Contractual controls
Identify the direct employer and each relevant contractual relationship. Review written Right to Work obligations, subcontracting consent and any further subcontracting.
PRACTICAL READINESS REVIEW
Extended Liability Checklist
Review your subcontractor controls against the key requirements introduced from 1 October 2026.
Are your subcontractor controls ready? Work through the checklist to identify matters needing review across contracts, substitutions, identity verification and evidence.
REVIEW YOUR CURRENT CONTROLS
A structured starting point.
Review one relevant arrangement or project at a time. Select “In place”, “Needs review” or “Unsure” for each control. No contact details or worker information are required; your selections remain only while this page is open.
Not sure whether extended liability may apply to the arrangement? Use the Extended Liability Assessment first →
0 of 12 controls reviewed
Completing the review records your selections. It does not certify compliance or establish a statutory excuse.
WHAT THE CHECKLIST COVERS
Control, practice and evidence.
Substitution controls
Identify substitution clauses and compare them with actual working practices. Record who can authorise a substitute or replacement and how that decision is evidenced.
Identity verification
Identify the employer responsible for the prescribed Right to Work check. Review how the person attending the project is matched to the relevant check and assurance record.
Evidence and assurance
Maintain relevant contracts, consent decisions, check assurance and identity-verification evidence. Record exceptions, actions, reviewer decisions and their rationale in the project evidence trail.
The relevant contractual structure and actual working practices determine whether extended liability may apply. A pre-1 October 2026 arrangement is not brought into scope solely because work continues after that date; renewals, replacements, new downstream contracts and material changes should be reviewed separately.
COMMON QUESTIONS
Using the checklist
What is the Extended Liability Checklist?
A practical review of contractual, substitution, identity and evidence controls relevant to subcontractor-heavy organisations. It helps you identify matters needing review and plan a clearer evidence trail.
Who is the checklist for?
Main contractors, project teams and organisations reviewing arrangements in which other businesses or individuals deliver work. The relevant contractual structure and actual practices determine whether extended liability may apply.
What controls does the checklist cover?
Contractual obligations and subcontracting consent, substitution arrangements, employer responsibilities and identity verification, and the evidence needed to record decisions, exceptions and reviews.
Does the checklist replace a Right to Work check?
No. The direct employer remains responsible for prescribed Right to Work checks. Completing this checklist does not establish a statutory excuse or replace legal advice.
What should I do if the checklist identifies a gap?
Review the relevant contracts, working practices and evidence with the responsible people. Assign actions and owners, and consider a CrewDiligence readiness review to help operationalise the controls.
PUT THE REVIEW INTO PRACTICE
Identified a gap?
CrewDiligence provides the workflow, control and evidence layer to help operationalise these requirements across subcontractor-heavy projects.
This checklist is a practical readiness and assurance tool. It provides general information only and does not determine liability, establish a statutory excuse, replace prescribed Right to Work checks or provide legal advice.
Reference: Home Office employer’s guide published 1 October 2026.