Right to Work Changes 2026: Why Every Contractor and Client Needs to Review Their Compliance Processes Now
Significant changes to Right to Work (RTW) compliance are expected to take effect from October 2026, widening responsibility beyond direct employers and creating new risks for organisations that engage labour through complex supply chains.
The most notable change is the introduction of Extended Liability. Under the new approach, responsibility for illegal working may no longer sit solely with the direct employer or labour provider. Contractors, agencies, umbrella companies, MSPs, and end clients could all face exposure where appropriate checks have not been carried out.
For contractors, this means RTW verification will become an increasingly important part of workforce onboarding. Workers are likely to undergo checks by multiple organisations before starting work, and businesses will need robust processes to ensure nobody accesses site before verification has been completed.
Another key area of focus will be impersonation and worker substitution. Organisations will be expected to demonstrate that the individual carrying out the work is the same individual whose RTW status was verified. As a result, digital identity verification and technology-enabled access controls are expected to become more widely adopted.
To prepare, businesses should review workforce engagement models, strengthen onboarding procedures, audit existing RTW records, and assess whether their current technology can support compliance efforts.
The direction of travel is clear: every organisation within the labour supply chain will be expected to take greater responsibility for preventing illegal working and demonstrating effective due diligence.
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