The UK’s Right to Work (RTW) landscape is changing from 1st October 2026, and organisations that rely on temporary labour, contractors and flexible workforce models need to understand what the changes mean for their recruitment processes.
The updated Home Office guidance expands the scope of the Right to Work Scheme to cover additional working arrangements, including certain individuals engaged under a worker’s contract, individual subcontractors and online matching services that provide details of individual service providers to clients or customers. The updated guidance will apply to relevant employment beginning on or after 1st October 2026.
For businesses already dealing with staff shortages, high temporary labour volumes and multiple recruitment suppliers, this makes workforce visibility more important than ever.
The question is no longer simply whether a Right to Work check has been completed. Organisations also need to understand who is working for them, how those individuals have been engaged, which supplier introduced them and where responsibility for compliance sits.
From 1st October 2026, the Right to Work Scheme will apply to a broader range of working arrangements.
The latest Home Office guidance specifically covers employers and others who may have responsibilities under the Scheme where individuals are engaged under contracts of employment, worker’s contracts or as individual subcontractors. It also addresses online matching services providing details of individual service providers.
The changes are particularly relevant to organisations using temporary workers and contingent labour because these workforces can involve several parties: the hiring organisation, recruitment agencies, payroll providers, umbrella companies, subcontractors and other intermediaries.
For procurement and HR teams, this creates a clear need for greater control over the entire temporary labour process.
Temporary labour remains an important tool for UK organisations dealing with fluctuating demand and ongoing staff shortages.
However, using multiple recruitment agencies can create fragmented processes. One supplier may manage onboarding differently from another. Documentation can be stored in different systems. Responsibility for checks may not always be clear, and hiring managers may have limited visibility of the wider supply chain.
That fragmentation creates unnecessary risk.
The October changes mean businesses should review whether their existing recruitment model provides enough visibility and consistency across the temporary workforce.
This is especially important where organisations use a large number of workers across multiple sites, departments or recruitment agencies.
Employers must complete the appropriate Right to Work check before employment begins. The current Home Office guidance identifies three routes for conducting checks: a check using a Right to Work digital verification service provider, a Home Office online check or a manual document-based check. Completing the prescribed process can provide an employer with a statutory excuse against a civil penalty for illegal working.
Where an individual’s right to work is time-limited, follow-up checks may also be required.
The updated code of practice also highlights the importance of avoiding discrimination. Employers should apply Right to Work processes consistently and should not make assumptions about an individual’s immigration status based on race, nationality or ethnic or national origin.
This is another reason why standardised processes are valuable.
When several recruitment agencies are supplying temporary workers, relying on every supplier to interpret and implement processes in exactly the same way can make governance more difficult.
Right to Work compliance is not simply an administrative issue.
Government guidance states that employers can face a civil penalty of up to £60,000 per illegal worker where the relevant requirements are not met and the employer is liable. Establishing the required statutory excuse depends on completing the prescribed checks correctly.
For organisations with significant temporary labour requirements, the potential exposure can therefore be substantial.
There can also be indirect costs associated with compliance failures, including management time, workforce disruption and the need to investigate supplier processes.
This makes Right to Work compliance part of a wider temporary labour procurement strategy rather than an isolated HR responsibility.
A neutral vendor recruitment model can provide organisations with a central point of control across their recruitment supply chain.
Rather than managing multiple recruitment agencies independently, a neutral vendor acts as an impartial intermediary, coordinating suppliers through one managed process.
This can help organisations establish consistent standards for recruitment, onboarding, compliance, reporting and supplier performance.
For example, a neutral vendor model can help provide:
The objective is not simply to add another layer of administration. It is to create a more structured way of managing the temporary workforce.
The October 2026 changes also provide an opportunity to look at the wider ROI of temporary workforce management.
If an organisation is already investing heavily in agency labour, improving compliance should sit alongside efforts to control costs, improve fill rates and reduce unnecessary administration.
Datum RPO’s neutral vendor model is designed to give organisations access to multiple recruitment suppliers without favouring one agency. This allows suppliers to compete while the organisation maintains a centralised management process.
For businesses facing ongoing staff shortages, this combination of supply access and greater governance can be particularly valuable.
At Datum RPO, we help UK organisations take greater control of their temporary and contingent workforce through an independent Neutral Vendor Managed Service.
Rather than acting as another recruitment agency, Datum RPO manages the recruitment supply chain on behalf of the client. Multiple recruitment agencies can continue to supply workers, while Datum RPO provides a central point of control across recruitment, compliance, supplier management, reporting and workforce spend.
Our approach can help organisations improve visibility across temporary labour, standardise processes, strengthen compliance governance, manage recruitment suppliers consistently and identify opportunities to improve cost efficiency.
For organisations preparing for the October 2026 Right to Work changes, this provides an opportunity to review the entire temporary labour supply chain rather than focusing on compliance in isolation.
From 1 October 2026, the Right to Work Scheme is being extended to cover additional working arrangements, including relevant workers under worker’s contracts and individual subcontractor arrangements. The updated guidance also covers certain online matching services.
Organisations using temporary workers need appropriate processes to establish an individual’s right to work before employment begins and, where applicable, complete follow-up checks. With multiple recruitment agencies and different worker engagement models, maintaining consistent processes and clear records becomes particularly important.
Yes. A Neutral Vendor Managed Service provides a central point of control across multiple recruitment agencies. It can help organisations standardise processes, improve supplier performance, increase visibility of agency spend and strengthen compliance governance while retaining access to a broad recruitment supply chain.
Datum RPO provides an independent, vendor-neutral approach to temporary workforce management. Rather than favouring one recruitment supplier, Datum RPO manages a competitive supplier network on behalf of the client.
For UK organisations preparing for the October 2026 Right to Work changes, a neutral partner can provide greater oversight of recruitment processes, supplier performance and workforce compliance.
The October 2026 Right to Work changes are therefore more than a compliance update. They are an opportunity to review how effectively your organisation manages temporary labour.
By combining consistent compliance processes with effective supplier management and temporary labour procurement, organisations can strengthen workforce governance while also looking for opportunities to improve efficiency, control costs and increase ROI.
Datum RPO can help organisations create a more controlled, compliant and commercially effective approach to temporary workforce management.