Right-to-work checks from 1 October 2026: the gig-economy expansion

DRAFT for founder review — the 1 October 2026 commencement must be confirmed against the final Code of Practice (draft published 30 June 2026) before publishing; see VERIFICATION_PACK.md §G.2. Everything else is sourced.

For twenty years, right-to-work checking has been an employer's duty — engage someone as a contractor or through a platform and the checking obligation largely stopped at the contract boundary. That boundary is going. From 1 October 2026 (commencement per the draft Code of Practice published 30 June 2026 — confirm against the final Code), businesses engaging gig-economy and casual workers are brought into the checking regime.

Who is newly in scope

If your business engages couriers, drivers, riders, platform workers, or casual and substitute labour — construction subcontracting chains very much included — you will need a right-to-work checking process for those people, not just for employees. The change targets precisely the arrangements that were previously used to route around checking duties.

What a compliant check is (unchanged in kind, expanded in reach)

The three valid routes stay the same:

1. Online share-code check — for anyone with digital status; you need the share code and date of birth, and you keep the profile page with the date checked.
2. Manual document check — original documents from the approved lists, checked in the holder's presence, copied and dated.
3. IDSP check — identity verification through a certified provider for eligible British/Irish passport holders.

Whichever route: the evidence, and the date you performed the check, must be kept — and time-limited permission means a follow-up check before expiry.

Why it's worth doing properly

A compliant check gives you the statutory excuse. Without it, employing (and now, engaging) someone without the right to work risks a civil penalty of up to £60,000 per worker [^1] — per worker, not per incident. The Home Office publishes the names of penalised businesses.

A 30-day preparation plan

• Days 1–5: list everyone you engage who isn't a conventional employee — platform, casual, substitute, subcontracted.
• Days 6–15: run checks for that population using the routes above; a share-code check takes about two minutes per person.
• Days 16–20: build the log — who was checked, when, how, what was seen, when a re-check is due. (This is the exact structure of SponsorFort's RTW log.)
• Days 21–30: diarise every re-check with escalation so nothing waits on memory, and write the one-page internal process for whoever does checks after you.

Sponsors have one advantage here: if you already run checks for sponsored workers, extending the same discipline to the wider population is process, not invention. Log a check in SponsorFort and the re-check reminder exists before you've closed the tab.

[^1]: Penalties for employing illegal workers — gov.uk (fetched 5 July 2026). Employer's guide edition: 26 June 2025; expansion per the draft Code of Practice published 30 June 2026 — verify the final Code's commencement clause.

This is guidance based on published Home Office sponsor guidance, not legal advice. For advice on your specific situation, consult a regulated immigration adviser or solicitor.