Right to work checks are changing: What employers need to know now
11 Sep 2026
Right to work checks are changing: What employers need to know now
Right to work checks are about to change, and the impact will reach far and wide.
From October 1 employers will be responsible for verifying the right to work status of a much broader group of people delivering work on their behalf.
It might not sound much, but this is one of the most significant shifts in compliance duties in over a decade. And it affects organisations of every size and sector.
A wider scope and wider liability
Until now, right to work checks have focused mainly on employees and certain categories of workers.
The new legislation expands that scope considerably. Casual workers, subcontractors, gig‑economy workers and individuals sourced through online matching platforms will all fall under the umbrella of “people carrying out work in your organisation’s name”.
In practice, this means that if someone is delivering work for you – even without a direct contract – you could be held responsible if they do not have the legal right to work in the UK.
For employers who rely on flexible labour models, this is a major change in liability.
It also means that the traditional boundaries between “employee”, “worker”, “contractor” and “platform‑sourced labour” matter less from a compliance perspective. The focus is shifting to the nature of the work being done, not the contractual arrangement behind it.
What this means for employers
It is clear that employers will need stronger oversight of anyone delivering work on their behalf. That includes:
- Mapping your labour supply chain – understanding who is doing work for you, how they are engaged and where responsibility currently sits.
- Updating policies and procedures – ensuring right to work checks cover all relevant categories, not just employees.
- Strengthening contracts – making expectations around right to work checks explicit for subcontractors and platform providers.
- Training managers – especially those who engage casual labour or commission work at short notice.
The organisations most at risk are those with complex supply chains or high volumes of temporary labour – sectors such as construction, hospitality, logistics, beauty, delivery services and warehousing, to name a few.
A proactive approach is the safest approach
The October changes are not designed to catch employers out – they are intended to strengthen safeguards and reduce illegal working across the labour market.
But they do require employers to be more organised and more confident in their processes.
It’s essential that all employers review the way they currently hire labour to ensure they can comply with the new regulations.
Whilst the government might take a softly-softly approach to enforcement in the first few months of the new legislation, that will not last, and there will be little excuse for anyone found the wrong side of the law.
How we can help
We’re here to make compliance as painless and efficient as possible for all employers.
We can review your current structures, advise what needs to change and draw up new processes to ensure you continue to get the labour you need without falling foul of the law.
Just get in touch for a free consultation and chat about how we can make sure you do all your employment processes the Wright Way.
