Compliance dates · 1 October 2026 · UK
Right to work checks extend to agency, gig and subcontract labour on 1 October 2026
From 1 October 2026 right to work checks extend beyond employees to agency workers, individual subcontractors, zero-hours staff and gig and platform workers. The extension comes through section 48 of the Border Security, Asylum and Immigration Act 2025.
Civil penalties run up to £60,000 per illegal worker. A business that has only ever checked its payroll now has a population of workers it has never checked at all. Section 48 names the categories, so the question for a business is which of those categories it engages.
Anyone engaging labour they do not employ
Any business engaging labour it does not directly employ, plus recruitment agencies and umbrella companies. A firm that runs on subcontractors and has no employees at all is inside the new scope.
Building the check into how labour arrives
- Count every worker who is not on your payroll: agency, subcontractor, zero-hours, gig and platform.
- Run a right to work check on each of those categories before 1 October 2026.
- Set the check as a step that happens before the work starts, not after it.
- Keep the check record for each person against the £60,000 per worker penalty.
- Agree in writing with agencies and umbrella companies who runs the check.
The right to work checks system
Right to work checking already has its own system, and this date widens who has to be checked rather than how.
Right to Work Checks £750
Employer duty to verify right to work before employment begins. Civil penalties per worker.
Immigration, Asylum and Nationality Act 2006 · United Kingdom
Verified 19 August 2026.