As a hospitality recruitment specialist working with clients and candidates across the UK, Jubilee is committed to keeping our partners informed of important employment and compliance developments. Significant changes to Right to Work (RTW) requirements are due to come into effect in October 2026, and businesses that rely on temporary, contract, self-employed, or subcontracted workers should start preparing now.
What Is Changing?
The biggest change is the expansion of who falls under Right to Work requirements. Previously, the focus was largely on employees, but the new framework widens responsibility to include many subcontractors and self-employed workers operating within labour supply chains.
Alongside this, liability for non-compliance will no longer sit solely with the direct employer or labour provider. Responsibility can now extend further up the supply chain, meaning businesses may be held accountable if appropriate checks have not been carried out, even where they are not the direct engager of a worker.
What Does This Mean for Hospitality Employers?
For hotels, restaurants, event venues, contract caterers and other hospitality businesses, the changes are likely to result in more robust onboarding procedures and increased compliance checks.
Workers who may previously have provided documentation after starting an assignment will now be expected to complete full Right to Work verification before commencing work. In some cases, checks may be undertaken by multiple parties, including agencies, umbrella companies and end clients.
While this may create additional administration, it is designed to reduce the risk of illegal working and improve accountability throughout the workforce supply chain.
Extended Liability Explained
Under the new rules, organisations may no longer be able to rely on another business within the supply chain to manage compliance on their behalf.
Importantly, Right to Work checks are not transferable. If an agency, umbrella company or labour provider has completed a compliant check, this does not automatically protect other organisations involved in the engagement. Businesses will need to ensure they have their own processes in place and retain the necessary records to demonstrate compliance.
Increased Focus on Identity Verification
Another key area of focus will be worker identity verification. Employers are expected to take reasonable steps to ensure the individual attending work is the same person whose Right to Work documentation was originally checked.
As a result, we expect to see greater use of digital verification tools, identity checking technology and enhanced site access controls across a range of sectors, including hospitality.
How Can Businesses Prepare?
To stay ahead of the changes, employers should consider:
- Reviewing all workforce engagement models, including agency, self-employed and subcontractor arrangements.
- Ensuring clear responsibility for Right to Work checks within the organisation.
- Auditing existing records and addressing any compliance gaps.
- Reviewing contracts and due diligence procedures with labour suppliers.
- Implementing robust onboarding and worker verification processes.
- Ensuring records are securely retained and readily accessible for audit purposes.
- Providing training for managers responsible for onboarding workers.
Jubilee’s View
The upcoming changes are designed to ensure that every organisation within a labour supply chain takes an active role in preventing illegal working. While this will increase compliance responsibilities, it should also create greater transparency and consistency across the recruitment sector.
At Jubilee, compliance has always been a core part of our recruitment process. We will continue to support both clients and candidates through any regulatory changes, helping hospitality businesses remain compliant while maintaining access to the talent they need to succeed.
For advice on staffing, recruitment compliance, or preparing your business for the upcoming Right to Work changes, speak to the Jubilee team today.