From 1 October 2026, the UK's right to work regime will undergo its most significant expansion in years. Under section 48 of the Border Security, Asylum and Immigration Act 2025, the obligation to carry out right to work checks will extend well beyond traditional employers, reaching businesses that engage flexible, outsourced or platform-based labour for the first time.
The changes affect who must check, who faces liability, and how digital verification is carried out. Key developments include:
- Wider scope – Right to work checks will now apply to workers on casual, temporary and zero-hours contracts, individual sub-contractors, and those engaged through online matching services.
- Extended liability – Civil penalty exposure will no longer be limited to the party holding the direct contractual relationship. Businesses higher up the supply chain, platforms and those permitting substitution may all be caught.
- Stricter penalties – Fines of up to £60,000 per illegal worker, together with potential criminal sanctions, will apply across all new categories of working arrangement.
- Digital verification requirements – Employers using digital right to work checks must now use a provider registered on the OfDIA register and specifically authorised for right to work purposes. General identity verification authorisation alone will no longer be sufficient.
With the new regime applying to engagements starting on or after 1 October 2026, and to repeat checks falling due from that date, businesses should act now.
Click below to read our full briefing for a practical guide to what your organisation needs to do before the deadline.
