Right to Work Checks — Gig Economy & Contractor Expansion Check

Why this matters

From 1 October 2026, Section 48 of the Border Security, Asylum and Immigration Act 2025 extends the UK’s illegal working civil penalty regime beyond traditional employees for the first time. Businesses that engage agency workers, individual subcontractors, casual or temporary staff, zero-hours workers, gig economy “workers” and platform-based labour will need to carry out right to work checks on them, not just on people with a standard employment contract. Civil penalties can reach £45,000 per worker for a first breach and £60,000 per worker for a repeat breach — and an organisation can be penalised even where it doesn’t directly employ or engage the worker, for example where illegal working occurs further down a chain of subcontracts.

The Home Office has flagged hospitality, construction, logistics and the gig economy as high-risk sectors for continued enforcement activity, and has said the period before 1 October 2026 should be used to prepare rather than waiting for enforcement to begin. Many businesses that use gig or platform workers, casual staff, or subcontracted labour have never built right to work checks into that part of their onboarding, because the duty previously applied only to employees. Getting processes in place now — including for workers engaged indirectly through agencies or subcontracting chains — is the difference between having a “statutory excuse” against a penalty and facing one after the fact.

What you'll need

• Whether your business engages workers outside standard employment contracts (gig workers, subcontractors, agency staff, zero-hours or casual workers)
• Your current right to work checking process for employees, and whether it extends to non-employees
• Whether you operate in a high-risk sector such as hospitality, construction, logistics or gig/platform work
• Whether you engage labour indirectly through subcontracting chains you don't directly manage

What you'll get

A personalised compliance report covering: a score out of 100, an executive summary, a list of findings ranked by severity, and a prioritised action plan with timeframes.