Law firm Foot Anstey’s latest business-immigration bulletin, published on 30 September, underscores a busy month for HR and mobility managers ahead of the UK’s 1 October 2026 regulatory roll-out. Chief among the changes is a revised draft of the Home Office Employer’s Guide to Right to Work (RtW) checks. From today, civil penalties for illegal working—currently capped at £20,000 per worker—extend beyond direct employment contracts to capture labour supplied through subcontractors, online platforms and certain worker contracts. The updated guidance introduces an ‘extended liability’ concept for supply chains and an eight-factor test to help businesses identify when they could be liable. Importantly, employers may delegate document or digital checks to shared-service teams, but liability for errors remains with the sponsoring entity. Second, the government has quietly widened eligibility for the high-profile Global Talent visa. From 1 October, recognition bodies in gaming, fintech and quantum technologies can endorse candidates, and the “promise” category has been lowered to three years’ relevant experience. This offers multinational firms a swifter alternative to the Skilled Worker route because no salary threshold or sponsor licence is required. Third, sponsors using the Sponsorship Management System (SMS) must now activate multi-factor authentication and assign a named ‘security contact’. Failure to comply by 31 December will lock the account and freeze all Certificate of Sponsorship (CoS) issuance—potentially delaying new hires. Foot Anstey advises multinational employers to update onboarding checklists immediately, audit labour-supply chains for RtW exposure and consider the enhanced Global Talent path for critical hires who fall short of Skilled Worker salary thresholds after July 2025 uplifts. The firm also expects a mid-October fee order increasing the Immigration Skills Charge in line with inflation.
Source: Foot Anstey
