UK Employers Face October Deadline as Right to Work Checks Expand to Supply Chains
Published on 09/03/2026 at 21:27 | Editorial boerse-global.de
UK businesses have under a month to prepare for a major expansion of immigration compliance rules that will make them responsible for the legal status of workers employed by subcontractors and agency labour providers. From October 1, 2026, the Border Security, Asylum and Immigration Act 2025 extends Right to Work obligations across the wider supply chain, meaning firms can no longer rely on checks carried out by third-party labour suppliers.
The Home Office published a draft guide in July to help organisations navigate the transition, but legal experts warn that time is running out. Irwin Mitchell has urged companies to begin mapping their supply chains immediately to ensure all third-party labour providers are compliant before the deadline.
These expanded duties add another layer of compliance risk to an already crowded employer checklist. With fines now reaching £60,000 per worker, having your workplace safety and employment documentation in order has never been more important. A free Health & Safety Toolkit provides ready-to-use risk assessments and checklists covering key UK regulations, helping you demonstrate compliance if inspectors come calling. Download the free Health & Safety Toolkit
Penalties Rise to £60,000 Per Worker
The expanded requirements bring significantly higher liabilities. Organisations found to be employing illegal workers face civil penalties of up to £60,000 per individual, while criminal sanctions for non-compliance carry prison sentences of up to five years.
To support the new checks, the government updated its digital infrastructure on September 2, 2026. Supplementary codes for digital Right to Work and Right to Rent checks moved to version 1.1, aligning with the October regulations. The update simplifies data outputs and permits the use of expired passports—provided they are within six months of their expiry date—for checks involving chip-reading technology.
On the same day, the transition from trust framework version 0.4 to version 1.0 officially began. Service providers involved in digital identity verification have been given a minimum of 15 months to complete the necessary technical upgrades to meet the new standards.
Enforcement Intensifies as Raids Target Fishing Fleet
The regulatory shift comes amid a period of heightened enforcement. Between July 26 and July 30, immigration officers conducted raids on 34 fishing vessels at the Scottish ports of Mallaig and Fraserburgh, leading to nine arrests. The Home Secretary has signalled further crackdowns, with plans to double the immigration enforcement budget by the 2028/29 fiscal year.
While tightening employer obligations, the Home Office has also introduced new protections for exploited workers. On September 3, 2026, officials announced that Skilled Worker visa holders recognised as victims of modern slavery will be permitted to change employers without jeopardising their visa status. The move specifically addresses concerns regarding care workers and hospitality staff who may have been abused by their initial sponsors.
With enforcement activity intensifying across UK workplaces, ensuring your own safety documentation is audit-ready can reduce stress when regulators pay a visit. Over 37,000 UK businesses already rely on a free Risk Assessment Toolkit offering 41 ready-made templates and checklists covering fire safety, manual handling, first aid and lone working. Get the free Risk Assessment Toolkit
Seasonal Worker Visas Confirmed for Agriculture
Alongside the compliance changes, the government has addressed ongoing labour shortages in the agricultural sector. On September 3, officials confirmed the allocation of 1,900 visas for poultry seasonal workers under the 2027 Seasonal Worker Scheme, alongside 41,000 visas for the horticultural sector. The application window for these roles is scheduled to open in early October.
