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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Expenses and Reimbursement Policy

1. Purpose

The purpose of this policy is to establish clear, fair and lawful rules for the reimbursement of expenses incurred by employees, agency workers and, where expressly agreed in writing, contractors while carrying out authorised duties on behalf of {{org_field_name}}. This policy is intended to promote transparency, consistency and proper financial control and to support compliance with applicable law in England, including the Employment Rights Act 1996, the National Minimum Wage Act 1998 and National Minimum Wage Regulations 2015, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, HMRC rules on travel and subsistence, and applicable data protection legislation. No part of this policy authorises deductions from wages or charges to work-seekers except where lawful and expressly agreed in writing, and nothing in this policy overrides any statutory right.

2. Scope

This policy applies to all employees and agency workers engaged or supplied by {{org_field_name}} and, where the relevant written contract expressly provides for reimbursement, to contractors or self-employed individuals engaged by {{org_field_name}}. References in this policy to “staff” include employees and agency workers unless the context requires otherwise.

Where an individual’s contract of employment, contract for services, assignment schedule, worker terms, or client-specific booking terms contains more specific expense provisions, those provisions shall apply in addition to this policy to the extent that they are lawful. For the avoidance of doubt, self-employed contractor status for tax or employment-law purposes is not created or changed by this policy.

3. General Principles

Expenses must be reasonable, necessary, properly evidenced, and incurred wholly and exclusively for authorised business purposes connected with an assignment, placement, training activity, or other duty approved by {{org_field_name}}.

Prior approval must be obtained before incurring any unusual, exceptional or high-value expense and in all cases where this policy specifically requires pre-approval.

Original itemised receipts, invoices, booking confirmations, mileage records, or other satisfactory proof of payment must be provided. {{org_field_name}} may reject claims that are incomplete, unclear, duplicated, altered, excessive, or submitted without adequate supporting evidence.

Expense claims must normally be submitted within 30 calendar days of the expense being incurred, unless exceptional circumstances are accepted in writing by {{org_field_name}}.

No deduction shall be made from wages or other sums due to an employee or worker in respect of expenses, equipment, training, checks, transport, accommodation, administration, overpayments or any other matter unless the deduction is lawful, contractually authorised or separately agreed in writing in advance, and applied in accordance with the Employment Rights Act 1996.

{{org_field_name}} will not require an employee or worker to bear costs, or make deductions or seek repayments, in a way that would reduce pay below the applicable National Minimum Wage or National Living Wage, unless the law clearly permits the deduction to be disregarded for minimum wage purposes. Particular care will be taken in relation to uniform costs, transport costs, criminal record check costs, training costs, equipment costs and similar work-related charges.

{{org_field_name}} will not charge work-seekers a fee for finding or seeking to find them work, except in any very limited circumstance expressly permitted by law. Any optional ancillary service must never be made a condition of registration or work-finding services and must be documented separately in writing.

Reimbursement under this policy does not mean that an expense is exempt from tax or National Insurance. HMRC rules on business travel, ordinary commuting, temporary workplaces, and workers engaged through employment intermediaries shall apply. Where a payment is taxable, {{org_field_name}} may process it through payroll and make the required deductions.

Fraudulent, dishonest, inflated or duplicate claims may result in disciplinary action, termination of engagement, recovery proceedings, notification to clients, and where appropriate referral to external authorities.

4. Allowable Expenses

4.1. Travel Expenses

General rule

Only necessary business travel authorised by {{org_field_name}} will be reimbursed. Staff must use the most reasonable and cost-effective mode of transport, taking account of urgency, safety, practicality, client requirements, and total cost.

Mileage for personal vehicles

Where prior authorisation has been given for the use of a personal vehicle for business travel, mileage will normally be reimbursed at the following HMRC Approved Mileage Allowance Payment rates current at the date of this policy review:

• Cars and vans: 45 pence per mile for the first 10,000 business miles in the tax year and 25 pence per mile thereafter;
• Motorcycles: 24 pence per mile;
• Bicycles: 20 pence per mile;
• Passenger payments: 5 pence per passenger per business mile where an authorised employee or worker carries a fellow employee on the same business journey.

If HMRC changes these rates, {{org_field_name}} may apply the revised HMRC rates from the effective date without waiting for the next scheduled policy review.

Mileage records

Mileage claims must state the date of travel, start point, destination, purpose of journey, number of miles claimed, and where requested, supporting map or route evidence. False or estimated mileage claims are not permitted.

Ordinary commuting

Travel between home and a normal place of work, assignment location, or other permanent workplace is ordinarily commuting and will not normally be reimbursed unless {{org_field_name}} has expressly agreed otherwise in writing for operational reasons. Reimbursement in such cases may still be taxable.

Business travel between sites

Travel between client sites, between assignments during the working day, from one authorised work location to another, or travel required to attend approved training away from a normal work location may be reimbursable where properly authorised. Tax treatment will depend on HMRC rules in force at the time.

Workers supplied through employment intermediaries

Where a worker provides services through an employment intermediary and is subject to, or to the right of, supervision, direction or control, travel between home and the assignment is generally treated as ordinary commuting for tax purposes and travel and subsistence relief will not normally be available. Nothing in this policy should be read as guaranteeing tax-free reimbursement for such journeys.

Public transport

Standard class rail, bus, tram and underground fares may be reimbursed where incurred wholly for authorised business travel. First class travel will only be reimbursed where pre-approved or where there is no reasonable alternative.

Taxis and private hire

Taxi or private hire costs will only be reimbursed where public transport is unavailable, unsafe, unsuitable because of working hours, health, disability, or equipment being carried, or where the overall cost is reasonable in the circumstances.

Parking, tolls and congestion charges

Necessary parking charges, tolls and congestion charges incurred for authorised business travel may be reimbursed. Parking fines, speeding penalties, clamping charges and other traffic or parking offences will not be reimbursed under any circumstances.

Insurance and legal compliance

Any person using a personal vehicle for business travel must ensure that they hold a valid driving licence, appropriate insurance covering business use, a valid MOT where required, and a roadworthy vehicle. {{org_field_name}} may require proof before authorising reimbursement.

4.2. Accommodation Expenses

Pre-approved overnight accommodation required for authorised business travel may be reimbursed where an overnight stay is reasonably necessary. Accommodation must be booked at a standard business rate, be appropriate to the location and purpose of travel, and represent reasonable value for money. Where possible, booking should be made through the arrangements approved by {{org_field_name}}.

Itemised receipts must be provided. Personal expenses, including minibar charges, leisure services, in-room entertainment, alcohol, personal guests, room upgrades not approved in advance, and other non-business costs, will not be reimbursed. Where breakfast is included within the room rate, no separate breakfast claim may be made for the same period.

4.3. Subsistence (Meals and Refreshments)

Reasonable subsistence costs may be reimbursed where they are incurred as part of authorised business travel, attendance at approved training, or an authorised overnight stay and are supported by receipts, unless {{org_field_name}} operates an approved scale-rate arrangement.

Ordinary meals, snacks or refreshments purchased during normal commuting or as part of an employee’s or worker’s usual day-to-day living costs will not normally be reimbursed. Alcoholic drinks will not be reimbursed unless exceptionally authorised in advance for a specific client-facing business purpose.

Where {{org_field_name}} pays a flat or scale-rate meal allowance, that allowance will be paid only in accordance with HMRC rules and internal approval arrangements. If any payment exceeds what may be paid tax-free under applicable law or HMRC practice, the excess may be treated as taxable and processed accordingly.

4.4. Work-Related Training and Professional Development

Fees and reasonable associated costs for training, courses, certifications, books, materials or examinations may be reimbursed only where the training has been approved in advance by {{org_field_name}} and is relevant to the staff member’s role, assignment, compliance requirements, or professional development.

Where training is mandatory for the role or required by law, regulation, client specification, or internal compliance standards, {{org_field_name}} will determine in advance whether the cost will be met directly, reimbursed on production of receipts, or governed by a separate written training agreement.

No deduction, repayment requirement or recovery of training cost shall be made from wages unless it is lawful and clearly authorised by contract or separate written agreement in advance. {{org_field_name}} will not apply any training-related charge or deduction in a way that breaches National Minimum Wage requirements.

4.5. Office Supplies, Equipment, Uniforms, PPE and Work-Related Items

Reasonable costs of essential work-related supplies or equipment may be reimbursed where pre-approved by {{org_field_name}} and supported by receipts. Where procurement arrangements exist, staff must follow those arrangements rather than purchasing items independently unless urgent prior approval has been given.

Where uniforms, PPE, checks, licences, registrations, equipment or other items are required for the role, {{org_field_name}} will ensure that any charge, repayment or deduction is handled lawfully and does not reduce pay below the applicable National Minimum Wage or National Living Wage where the law requires the cost to be borne by the employer or treated as reducing minimum wage pay.

4.6 Criminal Record Checks, Registration Fees and Other Compliance Costs

Where a criminal record check, identity check, right to work check, professional registration, licence, or other compliance-related requirement is necessary for a role or assignment, {{org_field_name}} will specify in writing before the cost is incurred whether the business will pay the cost directly, reimburse it on receipt, or require the individual to bear the cost personally where lawful.

Any recovery, repayment or deduction relating to such costs must be lawful, transparent, documented in advance where required, and must not be applied in a way that causes National Minimum Wage or National Living Wage underpayment. No administration fee will be imposed on a worker in connection with mandatory compliance checks unless expressly lawful.

5. Expense Claim Process

• Claims must be submitted using the expense claim form or expense system designated by {{org_field_name}}.
• Claims must include all required supporting documents, including receipts, invoices, tickets, booking confirmations, mileage details, and any prior written approval required under this policy.
• Claims should normally be submitted within 30 calendar days of the expense being incurred. Late claims may be rejected unless exceptional circumstances are accepted in writing.
• Claims will be reviewed by the appropriate manager, payroll team, finance team, or other authorised approver appointed by {{org_field_name}}. Approval may be refused where the expense is not adequately evidenced, not business-related, excessive, out of policy, duplicated, or otherwise non-compliant.
• Once approved, reimbursement will normally be made within 14 days or in the next available payroll or payment cycle, subject to payroll deadlines and any necessary tax treatment.
• Where {{org_field_name}} reasonably considers that an expense payment is taxable, reportable, or subject to National Insurance, it may process the payment through payroll and make any required deductions.

6. Payroll, Deductions, Overpayments and Recovery

{{org_field_name}} may recover an expense overpayment, duplicate payment, advance, or payment made in error, but any deduction from wages will only be made where permitted by law and authorised by the relevant contract or separate written agreement, or otherwise with the individual’s prior written consent.

Where recovery from wages is not lawful or is not appropriate, {{org_field_name}} may seek repayment by invoice, written repayment arrangement, or other lawful means.

Any recovery arrangement will, where required by law, be implemented in a manner that does not reduce pay below the applicable National Minimum Wage or National Living Wage.

All deductions and reimbursements processed through payroll will be identified clearly on the individual’s payslip or pay statement where required by law.

7. Non-Reimbursable Expenses

The following expenses will not normally be reimbursed unless expressly authorised in writing in advance by {{org_field_name}}:

• ordinary commuting costs between home and a normal assignment or workplace;
• personal expenses unrelated to business duties;
• fines, penalties, speeding tickets, parking contraventions, clamping charges or other unlawful costs;
• excessive, luxury or unapproved accommodation, travel or meal costs;
• alcohol, minibar, leisure or entertainment costs not expressly authorised for a specific business purpose;
• costs arising from loss, theft or damage to personal belongings unless covered by a separate written agreement;
• duplicated claims or claims without satisfactory evidence;
• personal upgrades, companion travel, or expenses for family members or guests.

8. Monitoring and Compliance

{{org_field_name}} will monitor expense claims, reimbursements, deductions, advances and recoveries to ensure compliance with this policy, payroll rules, National Minimum Wage requirements, tax rules, and applicable employment agency legislation. Random audits and targeted reviews may be conducted.

Managers, payroll personnel and finance personnel must take reasonable steps to identify patterns that may indicate fraud, duplicate claims, improper deductions, inflated mileage, repeated out-of-policy spending, or systemic underpayment risk. Where required, records will be made available for internal audit, statutory audit, HMRC, or other competent authorities.

9. Data Protection and Record Retention

{{org_field_name}} will process personal data contained in expense claims, receipts, invoices, bank details, mileage records, investigation records and related correspondence in accordance with UK data protection law. Such information will be used for purposes including verifying claims, preventing fraud, processing reimbursement, operating payroll, complying with legal obligations, dealing with audits and defending legal claims.

Expense records will be kept only for as long as reasonably necessary in accordance with {{org_field_name}}’s retention arrangements and legal obligations. Access will be restricted to those who need it for legitimate business, payroll, finance, legal, audit or compliance purposes. Staff must not include unnecessary personal or special category personal data in expense claims unless it is strictly required.

10. Related Policies

This policy should be read alongside the following, where applicable:

• Payroll Policy;
• Training and Development Policy;
• Data Protection and Confidentiality Policy;
• Disciplinary Policy;
• Equal Opportunities Policy;
• Anti-Fraud, Bribery and Corruption Policy;
• Right to Work Checking Policy;
• Health and Safety Policy.

11. Policy Review

This policy will be reviewed at least annually and earlier where required by changes in legislation, HMRC rules, payroll practice, employment agency regulation, case law, or business need. Where a legal or HMRC change takes effect before this policy is formally reissued, {{org_field_name}} may apply the updated legal requirement immediately and treat this policy as amended to the extent necessary for compliance.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.