Law-firm Blake Morgan’s Autumn 2026 employment newsletter, released on 14 October, confirms that the updated Code of Practice on preventing illegal working took effect on 1 October 2026. The code widens liability beyond direct employers to include businesses that engage labour via agencies, online platforms, individual subcontractors and—most significantly—multi-tier supply chains. From next month, firms must ensure that any Digital Verification Service (DVS) they use is certified under the OfDIA trust framework and listed on the statutory register before conducting remote right-to-work (RTW) checks. Extended civil penalties of up to £45,000 per illegal worker apply where a subcontractor’s status is unchecked, even if the principal contractor never meets the individual. Global companies relying on flexible talent pools in the UK tech, logistics and creative sectors should audit contracts urgently. Customer procurement teams are already inserting indemnity clauses that require evidence of RTW compliance from third-party vendors, with non-compliant suppliers at risk of losing business before the Home Office intervenes. The newsletter also notes that the Immigration Salary List will close on 31 December 2026, signalling further reform of the Skilled Worker route salary thresholds. HR teams should review pipeline sponsorships and budget for higher wages where roles may fall outside post-ISL occupation bands.
Source: Blake Morgan LLP – BM Insights
