04/09/2026
Right to work checks should be on your September compliance list.
From 1 October 2026, published Home Office materials set out a wider Right to Work Scheme covering additional working arrangements, including some worker contracts, individual subcontractors and online matching services.
That matters for businesses using temporary labour. Review how responsibilities are allocated across your business, agencies, subcontractors and other labour-supply arrangements : and make sure the evidence is clear and accessible.
A practical review should include:
• Checks completed before work starts
• Clear records of the check and the date it was completed
• Follow-up checks diarised where permission to work is time-limited
• Current Home Office processes and acceptable documents being used
• Contractual responsibilities agreed with agencies and subcontractors
• A consistent, non-discriminatory process applied to everyone
You may also have seen reports about civil penalties increasing. The current Home Office code already sets maximum penalties of £45,000 per illegal worker for a first breach and £60,000 for a repeat breach within three years. The key October issue is the wider scope of arrangements that may need closer attention : not simply a new blanket fine.
Compliant processes, accurate records and an accountable recruitment partner can help reduce operational risk and avoid last-minute disruption. Aqumen is a member of SEDEX and ALP and holds a gangmasters licence.
This is general information, not legal advice. Review the latest GOV.UK guidance before making changes to your process.
Is your temporary labour process ready for 1 October?