31st December 2021 was the implementation date for NSI Guarding and Cash companies to have incorporated NCP 119 into their Approval – meaning their supply chain for labour provision in the security and events sector has been verified as being compliant with NCP 119. In our circular letter of 20th May 2021, we outlined options for how this new requirement can be met: a) By only sourcing additional labour from labour providers approved by NSI to NCP 119 – The provision of labour in the security and events sector or equivalent; or b) By demonstrating at audit that your company has completed an internal audit of each labour provider against the requirements of NCP 119. If option b) is your preferred route, we remind you that you are required to provide evidence to your auditor that a robust internal audit of your labour providers has been undertaken. We have available a checklist which you may wish to use for the purpose of internal audit which is attached. Up to 31st March 2022, any identified issues in relation to the use of labour providers and the above requirement will be raised as an Improvement Observation. From 1st April 2022, such identified issues will be raised as Improvement Needs with clear timeframes set for resolution of the finding.