure.

There is also the question of enforcement. Standards, however well designed, are only as effective as the resources and mechanisms used to enforce them.

What It Means for Clients

Clients, as ever, play a critical role.

A more robust business approval framework, whether voluntary or mandatory, will only deliver its intended benefits if buyers engage with it. Selecting providers based on verified standards rather than the lowest cost will be essential.

BAS offers the potential for a clearer, more meaningful benchmark of quality. But it will require clients to value that benchmark.

Recommended Reading: Why the Cheapest Bid Can Fund Organised Crime

Final Thoughts

The Business Approval Scheme is not just another industry initiative. It is a signal of intent, a recognition that the current model has limits, and that the future of security regulation must extend beyond the individual licence.

Whether BAS becomes a stepping stone to mandatory licensing or remains a strengthened voluntary framework, its impact will be significant.

For those who have long argued that the industry needs to move beyond minimum compliance, this is a moment of opportunity.

For those who have built their business on the margins of that compliance, it may be a moment of reckoning.

Either way, the message is clear: the days of light-touch oversight at the business level are numbered, and in a sector that exists to protect the public, that can only be a good thing.

Is Your Business Ready for What’s Coming?

Whether BAS remains voluntary or becomes mandatory, the direction is clear: standards are rising. GuardPass helps security companies stay ahead — connecting you with SIA-licensed professionals through the UK’s largest talent pool, with BS7858-compliant vetting through GuardCheck built in from the start.

See how GuardPass supports compliant security operations →

The post The Business Approval Scheme: What It Means for the UK Security Industry appeared first on GuardPass Resources.

There is a hard truth in the UK private security services industry that many clients would rather ignore: if the price looks too good to be true, it almost certainly is, and the consequences reach far beyond poor service delivery. In a sector built on trust, compliance and public safety, the relentless pursuit of the cheapest bid has created a dangerous ecosystem where criminality can thrive.

After three decades in and around this industry, I have seen the same cycle repeat itself. A client tenders for security services. The brief is sound, the expectations are high, but the decision is driven almost entirely by cost. The lowest bidder wins. On paper, everything appears compliant. In reality, the mathematics simply do not stack up.

Let’s start with the basics. A legitimate security provider operating within UK law must account for the National Living Wage, holiday pay, pension contributions, National Insurance, training costs, supervision, uniforms, insurance and a modest margin. Strip those costs back, and you quickly arrive at a minimum sustainable charge rate. When a contractor significantly undercuts that rate, there are only two possibilities: they are incompetent, or they are non-compliant. Let that sink in.

Too often, it is the latter.

The Race to the Bottom

The pressure to win contracts at unsustainable rates has created a race to the bottom. Companies that cut corners can underbid compliant providers by a significant margin, effectively locking ethical businesses out of the market. This is not just unfair competition; it is a gateway to systemic abuse.

We know from government enforcement that underpayment alone is widespread. Hundreds of employers have been publicly named for failing to pay the legal minimum wage, with workers collectively short-changed by millions of pounds. In the security sector, where margins are tight and oversight can be inconsistent, the risk is amplified.

Once a provider is operating below a viable charge rate, unlawful practices are not a possibility; they are a necessity.

Tax Evasion and Payroll Manipulation

One of the first casualties of the “cheap bid” model is tax compliance. Payments made “cash in hand”, false self-employment arrangements, and manipulated payroll systems are all used to disguise the true cost of labour.

By avoiding tax and National Insurance contributions, rogue operators can artificially reduce their costs. This not only deprives the Treasury of revenue but creates an uneven playing field where legitimate firms cannot compete.

Recent joint enforcement activity between HMRC and regulators has specifically targeted these practices. In March 2026, coordinated inspections involving HMRC and enforcement partners focused on “suspected tax evasion, unlawful employment, and worker exploitation” within the night-time economy. The message is clear: the authorities understand the link between low pricing and financial misconduct.

Training Malpractice and Licence Fraud

Proper training is expensive. It requires accredited providers, qualified instructors, and genuine assessment.

Where margins are squeezed, training becomes a box-ticking exercise, or worse, a fraud. There have been increasing concerns around malpractice in the delivery of qualifications required for licensing, undermining the integrity of the entire system.

The Security Industry Authority (SIA), established to regulate the industry and enforce licensing standards, has identified training malpractice and licence fraud as key risks. Its enforcement work has included nationwide operations targeting these issues alongside labour exploitation and immigration offences.

When individuals are improperly trained or fraudulently licensed, the implications are serious. Security officers are often the first line of response in critical situations. If they lack the competence or legitimacy to perform their role, public safety is hugely compromised.

Recommended Reading: BS7858 Vetting Made Easy

Illegal Working and Organised Crime

Perhaps the most troubling consequence of the “cheapest bid wins” mentality is its link to organised crime. Labour is the largest cost in security provision, and the easiest way to reduce it unlawfully is through the exploitation of vulnerable workers.

The UK has a long and uncomfortable history in this area. Past investigations revealed thousands of individuals working in the sector without the legal right to do so, including significant numbers of illegal migrants holding or using security licences.

Today, the problem has evolved but not disappeared. Criminal networks exploit illegal migrants, often indebted to traffickers, placing them in security roles where they are paid well below the legal minimum wage, sometimes in cash, sometimes not at all. These individuals are unlikely to report abuse, making them ideal targets for exploitation.

This is not just illegal working; it is a form of modern slavery.

The broader context is important. The UK continues to face challenges around illegal immigration and exploitation, with organised gangs facilitating entry and employment in sectors where oversight can be weak. Security, with its fragmented supply chains and subcontracting practices, is particularly vulnerable.

Enforcement and Industry Response

The good news is that enforcement is becoming more coordinated and more visible. The SIA, working alongside HMRC, police forces and immigration enforcement teams, has stepped up its activity.

Joint operations have led to arrests for unlicensed security work and immigration offences. In one such operation in Brighton, unannounced inspections resulted in multiple arrests linked to illegal door supervision. Several nationally coordinated “blitz” operations have targeted licence fraud, labour exploitation and organised criminal involvement in the sector.

Initiatives such as Operation EMPOWER have also focused specifically on labour exploitation, underpayment and fraudulent employment practices, demonstrating a clear recognition of the problem at a strategic level.

However, enforcement alone can not solve the issue.

The Client’s Responsibility

Here is the uncomfortable truth: clients are not passive victims in this system. The demand for unrealistically low prices is a primary driver of non-compliance.

When a buyer selects a provider whose pricing is clearly below the cost of legal delivery, they are, knowingly or otherwise, creating the conditions for exploitation and criminality. Due diligence cannot stop at checking licences and paperwork. It must include a fundamental assessment of whether the proposed charge rate is viable.

Ask the simple question: how are they doing it?

If the answer is unclear, evasive, or relies on “efficiencies” that defy basic arithmetic, alarm bells should ring.

Breaking the Cycle

The industry must move away from price-led procurement towards value-based decision-making. This means recognising that compliant security provision has a cost, and that cost reflects legal wages, proper training, and ethical employment practices.

Clients should:

• Benchmark charge rates against realistic cost models
• Demand transparency in pay and employment structures
• Audit supply chains, particularly where subcontracting is involved
• Engage with accredited providers and approved contractor schemes
• Access the fair charge rate frameworks published by the International Professional Security Association and the UK Security Industry Compliance Association (URL to be verified before publishing)

At the same time, regulators must continue to increase visibility and enforcement, ensuring that those who break the rules face meaningful consequences.

Final Thoughts

The cheapest bid is rarely the cheapest in the long run. It undermines legitimate businesses, exploits vulnerable workers, and, in the worst cases, channels money into organised crime.

Security is not a commodity. It is a critical service that protects people, property and reputation. Treating it as a race to the bottom on price does not just erode quality; it erodes integrity.

And when integrity is lost, the entire system becomes vulnerable.

The next time a bid crosses your desk that looks too good to be true, remember this: someone, somewhere, is paying the real price.

Protect Your Business From The Compliance Trap

Whether you’re a security buyer conducting due diligence or a provider competing against non-compliant firms, the right tools make all the difference. GuardPass connects you with the UK’s largest pool of SIA-licensed professionals—properly verified, compliantly sourced. Combine that with BS7858-compliant vetting through GuardCheck, and you remove the legal and reputational risk that cheap procurement creates.

Find compliant security officers on GuardPass.

The post Charge Rate Reality: Why the Cheapest Bid Can Fund Organised Crime appeared first on GuardPass Resources.

In recent years, the UK private security industry has approached a crossroads. We are operating in an environment shaped by shifting threat dynamics, significant legislative changes and an increasingly vocal call for professionalisation across every level of our sector. In this article, I want to explore whether the reforms we are witnessing represent an evolution, steady progress built on decades of collective effort, or a revolution, a disruptive shift in how security is regulated, delivered and perceived in the UK.

From my vantage point as a security industry professional deeply invested in raising standards and supporting colleagues across the discipline, I firmly believe we are witnessing both evolutionary foundations accelerated by revolutionary momentum. Let’s unpack what that means in practice, starting with the pivotal players in this story.

The Security Industry Authority: The Regulatory Bedrock

At the heart of UK security regulation sits the Security Industry Authority (SIA), the statutory body established under the Private Security Industry Act 2001 to regulate key areas of our profession. The SIA’s role in licensing individuals, setting minimum standards and administering the Approved Contractor Scheme (ACS) has, over the last two decades, provided a critical structure on which legitimacy and public trust have been built, after several decades of decaying professional and behavioural standards, in some sectors of the industry.

While many of us may sometimes feel constrained by regulatory burdens, it’s important to recognise that a well-regulated sector protects everyone, clients, officers and the general public alike. The licensing regime ensures that those entering our field are properly vetted, trained and held to standards that the public can depend on. And the ACS, despite its voluntary nature, was established with the intention of being a benchmark of quality and professionalism, something that clients, particularly in the private and public procurement space, increasingly ask for when sourcing security services.

That said, there is always room for evolution. Critics sometimes argue, and with some justification, that the ACS doesn’t represent value for money, with many poorly run companies managing to attain approved status. The cost and compliance complexity also tends to put off emerging small businesses or specialist niche providers. So, continuing to refine the ACS and making it relevant to the realities of the 2020s and beyond is, thankfully, already a priority.

Recommended Reading: Insights Into the Approved Contractor Scheme

S12 Leadership Group: A New Collective Voice

Enter the Security Guarding Leadership Group, S12. Officially launched in 2025, the S12 was formed to act as a collective leadership forum that brings together senior figures from across guarding and security services to work in concert with government, the SIA, and other stakeholders. Its goal: to “raise industry standards, help shape policy, accelerate the implementation of critical legislation and ensure that a diverse range of voices are heard to inform future decisions.”

In many ways, S12 reflects an important shift, an industry recognising the value of aligning its thought leadership and decision-making capability in a way that government can engage with clearly and constructively. The fact that it has already met with Security Minister Dan Jarvis at the International Security Expo and has established regular engagement with both the Home Office and the SIA is testament to its early impact.

However, whilst the intentions of the S12 are commendable, and I genuinely believe the initiative has the potential to shape meaningful reform, I have to voice a genuine concern that has been echoed across boardrooms and breakrooms alike. Despite recent new additions to the S12 central leadership board, there remains an absence of representation from non-SIA Approved Contractor Scheme companies. 

This omission, even if unintentional, risks narrowing the range of operational perspectives and lived experiences feeding into discussions that are meant to represent the whole industry. It also means that the S12 does not appear to achieve the stated desire of the Government, in becoming the all “inclusive” industry representational body that was requested. True leadership must not only bring together senior stakeholders from large firms and associations, but actively include those voices, from over 10,000 companies that operate outside the traditional ACS paradigm and who are often closest to frontline delivery challenges.

To truly be a representative leadership forum, S12 must continue to open its doors, not just to more organisations, but to the diversity of business models and operational contexts that reflect today’s multifaceted market. Looking inwards, to the usual traditional stakeholders, is something that the SIA has done for the last two decades, and sadly, it has achieved very little in the way of industry improvement. We all still hope that the S12 will do something different, not simply dress big businesses, with the biggest reasons to maintain the status quo, in a new suit of clothes.

Recommended Reading: Mandatory Security Business Licensing: A Step Towards Reform

Membership Organisations: Building Professional Foundation

Alongside regulatory and leadership developments, the growth of membership organisations has played a transformational role in shaping the professional landscape of UK security.

Take, for example, the International Professional Security Association (IPSA), the UK’s longest-established trade association, championing career pathways, professional recognition and support across the broad spectrum of security disciplines. IPSA’s mission to ensure professionalism, advocate for fair pay and working conditions, and provide a community for frontline professionals has been a cornerstone for raising industry standards.

IPSA’s commitment to providing training, mentoring and welfare support reflects the genuine professional heart of our sector. It’s not just about badges or uniforms, it’s about career development, skills and respect. Its success in bringing thousands of security officers, technicians and companies under a unified association umbrella underscores the growing appetite for professional identity and community.

On the education and credentialing front, organisations like the International Foundation for Protection Officers (IFPO) are expanding opportunities for quality education and certification in specialist security disciplines. IFPO’s focus on competence and continuous learning is exactly the kind of thing that elevates performance and credibility in the field.

There are other bodies too, including the Guild of Security Industry Professionals, the British Security Industry Association (BSIA), and more niche collectives, all contributing to a richer ecosystem of professional support, advocacy and standards.

These membership organisations collectively represent the evolutionary muscle of our industry. Institutions that have grown organically over decades, responding to real needs from the ground up.

The Role Of Government Leadership: Dan Jarvis And Positive Momentum

After year after demoralising year of Home Office failure to implement the recommendations of the security industry, and even its own regulator, the SIA, we’ve now seen notable positive action from the UK government, particularly through the office of the Security Minister, Dan Jarvis MBE. In recent months, Minister Jarvis has demonstrated a clear commitment to engaging with industry leaders, supporting regulatory refinement and promoting collaboration between government, the SIA and private security stakeholders.

This is not mere symbolism. By bringing the SIA under the Department of Homeland Security (or is that the yank’s term? I digress.) portfolio, the government has signalled that the private security industry matters, not just to economic output, but to national safety, public confidence and resilience in the face of evolving threats.

We have also seen a firm focus on the implementation of Martyn’s Law, stronger screening requirements and enhanced public protection measures. All areas where government leadership has been essential. Although not without its implementation challenges, this approach demonstrates a willingness to act, engage and support, qualities that we have seen precious little evidence of over the years, but when sustained, can truly elevate our industry’s contribution to UK society.

Evolution AND Revolution: Where We Go Next

So, are we seeing an evolution or a revolution?

It’s both.

Evolution, because decades of professional association growth, regulatory foundations, and years of incremental improvement have brought us to this point. Organisations like the SIA, IPSA, IFPO and others have quietly and persistently nudged this industry toward higher standards.

Revolution, because new leadership paradigms like S12, combined with active government engagement, have the potential to accelerate change in ways that were unimaginable just a few years ago, provided that broad representation, transparency and genuine inclusion remain at their core.

For meaningful reform to continue, we must champion professionalism over politics, inclusion over exclusion, and collaboration over competition. Our industry is too important, too integral to public safety and national security, to be anything less than effective, credible, and respected.

It’s time we asked not just “are we progressing?” but “are we progressing together?” And in that collective spirit lies the path to positive UK security industry reform.

Building For The Industry We Want

Reform at the policy level only succeeds when it’s matched by operational excellence on the ground. Whether you’re an ACS-approved contractor or an emerging operator building your reputation, the fundamentals remain the same: recruit the right people, vet them properly, and invest in their development.

GuardPass supports security companies of all sizes with access to the UK’s largest pool of SIA-licensed candidates, BS7858-compliant vetting through GuardCheck, and CPD training via GuardSkills. The tools exist to raise your standards today, regardless of where the policy debate lands tomorrow.

Book a demo and see how GuardPass can support your contribution to a more professional industry.

The post Evolution Or Revolution? The Path To Security Industry Reform appeared first on GuardPass Resources.

Let’s be honest: the private security industry is often misunderstood, both by the public and by policymakers. Yet, it’s a sector that quietly underpins the safety of millions across Europe. Having spent decades on the ground and in management, I’ve seen firsthand how the UK’s approach to private security stands apart from our European neighbours. This isn’t just about paperwork or politics; it’s about how we keep people safe, how we train our staff, and how we build trust in a profession that’s too often overlooked.

Market Size and Structure: Not All Security Is Created Equal

The UK’s private security sector is a heavyweight. With revenues nudging £9 billion and a workforce of over 400,000, it’s a major employer and a critical cog in the national safety machine. London, of course, is the epicentre, where the stakes are highest and the standards are (or should be) at their sharpest. The sector’s growth has been fuelled by public sector outsourcing, rising crime, and, frankly, the police being stretched to breaking point.

Now, zoom out to the EU. The numbers are even bigger: €76 billion in revenue, 2 million people employed. Germany leads the pack, followed by France, Spain, and Italy. But here’s the rub: the EU market is fragmented. You’ve got everything from global giants to tiny local firms, all jostling for contracts in manned guarding, electronic security, cash handling, and event management. It’s a patchwork, not a tapestry.

Regulation: The SIA and the “Gold Standard” (Or Is It?)

Here in the UK, we love a bit of regulation. The Security Industry Authority (SIA) is the gatekeeper, and if you want to work in security, you need their licence. No badge, no job. The SIA regime is strict: mandatory training, criminal record checks, security vetting standards, and ongoing professional development. Frontline operatives must display their licence at all times whilst on duty, no exceptions. Well, almost none. Store detectives swerve this, for obvious reasons. Managers and directors need non-frontline licences if they’re supplying staff. There’s an “in-house” exception, as it was forgotten about in the PSIA 2001, but it’s narrow and getting narrower.

Contrast this with the EU. There’s no Brussels-based SIA. Each country does its own thing. Belgium and Spain are famously strict, with lots of hoops to jump through. Germany and France? Big markets, but regulation is often regional or even municipal. Training and vetting requirements can vary wildly, even within the same country. If you’re licensed in one EU state, don’t expect to waltz into another and start work. Cross-border recognition is, frankly, a mess.

Brexit? It’s made things even more complicated. The UK is now free to diverge from EU rules, and we’re already seeing differences in how investments and reporting are handled. For the average security officer, it means more paperwork and less mobility.

Training and Professional Standards: The Devil’s in the Detail

The SIA sets a minimum bar for training, but let’s be clear: it’s just that, a minimum. Good employers go further, offering site-specific and ongoing training. The SIA’s Approved Contractor Scheme (ACS) is supposed to recognise the best of the best, but as anyone in the industry knows, ACS status doesn’t always guarantee quality on the ground.

Across the EU, training is a mixed bag. Some countries demand extensive courses and background checks; others are more relaxed. The European Confederation of Private Security Services (CoESS) has been banging the drum for harmonisation, but progress is glacial. Until there’s real consistency, standards will remain uneven.

Recommended Reading: Building a Strong Security Culture

Trends and Challenges: What’s Really Happening on the Ground?

UK

• Integration with Police: Increasingly, UK private security is plugging gaps left by the police, especially during crises like the pandemic. We’re not the police, but we’re often the first responders.
• Counter-Terrorism: New laws like Martyn’s Law are bringing the UK’s private security into the heart of national counter-terrorism strategies. This is a huge responsibility and a huge challenge.
• Tech Adoption: The UK is leading the way in electronic surveillance and integrated systems. But technology is only as good as the people using it.

EU

• Event-Driven Growth: Major events (think football tournaments, festivals) drive demand for security. But when the crowds go home, so do the jobs.
• Digital Transformation: The move to contactless payments and digital security is reducing the need for old-school cash-in-transit services.
• Regulatory Fragmentation: The lack of harmonised standards is a real headache for companies and professionals alike.

Conclusion: Where Do We Go from Here?

The UK’s private security industry is, in many ways, a model of centralised regulation and professionalisation. But we shouldn’t get complacent. The SIA system is far from perfect, and standards on the ground are at best “patchy”. Across the EU, diversity is both a strength and a weakness: local knowledge is invaluable, but the lack of harmonisation holds the sector back.

As the industry grows and evolves, the pressure for higher standards and greater consistency will only increase. For now, the UK leads in regulation and training, but we must keep pushing for real professionalism, because at the end of the day, security is about people, not just policies.

While the UK and EU private security industries share common drivers, rising crime, public sector outsourcing, and technological change, the UK stands out for its centralised, rigorous regulatory regime and professional standards. EU countries, by contrast, display significant diversity in licensing, training, and oversight, reflecting local legal and market conditions. 

Brexit has accentuated these differences, with the UK moving towards greater regulatory autonomy. As the sector continues to grow and evolve, calls for harmonisation and higher standards across Europe are likely to intensify, but for now, the UK remains a model of centralised regulation and professionalisation (well, if the new S12 group performs as we all hope). 

Stay Ahead with the UK’s Trusted Security Hiring Platform

While the UK and EU private security industries share common drivers—rising crime, public sector outsourcing, and rapid technological change—the UK leads with its centralised regulation and clear compliance standards. But leadership requires momentum.

If you’re serious about building a trusted, high-performance security team, GuardPass gives you the tools, talent, and technology to do it right. From building a flexible guard pool to accessing a purpose-built security recruitment platform, we help you meet today’s demands with tomorrow’s expectations.

Hire better with GuardPass.

The post The UK Private Security Industry vs. the EU: Key Differences and Trends appeared first on GuardPass Resources.

For many years, the Security Industry Authority (SIA) has consulted with an amorphous group of security industry “stakeholders” to look at policy, planning and development of the industry. Many would say that during this time, very little change or improvement actually took place, possibly due to the fact that these “stakeholders” were doing very nicely financially, thank you. Change did not suit their business plans. Now, however, the SIA has been placed under the umbrella of the Home Office’s Homeland Security division, and things seem to be changing.

The first recent change was the formation of the new S12, a UK security industry consultation group. The arrival of the S12, “security guarding leadership group”, could not be more timely. With increased demands on the sector caused by the introduction of Martyn’s Law, there is a genuine chance for the organisation to become a catalyst for lasting, practical improvement. Get it wrong, however, and there is a grave danger that an already cynical industry will view the S12 as just another defensive veneer and PR face for the industry, whilst leaving systematic problems untouched.

What Does the S12 Security Guarding Leadership Group Aim to Do?

Officially launched during the International Security Expo at London’s Olympia earlier this month, the S12 is being billed as a cross-industry forum to raise standards, shape policy, and accelerate implementation of key legislation. The group’s main aims include broader integration with policing, the creation of a Security Skills Academy and improved professional standards across the contract guarding sector. 

This sounds good so far, uncontroversially so, and indeed the security minister, Dan Jarvis, attended the launch, giving a significant speech to the assembled members. His speech is available in full here.

Who’s In the Room? Meet the S12 Board

The composition of this group is critically important. Credibility depends on it, and the S12 is off to a good start. Highly respected Paul Evans (Carlisle) has been named chair, with equally well-regarded Peter Harrison (FGH Security) as deputy chair; the group includes senior executives from national providers, SMEs and trade bodies, and has observers from the National Security Inspectorate and other governance outfits. 

Members are committed to two-year terms and monthly meetings, with each member sponsoring at least one initiative. There is also a commitment to introduce wider ‘sub-working groups’, spreading involvement further across the industry—full list of board members below.

S12 Security Guarding Leadership Group Members

• Paul Evans, CEO, Carlisle Security Services Limited (Chair)
• Peter Harrison, Managing Director, FGH Security (Deputy Chair)
• Gary Culloden, Managing Director, Security, Mitie
• Tim Kendall, President, G4S Secure Solutions (UK&I)
• Rachel Fleri, Managing Director, Specialist Security
• Ahmad Rafique, CEO, SSG Support Services
• Claire Shrosbree, CEO, CYS Security
• Alex Booth, Managing Director, AURA UK Services
• Paul Howe, Managing Director, Venture Security Management,
• John MacAskill, British Security Industry Association (BSIA)

Observation and Governance Roles

• David Ward, City Security Council
• Richard Fogelman, National Security Inspectorate (NSI)

From S10 to S12: A Move Toward Inclusion?

When the initial idea of a security guarding leadership group was announced, it was framed as the S10. This was met with substantial criticism as many engaged individuals were automatically excluded from participation. This led to the group being widely viewed as just a formalisation of the SIA’s ‘usual’ consulting stakeholders. Stakeholders that had achieved little in the way of security industry improvement over the years. 

Indeed, I was one of the critics of the initial idea for just that reason. To its credit, these objections were taken on board rapidly, and a more open and inclusive organisation was proposed, with membership across numerous categories being democratically voted to the board.

If the S12 can convert its new and unprecedented access to Government and regulators into positive, concrete change, it will have achieved its goals and gained industry respect.

The Challenges Ahead

There are, however, three quick and uncomfortable truths the S12 Security Guarding Leadership Group must confront:

1. Representation is not the same as reach.

The group’s membership includes heavyweights and trade association nominees, but voices from the trenches, small guarding firms, security operatives themselves, and front-line client procurement teams need structured, funded channels into S12’s policymaking. Token representation on a committee is not the same as systemic pulling power over tendering practice, low-margin outsourcing and the use of casualised labour models that corrode standards. 

2. Standards without enforcement create perverse incentives. 

Raising the bar for training and conduct matters, but it must be paired with consistent audit, accessible escalation paths for contract breaches, and proportionate sanctions for malpractice. Otherwise, the market will continue to reward the providers who cut corners on wages, training and supervision. S12’s promise to work with the SIA and regulators is necessary; now it needs to define measurable KPIs and public reporting on progress. 

3. Perception is policy. 

The sector still carries reputational baggage. Ministers and officials will listen to S12, but they will also ask whether its conclusions reflect the real world or merely the interests of larger incumbents. That’s not paranoia; there are already public expressions of scepticism from parts of the industry suggesting S12’s composition risks privileging bigger players. For S12 to be credible, minutes, membership criteria, voting procedures, and conflict of interest declarations should be transparent and easily accessible. 

Recommended Reading: Mandatory Security Business Licensing

Setting a 100-Day Roadmap

So, how is the S12 going to get started? Momentum is important, and the industry will be watching, so if I were setting the first 100-day deliverables for the S12, they would look something like this:

1. Publish a one-page public roadmap with named owners. 

We don’t need vague commitments; we need named people, milestones and measurable outcomes for the Skills Academy, a sector-wide training baseline and proposals for procurement reform. Transparency builds accountability and reduces the ‘closed circle’ perception.

2. Launch a rapid-response standards task force focused on contracts and procurement. 

Building on the minimum charge rate framework published by the IPSA, and created by John Lambert, the group should produce a short, client-facing code of practice for procurement teams (public and private) that disincentivises the race to the bottom.
It should be short, enforceable, and include simple mechanisms for clients to check whether a provider meets minimum pay, training and supervision thresholds.

3. Commit to worker engagement. 

Create a standing workers’ panel and fund independent surveys of front-line staff. If the industry is serious about professionalism, it must listen to the people who do the work night after night, day after day. Their insights on rota design, supervision levels and unrealistic client expectations are often the fastest route to meaningful improvement. This is no easy task, and the S12 will inevitably need to work with organisations such as the IPSA, Guild of Security Industry Professionals and IFPO.

Pitfalls to Avoid

The S12 has access to the minister and to regulators. Valuable political capital. But the group must avoid two traps. 

First, capture: if S12 becomes a lobbying group for privileged commercial interests rather than a public-interest forum, ministers will move on, and the sector’s window to influence policy will shut. 

Second, inaction: announcing committees, working groups, and further consultations is easy; delivering systemic change is not. The political appetite for fixes will be finite unless S12 demonstrates early wins. 

Recommended Reading: Security Industry Business Challenges

Closing Thoughts: Can the S12 Earn Industry Trust?

This industry is capable of self-improvement. We have competent professionals, committed firms, and a regulator that can be constructive despite historically being hindered by its Home Office overlords. The S12 might just be the mechanism that turns scattered initiatives into a coherent, credible programme that elevates guarding from a poorly regarded tactical commodity to a recognised, respected, trained profession that serves public safety.

Credibility and respect need to be earned. The S12 must be brutally practical, setting target outcomes, not stating aspirations. It needs to publish data, not PR platitudes. Crucially, it needs to show that the UK security industry can effectively protect the public whilst advancing the legitimate commercial interests that sustain the workforce. 

If it does that, politicians will listen and reputations will mend. 

If it doesn’t, it will become just another ‘old boys club’, fuelling more cynicism and achieving nothing for nearly half a million workers in the sector.

Either way, the industry will be watching.

Building a Fairer Future for Security Employers

As the S12 group aims to raise standards and open up industry influence, the question remains — who gets to benefit from these changes? At GuardPass, we’re making sure it’s not just the biggest players. Our platform gives security companies of all sizes a direct route to qualified, licensed professionals — without relying on legacy networks or outdated recruitment methods. 

Discover how we’re building a fairer, faster hiring ecosystem at GuardPass.

The post The New “S12” Security Group: Who Are They and What Is It All About? appeared first on GuardPass Resources.

A single SIA compliance failure cost Titan Security Services 24/7 Ltd over £4,000 in August 2024. The company directors were prosecuted after deploying a door supervisor with a suspended SIA licence at a Bristol nightclub. Despite claiming 20 years of experience in the security industry, they told Bristol Magistrates’ Court they “did not realise online licence checks existed”.

This case demonstrates how quickly SIA compliance failures can escalate into criminal prosecution, devastating fines, and public humiliation that destroys business reputations.

Titan Security’s Nightmare: When Ignorance Becomes Criminal

In October 2023, Mohammad Nazar was found working at a nightclub in Kingswood with an SIA licence that had been suspended eight months earlier. He was deployed by Titan Security Services 24/7 Ltd, whose directors, Aaron Williams and Ashley Fido, faced criminal prosecution for the violation.

The Brutal Financial Reality

• Each company director: £753 fine + £293 victim surcharge + £342 prosecution costs = £1,388
• Company penalty: £1,388
• Total cost: Over £4,000 for one incident

The Reputational Execution

The case became a government press release, creating permanent public records linking the company name to criminal prosecution for regulatory violations. In an industry built on trust and reliability, this kind of publicity can be business-ending.

The SIA’s Criminal Investigation Manager stated: “Our robust licensing system is there for a reason: to protect the public. Door supervisors play a vital role in keeping people safe and are specially trained to respond to dangerous situations and safely de-escalate conflict. When security companies and individuals flout these regulations, they put people at risk.”

Criminal Penalties Are Waiting for You

The Security Industry Authority operates under the Private Security Industry Act 2001, with powers to impose severe penalties for licence condition breaches. These penalties include:

• Written warnings that affect future licensing decisions
• Licence suspension or revocation
• Criminal prosecution under Section 9 of the Act

Breaching SIA licence conditions is a criminal offence, not merely an administrative violation. This means companies and individuals face criminal records, substantial fines, and prosecution costs.

The SIA Compliance Minefield: One Mistake Ends Everything

Front-line licence holders must comply with strict legal obligations:

• Wear licences visibly at all times during designated activity
• Report lost or stolen licences to both the SIA and the police
• Notify the SIA of any convictions, cautions, or charges within 21 days
• Report name or address changes within 42 days
• Produce licences for inspection when requested by police, SIA members, or authorised persons
• Do not deface or alter licences in any way

Companies employing security staff must ensure these conditions are met. Failure to do so can result in criminal prosecution, as demonstrated by the Titan Security case.

Why Companies Like Yours Are Failing Right Now

The Titan Security case reveals a fundamental problem: companies operating without proper SIA compliance systems. Despite 20 years in the security industry, the directors claimed ignorance of basic licence checking procedures.

This highlights the compliance failures happening in your industry today:

Inadequate Licence Monitoring: Companies without systems to verify current licence status risk deploying staff with suspended or revoked licences, leading to criminal prosecution.

Poor Record Keeping: Maintaining accurate records of staff training, licence status, and compliance activities is essential but often neglected.

Training Documentation Gaps: Security staff must complete ongoing CPD requirements. Companies unable to demonstrate continuous professional development face compliance issues during audits.

The Business Death Spiral Starts Here

Beyond immediate fines, SIA compliance failures create cascading business consequences:

Contract Termination: Clients increasingly include strict compliance clauses in security contracts. Regulatory violations can trigger immediate contract termination.

Insurance Void: Professional indemnity and public liability insurers are becoming stricter about compliance requirements. Violations can void coverage or increase premiums significantly.

Operational Collapse: When staff have licences suspended or revoked, companies face immediate service delivery problems and struggle to find replacement licensed personnel.

Recruitment Crisis: Companies with compliance violations face increased regulatory scrutiny and may struggle to attract quality staff.

GuardSkills: Your Last Line of Defence Against SIA Compliance Disaster

GuardSkills provides a comprehensive training and SIA compliance management solution designed specifically for UK security companies. The platform offers:

CPD-Certified Training

Over 50 CPD-certified courses delivered through a single dashboard for assigning training, monitoring completion, and downloading reports.

Audit-Ready Documentation

The platform generates instant audit reports for inspection readiness, helping companies demonstrate ongoing compliance.

Mobile Learning

Short, engaging videos accessible on mobile devices allow security staff to complete training during downtime.

Professional Development

Role-relevant content that meets CPD standards supports career progression whilst maintaining SIA compliance requirements.

Flexible Pricing

Credit-based pricing starts at £100, with each seat valid for a year and reassignable as team composition changes.

The Math That Should Terrify You

The mathematics are stark: the Titan Security case cost over £4,000 for a single violation involving one employee. This represents only the immediate financial cost, excluding reputational damage, potential contract losses, and ongoing regulatory scrutiny.

Compare this to GuardSkills’ starting price of £100 for comprehensive compliance training and documentation capabilities. The platform addresses the fundamental compliance challenges that lead to prosecution: inadequate training records, missing CPD documentation, and inability to demonstrate ongoing professional development.

Act Now Before You Become the Next Case Study

Companies relying on manual systems and spreadsheets are vulnerable to the same fate as Titan Security Services. The question isn’t whether regulatory scrutiny will occur—it’s whether you’ll be ready when it does.

GuardSkills provides the CPD-certified training and audit-ready documentation that eliminates regulatory risk. For security company directors serious about avoiding criminal prosecution and business-destroying compliance failures, the choice is clear.

The cost of non-compliance isn’t just financial—it’s reputational, operational, and potentially criminal. A single compliance failure can destroy decades of hard work. Don’t wait for compliance failures to destroy your business. In the security industry, SIA compliance isn’t optional—it’s essential for survival.

Watch the demo here and protect your business from the devastating costs of non-compliance.

The post Your Next SIA Compliance Failure Will Destroy Your Business — Just Ask Titan Security appeared first on GuardPass Resources.

It has been coming for what seems like aeons, but at long last, Martyn’s Law, the Terrorism (Protection of Premises) Act 2025, has been signed off by the Government. Setting up the regulatory system, procedures, and compliance enforcement will still take some time, with a practical roll-out pencilled in for commencement sometime in early 2027. 

Much has been written about the background to this new law and its importance, and I will not go over old ground. Here I’d like to give security managers and those responsible for the safety of qualifying premises an indication of the top 10 areas they need to be considering to not only get a head start on legal compliance, but to ensure your sites are as safe as possible from the results of terrorist action.

1. Establish Legal Obligation

Is the site/event deemed small enough for Martyn’s Law not to apply? That is to say, does it only hold a maximum of 199 persons? 

Where the Act applies, does the site qualify as a “Standard Tier”, ie, a 200 – 799 person maximum site or event capacity? 

or “Enhanced Tier” for sites and events over 800 people.

• If the TPPA2025 does not apply to your site due to the low capacity driven risk profile, please be aware that there may be nearby buildings or sites that may be at higher risk.
  If this is the case, consider, understand, and take reasonable steps to mitigate the effect on your property or site of an incident taking place nearby. Consultation with other local businesses will have significant mutual benefits. 
• Should your venue or business fall in the “Standard Tier” category, the steps you will need to carry out are, on the whole, simple, basic and largely common sense.
• For “Enhanced Tier” sites or events, the Act requires somewhat more compliance activity from owners and management.

NB: For the full responsibilities of Standard and Enhanced Tier buildings or events, and the idea behind the creation of the legislation, please visit the official government announcement. 

2. Review Staff CT Awareness & Perform Appropriate Training

Do you have staff on site with counter terrorism training, and is a CT incident plan in place?

• Arrange ACT online training for all staff in security roles and consider basic awareness training for public-facing and engineering/maintenance staff members as well. 
• Ensure that all staff members are trained and aware of the nature of threats, likely attack methodologies, and are taught to identify the signs of hostile reconnaissance and take appropriate action. 
• It is vital that regular refresher training takes place on site and is fully documented, as all staff must be clear in their responsibilities and actions if a CT plan needs to be activated.

NB: Check out the resource by ProtectUK for more details.

3. Assess Access Control

Do you have an appropriate access control system and procedure?

• Consider the use of physical restrictive access measures, technology and trained staff to detect and mitigate risks from intruders carrying concealed weapons or explosives. 

NB: For advice, guidance and signposting to appropriate equipment and suppliers for all security-related hardware, I strongly recommend the Secured by Design website. 

4. Evaluate Perimeter Security

Where applicable, is your site perimeter secure and are all doors and windows locks in good condition? 

• Perform basic maintenance or replace any substandard locks or closing mechanisms. 

NB: For detailed guidance, explore the resource by NPSA.

5. Audit CCTV

Where applicable, is your CCTV system providing clear recorded footage of all entrances, exits, external and public areas? Is it monitored when the site is open?

• Revise or update the CCTV cameras and recording system to provide full coverage of vulnerable or high-risk areas, in all light conditions. 
• Where applicable, ensure that an SIA-licensed CCTV operator is on duty to monitor your system when needed. 

NB: Check out ProtectUK’s resource on CCTV operation. 

6. Ensure Safe Movement During Evacuation / Invacuation / Lockdown

Have you evaluated the layout of your site and designated escape routes to ensure a safe and rapid site evacuation/invacuation or lockdown?

• Keep all fire exits and escape routes clear of obstructions. Attempt to position furniture or equipment to minimise “choke points” and maximise the ease of movement in an emergency. 
• Ensure effective communication measures are in place to clearly and concisely inform staff and visitors what is happening and what they need to do. 

NB: Check out HSE’s resource on planning for event safety and emergencies. 

7. Review External Environment

Have you examined the open areas around your site to mitigate the risk of a “vehicle as a weapon” attack?

• Review the approach to your building or site, and where appropriate, look at the built environment and methods. Use these to prevent or hinder the progress of a vehicle driven with hostile intent. 

NB. Review the official Hostile Vehicle Mitigation (HVM) guidance for more details. 

8. Consider Advanced Trauma Care Training Needs

Do any of your staff have advanced trauma training?

• Where appropriate, consider training a percentage of personnel in D13 / FREC3 first responder emergency trauma first aid. This will ensure the best possible outcomes for those injured in any serious incident, in or around your site. 

NB: One of the most well-respected sources of advice and guidance on pre-hospital care is the Royal College of Surgeons of Edinburgh. 

9. Conduct Blast Mitigation

Have you implemented blast effect mitigation measures?

• Consider minimising the use of interior glass panels or using clear plastic film on windows and areas of glass to minimise fragmentation. 
• Use heavyweight materials for furniture and fittings in public areas to reduce the chance of fragmentation and to help divert blast and absorb shrapnel or debris.

NB: For more information, check out the resource by the National Protective Security Authority. 

10. Monitor Threat Levels

Are you aware of the current threat levels, and where applicable, do you have a building response plan?

• Where appropriate, write an emergency response plan. 
• Brief your staff when threat levels are heightened and adjust your procedures, staffing and general readiness when required. 
• Assign someone to check on the “UK National threat level” and the “building response level” daily. 
• Note the actions you take. If you have an emergency response team, ensure they are trained and tested regularly. 

NB: Visit the official government website covering guidelines on threat levels and building response plans for more information.

Stay Compliant: What Martyn’s Law Means for Your Site’s Future

I hope that this provides a decent starting point for counter terrorism awareness and legal compliance. The body tasked with the enforcement and regulation of Martyn’s Law is our very own Security Industry Authority (SIA), which will be releasing much more in the way of guidance over the next year and a half, so please keep an eye on their website for updates.

GuardPass can support your site’s compliance journey and help you keep up with SIA licensing changes with access to licensed professionals, quick onboarding, and BS7858 vetting solutions. Tap into our trained talent pool and ensure you’re legally prepared for Martyn’s Law. 

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