Right-to-work checks in October 2026 started with the actual arrangement

The scope set out in the October code

The updated Home Office code defined the relevant employer and worker terms to include these additional arrangements for right-to-work purposes. It applied to employment commencing on or after 1 October 2026 and relevant repeat checks. The definitions for this scheme were not simply interchangeable with every employment-status label used elsewhere.

The code also addressed avoiding unlawful discrimination. A broader checking duty did not justify choosing who to check based on appearance, name or presumed nationality. Organisations needed the prescribed process and appropriate advice about which duties applied to the particular arrangement.

Look past the contract label

A database may describe someone as self-employed, contractor or platform worker without recording who engages the person or what services they provide. Those shorthand labels are not enough to resolve the new scope. An employer-led inventory should identify the parties, actual arrangement and responsible decision-maker before an administrator updates the checking workflow.

Recruitment providers also needed clarity about handovers with clients. Who performs the relevant check, who retains the result and who monitors a required follow-up? An assumption that another party has handled it is difficult to investigate if neither side can identify the agreed responsibility or the supporting record.

The inventory should identify where the arrangement was confirmed, so later administrators can distinguish an approved classification from an inherited database label.

Map the facts for the responsible reviewer

Key Med Solutions can help organise a client-approved inventory of engagement types and collect the factual information needed for professional review. It can then maintain the approved onboarding checklist, chase outstanding items and flag unresolved cases before a proposed start. Legal classification and the sufficiency of checks remain with the responsible organisation and its advisers.

An exception register should distinguish a missing record from a question about scope. The first may need an administrative action; the second needs an authorised decision. Keeping those categories separate helps support staff avoid resolving a legal uncertainty by simply selecting the nearest available system status.

The October 2026 lesson is to map the real working arrangement and document the checking owner. Key Med can provide administration and coordination within that map, while organisations retain their duties and use qualified advice for interpretation. The process should remain consistent and respectful for everyone affected.