Right to Work Checks Extended to Gig Economy & Zero Hours Workers: What Employers Need to Know

The UK Home Office has launched a consultation running until December 10, 2025, proposing an extension of Right to Work checks to cover gig economy workers and those on zero-hours contracts. This significant change means employers, HR professionals, and global mobility managers in mid-sized organizations will face expanded compliance responsibilities to prevent illegal working in the UK labor market.

What Are Right to Work Checks and Why Are They Expanding?

Right to Work checks are mandatory verifications that employers conduct to ensure that individuals they hire are legally permitted to work in the UK. Until now, these checks have applied primarily to employees under traditional employment contracts. The consultation seeks to broaden these requirements to include workers engaged through gig economy arrangements, zero-hours contracts, casual work, self-employment, and subcontracting via online platforms.

This move addresses a current regulatory gap where many flexible workers remain outside the scope of the scheme, increasing risks of illegal working and associated penalties for businesses. The expansion will make the obligation to check immigration status legally binding across a wider range of worker categories, including those hired via digital platforms or temporary agencies.

Who Will Be Affected?

Businesses across various sectors heavily reliant on flexible labor models will be impacted. These include construction, delivery and courier services, warehousing, hospitality, beauty, and care services. Employers who engage gig workers, zero-hours staff, or subcontractors through online matching services will need to implement robust Right to Work verification systems.

Failure to carry out checks correctly could result in severe penalties, including fines up to £60,000 per illegal worker, business closure, and even criminal sanctions for company directors.

Practical Implications for Employer HR and Mobility Teams

HR and global mobility managers should prepare to:

• Update recruitment and onboarding processes to include Right to Work checks for all types of engagements, not just traditional employees.
  
  
• Ensure comprehensive record-keeping and compliance monitoring systems cover gig economy and zero-hours workers.
  
  
• Engage with third-party platforms and agencies to clarify responsibilities and ensure joint compliance.
  
  
• Stay informed on guidance published following the consultation and upcoming statutory codes of practice.
  
  

This change will require collaboration across HR, legal, and operational teams to adapt workflows and maintain compliance in a more complex labor market environment.

What Can You Do Now?

Though the consultation closes on December 10, 2025, proactive employers can review current worker classifications and audit their Right to Work check processes. Preparing staff and technology systems for an expanded scope of verification will reduce risk and enable smoother transitions as regulatory changes take effect.

HR leaders and global mobility managers are encouraged to contribute to the consultation. Providing input will help shape practical guidance and enforcement policies that reflect real-world business needs.

For more insights on future immigration compliance and workforce mobility in the UK and Europe, visit www.jobbatical.com, your partner for all immigration and relocation solutions.

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