Emergency update: everything you need to know in light of October's RTW rule changes

Until 1 October 2026, right to work (RTW) checks were about the people on your payroll. Under the Border Security, Asylum and Immigration Act 2025, the illegal working rules now extend to people on worker contracts, individual subcontractors in a contracting chain, and people matched to work through online platforms. If someone without the right to work turns up anywhere in that chain, your organisation can be liable even though it never employed them, with civil penalties of up to £60,000 per illegal worker.

For mid-sized and larger employers, that's where the new exposure sits: bank and casual workers, outsourced contracts such as cleaning or facilities, self-employed subcontractors, and any arrangement where someone can send a substitute. This emergency update walks through what changed, who it now covers, and how to update your checks and supplier contracts so you keep your statutory excuse.

What you'll learn

• Exactly who the RTW rules now cover, from worker contracts to individual subcontractors and online platforms.
• How liability travels up a contracting chain, and what your supplier contracts need to protect your statutory excuse.
• What the changes mean for digital checks through a registered identity service provider.
• A practical plan to find the gaps across your contractors and suppliers before a Home Office check does.