From 1 October 2026, the UK’s right to work regime will undergo its most significant expansion in years.
What’s changing?
New legislation extends compliance obligations beyond traditional employment relationships to cover contractors, subcontractors, and labour supplied through third parties. For businesses in our sector, where subcontracting, labour-only operatives, and agency labour are part of everyday site life, this is a meaningful shift.
The Home Office’s position is clear: responsibility for compliance sits with the organisation that has the direct contractual relationship with the individual. Where that cannot be clearly identified, liability may extend further up the contractual chain. A new extended liability regime means a business can be fined up to £60,000 per illegal worker for illegal working further down its supply chain — even where it has no direct contract with that worker.
What should you do now?
The existing right to work checking methods remain in place — what changes is the scope of who those checks need to cover, and who within your organisation is responsible for ensuring they happen. Before 1 October, businesses should consider:
- Mapping all the ways labour enters their business — not just direct employees, but subcontractors, agency workers, and outsourced services
- Reviewing existing contracts to confirm who is responsible for right to work compliance at each stage
- Ensuring procurement and commercial teams, not just HR, are across the new obligations
- Checking that substitution arrangements have appropriate identity verification controls in place
A free course to help you get compliant
To help members understand exactly what is required and how to put it into practice, we have developed a free e-learning module — no sign-up required — covering everything you need to know in plain English, with examples drawn from real fit-out projects.
The module covers:
- How to carry out a compliant check using the right method, including the new digital verification rules
- Who is now in scope — because labels like “self-employed” no longer settle the question
- How to protect your business against extended liability with the right contract terms and site controls
- When follow-up checks are due and what records to keep
- How to run checks fairly and avoid discrimination claims
It takes around 30 minutes, is completely self-paced, and is suitable for directors, HR teams, commercial and procurement staff, contract managers, and site managers. There is a final assessment with an 80% pass mark.
👉 Access the free course here — no sign-up needed
Could the NAS help further?
We are also exploring whether there is appetite among members for a dedicated NAS employee verification service — helping businesses meet their compliance obligations simply, affordably, and with the confidence that comes from working through a trusted industry body. If that is something that would be of value to your business, we would love to hear from you.