New rules imposing requirements to conduct right to work checks on a wider range of organisations came into force on 1 October 2026.
As we have discussed previously, Section 48 of the Border Security, Asylum and Immigration Act 2025 significantly expands the UK’s right to work regime by broadening the scope of who qualifies as an ‘employer’ and ‘worker’ for right to work purposes, capturing a broader range of working arrangements beyond traditional employee-employer relationships.
The new law also provides for circumstances in which liability for civil penalties for illegal working may extend beyond the organisation with the direct contractual relationship with the worker (so-called ‘extended liability’).
Earlier this summer, we discussed here updated guidance from the Home Office which explains in detail how the new regime will operate in practice, the various new relationships that will now fall within its scope, and the circumstances in which the new extended liability provisions will arise.
While many of the scenarios in the guidance focus on the hospitality, construction, and food delivery industries, the entertainment industry is likely also to be significantly affected. This is particularly so given its reliance on freelancers, short-term engagements, day players and crew engaged at short notice, often through production companies, agencies and personal service companies.
Ahead of the changes coming into force, we published advice (here) on how the industry can get ahead of the rules. We have since also published more detailed advice here.