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ARTICLE · 06 OCTOBER 2026

Right-to-work Changes: Your Liability For Subcontractors

Vanessa Ganguin Immigration Law
Vanessa Ganguin Immigration Law
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Vanessa Ganguin Immigration Law

Vanessa Ganguin Immigration Law

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From 1 October 2026, UK contractors face unprecedented liability for illegal workers anywhere in their subcontracting chain, with fines up to £60,000 per worker even if they never met them. The most radical expansion of right to work laws since 2006 redefines employer liability across construction projects, requiring organisations to rethink workforce engagement, supplier contracts, and compliance evidence before penalties arrive.

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From 1 October 2026, contractors could be fined up to £60,000 for a worker lacking the right to work, even if they never met them or knew they were on site. It is the most radical expansion of the right-to-work regime since it began in 2006.

The new laws redefine employer liability and protection against illegal working practices. It is crucial that contractors understand their full exposure and how to protect themselves from serious sanctions. 

What’s changing?

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. 

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