Significant changes to the UK's right to work regime
Today (1st July 2026), we have had the clearest indication yet of significant changes to the UK's right to work regime. The new legislation will take effect from 1 October 2026 and will substantially widen the range of working arrangements which will be subject to right to work liability.
Why does this matter?
Until now, right to work checks have focused on employees. However, under proposals contained in the Border Security, Asylum and Immigration Act 2025, the regime will be extended to include a much broader range of working relationships, including:
Casual and zero-hours workers
Agency-supplied labour
Self-employed contractors
Individual subcontractors
Workers engaged through online platforms and gig economy arrangements
This reflects the Government's intention to modernise immigration compliance rules and address perceived loopholes in sectors that rely heavily on flexible staffing models.
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What should employers do now?
For employers, right to work compliance will be an important consideration throughout your supply chain and labour relationships. With the proposed expansion of the right to work regime, businesses should review their workforce models now to ensure they are prepared for the new requirements and minimise the risk of costly civil penalties when the changes are implemented in October 2026.
The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
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