Right-to-work compliance changed across the UK on 1 October 2026. The scheme now covers more than conventional employees, reaching people engaged under a worker’s contract, individual subcontractors and certain online matching-service arrangements.
For care providers and recruitment businesses, the crucial point is responsibility. The final Home Office guidance says an employment business supplying temporary workers remains responsible for checks where it is the workers’ employer. The new extended-liability rules do not automatically transfer that duty to every hirer in a staffing chain.
Different arrangements can produce different answers. Where services are delivered through subcontractors or a chain of contracts, another party may face civil-penalty exposure and need evidence that prescribed requirements were met. Contract labels alone do not decide the issue; the practical arrangement matters.
The expanded rules apply to newly covered employment starting on or after 1 October. For extended liability, the key date is when the relevant contractual arrangement is entered into. Existing arrangements are not automatically caught simply because work continues, although renewals or substantial changes need careful review.
There is no general grace period. Care organisations should map who engages each worker, identify who completes and retains the prescribed check, review new or renewed supply contracts, and make sure time-limited permission triggers a follow-up before it expires.
Checks must also be applied consistently. The updated discrimination code warns employers not to make assumptions based on nationality, accent, surname or perceived immigration status.
This is a live compliance change, not a consultation. The practical priority is a clear audit trail: the worker, the contractual route, the responsible checker, the evidence retained and the next review date. Complex supply chains may need specialist advice.