Four markets.
Four different rulebooks.

United States

Fifty answers to one question

The largest staffing market in the world, and the one where the basic question — is this person an employee or a contractor — has the least settled answer. The test varies by state and, within a state, by which statute is being applied. A model that is comfortable in one jurisdiction can be a liability two states over.

Working here since 2019

What changes here

Classification

Federal and state tests diverge, and several states apply a stricter standard than the federal one.

Benefit thresholds

Hours worked drive health coverage obligations, which makes accurate hours capture a compliance matter and not just a payroll one.

Pay transparency

A growing number of states require pay ranges in postings, which changes how rates can be presented.

Co-employment

The staffing firm and the client can both be treated as employers, and the allocation of that risk belongs in the contract.

Canada

Regulated province by province

Employment standards are largely provincial, so a national staffing operation is really several operations that happen to share a brand. Ontario now licenses temporary help agencies and recruiters outright, which turned a commercial question into a permission-to-operate one.

Working here since 2019

What changes here

Agency licensing

Ontario requires temporary help agencies and recruiters to hold a licence to operate lawfully.

Provincial standards

Hours, overtime, termination and vacation entitlements differ by province rather than nationally.

Language obligations

Quebec imposes French-language requirements that reach into postings, contracts and workplace communication.

Fee prohibitions

Charging work-seekers for placement is restricted, and the restrictions are not uniform across provinces.

Japan

The most structured market we work in

Japan draws a hard legal line between dispatching a worker (派遣) and contracting for a result (請負), and treats confusing the two as a serious matter. Dispatch is a licensed activity. For anyone building staffing technology, Japan is the market that forces the model to be precise, because the law will not accept an ambiguous one.

Working here since 2019

What changes here

Dispatch licensing

Operating a worker dispatch business requires a licence under the Worker Dispatch Act.

The three-year rule

A dispatched worker generally cannot remain in the same organisational unit of a client beyond three years.

Dispatch versus contracting

Who directs the work determines which regime applies, and disguised dispatch carries real consequence.

Equal pay for equal work

Reforms require dispatched workers’ treatment to be justified against comparable directly-employed staff.

United Kingdom

Well-mapped, and closely watched

The UK has the most explicitly written rulebook for employment businesses of the four, along with an inspectorate that enforces it. It also has the most scrutinised intermediary layer: umbrella arrangements and off-payroll rules have both been through repeated reform, and both change who carries the tax risk.

Working here since 2019

What changes here

Conduct Regulations

The Conduct of Employment Agencies and Employment Businesses Regulations govern how agencies may operate.

Agency Workers Regulations

After a twelve-week qualifying period, agency workers become entitled to equal basic working conditions.

Off-payroll working

The IR35 rules determine who is responsible for assessing status and for the tax that follows.

Umbrella arrangements

The intermediary layer is under continuing scrutiny, and supply chains are expected to know what sits inside them.