Authored by:
Rianka Gupte
Right to Work checks for construction subcontractors are changing from 1 October 2026, creating an important new workforce compliance requirement for UK contractors.
The new rules extend the Right to Work Scheme beyond traditional employees to cover additional working arrangements, including people engaged under worker contracts and individual subcontractors. This is particularly relevant to construction, where projects commonly rely on large, changing workforces made up of subcontractors, self-employed trades and temporary labour.
The Government has specifically identified construction subcontracting as an area where gaps in Right to Work oversight can occur. From October, contractors will need to take a closer look at how workers are engaged, who is responsible for completing the appropriate checks and how evidence is retained.
For contractors, there is also a wider operational challenge.
It is not enough simply to know that a worker has a record somewhere. Project teams increasingly need to know who is on site, who they work for, whether they have been approved and whether their CSCS cards, project-specific training and task-specific training remain compliant.
That is where construction workforce management software becomes particularly important.
From worker onboarding, training records, compliance tracking, safety documents, equipment management, to on-site time and attendance tracking — Boxcore’s software greatly simplifies construction site safety.
Section 48 of the Border Security, Asylum and Immigration Act 2025 expands the Right to Work framework.
The legislation extends the relevant provisions beyond traditional employment to include a person engaging an individual under a worker’s contract and a person engaging an individual subcontractor, as well as certain online matching service arrangements.
The Home Office’s updated guidance states that the new framework will apply from 1 October 2026 and includes:
The updated guidance also applies to relevant repeat checks carried out from 1 October 2026.
This is an important change for construction because individual subcontracting and non-standard labour arrangements are widespread across the industry.
Construction projects can have hundreds or thousands of people moving through them over their lifetime.
A main contractor might manage dozens of subcontractors, while those companies may themselves provide large numbers of workers across several projects.
The workforce can also change very quickly.
That creates a practical question:
Does the contractor have a clear and current view of everyone working across its projects?
Following the October changes, contractors should review whether they can readily determine:
The Government’s consultation specifically highlighted construction as a sector where the use of subcontracting can reduce oversight of workers’ Right to Work status.
For many contractors, therefore, the October change should prompt a wider review of construction workforce management rather than simply another document collection exercise.
The answer should not be reduced to a blanket yes or no.
The expanded scheme brings individual subcontractors and other working arrangements within the Right to Work framework, but responsibility will depend on how individuals are contractually engaged and the particular supply-chain arrangement.
That can become complicated on construction projects involving several layers of subcontracting.
Contractors should therefore review their contractual structures and obtain appropriate legal or immigration advice where responsibility is uncertain.
What is clear is that businesses should no longer assume that Right to Work responsibilities are relevant only to traditional direct employees.
The new rules substantially broaden the scope of the scheme.
A successful Right to Work check does not mean a worker is automatically ready to start work on a construction project.
The contractor may separately need to confirm:
This is why workforce compliance works better when contractors have one clear worker record rather than several disconnected spreadsheets and folders.
A practical process looks something like:
Each stage answers a different question.
Right to Work determines whether the individual has permission to work.
CSCS and training records help demonstrate competence.
Project-specific and task-specific requirements establish whether the person is suitable for that particular project or activity.
Attendance confirms whether the person is actually on site.
Access control determines whether the worker should be permitted to enter.
Boxcore’s construction workforce management software helps contractors connect these operational elements within one worker profile.
Boxcore does not replace the statutory Right to Work check.
The relevant Right to Work process must still be completed correctly through the appropriate Home Office, manual or approved digital checking route.
Where Boxcore helps is what happens around that check.
Once the appropriate worker approval information has been collected, Boxcore gives contractors a simple way to connect that information with the other requirements needed to manage a construction workforce.
Instead of having Right to Work information in one location, CSCS cards in another spreadsheet, training records with the safety department and attendance information sitting somewhere else, contractors can manage the worker through one central profile.
Through Boxcore, contractors can bring together:
The result is a much clearer view for project teams.
They can quickly answer:
This is particularly useful for contractors managing large subcontractor workforces across several projects.
One of the practical problems with workforce compliance is not necessarily collecting information in the first place.
It is keeping that information current.
A spreadsheet may be accurate when it is created, but construction workforces change constantly.
People leave projects. New workers arrive. CSCS cards expire. Training needs renewing. Workers move between sites. Different projects have different competency requirements.
Boxcore allows contractors to maintain workforce and training records centrally rather than repeatedly exchanging updated spreadsheets and attachments.
The platform is designed around busy construction teams, making it straightforward for general contractors and subcontractors to manage and share the information required across projects.
This becomes increasingly useful as contractors take on greater responsibility for understanding exactly who is working across their business.
Maintaining a compliant worker record solves only part of the problem.
The next question is:
Is the person arriving on site actually the worker associated with that approved record?
This is where facial recognition can provide an important additional control.
Boxcore links the approved worker profile with facial recognition-powered time and attendance.
This allows project teams to see in real time:
It creates a direct connection between the workforce record and the individual actually attending the project.
This becomes particularly relevant where contractors are trying to improve control over complex subcontractor workforces.
Right to Work is an important legal requirement, but it is only one piece of the construction workforce compliance picture.
A worker can have full permission to work in the UK and still not meet the requirements of a particular construction project.
For example, they may have:
Boxcore’s worker onboarding and training management helps contractors collect and track these requirements before workers start on site.
Rather than relying on project teams to manually check every document at the gate, the aim is to identify compliance gaps earlier in the onboarding process.
That is particularly valuable on projects where hundreds of workers may be starting or moving between contractors during a short period.
There are several practical steps UK contractors should consider before 1 October 2026.
Finally, consider how approved workforce records are connected to actual attendance.
Knowing that somebody is approved is only useful operationally if the contractor can also establish whether that same person is actually working on the project.
The Right to Work changes taking effect on 1 October 2026 will increase the focus on how UK businesses manage people engaged outside traditional employment arrangements.
For construction, that is particularly significant because subcontracting sits at the centre of how projects are delivered.
Contractors therefore need more than a collection of documents.
They need a reliable process for understanding who is working across their projects and whether those individuals meet the requirements placed on them.
Boxcore provides that operational layer.
The statutory Right to Work check remains a separate legal process, but Boxcore helps contractors connect the resulting worker approval information with CSCS cards, digital inductions, project-specific and task-specific training, workforce attendance and site access.
Facial recognition then helps connect the approved digital worker record with the person who is actually attending site.
And because Boxcore can operate with or without a turnstile, the same approach can be rolled out across projects ranging from regional residential and civil engineering sites to major projects requiring controlled physical access.
For contractors preparing for October 2026, the objective should be straightforward:
Know who is working on your projects. Know they have been approved. Know their training is compliant. Know who is actually on site.
That is exactly the problem Boxcore is built to solve.
