In force from 1 October 2026

The 1 October change, and the file that shows your side of it

Worker's contracts, individual subcontractors, platform workers, and — upstream — labour supply chains, online matching services and contracts that allow substitution.

Section 48 of the Border Security, Asylum and Immigration Act 2025 has been in force since 1 October 2026. If you use subcontractors, labour suppliers, platforms or substitution clauses, check whether this now reaches you. Genuinely self-employed people who run their own business can fall outside. A label of self-employed, on its own, does not decide that. In a standard agency supply, the hirer need not repeat the check the agency has already carried out.

GOV.UK says a civil penalty can be up to £60,000 per illegal worker. Those penalty levels are not new. The wider scope is. The code of practice starts at £45,000 for a first breach and £60,000 for a repeat within 3 years.

What an upstream business has to have in writing

Before work starts, the upstream business needs a written statement requiring six terms in its contract with the supplier, and systems to ensure the same individual is doing the work. A substitute is checked before they work. The six terms are:

The supplier carries out the checks.
No further subcontracting without written consent.
A right to audit.
Enforcement provisions.
Those enforcement terms in the supplier's contract with the worker.
Cooperation with Home Office investigations.

That list is the Home Office position under SI 2026/700. You write the contract. Vernx does not draft terms or supply a template.

The evidence trail Vernx already keeps

The right-to-work wording you type from the contract, and the contract PDF if you upload one.
Subcontracting consent as yes or no, with a date and a note.
Dated assurance checks: when, who checked, what was checked, and the outcome. A supplier with no logged check inside 12 months — or another interval you set from 1 to 36 — is flagged overdue.
Workers linked to that supplier.
A substitute flag that stays labelled "check not yet recorded" until a check date is on the file.
A link the supplier uses to type check records: name, check type, dates and a note.

The same workspace holds the worker file: the document copy, who checked, when, and which route (manual, online or DVSP). The dashboard shows what's due in the next 90 days. A weekly Monday email lists items due within 30 days, or within each document type's own reminder days. Upload chases go on day 1, day 3 and day 7, and a worker or site pack is there for CQC or UKVI. Optional DBS log, sponsor clocks and a sponsor-register check log sit on the same file. Your own document types, such as CSCS, SIA and food hygiene, take expiry dates too.

A practical order of work

List people on worker's contracts, individual subcontractors, and people supplied through a platform, alongside direct staff.
Where you sit upstream, record the six contract points you have agreed, the consent position, and the assurance checks you have actually done.
For each name: the copy, who checked, the date, the route, and the next date due.
Read the current employer guide on GOV.UK before you change process. In one Home Office consultation question, 46% of 145 respondents said they only checked direct employees (government response, para 3.2).

Keep that file in Vernx. Sign in, add the people, upload what you already hold. Plans from £69/month. No call.

Free file score · Pricing · Supplier checklist · Who holds the file

Do the changes apply to contracts already in place?

Annex C of the Home Office Employer's guide (1 October 2026, page 77) says the measures are not intended to be retrospective. The relevant date is when the contractual arrangement is entered into, not when the work starts or continues. An arrangement entered into before 1 October 2026 is not brought within scope solely because the work or services continue afterwards.

Official sources

Published 10 September 2026. Updated 25 October 2026. Vernx records your check; it doesn't perform the Home Office right-to-work check or give legal advice.