The Government’s October 2025 consultation on extending the Right to Work Scheme shows where policy is heading next. It is not limited to standard employment relationships. The consultation proposes extending checks into other working arrangements, including people engaged under a worker’s contract, individual subcontractors and online matching services.
This especially impacts businesses built around flexible labour rather than permanent recruitment. The consultation names sectors such as construction, food delivery, beauty salons, courier services and warehousing. Once Right to Work obligations move further into these models, compliance become part of wider workforce control instead of a narrow HR step.
The same consultation explains the enforcement backdrop. It says illegal working arrests were up 63% and visits or raids were up 51% in the year to September 2025. Taken together, that gives employers a much clearer signal: the government is widening both the scope of checks and the intensity of scrutiny.
Sources: Home Office consultation on extending the Right to Work Scheme and related impact material.
This is blog 2 in a 6-part series, subscribe here to be notified of future changes to Right to Work Compliance based on HMRC updates and Gov.uk sources.
- You can read how the Home Office’s draft 2026 code shifts Right to Work compliance in part 1 here.
- In part 3, we outline how digital-only Right to Work journeys can leave gaps.
- In part 4, we cover how rechecks have been causing employers to become unstuck with regards to their right to work compliance.
