23/10/2026
🚨 RIGHT TO WORK COMPLIANCE IS NO LONGER JUST AN HR RESPONSIBILITY. IS YOUR SUPPLY CHAIN PROTECTED?
From 1 October 2026, changes to the UK Right to Work Scheme have expanded the scope of checks and the potential for liability for illegal working across certain contractual arrangements. Businesses can no longer assume that responsibility stops with their direct employees or immediate contractors.
Under the new provisions, organisations further up a contractual chain may face liability where workers supplied through contractors or subcontractors do not have the right to work in the UK, even where there is no direct contractual relationship with those individuals.
📌 Who needs to pay attention?
🏗️ Construction businesses: Review arrangements involving subcontractors, labour providers and multiple tiers of contractors.
🤝 Main contractors and service providers: Understand where responsibility for right-to-work checks sits throughout your contractual arrangements.
👥 Businesses using agencies or outsourced labour: Review how workers are sourced, verified and supplied, rather than relying solely on checks carried out by another organisation.
💻 Businesses using flexible or platform-based workers: Check whether your working arrangements fall within the expanded scope of the rules.
⚠️ What should businesses do now?
✅ Map your supply chain and identify who provides labour at each contractual level.
✅ Confirm who is responsible for carrying out compliant right-to-work checks.
✅ Review contracts, due-diligence procedures and evidence of checks.
✅ Ensure checks are completed correctly and follow-up checks are conducted where required.
✅ Where digital verification is used, confirm that the provider meets the Government's requirements.
At The Infinity Group, we help UK businesses stay informed about employment law changes, strengthen compliance processes and understand their responsibilities as regulations evolve.
📞 0203 283 7633