New right to work duties for gig workers and supply chains
Right to Work checks expand from direct employees to gig workers, individual subcontractors and platform based staff engaged anywhere in your office. From 1 October, the Home Office will treat agency cleaners, contract caterers, freelance IT engineers, security guards and maintenance workers as part of your effective workforce for immigration compliance, even when an external business supplies the personal service. For any UK office manager, this shift turns what looked like a simple facilities contract into a regulated employment style relationship, with extended liability for illegal working across the full chain of services.
The policy sits within the Border Security, Asylum and Immigration Act and is backed by a revised Code of Practice on Right to Work checks and immigration compliance. Under the new regime, employers and upstream businesses can face a civil penalty of up to GBP 45,000 per illegal worker for a first breach and GBP 60,000 for repeat breaches, even where a gig worker is technically on another company’s books. The Home Office has been explicit that online matching platforms and work services intermediaries in the gig economy will no longer shield end user offices from liability when work checks fail or when an illegal worker is deployed on site.
For office managers, the headline is simple but uncomfortable and it will cut across procurement, HR and facilities decisions. If someone is physically working in your office, serving your people or visitors, you must be able to show that prescribed work checks were done correctly by you or by a contracted supplier with clear audit trails. Without that employer guide level of rigour, your business risks losing the statutory excuse defence, facing sponsor licence scrutiny and absorbing reputational damage that far outweighs any short term saving on low cost services.
Five actions before October for offices using cleaners, caterers and temps
Office managers now need a structured employer guide style playbook rather than ad hoc assurances from suppliers about right work processes. First, map every worker on site by engagement type, separating employees, agency staff, gig workers, individual subcontractors, consultants, platform based couriers and any gig worker providing ad hoc personal service such as event staff or baristas. This workforce mapping should link each individual to a specific contract, service line and supplier so that you can see where rtw checks are performed, where digital verification is used and where manual document checks still rely on front line supervisors.
Second, decide which of the three compliant methods you will accept across your contracts and services. The Home Office online service works for many immigration statuses, while manual checks remain valid for British and Irish citizens and some legacy documents, and certified Digital Verification Service Providers offer remote identity verification that can scale across multiple businesses and locations. Third, update all facilities management, cleaning, catering, reception, security and maintenance contracts to include detailed right to work clauses, substitution controls, subcontracting restrictions, audit rights and clear allocation of extended liability for illegal working, aligning renewal cycles with the best quarter to renegotiate office supplier contracts so that you do not miss commercial leverage.
Fourth, train procurement, office management and front of house teams so they understand when a worker on site is an employee, a gig worker, an agency worker or an individual subcontractor and what checks must exist before access badges or system logins are issued. This training should sit alongside your wider employment law updates, such as new onboarding and absence rules, so that right to work compliance is treated as part of the same operational playbook rather than a separate legal project. Finally, establish a simple but firm gatekeeping process at the office level, where no new work services, no new online matching platform and no new personal service contract goes live without documented rtw checks, a clear guide right summary from the supplier and a named contact responsible for immigration compliance in that business.
Liability chains, verification methods and contract clauses every office must use
The most significant shift for office managers is the way extended liability now runs up contractual chains, reaching businesses that never issued a payslip to the worker on site. If your office relies on a single integrated facilities contract that bundles cleaning, catering and reception services, you may be held liable if a downstream subcontractor fails to complete compliant work checks on a single illegal worker. That liability can arise even when an online matching platform or labour provider inserted the gig economy worker into the rota without your knowledge, because the Home Office will look at who benefited from the work and who controlled access to the workplace.
To manage this risk, contracts must move beyond generic compliance wording and into operational detail about right to work processes. Specify which party will perform rtw checks, which digital verification tools are approved, how often audit files will be shared, and what happens if an individual fails a check or loses immigration status during ongoing employment. Include clauses that prohibit uncontrolled use of individual subcontractors, require prior approval for any new work services or personal service arrangements, and allow you to suspend services immediately if immigration compliance concerns arise without breaching payment obligations for unaffected workers.
Offices that already operate structured onboarding in a hybrid environment can adapt those controls to non employees, extending badge issuance rules, visitor logs and system access workflows to every gig worker and contractor. The aim is to create a single, auditable front door where every worker, whether permanent, temporary or gig, passes through the same documented right work verification before they start working on site. In practice, that means your office team becomes the last line of defence for statutory excuse protection, sponsor licence integrity and the wider reputation of the business, because what matters now is not the square footage, but the Monday morning friction.