Britain is about to close a compliance gap that HR teams have used contractors and platform workers to route around. A draft Code of Practice from the Home Office, most recently updated on 30 June 2026, confirms that from 1 October 2026 the UK’s right-to-work check regime will extend well past direct employees. Under Section 48 of the Border Security, Asylum and Immigration Act 2025, the definition of “employer” now captures anyone who engages a worker under a personal-service contract, brings on an individual subcontractor, or matches workers to clients through a fee-charging online platform. Civil penalties for non-compliance rise to £60,000 per worker.
For HR and people-ops leaders, the change matters because it moves liability up the supply chain. A business that never directly contracted with a worker can still be exposed if it sits above that worker in a chain of agencies, platforms, or subcontractors, and cannot show it verified their right to work. Organizations already tracking the tightening rules around skilled worker visas now face a parallel obligation on their contingent workforce: audit rights written into vendor contracts, a requirement to check any substitute worker directly, and an evidence trail that can be produced on demand.
The original insight is where the pressure lands next. Right-to-work verification has mostly been an onboarding-day task bolted onto HRIS platforms for direct employees. Extending it to gig workers and subcontractors means compliance tooling and contingent-workforce-management systems, which have largely run as separate stacks, now need to talk to each other, or HR risks discovering its exposure only when a Home Office audit does. Expect right-to-work vendors to push identity-verification products further into procurement and vendor-management workflows over the next two quarters.
Source: GOV.UK
