What changed on
1 October 2026
- What changed. Since 1 October 2026, Right to Work liability reaches beyond employees to certain contractor, platform and subcontracted arrangements.
- Who is liable. The employer who directly engages the worker remains responsible for the check. In some contract chains, liability can also extend to the business contracted to deliver the work.
- What to keep. Copies of the evidence for the length of employment and for two years afterwards.
Penalties, in context
GOV.UK states that an employer might have to pay a civil penalty of up to £45,000 for each illegal worker for a first breach and up to £60,000 for a repeat breach within 3 years. GOV.UK also states that you will not have to pay the civil penalty if you can show you made the correct Right to Work checks. Figures and rules change, so always confirm the current position on GOV.UK.
Read the official GOV.UK guidanceThis page is general information, not legal advice.
Digital checks
Optional, in pilot
Manual checks
For eligible staff
Secure record keeping
All in one place
Expiry reminders
Act before dates pass
Organise and evidence the process
Crew Matrix gives you a structured way to record and evidence your checks and keep track of follow-up dates.
- Keep Right to Work evidence for each worker in one place
- See what is held, what is missing and what needs review
- Track expiry and follow-up dates, with reminders
- Handle worker and subcontractor document workflows
- Digital identity checks, for example through TrustID, are optional, in pilot, and available only where set up for your account
Digital identity checks are in pilot
Optional TrustID digital identity checks are in pilot, are not part of the monthly subscription, and their pricing will be confirmed before they are offered generally. TrustID is optional and never required for Right to Work.
Your subscription stays at £3.99 per active worker per month, subject to a £49 minimum monthly subscription. See pricing.
What employers need to think about
In practice, the hard part is rarely the check itself. It is keeping the evidence organised: knowing what you hold for each worker, what is missing, and what needs to be looked at again, especially across subcontractors and multiple sites.
The legal terms in more detail
Employers must carry out a prescribed Right to Work check before a worker starts and keep copies of the evidence for the length of employment and for two years afterwards. The check can be a manual document check, a Home Office online check using a share code, or, for eligible documents such as British and Irish passports, if the employer chooses, a check through a Right to Work digital verification service provider registered on the Office for Digital Identities and Attributes register.
The employer who directly engages the worker remains responsible for the check. Using a Right to Work digital verification service provider is optional and does not move that responsibility, and contract terms alone are not enough. In some contract chains, liability can also extend to the business contracted to deliver the work. From 1 October 2026, a business in a chain of contracts may also need written contract terms, audit rights and identity controls in place before work starts. The guidance does not apply to individuals who run an independent business and contract directly with clients or customers, but calling someone a contractor does not by itself take an arrangement out of scope. Check the GOV.UK guidance for your circumstances.
Statutory excuse. A statutory excuse is the protection GOV.UK describes: you will not have to pay the civil penalty if you can show you made the correct Right to Work checks. Crew Matrix does not, by itself, create a statutory excuse.
What Crew Matrix does not do
- It does not complete the legal Right to Work check for you.
- It does not guarantee legal compliance or prevent penalties.
- It does not, by itself, protect you from a civil penalty.
- It does not replace legal, HR or health-and-safety advice.
Crew Matrix records and evidences the employer-side Right to Work process. The employer or appointed competent adviser remains responsible for the check and for compliance decisions.
Get your evidence in order.
Read the guidance, record each check, and keep the evidence and follow-up dates in one place.