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Photograph courtesy of Annabel Skinner
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Right to work changes from October 2026: what London businesses need to know
By Francesca Sciberras at Laura Devine Immigration
Testing the waters
Sea Lanes in Canary Wharf is the latest project in London’ s long tradition of encouraging the city’ s inhabitants to water.
The attraction-cum-facility opened in June not long before the series of summer heat waves and is a 50-metre, six-lane natural water swimming pool floating in a dock. The idea, clearly a successful one, is to bridge the gap between traditional pools and open water.
Washhouse
In Covent Garden, the Oasis Sports Centre( truly an‘ oasis’) can claim to be on or adjacent to the site of a Turkish bath, established in the 1700s. It became Bloomsbury Baths and Washhouse in the 1800s and Holborn Baths in 1902. The current baths, opened in
1946, was the site of a military hospital in during WW1. Housing over 500 beds it was the only British army hospital to have been staffed entirely by women and treated over 24,000 soldiers.
Lidos
The 1920s and 30s have been termed the‘ golden age’ of lidos – over 60 were built in the capital as London County Council set out to make it a city of water features. Seventeen now remain with notable ones in Tooting Bec, Parliament Hill, London Fields and Brockwell. This summer all have been doing record business.
www. sealanescanarywharf. co. uk
www. better. org. uk / leisurecentre / london
From 1 October 2026, UK right to work obligations will extend beyond traditional employeremployee relationships to a much wider range of working arrangements. The expanded regime will cover individuals engaged under a‘ workers’ contract’, individual subcontractors and certain online matching service arrangements. In some circumstances, liability may also extend through labour supply chains, potentially exposing businesses to liability for workers with whom they have no direct contractual relationship.
For businesses, this is more than an HR issue. It creates a wider operational, procurement and contractual compliance risk, particularly for SMEs that rely on flexible labour or outsourced services.
How should businesses adapt Businesses should ensure appropriate contractual arrangements are in place to require suppliers and subcontractors to carry out compliant checks where responsibility sits with them. Contracts may need to include provisions requiring checks before workers start, controlling substitution, permitting audits and requiring cooperation with Home Office enforcement action.
Businesses using sub-contractors or arrangements permitting worker substitution may also need proportionate systems to verify workers’ identities.
The rules will not generally apply to genuinely self-employed individuals operating businesses in their own right and providing services directly to customers. They will also not generally apply to end-users purchasing a completed service for their own use.
The expanded provisions are not retrospective. Civil penalties can only apply to in-scope arrangements commencing on or after 1 October 2026.
What are the risks? Civil penalties for non-compliance can be up to £ 45,000 per illegal worker for a first breach and up to £ 60,000 for repeat breaches. Knowingly employing an individual without the right to work or doing so where there is reasonable cause to believe illegal working is occurring may give rise to criminal liability.
Businesses holding sponsor licences face an additional risk: serious compliance failures including civil penalties for employing illegal workers can put their licence at risk, potentially disrupting their ability to employ sponsored workers.
What should businesses do now? Businesses should start by mapping their workforce and supply chains to identify which arrangements may fall within the new regime. They should review supplier and contractor agreements, update onboarding and right to work processes, consider whether identity verification systems are required and train HR, recruitment, procurement and operational staff. Maintaining comprehensive records will also be important in demonstrating compliance.
Businesses should not wait until October to prepare. Early action will be key to identifying exposure, updating contractual arrangements and ensuring compliance with the new regime.
Get in touch For advice on how these changes may affect you or your business, please contact our Enquiries team at enquiries @ lauradevine. com.
www. lauradevine. com
Francesca Sciberras is a Partner at Laura Devine Immigration, a transatlantic boutique immigration firm with offices in London and New York.