Right To Work Checks Are Changing: Is Your Extended Workforce Ready?

From 1 October 2026, right to work compliance will no longer be confined to traditional employees. Employer right to work obligations will extend to a wider range of working arrangements including contractors, consultants, agency workers, individual subcontractors and people obtaining work through online platforms. Consequently, a person who is not on your payroll could create the same immigration compliance risk as an employee. Businesses that cannot identify who is working for them or who checked their work permission may face significant financial and operational consequences.

This will turn right to work compliance from a largely HR and direct-employment issue into a broader workforce and supply-chain risk. Responsibility will not stop with the organisation that contracts directly with the individual, leaving businesses with complex labour supply chains exposed in respect of workers they have not engaged themselves.