UK extends right-to-work fines to firms using contractors
- UK right-to-work liability now extends to businesses using contractors and platforms.
- The changes took effect on Oct. 1, 2026.
- Civil penalties reach up to £60,000 ($81,000) per illegal worker.
- The Border Security, Asylum and Immigration Act 2025 brought in the change.
LONDON, UNITED KINGDOM — Businesses in the United Kingdom can now face right-to-work penalties for illegal workers supplied through contractors, agencies, subcontractors and online platforms, not just for their own direct employees.
The changes took effect on Oct. 1, with civil penalties of up to £60,000 ($81,000) per illegal worker.
A wider definition of employer
The Border Security, Asylum and Immigration Act 2025 amends the Immigration, Asylum and Nationality Act 2006 to extend the term “employer” beyond the traditional contract of employment, according to law firm Osborne Clarke.
The new definition covers those who employ people under contracts of employment, engage workers or individual subcontractors, and operate online matching services connecting service providers with customers.
Labels such as “self-employed” or “contractor” are not decisive, as the Home Office will look at how work is arranged and performed in practice.
Liability can arise in contracting chains, on online matching platforms, and where contracts let a worker send a substitute.
What businesses must do
Extended liability focuses on businesses contractually responsible for providing work or services onward as part of a chain.
A client buying work or services for its own internal operations is generally not in scope, though it keeps direct duties for its own employees.
To have a statutory excuse, businesses need written statements requiring right-to-work checks across their chains, audit rights, controls on further subcontracting, and identity checks on anyone actually doing the work.
The Home Office recommends re-verification at least once every 24 hours or shift where risk is higher.
Removing illegal workers from operations such as warehousing, construction, logistics, facilities and delivery could disrupt businesses, the firm said.
The risk no longer sits only with HR but extends to procurement, operations and platform teams, Osborne Clarke said.
Directors also face possible disqualification and criminal liability in serious cases, and non-compliant employers can be named on a Home Office list.
The rules apply to work starting on or after Oct. 1 and have no retrospective effect.
For businesses that supply labor or services onward, the reform turns right-to-work checks into a supply-chain duty, not just an HR task.
Providers delivering compliance outsourcing or staffing agency services into the UK will need checks and records that clients can audit.
Firms comparing partners can use the top BPO companies worldwide list and ask how each verifies workers across its subcontractors.
Related news
- Serco wins $101Mn home office passport call center contract · 1 Apr
- IBM buys U.K. cyber consultancy Logiq to expand defense work · 28 Sep
- Infosys BPM adds an AI delivery hub in Philippines · 1 Sep
Disclosure: Outsource Accelerator uses AI tools in the backend of its editorial workflow. Every article is reviewed and verified by a human editor before publication.
Stay ahead of the outsourcing industry. Join thousands of business leaders who rely on Outsource Accelerator for the news, trends, and expert insights that matter. Subscribe to our free newsletter and never miss an update.
