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Warnings10 Mar 2026

Swedish Derogation UK: Loophole Let Agencies Pay Less 2011-2020

Document showing UK agency worker pay gap under the Swedish Derogation loophole 2011–2020
A decade-long loophole let temp agencies legally underpay thousands of UK workers — finally abolished in April 2020.

By Catalin Comiza

Founder

On 10 Mar 2026

1 min read

What Was the Swedish Derogation?

The Agency Workers Regulations 2010 said temp workers should get equal pay after 12 weeks. But Regulation 10 created a loophole: agencies could pay less if they gave a small payment between jobs. In reality this meant thousands of workers earned hundreds of pounds less every month for doing the exact same work as permanent staff.

The BT Case

Around 2,000 agency workers at British Telecom (supplied by Manpower) were paid significantly less than permanent colleagues while handling 999 emergency calls. Many had no real choice — they had to accept the lower-pay contract or get no work at all.

How It Was Finally Stopped

After seven years of campaigning by the Communication Workers Union and the 2017 Taylor Review, the government abolished the Swedish Derogation on 6 April 2020. The change was estimated to cost hiring companies up to £380 million a year in higher wages.

What This Means Today

This scandal shows how small legal loopholes can create huge unfairness. Even big, well-known agencies used it. The good news is that when workers and unions push hard enough, bad rules can be changed.

Important:I lived through similar agency problems myself. That’s why I built Sprint — so you can see only serious agencies and apply faster, without falling into the same traps.

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