Right to Work Updates October 2026: What You Need To Know

Major changes to the UK Right to Work (RTW) checking framework came into play on October 1st 2026, and it impacts the full spectrum of the workforce supply chain. End-clients, Managed Service Providers (MSPs), recruitment agencies, umbrella companies and contractors are all affected, so it’s important you know what’s changed and what to expect going forward. 

The key changes at a glance:

• • Section 48 of the Border Security, Asylum and Immigration Act 2025 has expanded scope beyond traditional employees. 

• • Stricter digital and verification requirements will be in place, with higher fines and severe non-compliance risks. 

Here, we’ll highlight what this means for agencies and umbrella companies, and why using a reliable digital verification provider is essential for compliance, security and efficiency.

Who do the new rules apply to?

RTW checks have now broadened beyond what is considered a ‘traditional employee’. That includes specified non-employed workers, individual subcontractors and online matching service arrangements.

Organisations will be in scope of the updated provisions if they employ or engage any individuals that are working:

• • under a contract of employment

• • under a worker’s contract

• • as an individual subcontractor

In short, individuals that work for or within a business without being directly employed by it will be subject to RTW checks. As a result, contractors can expect duplicated onboarding and repeated checks every time they switch umbrella company, while limited company contractors will face closer scrutiny of substitution clauses.

What is extended liability?

It can no longer be assumed that responsibility for RTW checks simply sits with another party in the supply chain. Where the required checks have not been completed correctly, there can be consequences for multiple parties within the supply chain. 

This makes it increasingly important for agencies, employers and other parties involved in supplying workers to understand who is completing the RTW check, what check is being completed, and whether there is appropriate evidence that the check has been carried out.

Understanding digital verification

A business or employer can use a Digital Verification Service (DVS) provider to verify RTW status securely and efficiently. However, the DVS provider must be registered with the Government’s Office for Digital Identities and Attributes (OfDIA).

At ADVANCE, we use the registered provider TrustID for a secure and seamless process for contractors and agencies alike.

Why TrustID?

We carefully selected TrustID as our registered provider based on several features designed to help strengthen the RTW checking process, including:

• • Biometric document checks – helping to identify altered or tampered documents.

• • Tamper detection – checking documents for signs of manipulation or alteration.

• • Liveness checks – helping to establish that the person completing the check is physically present rather than using a photograph or other representation.

• • Biometric facial matching – comparing the individual’s face against the identity document to help confirm that the person presenting the document is the genuine document holder.

Assuring RTW compliance

After an initial RTW verification for an in-scope worker, businesses must make additional checks to ensure the individual commencing the assignment is doing so compliantly. 

Imposter checks

The purpose of an imposter check is to provide an additional level of assurance that the individual presenting themselves for work is the person who completed the original RTW check.

This is particularly relevant for agencies and businesses supplying workers to different sites.

Day-one checks

Day-one checks confirm the identity of workers when they commence an assignment. The responsibility can sit with the agency or the employer, provided there is a process in place to establish that the appropriate check has been completed. This is particularly important for agency workers where the individual may be attending an end-client site. 

A day-one identity check helps confirm: “Is this the same person who completed the RTW check?” It can also help identify situations where a worker attempts to have another individual attend an assignment on their behalf. Where workers are permitted to be substituted, appropriate checks should still be considered to ensure that the individual attending the site has the necessary right to work.

Trust ADVANCE for efficient, compliant workforce management

Regulatory shifts continue to change business practice in the temporary workforce supply chain, but our commitment to 100% compliance for our agency partners and contractors remains constant. For a partnership built on absolute transparency and streamlined processes, choose ADVANCE.

Got a question about the updated RTW provisions? Speak to one of our experts, we’d be happy to help.