Expert blog: Reviewing 20 years of labour exploitation policy - gaps, missed opportunities and what’s next
As April 2026 marks three significant milestones in labour exploitation policy, researchers from the Work, Informalisation and Place Research Centre look back on 20 years of enforcement.
By Darryl Dixon, Rich Pickford, Professor Ian Clark, Nidhi Sharma | Published on 2 April 2026
Categories: Press office; Research; Nottingham Business School; School of Social Sciences;
Twenty years ago, the Gangmasters Licensing Authority (GLA) commenced licensing operations. Ten years ago, it was renamed the Gangmasters and Labour Abuse Authority (GLAA), with expanded powers to investigate the offences of forced labour in England and Wales.
On April 7 the GLAA ceased to exist as the Fair Work Agency (FWA) is created. The creation of the FWA is a significant change to labour market enforcement by consolidating existing powers of the GLAA with those of the Employment Agency Standards team and the National Minimum Wages teams into a single organisation.
In the analysis we produced for the TUC, our subsequent paper on a review of the first iteration of the Employment Rights Bill, and our preceding research on the informal economy, we have commented on the fragmented response to labour market compliance, whether through the silos of separate agencies, or limitations to their jurisdiction within the UK, and for the potential of the FWA to address these limitations.
However, it is our view that there remain gaps in powers and authority boundaries that undermine a consistent UK wide protection for workers, and standardisation of the regulatory burdens’ businesses may experience.
Whilst we welcome the FWA, the new body will be unable to solve the complex and inter-connected challenges we see from our research. This prompts several questions and reflection on how we arrived at this position:
Does the creation of a FWA mark a major change to labour market enforcement creating a single inspectorate, consolidating the existing powers of three bodies into a new organisation? Or will the FWA be insufficient to address the expanding scope and scale of labour market coercion and exploitation that is now significantly greater than when the GLA was introduced? Does the lack of remit throughout the UK create inconsistency of worker protections and employer regulation?
The informal economy has significantly expanded since the introduction of the GLA
Creation and remit of the GLA
The GLA was created by the Gangmasters (Licensing) Act 2004, initially as a private member’s Bill, introduced by Jim Sheridan.
The GLA’s remit was to licence and regulate the activity of “so-called” Gangmasters, legally defined in the Act, in the UK’s agricultural sector, but pejoratively considered to be operating in the informal economy since as far back as 1867 (in Marx’s Das Kapital, page 764).
In February 2004, the Morecambe Bay tragedy occurred. The death of 23 Chinese cockle pickers, and the national outcry over the tragedy, led to the adoption of the Bill by the Government, and its extension to include and regulate the shellfish industry.
Whilst Trades Unions argued that licensing should be extended to other UK sectors that use low paid and, low- skilled, labour, where exploitation flourished, the Government position was that there was only evidence to support licensing in the agricultural and shellfish industries.
If the Morecambe Bay tragedy had not occurred arguably the Government may have adopted a different position, given the de-regulatory environment prevalent at the time.
Recommendations for a single enforcement body
Prominent calls for the expansion of the role of the GLA came from the Organisation for Security and Cooperation (OSCE)’s Special Representative on Combatting Trafficking in Human Beings 2011 report, and the Council of Europe’s Group of Experts on Action against Trafficking in Human Beings (GRETA) 2012 report (see paras 100 and 109) on the UK’s response to modern slavery risks.
These reports examined the whole of the UK. Consequently, their recommendations were not limited to specific authority boundaries such as England and Wales only. GRETA’s subsequent 2021 report (paragraphs 244-245) recommended that a new “Single Enforcement Body” (a proposal preceding the FWA to combine the three aforementioned agencies) should have “a remit and resources which would enable it to effectively prevent and combat human trafficking for the purpose of labour exploitation”.
Similarly, this recommendation was not limited to specific jurisdiction boundaries within the UK. Despite the imminent arrival of the FWA regulatory and enforcement gaps remain, preventing a “whole of the UK” approach.
Challenges for the Fair Work Agency
The creation of the FWA introduces a single inspectorate body for labour market enforcement which aims to reduce regulatory overlap and burdens for business and improve coordination of enforcement within the labour market.
In doing so, including a remit to tackle forced labour offences in England and Wales, the FWA will need to have a focus on training to progressively create a single empowered inspectorate model; not one that might otherwise operate in silos under the FWA brand.
Ensuring powers are used correctly, and civil inspection powers are not misused to seize evidence to facilitate criminal investigations unlawfully, will be a priority and principle to establish in its future enforcement policy and operational procedures. Not to do so raises a risk of legal challenge to the appropriate use of its powers.
The FWA also needs to develop a recognisable brand that will be crucial to effectively “hit the ground running” so that workers and employers know where to find information in future.
It will lead to the cessation of the GLAA’s website, as information on the FWA’s functions, and advice for worker and employers, migrates to Gov.uk.
It will therefore be important to provide transparency on performance, and its impact in the labour market, publishing information on its successes, and sanctions, which can also provide a powerful deterrence and prevention pressure, supported by a recent Trust for London consortium report (Recommendation 3).
Such information has previously been published by the GLAA, but not currently, whereas data currently but published by the Security Industry Authority (SIA) stands as a good example and should be the benchmark for the FWA.
Let’s hope that once the FWA is up and running that it secures an expanded remit so that it can operate consistently with equivalent powers throughout the UK.
What’s next for labour market enforcement?
The FWA presents an opportunity to improve labour market enforcement. It will need to be a visible and effective body, recognised for its protection for workers, illustrated by transparent performance reporting, which, in turn supports the argument to align it functions throughout the UK.
That remaining gap is an area for future development. The UK labour market continues to be a “patchwork quilt” of uneven enforcement powers across distinct jurisdiction boundaries. Workers must be protected and employers must be regulated consistently throughout the UK.
Alignment of remit and powers throughout the UK is therefore required to avoid undesirable outcomes where workers and employers are treated differently based on different jurisdiction locations.
Where will the FWA be in the next 10 or 20 years? Let’s hope that once the FWA is up and running that it secures an expanded remit so that it can operate consistently with equivalent powers throughout the UK.
Furthermore, that its powers and remit are developed, to future-proof its ability to investigate emerging labour market risks, such as online recruitment fraud, expanding and complimenting the remit it has already obtained from the Fraud Act 2006.
If it does not it will be a lost opportunity, a degradation of continued efforts to tackle forced labour throughout the UK, and we should ask why.
Darryl Dixon, Senior Research Fellow
Rich Pickford, head of Nottingham Civic Exchange
Ian Clark, Professor Emeritus of Work and Employment, Nottingham Business School
Nidhi Sharma, PhD researcher
Read more about the Work, Informalisation and Place Research Centre