Record KeeperSubcontractor right to work · by Nero Labs
New rule from 1 October 2026

Check every subcontractor's right to work. Keep the proof. Never miss a recheck.

From 1 October 2026, UK right to work checks cover self-employed subcontractors, not just employees. Miss one and the fine is up to £45,000 per worker. The Record Keeper does the checks, the records and the reminders, from your phone.

Start the Record Keeper £9/month Do I need to check? Free test
  • £29 pack free inside
  • Cancel any time
  • No app to install
Record Keeper: asking a subcontractor for their share code with a Send on WhatsApp button
Record Keeper dashboard: 1 action now, 2 coming up, 2 all clear, with each subcontractor's status
£45,000maximum fine per worker, first breach
£60,000per worker for a repeat breach within 3 years
1 Oct 2026covers deals agreed on or after this date
+ 2 yearshow long you keep each record after the work ends
See it in 45 seconds

The new rule, and how the Record Keeper handles it for you

How it works

Three simple steps. Done from your phone.

No paperwork to chase and nothing to remember. The Record Keeper works in your phone's browser, so there's no app to install.

1

Add a subcontractor

Their name and mobile number. It takes about ten seconds, and they show as red until they're checked.

Adding a subcontractor called Jordan Price in the Record Keeper
2

Send a WhatsApp link

Tap "Send on WhatsApp" and it goes from your own phone. They add their share code and date of birth in two minutes, and it lands in your account.

The Send on WhatsApp button and the details-received confirmation
3

Get reminded

Do the check, save the proof, and every recheck, insurance renewal and CSCS card goes into your phone's calendar with an alert on the day.

Dashboard showing who needs action, who is coming up and who is all clear
The Record Keeper

Every subcontractor checked, recorded and reminded

The rule isn't a one-off. Every new subcontractor needs checking before day one, every time-limited permission needs rechecking, and every record has to be kept for two years after the work ends. The Record Keeper does the remembering for you.

  • Send a link, get the share code backOne tap sends a WhatsApp message from your phone. They fill in their own details, so you never type a share code again.
  • Every check saved with its proof and dateUpload the gov.uk result or document photos. Red, amber and green show at a glance who still needs checking.
  • Reminders on your phoneRechecks, insurance, CSCS cards and trade registrations go straight into your phone's calendar, with an alert on the day.
  • Inspection-ready in one tapPrint every record, or download a spreadsheet, if the Home Office ever asks.
A solicitor£200+ an hour
HR software£24 to £100+ a month
One fineup to £45,000
Record Keeper£9 a month
Free 30-second check

Do I need to check my subcontractors' right to work?

Answer 4 quick questions. Based on the Home Office's final guidance for the rules that started on 1 October 2026.

Question 1 of 4

Which of these best describes you?

Question 2 of 4

How does the person work?

Question 3 of 4

When did you agree the work with them?

Question 4 of 4

Who has the contract with that person?

Yes. You must check them before they start.

Because you contract directly with an individual to do work, you need a right to work check before they start. If you skip it and they turn out not to have the right to work, the fine is up to £45,000 per person, or £60,000 for a repeat breach.

How to check (pick one)

  1. Online with a share code. They get a 9-character code (starts with W) from gov.uk. You enter it with their date of birth at gov.uk/view-right-to-work and save the result page.
  2. Original documents. See their original passport or another document from the Home Office's List A or List B, in person or on a live video call, then keep a clear copy.
  3. A certified digital ID provider (for British and Irish passports), if you use one.

What to keep

  • A copy of the document or the online check result, and the date you checked.
  • Keep it for the whole time they work for you, plus 2 years.
  • If their permission is time-limited, check again before it runs out.
Let the Record Keeper do this for you

Probably yes, through your contracts.

The business with the direct contract (your subcontractor) must do the check. But from 1 October 2026 a fine can move up the chain to you if your subcontractor can't be found, or if you didn't put the required protections in place. To protect yourself, the Home Office code of practice says your contracts should:

  • require right to work checks on everyone who works on your job,
  • ban further subcontracting without your written consent,
  • let you audit their checks, and let you act if they don't comply,
  • require them to cooperate with Home Office investigations,
  • control substitutes (no one swaps in without being checked).

These terms must be set out in a written statement before the work starts (the final guide says this is mandatory, and your usual supplier paperwork does not replace it). Then keep evidence that you did all of this. The pack's Chain Protection Letter covers it.

Let the Record Keeper do this for you

Yes. Platforms are now covered.

From 1 October 2026, online platforms that match individuals to customers ("online matching services") must check those individuals, including substitutes who take a job in someone else's place. The Home Office also recommends identity is re-verified at least once in any 24 hours of activity. Fines are up to £45,000 per worker, or £60,000 for a repeat breach.

Let the Record Keeper do this for you

You already check, as before.

For agency workers, the agency is the employer and does the right to work check. The business that hires the worker through you does not, according to the Home Office guide (Example 12). Make sure your own checks and records are up to date.

Very unlikely to apply to you.

The new rules are aimed at businesses. A tradesperson who runs their own business and works for the public is "operating in business on their own account", which the Home Office says is not in scope. The Home Office's own example says a self-employed plumber with many customers does not need a check.

Usually not required, but it's not automatic.

The Home Office's own example says a client hiring a designer through the designer's own limited company (a personal service company) does not need to check them. But the final guide (1 October 2026) says there is no blanket exclusion: what counts is how the arrangement works in practice, not the label. If they genuinely run their own business with their own customers, you are usually fine. If their company is just a wrapper and they work on your jobs like any other subcontractor, checking them is the safe choice.

Let the Record Keeper do this for you

Not in scope.

Buying a service from someone who runs their own business and has their own customers is an ordinary business-to-business purchase. The Home Office says this is not covered. The new rules catch individuals who do work you have been contracted to provide.

No fine for the existing deal, but check new ones.

The final Home Office guide says what matters is when the arrangement was agreed, not when the work starts, so a deal made before 1 October 2026 is not caught just because the work carries on. Any new contract or new job from that date is covered, even with someone you've used for years, and a renewal or change may count as new. Many firms are checking everyone now so they're ready.

Let the Record Keeper do this for you
Are you the subcontractor?

Been asked for your share code?

It takes about two minutes on gov.uk and it's free. The code starts with W and lasts 90 days.

How to get your share code
Common questions

Straight answers

What changed on 1 October 2026?

Section 48 of the Border Security, Asylum and Immigration Act 2025 came into force. It extends the illegal working rules from employees to people on worker's contracts, individual sub-contractors and online matching services, and lets the Home Office fine a business further up a contract chain in some cases.

Is the online share code check allowed for subcontractors?

Yes. The Home Office guide applies the same three check methods to all the newly covered arrangements. The gov.uk service is still worded for "job applicants", but it is the one to use.

Is there a grace period?

No. The final Home Office guide says the rules apply from 1 October 2026 and there is no general grace period.

How long do I keep the records?

For as long as the person works for you, plus 2 years, then destroy them securely. The Record Keeper reminds you when that keeping period has passed.

What if their permission to work runs out?

Do a follow-up check before it expires. If they have a pending application, the Home Office Employer Checking Service can give a Positive Verification Notice, which protects you for 6 months.

Does the Record Keeper do the check for me?

No. You still do the official check (the share code online, original documents, or a certified digital ID provider). The Record Keeper collects the details, stores the result and the date, and reminds you when to check again.

Who can see my subcontractors' details?

Only you. Your business decides what's stored, and we act only as your data processor. Records are deleted when you delete them or close your account. Read the privacy policy.

Can I cancel?

Yes, any time. You keep access until the end of the period you've paid for, and you can export your records first. If you buy as a consumer, you can cancel within 14 days of first subscribing for a full refund.

Common questions answered

More straight answers

Every new subcontractor needs checking before day one

Get it sorted today, for £9 a month

Checks, proof and reminders for up to 25 subcontractors, with the £29 pack free. Cancel any time.

Start the Record Keeper Take the free check first