Right to Work Changes: An Employer’s Checklist for 1 October 2026
From 1 October 2026, important changes to the UK’s Right to Work Scheme will come into effect, extending the responsibilities businesses have when checking whether individuals are legally permitted to work in the UK.
Previously, we looked at what the changes mean for employers and contractors. With the deadline now approaching, the focus needs to shift from understanding the changes to making sure your organisation is ready for them.
The new rules will broaden the scope of Right to Work requirements beyond traditional employees, bringing additional working arrangements within the scheme.
Not sure if your business is ready? Staffvetting.com has created a free Right to Work Changes Compliance Support Tool to help you quickly assess your current arrangements and identify areas that may need attention ahead of 1 October.
Check your Right to Work readiness with our free Compliance Support Tool
So, what should businesses be doing before 1 October?
1. Understand who will fall within the expanded rules
One of the most significant changes is the expansion of the Right to Work Scheme to cover a wider range of working arrangements.
According to the latest Home Office guidance on Right to Work checks, from 1 October the scheme will apply to individuals carrying out work in the UK:
- under a contract of employment;
- under a worker’s contract; or
- as an individual subcontractor.
Organisations that have traditionally thought of Right to Work checks primarily as an employee onboarding requirement may therefore need to reconsider how they engage other types of workers.
Start by reviewing the different ways people currently work for your organisation and identifying which arrangements may fall within the expanded rules.
2. Review your contractors and labour supply chain
Businesses that rely on contractors, subcontractors, agencies or other forms of flexible labour should pay particular attention to the changes.
Review how individuals are currently engaged, who is responsible for carrying out Right to Work checks and how evidence that those checks have taken place is recorded.
If your organisation obtains workers through agencies, suppliers or subcontracting arrangements, consider:
- Who supplies labour to your organisation?
- Are individuals supplied through further subcontracting arrangements?
- Who currently conducts Right to Work checks?
- Are responsibilities clearly documented?
The new rules include provisions around extended liability in certain contractual arrangements, making visibility across labour supply chains increasingly important.
3. Review how you carry out Right to Work checks
The October deadline is also a good opportunity to review your existing checking procedures. Depending on an individual’s circumstances, prescribed checks can include a Home Office online Right to Work check, a manual document check or the use of an eligible Digital Verification Service.
Whichever method applies, it is important that the correct process is followed and appropriate evidence is retained.
Businesses should also have a reliable process for identifying when follow-up checks are required for individuals with time-limited permission to work in the UK.
4. Update your onboarding processes
If your onboarding checklist currently refers only to ‘employees’, it may no longer accurately reflect the wider scope of the Right to Work Scheme from October.
Review your recruitment and onboarding documentation and make sure Right to Work checks are incorporated consistently for every relevant working arrangement.
This is particularly important where different departments are responsible for recruiting employees, engaging contractors or working with external labour suppliers.
5. Make sure your team understands the changes
HR and recruitment teams shouldn’t be the only people aware of the new requirements.
Managers responsible for engaging contractors, procurement teams dealing with labour suppliers and anyone involved in onboarding workers may also need to understand what is changing.
Relevant staff should know who requires a check, when it needs to take place, how it should be completed, where evidence should be stored and who is responsible for resolving any issues.
6. Keep your processes fair and consistent
Right to Work checks must be carried out without unlawful discrimination. Businesses should have consistent procedures in place rather than making assumptions about an individual’s Right to Work based on factors such as their name, nationality, accent or appearance.
A standardised process can help organisations meet their responsibilities while treating applicants and workers fairly.
Don’t wait until 1 October
With the new rules taking effect on 1 October 2026, businesses should use the remaining time to review their workforce, supply chains, onboarding procedures and existing Right to Work processes.
At Staffvetting.com, we help businesses simplify pre-employment screening and Right to Work checks, helping employers build a more consistent and robust vetting process.
Need support with your Right to Work checks ahead of the October changes? Call 0191 588 7980 or email info@staffvetting.com to speak to our vetting experts.