For organisations across the UK, temporary labour has become an important part of workforce planning.
Whether businesses are responding to seasonal demand, filling skills gaps or managing ongoing staff shortages, recruitment agencies and flexible workers can provide the additional capacity needed to keep operations moving.
But from 1st October 2026, the Right to Work landscape is expanding.
The latest Home Office guidance extends the Right to Work Scheme to additional working arrangements, including relevant worker’s contracts and individual subcontractor arrangements. It also covers certain online matching services and introduces requirements concerning contractual arrangements and extended liability.
For organisations using multiple recruitment agencies, the change raises an important question:
Do you have enough visibility and control over your temporary workforce to demonstrate that the right processes are being followed?
Right to Work is becoming a supply chain issue
Historically, Right to Work has often been viewed as part of the recruitment and HR process.
But modern workforce models are rarely that simple.
A temporary worker may be sourced through a recruitment agency, processed through another organisation, paid through an umbrella arrangement and deployed into a different part of the business.
When several organisations are involved, it becomes increasingly important to understand where responsibility sits.
The October 2026 changes reinforce this need for supply chain visibility. The updated guidance applies to employers and others responsible for engaging workers in a wider range of arrangements, while specific requirements concerning contractual arrangements and extended liability apply from 1st October 2026.
For procurement teams, this means Right to Work should be considered alongside wider supplier governance.
What does the October change mean for employers?
The updated rules apply to relevant employment beginning on or after 1 October 2026 in the newly covered arrangements. The guidance also explains how the rules interact with repeat checks for existing workers where a check is required on or after that date to retain a statutory excuse.
This means employers should not assume that an existing process will automatically cover every type of worker in their workforce.
Businesses should instead ask:
- Which types of workers do we engage?
- How are temporary workers and contractors supplied?
- Which recruitment agencies are involved?
- Who carries out the Right to Work check?
- How is evidence retained?
- Are follow-up checks monitored?
- Can we report on compliance across different sites and suppliers?
- Do our contracts clearly identify responsibilities?
These questions are particularly important for organisations with high volumes of temporary labour.
Staff shortages make workforce agility essential
The challenge for many employers is balancing compliance with the need to recruit quickly.
When staff shortages affect operational capacity, hiring managers naturally want access to candidates as quickly as possible.
But speed cannot come at the expense of compliance.
The updated code makes clear that employers have responsibilities around appropriate Right to Work checks, while the code of practice also stresses that checks should be applied consistently and without unlawful discrimination.
The solution is therefore not to slow recruitment down. It is to build compliance into the recruitment process so that it becomes a consistent part of onboarding.
Where does neutral vendor recruitment fit?
This is where neutral vendor recruitment can provide a structured approach.
A neutral vendor sits between the organisation and its recruitment agency network, managing suppliers through a single process rather than allowing each agency relationship to operate independently.
For employers using several recruitment agencies, this can help create consistency.
Instead of asking multiple agencies to manage different versions of the recruitment process, organisations can establish common standards around candidate submission, onboarding, compliance, timesheets, reporting and supplier performance.
Datum RPO's model is designed to provide an independent approach to managing multiple recruitment agencies, without favouring one supplier.
This can be particularly useful when temporary labour volumes are high and internal HR or procurement teams do not have the capacity to manage every supplier relationship manually.
Compliance and cost control can work together
Right to Work compliance is only one part of effective temporary labour management.
Organisations also need to consider agency rates, supplier performance, recruitment speed, candidate quality, overtime, administration and workforce utilisation.
This is where temporary labour procurement becomes increasingly strategic.
If an organisation has limited visibility of its agency network, it may also have limited visibility of what it is paying.
Different agencies may charge different rates for comparable roles. Processes may vary between departments. Hiring managers may use suppliers outside agreed arrangements. And procurement teams may struggle to obtain reliable workforce data.
A managed neutral vendor model can bring these areas together.
The precise results will vary by organisation, workforce size and existing procurement model, but the principle is straightforward: greater visibility can support better decision-making.
Measuring ROI from workforce management
For procurement leaders, the conversation should therefore move beyond compliance alone.
What is the ROI of the organisation’s current temporary workforce strategy?
A useful assessment could consider:
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Cost: Are agency rates competitive and consistent?
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Speed: How quickly are vacancies being filled?
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Quality: Are suppliers providing workers who meet the required standards?
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Compliance: Can the organisation demonstrate that required checks are being completed?
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Visibility: Can managers see where temporary labour is being used and at what cost?
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Administration: How much internal resource is being spent managing recruitment agencies?
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Supplier performance: Are agencies being measured against agreed service levels?
A neutral vendor can bring these measures into one framework, giving organisations a clearer view of the relationship between workforce demand, supplier performance and spend.
Preparing for October 2026
Businesses should not wait until October to review their processes.
A practical preparation plan can start with a complete workforce and supplier audit.
Map every route through which temporary labour enters the organisation. Review contracts and supplier responsibilities. Check how Right to Work evidence is collected and retained. Confirm how follow-up checks are managed. Then review whether hiring managers, procurement teams and recruitment suppliers are working to the same process.
It is also important to remember that Right to Work compliance must be managed without unlawful discrimination. The October 2026 code states that employers should apply checks consistently and should not target individuals because of race, nationality or ethnic or national origin.
The potential financial consequences also make preparation worthwhile. The Home Office guidance explains the civil penalty framework for employers who fail to establish the required statutory excuse.
How Can Datum RPO Help?
For organisations experiencing staff shortages, temporary labour can be essential to maintaining operational performance.
But the more complex the workforce becomes, the harder it can be to manage recruitment agencies, compliance requirements, costs and workforce data effectively.
Datum RPO provides a Neutral Vendor Managed Service designed to simplify this process.
We act as an independent intermediary between organisations and their recruitment agency suppliers, managing the recruitment supply chain through one centralised model. This gives clients greater visibility while allowing multiple agencies to compete fairly for vacancies.
The service can support organisations with centralised recruitment supplier management, compliance oversight, agency performance management, recruitment spend analysis and reporting, temporary labour procurement and workforce management.
Datum RPO also provides independent compliance auditing and reporting designed to improve visibility across the temporary workforce.
For organisations preparing for the October 2026 RTW changes, this can provide an opportunity to look beyond compliance and review the wider performance of their temporary workforce strategy.
Frequently Asked Questions
1. Who needs to prepare for the October 2026 Right to Work changes?
Organisations that engage workers under arrangements covered by the expanded Right to Work Scheme should review their processes before 1st October 2026. This is particularly relevant to employers using temporary workers, workers under worker’s contracts, individual subcontractors and certain online matching arrangements. The exact obligations depend on the nature of the working arrangement.
2. How can businesses manage Right to Work compliance while dealing with staff shortages?
Businesses can build Right to Work checks into a consistent recruitment and onboarding process rather than treating compliance as a separate administrative task. Standardised processes, clear supplier responsibilities, appropriate record keeping and ongoing monitoring can help organisations manage compliance while continuing to recruit at pace.
3. What is the benefit of neutral vendor recruitment for temporary labour procurement?
Neutral vendor recruitment gives organisations a centralised way to manage multiple recruitment suppliers. Rather than dealing with each agency independently, the organisation can use one managed framework covering supplier performance, recruitment processes, compliance, reporting and commercial management.
This can provide greater transparency over temporary labour procurement while allowing recruitment agencies to compete fairly.
4. Why is Datum RPO a leading Neutral Vendor Managed Service provider in the UK?
Datum RPO specialises in independent temporary workforce management and operates a vendor-neutral model. Rather than replacing recruitment agencies, Datum RPO manages supplier relationships independently, allowing organisations to retain access to multiple recruitment suppliers while bringing them under one managed framework.
Datum RPO also provides compliance auditing, workforce reporting and supplier management to help organisations gain greater visibility across their temporary workforce.
For UK employers preparing for the October 2026 Right to Work changes, this independent approach can help create greater oversight of recruitment processes, supplier performance and workforce compliance.
The bigger opportunity for UK employers
The October 2026 Right to Work changes may initially look like another compliance requirement.
For organisations with large temporary workforces, however, they also provide an opportunity to review the way recruitment and labour supply are managed.
A more centralised approach can improve visibility, standardise processes and strengthen supplier governance while supporting more effective temporary labour procurement.
For businesses dealing with staff shortages, the objective is not simply to recruit more workers. It is to build a workforce model that is compliant, responsive, measurable and commercially sustainable.
That is where a Neutral Vendor Managed Service can play an important role.
By bringing recruitment agencies, compliance, reporting and workforce management together, organisations can create a clearer line of sight from candidate sourcing through to workforce deployment and spend.
For UK employers preparing for the October 2026 Right to Work changes, now is the time to ask whether the current recruitment model gives the organisation enough control.
Datum RPO can help organisations take greater control of their temporary workforce, improve visibility, strengthen supplier governance and identify opportunities to improve ROI from temporary labour.
