Right to Work Checks: What the October 2026 Changes Mean for Businesses Using Temporary Workers
Right to Work compliance has always been an important part of responsible recruitment. However, with significant changes to the Right to Work framework coming into force on 1 October 2026, businesses using temporary, flexible or contingent labour should be reviewing their processes now.
At Contract Personnel, we supply temporary and permanent workers to businesses across East Anglia and understand that our clients need more than simply a candidate who can start work.
They need confidence that their workforce is being supplied properly, compliantly and responsibly.
Right to Work enforcement is increasing
The latest Home Office enforcement figures demonstrate why this subject deserves attention.
Between 1 January and 30 June 2026, Immigration Enforcement carried out 7,270 illegal working visits, resulting in 4,756 arrests.
Compared with the same period in 2025, this represents a 31% increase in visits and a 20% increase in arrests. More than 1,200 businesses were also issued with civil penalties, with penalties exceeding £74 million.
The increase is particularly notable in sectors that rely heavily on flexible labour.
Warehousing, distribution and delivery under the spotlight
Between January and June 2026, Immigration Enforcement carried out 635 visits to businesses in the warehousing, distribution and delivery sector, resulting in 635 arrests.
That represents a 147% increase in visits and a 70% increase in arrests compared with the same period in 2025.
Across the two years from July 2024 to June 2026, almost 2,000 arrests were made during illegal working visits in this sector.
For businesses operating warehouses, distribution centres, manufacturing facilities and other labour-intensive environments, this should serve as a clear reminder:
Right to Work compliance needs to be taken seriously.
What changes in October 2026?
From 1 October 2026, the Right to Work framework is being expanded.
The changes extend the scope of the regime beyond traditional direct employment arrangements and introduce obligations covering certain worker arrangements, individual subcontractors and online matching services.
For businesses using flexible labour models, this makes it increasingly important to understand who is responsible for Right to Work checks and how those responsibilities operate throughout the supply chain.
This is particularly relevant where businesses work with recruitment agencies, MSPs, neutral vendors, subcontractors or other labour providers.
The exact responsibilities will depend on the nature of the arrangement and the contractual structure involved.
What does this mean if you use a recruitment agency?
This is an area where there can be confusion.
When a temporary worker is supplied to a business, there can sometimes be several organisations involved in the wider labour supply chain.
At Contract Personnel, we believe that clarity of responsibility is essential.
As a recruitment agency, our role is to recruit and supply workers to our clients and to operate appropriate compliance processes around the workers we supply.
We are not an umbrella company.
Our clients should therefore be clear about the recruitment model they are using, who their contractual supplier is and where responsibility sits for the various compliance obligations.
Businesses should not simply assume that because a worker has come through an agency, every possible compliance responsibility automatically transfers to the end client.
Equally, businesses should understand exactly what their recruitment partner is responsible for and how that is documented.
Why your recruitment partner matters
The recruitment industry is changing, and compliance is becoming an increasingly important part of the service a recruitment agency provides.
For our clients, supplying workers isn’t simply about filling a vacancy.
It is about providing people who have been appropriately recruited, checked and processed before they arrive at your workplace.
At Contract Personnel, we take this responsibility seriously.
Our approach is built around:
- Robust recruitment processes
- Appropriate Right to Work procedures
- Clear records and documentation
- Communication with our clients
- Monitoring where further checks are required
- A straightforward agency relationship
Our objective is simple:
To give our clients confidence in the people we supply.
What should businesses do before October?
If your business uses temporary workers, now is a good time to review your labour supply arrangements.
- Understand your supply chain
Make sure you know who is actually supplying workers to your business.
Is it a recruitment agency? An MSP? A neutral vendor? A subcontractor? Another intermediary?
Understanding the structure is the first step towards understanding the responsibilities.
- Speak to your recruitment agency
Ask your recruitment provider how they conduct Right to Work checks and how they manage follow-up checks where a worker has time-limited permission to work.
Your recruitment partner should be able to explain its process clearly.
- Review your contracts
Make sure your agreements clearly establish the respective responsibilities of the parties involved.
If several organisations sit between the worker and the end client, clarity becomes even more important.
- Don’t wait until October
The October changes may seem some way away, but putting processes in place now gives businesses time to identify and resolve any gaps.
This is particularly important for employers with large temporary workforces or high volumes of worker turnover.
The Contract Personnel approach
At Contract Personnel, we have been supplying temporary and permanent staff to businesses for many years.
We understand that our clients need a recruitment partner who can provide people and peace of mind.
Whether you are recruiting for production, assembly, warehouse, logistics, driving or other operational roles, our job doesn’t stop at finding someone who is available.
We want to make sure that the recruitment process is handled professionally from the initial registration through to the worker starting with our client.
As the Right to Work landscape continues to evolve, we will continue to monitor the changes and keep our clients informed.
Is your temporary labour supply chain ready?
The latest enforcement figures show that Right to Work compliance is receiving significant attention, while the October 2026 changes will broaden the scope of the regime.
For businesses relying on temporary labour, now is the time to ask:
Do we know who is responsible for our Right to Work checks?
Do our recruitment partners have robust processes in place?
Are our contracts and labour supply arrangements clear?
Are we ready for the October changes?
If you are reviewing your temporary workforce or would like to discuss your recruitment requirements, Contract Personnel is here to help.
Contract Personnel – supplying people, supporting businesses and recruiting responsibly.
Important note
The October 2026 Right to Work changes are an evolving area, and businesses should ensure they are working from the latest Government guidance and obtain professional legal advice where appropriate.
This article is provided for general information only and does not constitute legal advice.
Official guidance: GOV.UK – Employer’s guide to Right to Work checks
