Specialist firm Atwal Law has issued detailed guidance on major changes to the UK’s illegal-working regime that take effect on 1 October 2026 under Section 48 of the Border Security, Asylum and Immigration Act 2025. The amendments extend civil-penalty liability beyond traditional employment contracts to include individual subcontractors, labour-supply chains and certain online matching platforms. In practical terms, businesses could face fines of up to £60,000 per illegal worker even when the individual is engaged through a third-party platform rather than as a direct employee. The Home Office’s draft guidance also introduces the concept of “extended liability,” meaning upstream contractors may need to verify that downstream partners conduct compliant right-to-work checks. With Immigration Enforcement visits up 31 % year-on-year, Atwal Law advises companies to revisit HR onboarding processes, contractual terms with suppliers and identity-verification systems—especially in warehousing, construction and last-mile delivery, sectors singled out for heightened enforcement. Global mobility functions should loop in procurement and legal teams to ensure that project-based engagements of overseas staff do not slip through the new net. Failure to adapt could jeopardise sponsor licences in addition to incurring financial penalties. Training materials, policy handbooks and vendor contracts need updating before the 1 October deadline; retrospective fixes will not provide a statutory excuse once enforcement begins.
Source: Atwal Law
