This second article in an ongoing investigation builds on a theory of change for the UK translation and interpreting sector. The first article examined the institutional structure of Professional Interpreters for Justice (PI4J) and the tensions between claims of representation, institutional hybridity, and embedded organisational incentives.

This article turns to a critical analysis of the Working Together white paper, issued collaboratively by PI4J and the Association of Translation Companies (ATC), an interest group representing translation companies often referred to as language service providers (LSPs).

The Working Together document describes public service interpreting and translation as an “interdependent ecosystem” in which public bodies, language service companies, and freelance interpreters all play “crucial” roles in sustaining the supply chain. It attributes sector problems primarily to fragmentation, procurement complexity, economic pressures, and public resource allocation, while presenting collaboration between stakeholders as the principal route to reform.

However, this framework warrants critical reassessment because it emerged at a time when the structural contradictions of outsourced public service interpreting were already well documented. While the document acknowledges precarity and pressure on interpreter remuneration, it largely externalises responsibility for these outcomes onto market conditions, fragmentation, and public sector commissioning structures. At the same time, it leaves largely unexamined the role of outsourcing itself, contracting models, LSP pricing practices, and the distribution of power and public funding within subcontracted supply chains.

It is important to recognise that public service interpreting (PSI) is not a marginal or low-value area of public spending. Outsourced interpreting services operate through contracts worth hundreds of millions of pounds. For example, the Ministry of Justice interpreting contract scheduled to begin in October 2026 exceeds £200 million. Yet despite this scale of public investment, there remains limited transparency and weak enforceability regarding how funds are distributed through subcontracting chains and how much ultimately reaches interpreters.

Structural opacity and financial asymmetry

A key unresolved issue within outsourced interpreting systems is the lack of transparency regarding the distribution of public funds between intermediary profits and interpreter remuneration. Industry-reported figures suggest gross margins of up to 77% in translation and 67% in interpreting services (ATC and Nimdzi, 2021). These figures are self-reported and may understate actual margins.

In contrast, interpreters frequently report delayed payments, inconsistent scheduling, and unclear contractual terms. In some cases, payment delays extend over months, with limited recourse through formal grievance mechanisms.

Findings from my PhD research on UK outsourced PSI identify persistent and structurally embedded patterns of low pay, financial insecurity, and challenging working conditions. The research also highlights a lack of basic health and safety protections, alongside the increasing role of digital forms of control that may intensify precarity and weaken workers’ bargaining power.

These conditions are not incidental or temporary distortions. A wide range of academic literature on outsourced public services shows that subcontracted procurement systems tend to prioritise cost minimisation, labour fragmentation, and diffuse accountability.

Interpreters working within outsourced public service systems frequently experience:

• low and unpredictable pay
• precarious and irregular work patterns
• limited or no employment benefits such as sick pay, maternity leave, or pensions
• absence of effective grievance procedures
• emotional and ethical strain in high-stakes contexts
• structural exclusion from collective bargaining mechanisms

Despite working across critical public services—including healthcare, courts, asylum, and welfare systems—interpreters are frequently treated as independent contractors without corresponding protections.

These findings are consistent with wider public reporting, including BBC investigations into public service interpreting and bogus self-employment in outsourced public service work, which highlight similar patterns of precarity, payment insecurity, and structural imbalance.

The Working Together framework and its political consequences

Within this context, the Working Together framework attributes challenges in public service interpreting primarily to procurement complexity and external pressures. While it is one of the few sector documents that acknowledges unsustainable pay rates within outsourced interpreting, it nevertheless externalises responsibility for poor working conditions, treating exploitation as an effect of administrative fragmentation or market pressures rather than as a consequence of procurement design and intermediary contracting structures.

In its recommendations, the framework advocates the continuation of outsourced service delivery and increased public funding routed through existing intermediaries. However, it does not propose enforceable mechanisms to ensure that such funding meaningfully improves interpreters’ pay, working conditions, or employment security. This reliance on voluntarist reform narratives reflects a broader limitation in outsourced labour governance: the substitution of enforceable accountability with aspirational principles.

A further feature of the Working Together framework is its repeated use of the term “ecosystem”. While presented as neutral terminology, this framing disperses responsibility across multiple actors and obscures the specific role of LSPs in shaping remuneration structures, contracting conditions, and the distribution of public funds.

More broadly, it contributes to a depoliticised account of labour relations in which structural power asymmetries are rendered invisible. Interpreters are positioned as stakeholders within a collaborative system, without corresponding governance power or enforceable rights. This reflects the extent to which sector-wide reform coalitions have developed within an overarching acceptance of outsourced service delivery as the prevailing organisational model. It raises important questions about how labour representation operates within governance frameworks that do not fundamentally challenge outsourcing structures, and how such frameworks may inadvertently reinforce the role of intermediary providers as central actors in policy solutions.

Overall, this combination of professional, commercial, regulatory, and labour representation combined within a single umbrella structure reflects a form of institutional hybridity that complicates claims of representation. It raises important questions about how representation, standard-setting, and market participation intersect in shaping the governance of public service interpreting, and why these intersections require greater ethical and structural scrutiny.

The conflict of credentialism, governmentality and representation

One of the most significant statements in the Working Together document illustrates how responsibility for structural instability is subtly relocated onto interpreters themselves:

“A concerted effort with ongoing support from public sector buying organisations will be required to encourage those interpreters already successfully working with a Level 2 or Level 3 qualification to additionally invest in their future careers by achieving a Level 6 professional qualification…”

This statement relies on a narrowly defined and institutionally constructed notion of what counts as a “qualified” interpreter. In this context, “qualified” is effectively reduced to specific vocational credentials—most notably Diplomas in Public Service Interpreting (DPSI), administered through bodies such as the Chartered Institute of Linguists (CIOL). No evidence is provided that such diplomas are inherently more effective than university degrees, postgraduate qualifications, or extensive professional experience already held by many practitioners. Therefore, the term “Professional Interpreters for Justice” itself also warrants scrutiny. “Professional” is often implicitly aligned with specific institutional pathways, particularly CIOL qualifications and NRPSI registration. This risks excluding other highly qualified practitioners, including those with university degrees, postgraduate training, and extensive professional experience in public service interpreting.

Additionally, while the statement may appear to promote professional development. However, it embeds several shifts in responsibility.

First, it individualises what is fundamentally a structural problem. Despite acknowledging declining retention and financial pressure, the framework does not interrogate whether procurement models, intermediary contracting practices, and fee structures make long-term sustainability viable. Instead, it frames the solution as further individual investment in a narrowly defined qualification pathway.

Second, it normalises a human-capital logic in which labour market instability is addressed through continuous credential accumulation rather than structural reform. Sustainability becomes a matter of personal investment rather than procurement design or distribution of risk and reward. This raises policy questions that remain unaddressed in the document, including whether remuneration is appropriately linked to qualifications and experience, whether procurement should mandate enforceable pay structures, and whether intermediary systems ensure that professionalisation translates into improved working conditions.

Third, it reframes workforce retention as an individual skills deficit rather than a predictable outcome of low pay, insecure work, and weak protections. This is not a neutral descriptive move, but a shift in governmentality: it redefines the object of intervention from structural conditions of work to the conduct and self-improvement of workers themselves.

Within this framing, retention becomes a matter of individual responsibility to accumulate additional credentials, rather than a question of how procurement systems, intermediary contracting, and remuneration structures produce instability in the first place. In other words, the problem is relocated from the organisation of the labour market to the behaviour and “professional development” choices of interpreters.

The effect is a form of governance that operates through responsibilisation: interpreters are encouraged to invest in further qualifications in order to remain viable within the same labour conditions that generate attrition. Structural constraints—low pay, fragmented work allocation, and weak or absent enforceable protections—are therefore rendered secondary, or implicitly treated as background conditions rather than causal drivers.

This matters because it determines what counts as a legitimate policy response. Instead of interrogating commissioning practices or intermediary accountability, the framework privileges individual adaptation within existing constraints, thereby stabilising the very system that produces workforce instability.

Finally, this framing must also be read in the context of institutional structures within the sector, where organisations involved in policy discussions may also be embedded in qualification provision, or membership-based funding systems. This creates potential tensions between professionalisation agendas and the structural conditions they claim to address.

Overall, the statement reflects a broader governance tendency in outsourced labour systems: structural problems are acknowledged, but solutions are reframed as individual investment in credentials, while procurement structures remain largely unexamined.

The political economy of outsourcing

These conditions reflect a broader political economy in which governments procure labour while distancing themselves from responsibility for working conditions within subcontracted systems. Formally self-employed workers are placed in conditions of economic dependence and structural vulnerability, while accountability is diffused across contracting chains.

This issue is not confined to a single profession. It concerns the governance of outsourced public services more broadly: how labour is organised, how responsibility is allocated, and how equality commitments are translated—or not—into enforceable practice.

The Government’s acknowledgement that the current framework does not fully prevent worker exploitation adds weight to this analysis. It confirms what empirical research and lived experience have long indicated: vulnerability is structurally embedded within procurement systems.

Against this backdrop, earlier sector frameworks cannot remain analytically static.

Conclusion: a necessary first step

If the sector is serious about intellectual honesty, then previous frameworks and assumptions must be open to critical reassessment.

This is particularly important for organisations such as Professional Interpreters for Justice (PI4J), whose intervention in the Working Together framework helped shape how outsourcing and responsibility are framed in public discourse.

A first step forward is not agreement or consensus, but recognition: frameworks that normalised outsourcing without enforceable protections require critical review in light of empirical evidence and subsequent governmental acknowledgement.

Only through such ethical and political reassessment can any future discussion of reform, representation, or “working together” begin on structurally honest terms.

About the author
Fardous Bahbouh is a researcher and broadcast interpreter specialising in labour rights and the political economy of the translation and interpreting industry. Alongside her academic research, she continues to work with agencies and production companies that value interpreters and translators and provide fair working conditions. She also runs a small translation company and does not generalise critiques of unfair intermediaries to all translation companies or agencies.

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