From 1 October, right to work checks reach couriers, subcontractors and platform workers

From 1 October 2026 the UK switches on an expanded illegal working regime. It comes from section 48 of the Border Security, Asylum and Immigration Act 2025, which extends the regime in section 15 of the Immigration, Asylum and Nationality Act 2006. Until now the duty to check sat with the employer in the narrow sense — whoever hired under a contract of service. The circle is now considerably wider.

Who must be checked?

Four groups fall inside the new definition. People on a worker’s contract, where the individual performs the service personally even without employee status. Individual subcontractors in a chain: if a company hires a contractor who brings his own people, those people are in scope too. Agency workers, named expressly. And online matching platforms that connect providers with clients — food delivery, ride-hailing, cleaning, small repairs.

Only the genuinely self-employed professional who deals with the client directly, with no intermediary and no platform, stays outside. The line is thin, and in practice what decides is how the work is actually arranged, not the label on the contract.

From what date?

The rules apply to any working relationship starting on or after 1 October 2026, and to repeat checks on existing workers from that date. A contract signed in September is not swept in by itself — but the moment a follow-up check falls due, it runs under the new rules.

What does a mistake cost?

The civil penalty is up to £60,000 per illegal worker, and higher for repeat breaches. Where there is reasonable cause to believe the business knew, it becomes criminal: unlimited fines, and custodial sentences for directors. For a small firm with two couriers that is a risk on the scale of a year’s turnover.

What does the worker need?

The practical part is unchanged: the check runs on a share code. You generate it in your UKVI account through "Prove your right to work to an employer" on GOV.UK; the code is valid for 90 days and the employer enters it with your date of birth. If you do not yet have a UKVI account and an eVisa, set one up before October — platforms and agencies will start asking for codes in bulk, and the Home Office support queue in the first weeks is predictable.

The draft code also spells out the discrimination rule. An employer may not treat you less favourably merely because your permission is time-limited, and may not insist on a digital check only — except where you hold an eVisa and no other document exists. A refusal justified by your "complicated status" is worth putting in writing.

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What does the business need to do?

Before 1 October, walk the labour supply chain: who actually does the work, under which contracts, and who owns the check. Update contractor templates, name someone responsible for keeping evidence, and make sure the person doing the work is the person who was checked. In platform work that last point is the weakest link.

All the upcoming filing deadlines, bank holidays and decision dates are gathered in the ONLYWAY calendar, day by day with explanations.

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