AWR: Agency Workers Regulations Explained (2026)

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The Agency Workers Regulations (AWR) give people supplied by an agency the right to the same basic pay and working conditions as the client's own staff once they've done 12 weeks in the same role, and some rights from day one. This guide explains who the rules cover, what you're entitled to and when, and what they mean if you work in broadcast through an agency, an umbrella company or your own limited company.

Last updated November 2026. This is general guidance, not legal advice.

AWR in 60 seconds

The Agency Workers Regulations 2010 came into force on 1 October 2011 and still apply in the UK.
They cover temporary workers supplied by an agency to work under the supervision and direction of a client (the "hirer").
From day one, you can use the hirer's shared facilities and must be told about relevant job vacancies.
After 12 weeks in the same role with the same hirer, you're entitled to the same basic pay and working conditions as a comparable employee.
Freelancers who are genuinely in business on their own account, including many limited company contractors, are usually outside the rules.

Who counts as an agency worker?

You're likely to be an agency worker if:

you have a contract with an agency (an employment contract or a contract to do work for it), and
the agency supplies you to a hirer, and you work temporarily under the hirer's supervision and direction.

That includes freelancers paid through an agency's PAYE payroll and, in many cases, freelancers paid through an umbrella company.

You're usually not an agency worker if:

you're genuinely self-employed and in business on your own account, treating the hirer as a client or customer
you were introduced by an agency but are employed and paid directly by the company
you work for an in-house temporary staffing team run by the hirer itself

Working through your own limited company doesn't automatically take you outside the rules. What matters is how the work actually happens. If you're supervised and directed like a temp, you may still count as an agency worker. If you run a genuine business and the hirer is your client, you probably don't.

Your rights from day one

From the first day of an assignment, the hirer must give you:

Access to shared facilities on the same basis as its own staff, such as a canteen or food and drink facilities, workplace childcare and transport services (for example a staff bus).
Information about job vacancies, so you have the same chance as employees to apply for permanent roles.

The hirer can only refuse these if it can objectively justify treating you differently.

Your rights after 12 weeks

Once you've worked in the same role with the same hirer for 12 calendar weeks, you're entitled to the same basic terms you'd have had if the hirer had recruited you directly. That covers:

Pay, including basic pay, holiday pay, overtime, shift allowances and bonuses linked to your own performance
Working time, including rest breaks, night work limits and annual leave
Paid time off for antenatal appointments

Some things don't count as "pay" under the regulations, so you're not entitled to them:

occupational sick pay and pensions
redundancy pay and enhanced maternity, paternity or adoption pay
bonuses that aren't linked to your own performance, such as loyalty or company-wide bonuses
benefits in kind, such as a company car or health insurance
share and option schemes

How the 12-week qualifying period works

The 12 weeks are calendar weeks, and they count however many hours you work. One shift in a week still counts as a week. Some breaks pause the clock without resetting it, including:

breaks of up to six weeks between assignments with the same hirer in the same role
sickness or injury (up to 28 weeks)
annual leave, and the hirer's planned shutdowns
pregnancy, childbirth and maternity, adoption and paternity leave

The clock starts again if you have a break of more than six weeks, or if you move to a new role with the same hirer that is substantively different. There are anti-avoidance rules to stop agencies and hirers structuring assignments just to stop you qualifying.

What's changed since the rules came in

April 2020: the "Swedish derogation" ended. Agencies can no longer use pay-between-assignments contracts to opt workers out of equal pay after 12 weeks.
April 2020: Key Information Document. Agencies must give you a Key Information Document before you agree terms, setting out the type of contract, the minimum rate of pay, who pays you, any deductions or fees, and your holiday entitlement.
October 2026: longer time to bring a claim. Under the Employment Rights Act 2025, the time limit for most employment tribunal claims, including AWR claims, is six months instead of three for breaches from 1 October 2026.
Coming: guaranteed hours. The Employment Rights Act 2025 also extends new rights around guaranteed hours and shift notice to agency workers. The detail and timing are still being finalised.

What AWR means in broadcast

Broadcast relies heavily on freelancers booked for shifts, events and short runs, so it's worth knowing which side of the rules you're on.

Paid via an agency's PAYE payroll or an umbrella company: you're likely to be an agency worker, so the day-one and 12-week rights apply. Check your Key Information Document.
Working through your own limited company: you're outside the rules if you're genuinely in business on your own account. Agencies often ask limited company contractors to confirm they're opting out of the separate Conduct Regulations, but that's a different set of rules from AWR. IR35 is separate again. See our guide to IR35 for broadcast freelancers.
Self-employed with a Lorimer letter: you're treated as running your own business. See our guide to Lorimer letters.

Who's responsible for what?

The hirer is responsible for your day-one rights (facilities and vacancies). The agency is responsible for making sure you get equal pay and conditions after 12 weeks, and needs accurate information from the hirer about what a comparable employee receives. If you think you're not getting what you're entitled to, you can ask the agency in writing for information about the basic terms of comparable staff. It must reply within 28 days.

AWR FAQs

What does AWR stand for?

The Agency Workers Regulations 2010, the UK rules that give agency workers equal treatment with a hirer's own staff.

Does AWR apply to part-time agency work?

Yes. The 12-week qualifying period counts calendar weeks, not hours, so even a few hours a week counts.

Do I get the same pension as permanent staff after 12 weeks?

No. Occupational pensions aren't included in equal treatment, although you may be automatically enrolled into a workplace pension by whoever employs you for tax purposes.

Does AWR apply if I work through my own limited company?

Usually not, if you're genuinely in business on your own account. But having a limited company isn't enough on its own. It depends on how you actually work.

Is AWR the same as IR35?

No. AWR is about your employment rights as an agency worker. IR35 is a tax rule about how freelancers working through their own company are taxed.

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AWR: The Agency Workers Regulations Explained