From 1 October 2026, the UK government will significantly expand the scope of right to work ("RTW") checks for businesses. Introduced under the Border Security, Asylum and Immigration Act 2025, these changes will mean that responsibility for RTW compliance is no longer limited to traditional employment. A wider range of working relationships, including labour supply chains, subcontracting, and some online matching platforms will now be captured. The updated rules also increase the risk of substantial civil penalties, up to £60,000 per illegal worker, covering a much broader array of arrangements than before.
Who is affected
The new rules extend civil penalty liability to a broader range of business arrangements. Your organisation may be affected if you:
- Enter into contracts to supply workers or services to a third party and subcontract some or all of the work to another company, which employs the workers
- Operate an online platform that matches service providers with clients, where the service provider then contracts with the client or customer directly
- Employ an individual to deliver services under a contract that allows them to substitute another person to do the work in their place.
In these scenarios, your business will be responsible for carrying out the required right to work checks on any individual personally providing the service, even if you are not their direct employer.
Importantly, these provisions do not apply if your organisation is simply purchasing services for its own use and is not supplying those services onwards as part of a chain of contracts.
If you are only acting as an end-user, client, or customer (such as commissioning cleaning, repairs, or consulting services for your own business), this new right to work responsibilities should not apply. Liability will likely arise only when your business is part of a supply chain or contractual arrangements where services are passed on to another party.
What to do now
Although the changes do not come into effect until 1 October, we can help you over the coming months to review your staffing, supplier, and third-party arrangements, ensuring right to work compliance across all areas of your business.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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