Right to work reform: what HR leaders need to know

From October 2026, significant changes to the Right to Work (RTW) scheme are set to come into effect under the Border Security, Asylum and Immigration Act 2025. These reforms will impact how organisations manage compliance across their workforce and recruitment supply chain.

What’s changing with Right To Work checks?

Moving forward, the scope of who falls under RTW checks will go beyond traditional direct employment to include:

• Contractors and agency workers
• Self-employed contractors and sub-contractors
• Individuals sourced via digital platforms and gig economy marketplaces
• Workers engaged under implied or verbal agreements

The Home Office draft code of practice published in June made it clear that organisations will either need to carry out checks themselves or demonstrate they have robust processes in place across their supply chain.

Why the RTW changes matter to HR leaders

Failure to comply could leave businesses exposed to financial penalties of up to £60,000 per individual. This means HR managers and senior leaders cannot afford to overlook the importance of proactive compliance management and centralised processes to ensure all recruitment suppliers are following the same onboarding checks.

Who is affected?

Any organisation engaging non-permanent talent should review its RTW processes, as these changes will impact:

• Recruitment agencies and staffing suppliers managing temporary and contingent workers
• Employers hiring contractors or consultants directly or indirectly
• Umbrella companies and intermediaries facilitating contingent labour
• Gig economy platforms and businesses using on-demand freelance marketplaces
• End clients who remain responsible for ensuring compliance across their entire supply chain

If your workforce model includes sub-contractors, outsourced arrangements, or agency workers, you will need clear governance processes in place. Ignoring these wider obligations could result in serious compliance risks and financial penalties.

What HR leaders should do now to prepare

While the full requirements to make sure your business meets the upcoming changes are detailed, key actions include:

• Reviewing existing contracts as a matter of urgency
• Understanding any potential risks in your recruitment supply chain
• Putting processes in place for additional checks if contractual substitutions occur

These changes require more than a regulatory tick-box exercise. They call for a review of governance and communication across your entire contingent workforce process.

Why independent compliance auditing can reduce risk

To maintain confidence that all recruitment suppliers are meeting the updated RTW obligations, many organisations are choosing to engage independent compliance experts. Partnering with a specialist such as Linx provides an impartial way to audit your supply chain and ensure consistent practices are being applied to every worker.

External audits offer several benefits:

• Proactive compliance management: A dedicated team of experts review existing processes and identify issues before they become regulatory breaches
• Enhanced risk management: Catching inconsistencies early reduces the chance of costly fines and reputational harm
• Expertise on hand: Compliance specialists stay ahead of regulatory changes that will impact your operation, saving you time and resource internally
• Stronger governance: Independent verification can demonstrate compliance to regulators and stakeholders

Want the complete picture on RTW changes?

We’ve created a detailed compliance update guide that explains everything HR leaders need to know about the RTW reforms, including practical recommendations to manage risk across your supply chain.

READ THE RIGHT TO WORK COMPLIANCE UPDATE