The UK’s right-to-work regime is due to expand later in 2026, bringing more non-employee working arrangements within the legal checking framework. For Bromley businesses using casual workers, individual subcontractors or online platforms, the important point is that the change is not yet fully in force. The current statutory scheme mainly applies when employing someone under a contract of employment, but workers, individual subcontractors and certain online matching services will be brought into scope.
Why the Rules Are Changing
The Home Office says modern working models have created gaps in the existing system. Businesses may currently engage people as self-employed contractors, gig workers or casual workers without the same statutory checking responsibility that applies to employees. The extension is intended to close that gap and apply sanctions across more paid working arrangements.
Bromley employers in hospitality, care, construction, delivery services and retail should review their workforce now. Tailored immigration advice london can help identify which relationships are already covered and which may become subject to the expanded duty.
What a Compliant Check Looks Like
Right-to-work checks should be completed before employment begins. The method depends on the person’s status:
| Check method | Usually used for | Key requirement |
| Home Office online check | People with eVisas or eligible immigration status | Use the share code and date of birth, then retain evidence |
| Manual document check | British and Irish citizens using acceptable documents | Examine the original and keep a dated copy |
| IDVT check | British and Irish citizens with valid passports or Irish passport cards | Use a certified identity service provider |
Where permission is time-limited, a follow-up check must normally be completed before it expires. Checks must be applied consistently and must not be based on appearance, accent or assumed nationality.
Penalties and Sponsorship Risks
The maximum civil penalty is £45,000 per illegal worker for a first breach and £60,000 for a repeat breach within 3 years. A compliant check can establish a statutory excuse. Employers that knowingly employ someone illegally may also face criminal consequences.
Sponsors face additional risk because an illegal-working penalty can lead to sponsor licence action. Businesses recruiting overseas staff may therefore need advice on a sponsor licence application london as well as checking procedures.
Common Mistakes to Avoid
Do not rely on an expired share code, a driving licence or an unchecked photocopy. Do not forget follow-up checks for time-limited permission. Do not assume an agency worker, gig worker or subcontractor will always remain outside your responsibility once the expanded regime begins.
Review skilled worker visa eligibility, current sponsor licence compliance in 2026 guidance and the skilled worker sponsor licence guide before recruiting.
The safest approach is to map each paid working arrangement, assign responsibility for checks, train hiring staff and keep auditable records before the wider duties take effect.
Click here to read Part 2 of this article.
