From 1 October 2026, the Right to Work (RtW) regime expands beyond traditional employment to include worker contracts, individual sub contractors, and online matching services. This critical shift means civil penalties of up to £60,000 per illegal worker may extend beyond the direct employer and, in some circumstances, up the supply chain.

The new provisions are likely to require significant changes to contracting, onboarding and compliance processes across many sectors. Organisations that engage workers through agencies, platforms, subcontracting arrangements or other non-traditional models should assess their exposure now and begin preparing for implementation before 1 October 2026.

To help get you change-ready, we have produced a checklist highlighting the key steps organisations should be taking in the run up to the regime shift.

Download it here.