The Home Office has opened a six-week consultation that would radically widen the scope of the Right-to-Work Scheme, the compliance regime that obliges UK employers to confirm the immigration status of every new hire. Under the proposal, the statutory duty to carry out checks would no longer apply only to employees on a contract of employment: it would be extended to businesses engaging individuals on zero-hours contracts, in the platform or “gig” economy and in other irregular working arrangements such as courier, food-delivery, construction and beauty-salon work .
The measure is part of the forthcoming Border Security, Asylum and Immigration Bill and is explicitly designed to “clamp-down on illegal working”, which ministers argue is a key pull-factor for irregular migration. Employers would need to verify a worker’s digital status using the Home Office’s online checking service or see and copy original documentation before onboarding. Failure to comply already carries fines of up to £60,000 per illegal worker and potential criminal liability; industry groups expect penalties to rise once the new rules are in force.
For corporate mobility and HR teams the proposal has material implications. Large companies that rely on flexible labour—particularly in warehousing, logistics and last-mile delivery—will have to expand right-to-work processes beyond PAYE staff. That is likely to mean revisiting onboarding workflows, investing in digital identity solutions and training line-managers who engage casual labour. For multinationals, the consultation also signals the Government’s intent to align right-to-work with wider moves toward fully digital immigration status (eVisas) and the creation of a single enforcement code spanning employment, tax and immigration compliance.
The consultation asks businesses how best to operationalise the extended checks and what guidance they will need. It closes at 23:59 on 10 December 2025. Mobility managers should review existing supply-chain arrangements, respond to the consultation and prepare for the new statutory code of practice that will follow in 2026.
The measure is part of the forthcoming Border Security, Asylum and Immigration Bill and is explicitly designed to “clamp-down on illegal working”, which ministers argue is a key pull-factor for irregular migration. Employers would need to verify a worker’s digital status using the Home Office’s online checking service or see and copy original documentation before onboarding. Failure to comply already carries fines of up to £60,000 per illegal worker and potential criminal liability; industry groups expect penalties to rise once the new rules are in force.
For corporate mobility and HR teams the proposal has material implications. Large companies that rely on flexible labour—particularly in warehousing, logistics and last-mile delivery—will have to expand right-to-work processes beyond PAYE staff. That is likely to mean revisiting onboarding workflows, investing in digital identity solutions and training line-managers who engage casual labour. For multinationals, the consultation also signals the Government’s intent to align right-to-work with wider moves toward fully digital immigration status (eVisas) and the creation of a single enforcement code spanning employment, tax and immigration compliance.
The consultation asks businesses how best to operationalise the extended checks and what guidance they will need. It closes at 23:59 on 10 December 2025. Mobility managers should review existing supply-chain arrangements, respond to the consultation and prepare for the new statutory code of practice that will follow in 2026.
