The complexity of the directive suggests that in fact more than two consultation periods will be necessary if measures are to be fully workable. However, political priorities appear to mean that the final legislation is to be adopted more quickly than ideally it should be, with the consultation to be finished by the end of October so that the regulations can be finalised this year and come into force in April 2010.

Blake Lapthorn are confident that there are ways in which organisations will be able to supply and use temporary workers without too much extra administrative burden or cost, especially given the increased tax advantages that can be enjoyed when agency workers are used. Blake Lapthorn believe there is even “a possibility that judicious use of legitimate tax efficient models may even end up keeping the implications of implementing AWD adjustments cost neutralâ€Â?. However, users and suppliers of agency workers will need to adopt new procedures and contract models to minimise this burden.

The article states that the majority of UK spend on temporary agency workers is on skilled, professional and technical workers who already enjoy reasonable pay rates and who will be comparatively unaffected. While there may be particular challenges for suppliers and users of lower paid agency staff, Blake Lapthorn claim there will be workarounds for most types of supply into most types of end user.

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