United Kingdom Expands Right-to-Work Compliance Requirements

Key Point  

• The United Kingdom will expand right-to-work obligations from October 1, 2026, extending compliance requirements and potential penalties to contractors, subcontractors, online platforms and other non-traditional work arrangements.  

Right-to-Work Compliance Requirements 

The United Kingdom (U.K.) he Home Office published a draft updated Code of Practice on Preventing Illegal Working, which will take effect on October 1, 2026.  

The changes implement provisions contained in the Border Security, Asylum and Immigration Act 2025 and broaden the scope of the U.K.’s Right to Work Scheme beyond traditional employment relationships.  

Additional Working Arrangements Brought Into Scope 

Beginning October 1, 2026, right-to-work obligations will apply not only to employees but also to individuals engaged: 

• Under a worker contract; 
• As individual subcontractors; and 
• Through online matching services that connect service providers with clients or customers.  

The updated code confirms that civil penalties for illegal working may apply within these arrangements where compliance requirements are not met.  

Extended Liability for Supply Chains and Platforms 

The reforms introduce extended liability provisions that may apply in certain contracting arrangements, including: 

• Labor supply chains where one party contracts work to another employer; 
• Online matching platforms; and 
• Arrangements involving worker substitution.  

In certain circumstances, liability may extend beyond the employer with a direct relationship to the worker if prescribed compliance requirements have not been satisfied.  

Updated Right-to-Work Verification Requirements 

The code updates right-to-work procedures by: 

• Recognizing digital National Insurance documents issued by or on behalf of government agencies as acceptable supporting evidence in certain circumstances; 
• Requiring employers that use a digital verification provider to use a registered Right to Work Digital Verification Service Provider (RtW DVSP); and 
• Reaffirming the use of the Home Office online service for individuals who hold an eVisa.  

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