INSIGHTS

Do Right to Work checks apply to contractors from October 2026?

Right to Work Checks for Contractors

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] From 1st October 2026, the Right to Work Scheme will cover more than employees working under standard employment contracts. The expanded rules include people engaged under a worker’s contract, individual subcontractors and certain workers connected through online matching services. Some businesses further up a contractual chain may also face extended civil penalty Do Right to Work checks apply to contractors from October 2026?

Right to Work changes from 1st October 2026: What employers need to know

Right to Work Checks for Employers

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] The UK’s Right to Work Scheme will change on 1st October 2026, bringing a wider range of working arrangements within the illegal working civil penalty regime. The civil penalty for getting it wrong has fines up to £60,000 per illegal worker. Section 48 of the Border Security, Asylum and Immigration Act 2025 Right to Work changes from 1st October 2026: What employers need to know

Mini-series | Part 6: A DBS check is not a Right to Work check

A DBS check is not a Right to Work check

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] This is one of the easiest mistakes to make when screening journeys start to overlap. The DBS ID checking guidance says employers must complete a Right to Work check on all new recruits. Separate DBS guidance for employers is even more direct: the employer is responsible for checking whether someone has the Mini-series | Part 6: A DBS check is not a Right to Work check

Mini-series | Part 5: Illegal working penalties are not a theoretical risk

Illegal Working Penalties

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] The official penalty data is a useful reminder that Right to Work failures are not rare edge cases. The Home Office’s anonymous national report for 1st April to 30th June 2025 recorded 617 penalties, 831 illegal workers found and a gross penalty value of £34,265,000. Digital checking is useful but the Home Office guidance still draws firm boundaries Mini-series | Part 5: Illegal working penalties are not a theoretical risk

Mini-series | Part 4: Employers risk becoming unstuck on routine processes around rechecks

Right to Work Rechecks

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] The employer guide is clear that where a person has time-limited permission to work, the employer should carry out a follow-up check shortly before that permission ends. The same guidance states that it applies to checks conducted on or after 12th February 2025 for the purpose of establishing or retaining a statutory Mini-series | Part 4: Employers risk becoming unstuck on routine processes around rechecks

Mini-series | Part 3: Digital-only Right to Work journeys can leave gaps

Digital-only Right to Work

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] Digital checking is useful but the Home Office guidance still draws firm boundaries around where it works and where it does not. The June 2025 employer guide says a digital verification service can be used for British and Irish citizens who hold a valid passport or Irish passport card. It also says Mini-series | Part 3: Digital-only Right to Work journeys can leave gaps

Mini-series | Part 2: Right to Work is moving beyond employees

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] The Government’s October 2025 consultation on extending the Right to Work Scheme shows where policy is heading next. It is not limited to standard employment relationships. The consultation proposes extending checks into other working arrangements, including people engaged under a worker’s contract, individual subcontractors and online matching services. [/vc_column_text][us_separator link=”%7B%22url%22%3A%22%22%7D” show_line=”1″ thick=”2″ Mini-series | Part 2: Right to Work is moving beyond employees

The New Workforce Risk: Why employers need to look beyond background checks

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] Recent reports have highlighted warnings from UK intelligence agencies about hostile foreign actors using professional networking platforms and recruitment channels to identify and approach individuals with access to sensitive information. While these stories often focus on government officials, defence personnel and national security concerns, they raise an important question for employers across The New Workforce Risk: Why employers need to look beyond background checks

Mini-series | Part 1: The October 2026 Right to Work change is really about consistency

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] The Home Office’s draft code for employers, published in April 2026, is easy to misread as a technical update but it reframes compliance. The code says it will apply to employment starting on or after 1st October 2026, and to repeat checks on existing workers from that date. Its focus is avoiding Mini-series | Part 1: The October 2026 Right to Work change is really about consistency

Ofwat’s ‘fit and proper’ rule isn’t about hiring, it’s about continuous leadership vetting

[vc_row columns=”1″][vc_column link=”%7B%22url%22%3A%22%22%7D”][vc_column_text] When regulators introduce new rules, the first question is often who they apply to. In this case, the answer is water companies. But the more revealing question is what this says about the direction of regulation more broadly. Because Ofwat’s new fit and proper rule is not really just about board appointments. Ofwat’s ‘fit and proper’ rule isn’t about hiring, it’s about continuous leadership vetting