You run a desk supplying warehouse and distribution staff, and October is when the phone changes. Clients who used ten temps in summer want forty by mid November, a night shift that did not exist last month, and three more reach truck drivers by Monday. Filling warehouse temps for peak season is a volume job, and volume is where small mistakes get repeated forty times. This is the list worth working through now, while there is still time to fix things.
It reflects the rules in England, Scotland and Wales as they stand in October 2026.
Setting pay for warehouse temps for peak season
The National Living Wage has been £12.71 an hour for workers aged 21 and over since April 2026. The rate for 18 to 20 year olds is £10.85 and for 16 and 17 year olds £8.00. Peak brings in a lot of younger workers, students in particular, so check the age band on every worker and do not let a payroll default do it for you.
Watch the deductions too. Charges for uniform, safety boots or transport that take pay below the minimum are a breach, even when the worker agreed to them. If a client offers accommodation, the most it can count towards minimum wage is the accommodation offset, £11.10 a day.
Then talk to the client about where their rate sits against the warehouses down the road. In a tight peak, a site paying a few pence above the minimum loses people to the one paying a pound more, usually in week two.
Right to work checks at volume
The agency that employs or engages the worker is usually the one that must carry out the right to work check, and it must be done before the first shift. At volume it is tempting to let people start and catch up later. Do not. The civil penalty is per worker, and forty workers multiply it.
Most non British workers now hold an eVisa, so the check is done online with a share code through the Home Office service, and you keep the result. British and Irish citizens with a valid passport can be checked through a certified identity service provider. Build the check into the booking process so a shift cannot be confirmed without it.
Forklift drivers: there is no licence, there is training
Clients will ask for drivers with a forklift licence. There is no such thing in UK law. What the Health and Safety Executive expects, set out in its Approved Code of Practice L117 on rider operated lift trucks, is training in three stages. Basic training comes first, then specific job training on the type of truck, then familiarisation on the site itself under supervision. The employer should then authorise the operator in writing for the trucks they can drive.
For you, that means three things. Ask for a certificate from an accredited training body and check it covers the right truck type, counterbalance, reach or VNA. Confirm with the client, in writing, that they will provide site familiarisation and authorisation, because that part can only be done on site. And ask when the driver last drove that type of truck. HSE does not set a fixed refresher period but suggests employers consider refresher training every three to five years, and someone who has not driven a reach truck since last Christmas needs more than a quick look round.
The 12 week rule still applies at peak
Under the Agency Workers Regulations 2010, a temp who does the same job with the same hirer for 12 calendar weeks becomes entitled to the same basic pay and conditions as a comparable direct employee. A busy peak can run from early October to the first week of January, which is more than 12 weeks.
Ask the client now for their direct rates, shift premiums and overtime terms, so you can price week 13 before it arrives. A break of six weeks or less between assignments with the same hirer does not reset the clock, so workers who return after a short gap keep their accrued weeks.
Holiday pay for irregular hours
Most peak temps work irregular hours. For leave years starting on or after 1 April 2024, holiday for irregular hours and part year workers accrues at 12.07 per cent of hours worked, and you may pay it as rolled up holiday pay with each wage packet, provided it is shown as a separate line on the payslip. Decide which way you are paying before the first payroll, and tell the workers.
Before a worker starts, they must also receive a key information document from you setting out who pays them, how, and any deductions. That has been a requirement since April 2020 and it matters more at peak, when more workers come through umbrella companies.
Umbrella companies are now your liability
Since 6 April 2026, where an umbrella company in your supply chain fails to pay the PAYE tax and National Insurance due on a worker’s pay, HMRC can recover it from the agency that contracts with the end client. There is no defence based on taking reasonable care. If there is no agency in the UK chain, the client itself is liable.
If you use umbrellas for peak, check every one before the first worker goes through it. Ask for evidence that PAYE is being paid, look at a sample payslip, and put audit and indemnity terms in your contract. Some agencies find peak simpler on their own PAYE payroll.
A look ahead to 2027
The Employment Rights Act 2025 brings in rights for zero hours and agency workers to be offered guaranteed hours, along with reasonable notice of shifts and payment when shifts are cancelled at short notice. These are expected in 2027 and the detail for agency workers is still being consulted on. It does not change this peak, but it will change next year’s, so keep an eye on it when you plan your 2027 contracts.
What to do this week
Ask every warehouse client for their peak forecast by week and by shift, their direct pay rates and their site induction plan for drivers. Check every umbrella in your chain. And set your booking process so no worker gets a shift without a completed right to work check.
If you need vetted warehouse and industrial staff for peak, from pickers and packers to trained truck drivers, Flamingo Workforce supplies them across the UK. See our warehouse and industrial page or get in touch.