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ARTICLE · 07 AUGUST 2026

How The UK's New Illegal Working Rules Will Affect Your Commercial Contracts

Lewis Silkin
Lewis Silkin
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Lewis Silkin

Lewis Silkin

Joint managing partners: Jo Farmer, Richard Miskella International offices: Dublin, Hong Kong...

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From 1 October 2026, the UK's illegal working regime is undergoing a major overhaul with complex new rules that will significantly change who needs to conduct 'right to work' checks and when. While the immigration and employment implications are substantial, these changes will have far-reaching effects on commercial contracts, particularly in supply chains involving subcontracted services and intermediary platforms that connect workers with clients.

United KingdomEmployment and HR

From 1 October 2026, the UK's illegal working regime is getting a major overhaul. The new rules are complex, and they bring about significant changes to who needs to conduct ‘right to work’ checks and when. But beyond the immigration and employment headlines, these rules will have a major impact on commercial contracts – particularly where services are being subcontracted through supply chains, and for intermediary platforms that match workers with clients.

If your business sits anywhere between an end client and the people who actually deliver the work, this article is for you. For the full technical detail on the underlying legislation, see our Immigration team's articles on the draft Code of Practice and the draft Employer's Guide.

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