posted 21st September 2026
Major changes to the UK Right to Work Scheme take effect from 1 October 2026, expanding immigration compliance obligations across a much wider range of working arrangements.
The reforms, introduced through the Border Security, Asylum and Immigration Act 2025, extend Right to Work requirements beyond traditional employees. Businesses engaging workers under worker contracts, individual subcontractors and certain gig-economy or online platform arrangements will be brought within the scheme.
For businesses, this represents a significant shift. Right to Work compliance can no longer be viewed solely as an HR issue affecting employees. Organisations should consider how they engage contractors, subcontractors, agency workers and individuals sourced through digital platforms.
Who could be affected?
The expanded regime covers a broader range of working arrangements, including:
- Workers engaged under worker contracts;
- Individual subcontractors and certain self-employed arrangements;
- Workers operating through gig-economy models; and
- Certain online matching services connecting service providers with customers for payment.
Businesses involved in supplying or arranging labour should therefore review their contractual and operational structures, particularly where several organisations sit between the end client and the individual performing the work.
What should businesses do now?
Businesses should review their existing workforce and supply-chain arrangements before October. This should include identifying which contractors and other service providers may fall within the expanded scheme and checking whether contracts clearly allocate responsibility for Right to Work checks.
Where labour is supplied through another organisation, businesses should also consider whether their contractual arrangements provide sufficient evidence that the required checks have been completed.
Identity verification will also be important. The Home Office's updated guidance emphasises ensuring that the person carrying out the work is the individual whose right to work was checked. Depending on the circumstances, businesses may therefore need appropriate identification, access-control or digital verification procedures.
Penalties remain significant
Non-compliance can result in a civil penalty of up to £60,000 per illegal worker, alongside potentially more serious sanctions in certain circumstances.
With the reforms taking effect on 1 October 2026, businesses should now be reviewing contracts, supply chains and compliance procedures to ensure they are ready for the expanded Right to Work regime.
