The Recruitment Leadership Podcast
Aug 19, 2026 · 31 min · 10 segments
Welcome to the latest episode of the Recruitment Leadership Podcast, hosted by Alison Humphries. Compliance is often seen as a necessary administrative task. But what if it could become one of…
Abbie BlackGuest
Alison HumphriesHost
This act is a real, we're seeing it as a real structural shift when it comes to liability for right to work checks.

And section 48 of that act essentially extends the civil penalty liabilities beyond a traditional employment model that we've seen up until this point, in the sense that it's moving obligations from the employer to the organisation.

It's moving the compliance obligations and the liability to contractors, subcontractors, zero hour contract workers.

So whereby previously it would have maybe been more of if contractors are placed in an organisation, it's the recruiter responsible for checking those individuals.

The organisation that those workers are going to be working in is also going to become liable for ensuring that those individuals have the right to work in the UK.

So we're expecting the new right to work rules to come into place in October 2026.

It is extending that requirement for organisations to check not just their direct employees, but also ensuring that they are checking contractors, subcontractors, etc.

So do we see this as a duplication where the recruiter will do those checks because they're already obliged to and then the end hirer will also do those checks?

I would say this is one of the items that we are waiting to get more guidance from government on.

So through different working groups, we are waiting to, the Home Office is expected to publish more worked examples of different supply chain scenarios because Sort of as you've mentioned there, different scenarios, different supply chains can be complex.

This act is a real, we're seeing it as a real structural shift when it comes to liability for right to work checks.

And section 48 of that act essentially extends the civil penalty liabilities beyond a traditional employment model that we've seen up until this point, in the sense that it's moving obligations from the employer to the organisation.

It's moving the compliance obligations and the liability to contractors, subcontractors, zero hour contract workers.

So whereby previously it would have maybe been more of if contractors are placed in an organisation, it's the recruiter responsible for checking those individuals.

The organisation that those workers are going to be working in is also going to become liable for ensuring that those individuals have the right to work in the UK.

So we're expecting the new right to work rules to come into place in October 2026.

It is extending that requirement for organisations to check not just their direct employees, but also ensuring that they are checking contractors, subcontractors, etc.

So do we see this as a duplication where the recruiter will do those checks because they're already obliged to and then the end hirer will also do those checks?

I would say this is one of the items that we are waiting to get more guidance from government on.

So through different working groups, we are waiting to, the Home Office is expected to publish more worked examples of different supply chain scenarios because Sort of as you've mentioned there, different scenarios, different supply chains can be complex.
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