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ARTICLE · 09 OCTOBER 2026

Ben Maitland Explains How To Prepare For Right To Work Changes In The Engineer

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From October 2026, UK engineering firms face unprecedented liability for right-to-work compliance across their entire subcontracting chains. The new extended liability rules mean businesses can be penalized if anyone working on their projects—including substitutes and workers several layers down the supply chain—lacks proper work authorization.

United KingdomEmployment and HR

“New UK right to work rules will extend liability across engineering subcontracting chains from October 2026”, writes Senior Associate Ben Maitland in The Engineer. “From 1 October 2026, such arrangements acquire a new legal risk in the most significant expansion of the UK’s right to work regime since it began. The government insists that this expansion of organisations’ liability reflects modern working practices.”

On 1 October, the definition of “employment” for right-to-work purposes extends beyond direct employees to cover workers’ contracts, casual and agency-style labour, individual subcontractors and online platforms that match service providers with clients. At the same time, a new concept of “extended liability” means that where a business is contracted to provide work or services and subcontracts any part of them, it can be held liable for a civil penalty if anyone brought in to work on the project does not have the right to work. This extends down subcontracting chains.

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