Extended liability has been introduced as one of the term changes regarding right to work checks, with changes coming into effect this October 2026. Businesses in the supply chain could face penalties if immediate employers do not meet compliance checks.
The provisions direct employers with remaining time before the October 2026 changes to review their workforce compliance, which will affect contracts, supply chains, compliance and verification procedures.
For most companies, this will make little difference to their existing right to work checks but they will be required to investigate if their wider supply chain, including contractors, is compliant and put the appropriate checks in place.
Companies will be required to identify and engage their subcontractors and agency workers with the new rule changes to avoid penalties reaching up to £60,000 per illegal worker and licences being revoked.
Totally independent freelancers will remain excluded on evaluation of their working practices and not status.
These changes will initiated via section 48 of the Border Security, Asylum and Immigration Act 2025, with the Home Office also outlining draft guidelines this summer on preventing illegal worker contracts.
As organisations adapt to these expanded compliance requirements ahead of the October 2026 deadline, the broader operational and technological challenges of supply chain verification will take center stage at Identity Week Europe 2027. Dedicated sessions throughout the event’s Identity Access Management (IAM) and Verification & Authentication tracks will examine automated onboarding, third-party workforce governance, and fraud detection technologies designed to help enterprises streamline compliance across complex agency and contractor networks.
