From 1 October 2026, right to work obligations are expected to widen beyond direct employees to cover contractors, agency workers, casual staff and outsourced services — with liability extending through labour supply chains, so you can be exposed even without a direct contract with the individual doing the work. The check must happen before work starts: an online Home Office check using a share code for those with an eVisa, or a properly conducted manual document check for everyone else. Keep dated copies — that is what gives you the statutory excuse. Where someone’s permission is time-limited, a follow-up check is needed before it expires.
A civil penalty is a serious matter for a small business, in cost, time and reputation — we are not quoting figures here as they sit in Home Office guidance, which is still being finalised. The practical fix: one named person owns the process, a simple checklist covers every category of worker, and a records file holds dated copies and follow-up dates. Check the final published guidance and take employment advice before the deadline.