From October 1, the UK’s right-to-work check regime stops being an employee-only obligation. Under the Border Security, Asylum and Immigration Act 2025 (Commencement No. 4) Regulations 2026, Section 48 of the Act comes into force, extending the illegal working provisions in the Immigration, Asylum and Nationality Act 2006 beyond conventional employment contracts. The expanded scope now reaches contractors, agency workers, individual subcontractors, casual and zero-hours workers, and gig economy and platform-based labor, the kind of arrangement covering delivery riders, platform-booked care workers and app-dispatched cleaners. Civil penalties for getting it wrong scale with repetition: up to £45,000 per worker for a first breach, rising to £60,000 per worker for a repeat one.

For HR and compliance teams, the change matters because it closes a gap those same teams have relied on for years. A business that engaged workers through an agency, a platform or a subcontract chain could previously treat right-to-work verification as someone else’s problem, the agency’s, the platform’s, the subcontractor’s. That separation no longer holds. Anyone effectively using labor through one of these arrangements now carries direct exposure to the same illegal working penalties that have applied to direct employees since 2008, and the government has been explicit that the goal is to remove the “pull factor” the gig economy creates for unauthorized work.

The original insight here is where the compliance burden actually lands. This is not primarily a hiring-desk problem. It is a procurement and vendor-management problem: HR and legal teams now need visibility into every staffing agency, platform and subcontractor a business relies on, and a way to verify that each one is actually running right-to-work checks rather than simply asserting that it does. Companies that treat this as an update to onboarding paperwork will miss the workers who never go through onboarding at all. The compliance systems that already track visa status obligations for direct employees will need to extend that same discipline into contractor and platform relationships before the October 1 start date, in the same quarter that a separate wave of Employment Rights Act obligations is already landing on UK HR calendars.

Source: The Border Security, Asylum and Immigration Act 2025 (Commencement No. 4) Regulations 2026