Right to Work checks are expanding in 2026: what UK employers need to do now

From 1 October 2026, the UK Government will introduce significant changes to Right to Work (RTW) requirements. These reforms expand compliance obligations beyond traditional employees to include contractors, freelancers, contingent workers, and potentially other non-traditional labour models.

This marks an important shift: RTW compliance is no longer just an HR onboarding requirement, it is becoming a broader workforce governance responsibility spanning HR, procurement, legal, and supplier management functions.

For organisations that rely on flexible or extended workforces, the changes will require early preparation to avoid disruption and ensure continued compliance.

What is changing for UK right to work in 2026?

The UK Government is expanding the scope of RTW checks under updated legislation and guidance effective 1 October 2026.

Key changes include:

• Expanded scope of checks:  RTW checks will extend beyond employees to include contractors, freelancers, contingent workers, and other non-traditional work arrangements where applicable.
• Follow-up checks under new rules:  Any repeat RTW checks due on or after 1 October 2026 must comply with the updated requirements to maintain a statutory excuse against illegal working penalties.
• Updated statutory guidance and Code of Practice:  The Home Office will issue updated guidance, including measures designed to support compliance while reducing risks of unlawful discrimination.
• Greater organisational accountability:  Employers will be expected to ensure RTW compliance is embedded across onboarding, procurement, and workforce management processes.

Which roles are now in scope for UK right to work?

The expansion means organisations must reassess all categories of individuals who perform work on their behalf, including contractors, consultants, freelancers, sole traders, agency workers, statement-of-work engagements, gig and platform-based workers where applicable, and subcontractors engaged through third parties. This shift is particularly significant for organisations with complex supply chains or decentralised procurement models, where visibility over non-employee workers can be harder to maintain.

Why this matters

The implications go far beyond HR compliance. Organisations that fail to adapt may face loss of statutory excuse protection if checks are not properly completed, increased regulatory exposure during audits or investigations, fragmented processes across HR, procurement and supplier teams, inconsistent onboarding standards across workforce types, and reputational risk associated with non-compliance.

What employers should do now

Organisations should begin preparing ahead of the October 2026 implementation date by:

• Reviewing existing RTW policies and expanding scope definitions
• Mapping all worker types, including non-employee populations
• Aligning HR, procurement, and hiring manager guidance
• Reviewing supplier onboarding and contract requirements
• Assessing whether current systems can support higher volumes and varied worker types
• Ensuring follow-up RTW check processes remain compliant under new rules

Building a compliant workforce model

To adapt effectively, organisations should move towards a unified approach to workforce compliance. This means establishing one right to work policy across all worker types, standardising onboarding workflows across HR and procurement, centralising governance and accountability, using automated or system-supported verification processes, and maintaining audit-ready documentation and reporting.

How we can help

We support organisations in preparing for the expanded RTW framework by enabling:

• Consistent RTW verification across employees and non-employees
• Contractor and supplier onboarding compliance workflows
• Centralised audit-ready reporting and governance tools
• Scalable compliance processes for complex workforce models

The expansion of Right to Work checks represents a structural change in UK workforce compliance. Organisations that act early will be best placed to reduce risk, streamline onboarding, and maintain operational continuity.