UK Right to Work Changes: What Employers Need to Know for 2026

The UK’s Right to Work (RTW) regime is undergoing one of its most significant changes in recent years, with new requirements coming into force on 1 October 2026.

For organisations that rely on temporary workers, contractors, agency labour or other flexible workforce models, the changes could have a significant impact on how workers are sourced, onboarded and managed.

The key message for employers is simple: Right to Work compliance can no longer be viewed solely as an HR responsibility or something that sits with an individual recruitment agency. Businesses need greater visibility across their workforce and labour supply chain.

What is changing?

The current Right to Work scheme has historically focused primarily on employees. From 1 October 2026, the scope will expand to cover additional working arrangements, including certain workers and self-employed individuals, reflecting the changing nature of the UK labour market.

The changes are intended to address gaps in the existing system, particularly in sectors and business models where organisations rely on agency workers, casual arrangements, subcontracting, intermediaries and gig-economy platforms.

At a glance: what’s changing?

• A wider range of workers will come within the RTW regime, including certain individuals engaged under worker contracts and some self-employed or subcontracted arrangements.
• Certain labour supply and contractual arrangements will be affected, meaning businesses need to understand how their workforce is engaged and where responsibility for compliance sits.
• Responsibility can extend further through contractual arrangements in certain circumstances, increasing the importance of understanding the labour supply chain.
• Gig-economy and platform-based working arrangements are being brought further into scope, reflecting the growth of flexible and task-based work.
• Supplier and subcontractor governance will become increasingly important, particularly for organisations using multiple labour providers.
• Identity and substitution arrangements need careful consideration, particularly where a contract allows someone other than the originally engaged individual to undertake the work.
• Organisations will need to ensure appropriate RTW checks and evidence are in place for arrangements falling within the expanded regime.
• The financial consequences of non-compliance remain significant, making effective workforce governance and consistent processes increasingly important.

Importantly, this does not mean that every organisation in a labour supply chain automatically becomes liable for every worker. The responsibilities will depend on the particular working and contractual arrangements involved.

For businesses using temporary labour, understanding those arrangements and having appropriate controls in place should therefore be a priority ahead of October 2026.

Why does this matter for temporary workforce management?

For organisations with large contingent workforces, the challenge isn't simply completing a Right to Work check.

It is ensuring that the appropriate check has been completed, at the right time, on the right individual – and that the organisation can demonstrate appropriate evidence and processes when required.

This becomes particularly important where organisations work with multiple recruitment agencies.

Without a centralised approach, businesses can face inconsistent processes, limited visibility, duplicated administration and difficulty establishing whether workers have been appropriately checked.

The complexity increases further when temporary workers are supplied through multiple agencies, subcontractors or other intermediaries. Organisations need confidence that their workforce supply chain is operating consistently and that appropriate compliance controls are being followed.

The cost of getting it wrong

The financial consequences of illegal working can be substantial. Employers can face a civil penalty of up to £60,000 for each illegal worker in circumstances covered by the civil penalty regime.

For organisations employing or engaging large numbers of temporary workers, this means that even a small number of compliance failures can create significant financial and reputational exposure.

But the risk isn't limited to the fine itself. Businesses may also face disruption to their workforce, increased scrutiny, reputational damage and considerable management time dealing with compliance issues.

With potentially £60,000 at stake per worker, robust Right to Work processes should be viewed as an essential part of temporary workforce governance – not simply an administrative check.

This is where having strong supplier management, consistent processes and clear visibility across the temporary workforce can make a meaningful difference.

How can Datum RPO help?

This is where a Neutral Vendor Managed Service can make a significant difference.

At Datum RPO, we help organisations take greater control of their temporary workforce by bringing recruitment agencies, processes, compliance and workforce data together through a single managed model.

Our neutral approach means we don't favour one recruitment agency over another. Instead, suppliers compete against agreed standards for quality, service, compliance and cost.

For organisations preparing for the expanded Right to Work regime, this provides an additional layer of governance and visibility.

Datum RPO can help organisations to:

• Establish consistent onboarding and compliance processes across recruitment suppliers.
• Improve visibility of temporary and contingent workers across multiple sites and business units.
• Support robust agency governance and supplier performance management.
• Identify gaps and inconsistencies in existing workforce processes.
• Provide clearer reporting around temporary workforce activity and supplier performance.
• Help organisations adapt their processes as RTW requirements evolve.
• Reduce administrative pressure on internal HR, procurement and hiring teams.
• Improve control over agency labour costs while maintaining a competitive supplier network.

Datum RPO's neutral vendor model is designed to give clients one managed process rather than multiple disconnected agency relationships. This can be particularly valuable when organisations need greater transparency and consistency across a complex temporary labour supply chain.

What should employers do now?

With the changes coming into force on 1 October 2026, organisations should start reviewing their workforce arrangements now.

Begin by mapping how temporary workers, contractors, subcontractors and agency workers enter your organisation. Consider which recruitment agencies and labour providers you use, what contractual arrangements are in place and where responsibility for Right to Work checks currently sits.

Businesses should also review their onboarding processes and ask:

• Are RTW checks being completed consistently?
• Do all recruitment suppliers follow the same standards?
• Can we demonstrate who completed the check and when?
• Do we have visibility of workers supplied through different agencies?
• Are our contracts and supplier arrangements clear about compliance responsibilities?
• What happens when a worker's right to work is time-limited?
• Can our current systems provide the reporting and audit trail we may need?

For organisations managing high volumes of temporary workers, integrating compliance into a centralised workforce management process can provide significantly greater control than relying on multiple agencies to operate independently.

Turning compliance into an opportunity

While the expanded RTW regime introduces additional responsibilities, it also creates an opportunity for businesses to rethink how they manage contingent labour.

A centralised, neutral approach can help organisations move away from fragmented agency management towards a more consistent, transparent and measurable workforce model.

With the right processes, technology, supplier governance and reporting in place, employers can strengthen workforce compliance while also reducing unnecessary administration and agency costs.

The October 2026 RTW changes are therefore more than a compliance update. They are an opportunity to take a fresh look at how your entire temporary workforce is managed – particularly when the potential penalty can reach £60,000 for a single illegal worker.

For organisations using multiple recruitment agencies or managing significant temporary labour volumes, Datum RPO can help create a more controlled, transparent and efficient approach to workforce management.

FAQs

1. When do the new UK Right to Work changes come into force?

The expanded Right to Work regime comes into force on 1 October 2026. The changes extend the scheme beyond its traditional focus on employees to cover additional working arrangements, including certain workers and self-employed individuals.

2. Will the changes affect businesses using temporary agency workers?

Potentially, yes. Organisations using temporary and contingent labour should review their current processes and supply-chain arrangements.

The changes are particularly relevant to businesses operating models involving workers, self-employed individuals, subcontractors, intermediaries and other flexible working arrangements.

However, the precise responsibilities will depend on the nature of the engagement and contractual structure. Employers should therefore assess their specific workforce model rather than assuming every temporary worker will be treated in exactly the same way.

3. How can a Neutral Vendor Managed Service improve Right to Work compliance?

A Neutral Vendor Managed Service creates a central point of governance across multiple recruitment agencies.

Rather than relying on each supplier to manage its own processes independently, organisations can establish consistent standards, clearer reporting, supplier accountability and greater visibility of their temporary workforce.

For businesses facing increasingly complex workforce compliance requirements, this can provide a more structured way to manage the recruitment supply chain while also improving efficiency and cost control.

4. Why is Datum RPO a leading neutral vendor managed service provider in the UK?

Datum RPO is focused on delivering an independent, vendor-neutral approach to temporary workforce management.

Unlike a recruitment agency or master vendor model that may favour its own recruitment interests, Datum RPO does not supply candidates directly. Instead, we manage a competitive recruitment supply chain on behalf of the client, giving organisations access to multiple recruitment agencies while maintaining a single managed process.

This approach provides clients with greater visibility, compliance, supplier governance, process consistency and cost control.

For organisations navigating the 2026 Right to Work changes, having a neutral partner overseeing the recruitment supply chain can help create greater confidence that processes are being applied consistently across suppliers.

Datum RPO's goal is simple: to give organisations more control over their temporary workforce, while helping them improve compliance, reduce costs and simplify agency management.