From 1 October 2026, immigration compliance obligations will extend beyond traditional employment relationships to cover a wider range of working arrangements.
Background: What is changing?
The UK’s right to work regime is set for a significant expansion. From 1 October 2026, immigration compliance obligations will extend beyond traditional employment relationships to cover a wider range of working arrangements, including certain personal service arrangements, subcontracting models and online matching services.
The changes are introduced by section 48 of the Border Security, Asylum and Immigration Act 2025, which amends the Immigration, Asylum and Nationality Act 2006 and expands the circumstances in which civil penalty liability may arise.