The UK government has significantly broadened its Right to Work (RTW) requirements as of December 2, 2025, extending obligations far beyond traditional employment relationships. Companies now face expanded liability across their entire workforce ecosystem – including gig workers, subcontracted labor, and individuals hired through digital platforms.
What’s Changed
The definition of “employer” has been widened to capture three key scenarios:
Workers on Non-Standard Contracts: If your business engages someone under a worker’s contract (not a traditional employment or apprenticeship agreement) and you’re not acting as their client, you’re now considered their employer for RTW purposes.
Subcontracting Arrangements: Chain liability is now in play. When you subcontract work, both you and your subcontractor may be responsible for verifying workers’ right to work. For example, if you contract with a customer to provide construction services and then subcontract that work to another company, both businesses are on the hook for RTW compliance for those workers.
Online Matching Platforms: Digital platforms that connect workers with customers for a fee or commission are now classified as employers. This applies to app-based services, freelancer marketplaces, and similar platforms that facilitate work arrangements.
Who’s Exempt
End customers receiving services aren’t caught by these rules. If you’re simply purchasing services as a customer, you won’t have RTW obligations. Private households hiring tradespeople directly as consumers are also excluded.
What This Means for Your Business
The compliance landscape just got more complex. You’ll need to map your entire supply chain and service delivery model to identify:
- Who requires RTW verification
- Which entity bears responsibility for conducting checks
- Where shared liability may exist
The stakes are high. Penalties for employing illegal workers reach up to £60,000 per individual – a significant exposure when you consider how many workers might touch your operations through various arrangements.
Implementation Timeline
While the policy is officially in effect, practical guidance remains pending. The government is expected to publish detailed operational guidelines and Codes of Practice after December 10, 2025, following the close of the current consultation period. These documents will clarify how to implement these requirements in practice.
The Bigger Picture
This expansion reflects the government’s push to modernize RTW compliance for today’s workforce reality. Traditional employment relationships represent just one slice of how work gets done. With the rise of platform-based work, complex supply chains, and flexible labor arrangements, the old rules left significant gaps.
This change also aligns with broader enforcement trends. The government has already increased penalties and ramped up compliance activity around illegal working. The expanded scope continues this trajectory, casting a wider net to ensure all working arrangements are captured.
Next Steps
Start reviewing your workforce arrangements now. Don’t wait for the final guidance to assess your exposure. Identify all the ways individuals perform work for or on behalf of your organization, whether they’re employees, contractors, platform workers, or part of your subcontractor workforce.
Once the operational guidance drops, you’ll need to move quickly to implement compliant processes across all these relationships. We’ll keep you updated as implementation details emerge.