UK employers face expanded right-to-work checks as new immigration law takes effect

From today, employers across the UK face expanded right-to-work compliance obligations that go far beyond traditional employment. The new requirements, brought into force by Section 48 of the Border Security, Asylum and Immigration Act 2025, extend illegal working checks to agency workers, self-employed contractors, casual and temporary workers, zero-hours workers, and gig economy workers.

This marks a significant shift for UK businesses. Previously, right-to-work verification applied mainly to formal employees. Now, any business using platform-based labour, online job-matching services, or sub-contracting arrangements must verify the immigration status of those workers too.

What this means for employers

• All businesses—not just licensed visa sponsors—must review their right-to-work processes
• Updated Home Office guidance and a new statutory Code of Practice will detail compliance requirements
• Different rules apply depending on whether workers can be substituted, subcontracted, or matched online
• Enforcement is expected to intensify, with the Home Office already focusing on high-risk sectors including hospitality, construction, logistics, and the gig economy

Foreigners working in the UK should be aware that employers are tightening their verification procedures. If you're a migrant worker—whether employed, self-employed, on a zero-hours contract, or working through a digital platform—ensure your right-to-work documentation is in order and up to date. Non-compliance by your employer can now carry significant civil penalties. If you're unsure of your status or have concerns about your employer's immigration compliance, seek advice from an immigration solicitor or contact relevant authorities early.

Sources

• DLA Piper GENIE — Right to work compliance expands beyond employees