If your business holds COP 119 or NCP 119 certification, the standard you were certified against is on its way out. BS 10119:2026, the new British Standard for the provision of security and events labour, is replacing it. Certification bodies have started assessing new applicants against the new standard and have set dates for withdrawing legacy certificates.
For most labour providers, the question is no longer whether to transition, but how to do it without disrupting client contracts or letting certification lapse. The work involves understanding what has changed, testing your current systems against the new requirements, closing the gaps and passing a transition audit.
ESC Support is currently providing free end-to-end transition support for labour providers moving from NCP/COP 119 to BS 10119, at no consultancy fee. This article explains what is changing, the key differences between the two standards, the timeline, what existing certificate holders need to do and how our support works.
What Is Changing: From NCP/COP 119 to BS 10119
COP 119, the Code of Practice for the Provision of Labour in the Security and Events Sectors, was developed to bring transparency and legitimacy to a supply chain that had long been exposed to cash-in-hand pay, sham self-employment and weak vetting. The National Security Inspectorate (NSI) assessed it under the designation NCP 119, and other certification bodies such as SSAIB also certified against it. For a refresher on the baseline requirements, read COP 119 Explained: Requirements for Security Labour Providers.
BS 10119:2026 is a formal British Standard published by the British Standards Institution (BSI). It covers the same ground, supplying security and events workers to other organisations, but moves it from an industry code of practice to a national standard. In practical terms, that means:
- More prescriptive requirements with less room for interpretation
- A higher expectation of documented evidence that procedures work in practice
- A stronger focus on worker welfare, lawful payroll and transparent pay
- Tighter control over subcontracting and the wider supply chain
- Greater weight in procurement and client due diligence
For a full explanation of the new standard, see our BS 10119 guide and What is BS 10119:2026?
Key Differences Between the Standards
Much of what you already do under COP 119 remains relevant. Recruitment, BS 7858 screening, right-to-work checks, SIA licensing, PAYE compliance and client contracts are still at the heart of the new standard. The difference is mainly in depth, consistency and proof.
| Area | Under NCP/COP 119 | Under BS 10119:2026 |
|---|---|---|
| Status | Industry code of practice, voluntary but widely required by buyers. | Formal British Standard published by BSI. |
| Evidence | Some areas allowed assessor discretion and flexible interpretation. | More prescriptive. Auditors expect clear audit trails showing procedures are applied consistently. |
| Payroll and worker status | PAYE compliance required, with scrutiny of disguised employment. | Closer scrutiny of pay transparency, lawful deductions and any intermediary or umbrella arrangements. |
| Worker welfare | Working time and holiday obligations assessed. | Broader emphasis on communication, grievances, fatigue, working time and support for deployed workers. |
| Subcontracting | Focus mainly on the provider’s own worker files. | Stronger controls over any secondary suppliers, including approval, monitoring and evidence. |
| Governance | Management responsibilities defined. | Greater emphasis on oversight, management review, corrective action and continual improvement. |
The exact wording of each requirement is set out in the standard itself, and your certification body will assess against it. A proper gap analysis against the published text is the only reliable way to know where your business stands.
Transition Timeline
BSI publishes the standard, but each certification body sets its own transition arrangements. Taking NSI as an example, based on its published guidance:
| Milestone | NSI Position | What It Means for You |
|---|---|---|
| New applicants | Assessed against BS 10119 from 1 July 2026 | If you are not yet certified, build your systems around BS 10119, not COP 119. |
| Existing NCP 119 holders | NCP 119 certifications to be withdrawn by the end of June 2027 | Complete your gap analysis, upgrades and transition audit before the deadline to avoid a lapse in certification. |
If you are certified by SSAIB or another body, confirm the dates and transition route that apply to your certificate directly with them. Whatever your deadline, remember that the transition audit has to be booked, carried out and any findings closed before your old certificate is withdrawn. Certification body diaries fill up as deadlines approach, so leaving it late carries real commercial risk.
We recommend starting your transition at least 6 to 9 months before your deadline. That gives you time to update documentation, remediate worker files, run at least one payroll cycle under the new controls and complete a mock audit before the real one.
What Existing COP 119 Holders Need to Do
A structured transition usually follows six steps.
1. Confirm your deadline and transition route
Speak to your certification body and confirm when your NCP/COP 119 certificate will be withdrawn, whether the transition can be completed at a scheduled surveillance visit or needs a separate audit, and what they expect to see.
2. Get a copy of the standard
BS 10119:2026 is available from BSI. Your transition should be based on the published requirements, not summaries or assumptions.
3. Carry out a gap analysis
Compare how your business actually operates against each requirement of BS 10119. For COP 119 holders, the focus is on practices that were acceptable under the old code but fall short of the new standard. The output should be a prioritised action plan with owners and target dates.
4. Upgrade your documentation
Update your labour-provision manual, procedures, forms and registers. Much of your COP 119 documentation can be kept and improved rather than rewritten from scratch.
5. Put the changes into practice
Auditors look for evidence that procedures are followed, not just written. That means remediating worker files, applying new subcontractor controls, recording welfare activity and running payroll in line with your updated procedures, so there are real records to sample.
6. Test, then book the transition audit
Run an internal or mock audit, close any findings, then complete your transition audit with your certification body.
The Areas That Usually Need the Most Work
In our experience, the same areas tend to create the most work for COP 119 holders moving to BS 10119:
- Worker files: incomplete five-year employment histories, unverified gaps, missing references and inconsistent BS 7858 screening records
- Right to work and SIA licences: gaps in repeat checks for time-limited permissions and missing evidence of ongoing licence monitoring
- Payroll evidence: being unable to trace a shift from client timesheet to payslip, HMRC submission and bank payment
- Worker status: arrangements that treat frontline officers as self-employed, or intermediary structures that cannot be clearly justified
- Subcontracting: passing work to other suppliers without documented approval, vetting evidence or client consent
- Management review: no records showing that leadership reviews performance, complaints, audit results and corrective actions
Addressing these early makes the difference between a smooth transition audit and one that produces a long list of non-conformances.
How Our Free Transition Support Works
ESC Support delivers the same end-to-end BS 10119 consultancy we provide as a paid service, currently at no consultancy fee. For transitioning COP 119 holders, it is built around your existing certificate and deadline.
| Stage | What ESC Support Does | What You Receive |
|---|---|---|
| 1. Consultation | Review your current certificate, certification body, labour model, clients and deadline. | A clear scope and realistic transition timeline. |
| 2. Transition gap analysis | Compare your current COP 119 systems and records against BS 10119. | A written gap analysis showing what to keep, what to upgrade and what is new. |
| 3. Documentation upgrade | Update your manual, procedures, forms and registers to meet BS 10119. | Tailored documentation that reflects how your business operates. |
| 4. Worker-file remediation | Sample and review personnel files for screening, right-to-work, licensing and employment evidence. | A clear list of file gaps and support to close them. |
| 5. Payroll and supply-chain review | Review PAYE, pay practices, worker status and any subcontracting arrangements. | Evidence that will stand up to audit scrutiny. |
| 6. Mock transition audit | Run a realistic pre-assessment audit in the style of your certification body. | Written findings and corrective actions before the real audit. |
| 7. Audit support | Prepare your team for the transition audit and help close any findings. | Support through to the certification decision. |
If you are a new labour provider rather than an existing certificate holder, the same support is available to take you straight to BS 10119. Read Free BS 10119 Consultancy: Full Support From Gap Analysis to Assessment Preparation for details.
What the Offer Does Not Cover
- Certification body fees for your transition audit and ongoing surveillance, paid directly to your certification body
- The cost of the standard, purchased from BSI
- Your internal time: a nominated project lead and input from your HR, payroll and operations staff
- Operational investments you choose to make, such as HR software or extra screening capacity
Certification decisions are made by independent certification bodies. No consultant can guarantee an outcome. Our role is to make sure you go into the transition audit genuinely ready.
Why Is ESC Support Offering This for Free?
We want to build long-term relationships with security labour providers by proving the quality of our work, and to grow our track record of successful BS 10119 transitions. If you are happy with the result, we may ask for feedback or a case study, and some clients choose optional ongoing services such as internal audits or SIA ACS consultancy. None of this is a condition of the offer. Read more about why we are currently providing consultancy for free.
Frequently Asked Questions
Is our COP 119 / NCP 119 certificate still valid?
Yes, until your certification body withdraws it. NSI, for example, plans to withdraw NCP 119 certifications by the end of June 2027. Check the date that applies to your certificate with your certification body.
Do we need to start again from scratch?
No. Most of your COP 119 systems will remain relevant. The gap analysis identifies what can be kept, what needs upgrading and what is new under BS 10119.
How long does the transition take?
It depends on your size, the state of your worker files and payroll records, and how closely your current practice matches the new standard. We recommend starting at least 6 to 9 months before your deadline and will give you a realistic timeline after the gap analysis.
What happens if we miss the transition deadline?
Your COP 119 / NCP 119 certificate is likely to be withdrawn, and you may need to apply for BS 10119 as a new applicant. For many labour providers, that would mean a gap in certification at a time when clients expect it.
Can we transition at our next surveillance visit?
Some certification bodies may allow this. Confirm the transition route with your certification body early so you can plan the work around it.
Is the transition support really free?
Yes. ESC Support is currently providing full BS 10119 transition support at no consultancy fee. Certification body fees and the cost of the standard are separate.
Transition to BS 10119 at No Consultancy Fee
Transition gap analysis, documentation upgrades, worker-file and payroll review, mock audit and audit support, delivered end to end by ESC Support. Book a no-obligation consultation.