RIGHT TO WORK • 1 OCTOBER 2026
Right to Work changed.
Subcontractor controls changed with it.
From 1 October 2026, the Right to Work scheme extends into wider working arrangements. In certain subcontracting structures, civil-penalty liability can extend beyond the direct employer — creating additional requirements around contractual controls, substitutions, identity and evidence.

EXTENDED LIABILITY ASSESSMENT
How exposed is your current subcontractor model?
Answer a short series of questions about your contractual chain, substitutions, worker identity and evidence controls.
This tool provides general information only. It does not provide legal advice, determine liability, establish a statutory excuse or replace an employer’s prescribed Right to Work check.
Based on the final Home Office employer’s guide published on 1 October 2026.
2-MINUTE EXPLAINER
Right to Work changed. See what it means for subcontractor-heavy projects.
New controls, extended liability and how CrewDiligence structures the evidence trail.
01
CONTRACTUAL CONTROLS
Required Right to Work obligations, consent controls, audit rights, enforcement provisions and investigation co-operation need to be reflected in relevant contractual arrangements.
02
SUBCONTRACTING CONTROLS
Further subcontracting may require prior written consent and equivalent Right to Work obligations to flow down the contractual chain.
03
SUBSTITUTION CONTROLS
Where substitution is permitted, substitutes must be subject to prescribed checks and controlled before they carry out the work.
04
IDENTITY & EVIDENCE
Proportionate systems should link the individual carrying out the work to the person whose Right to Work was checked, with evidence retained to show how the controls operated.
THE CREWDILIGENCE PLATFORM
A dedicated platform for the new subcontractor assurance burden
CrewDiligence is not simply guidance or an audit service. We have built a dedicated workforce and supply-chain assurance platform to manage the additional controls, evidence and oversight created by subcontracted working arrangements.
CONNECTED CONTROLS
One platform. Six connected controls.
Built to reduce the administrative burden
One structured workflow instead of fragmented spreadsheets, emails and PDFs.
CONTROL
Controlled substitutions.
EVIDENCE
Project-specific evidence trails and close-out evidence packs.
ASSURANCE
Exception and corrective-action tracking. Independent assurance alongside existing Right to Work processes.
REUSE
Reusable subcontractor and worker records.
THE ASSURANCE OUTCOME
At any point, can you answer three questions?
01
Who was allowed to work?
02
Who actually worked?
03
What controls operated?
One defensible project evidence trail.
IMPORTANT DISTINCTION
Assurance around your existing responsibilities.
Contractual terms alone are not enough. The direct employer remains responsible for the prescribed Right to Work check. CrewDiligence does not replace those checks or legal duties; it adds control, workflow and evidence around subcontracted workforce assurance.
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