UK: Right-to-Work Liability Now Reaches Up the Supply Chain

15 October 2026 · General information, not legal advice

Since 1 October 2026, the UK illegal-working civil penalty regime reaches further up the contracting chain. A business can now be treated as “employing” someone for right-to-work purposes even if it has no direct contract with that person, and even if the person is engaged several tiers down.

What changes:

• The regime now covers intermediaries, subcontractors, labour suppliers, online matching platforms and substitution clauses.
• Liability is additive: the Home Office can pursue several companies in the chain for the same illegal worker.
• The maximum civil penalty remains £60,000 per illegal worker.
• A compliant right-to-work check is still a statutory excuse, but from 1 October 2026 it depends on specific contractual arrangements being in place before the work or services start.

What it means in practice:employers, agencies and subcontractors should review existing contracts now and vary them where the required terms are missing, and make sure it is clear who carries out right-to-work checks at each level of the chain. Also coming in UK employment law: a statutory statement on the right to join a trade union (January 2027), day-one bereavement leave of up to two weeks (April 2027) and a statutory reasonableness test for flexible-working requests (autumn 2027). Looking for a legal way to work in Europe? See our current offers for Serbia, the Czech Republic, Germany, Poland and Montenegro at https://www.mnidealcompany.com/.