Britain stands at another inflection point in its struggle to reclaim control of its borders and its labour market. On 1 October section 48 of the Border Security, Asylum and Immigration Act 2025 takes effect. The measure closes loopholes that have allowed flexible working arrangements to evade scrutiny for years.
The changes amend the Immigration, Asylum and Nationality Act 2006. They extend illegal working provisions and civil penalties far beyond conventional employment contracts. Individual contractors, agency workers, gig economy participants, casual staff on zero-hours terms, subcontracting chains, labour supply networks and online matching platforms all now fall within the net.
Organisations using these arrangements must carry out right to work checks. Only by doing so can they establish the statutory excuse that shields them from liability. Failure invites civil penalties of up to £60,000 per unauthorised worker. Repeat checks on existing staff will also be required where the new rules bite on or after the October date.
A draft revised code of practice, published at the end of June, sets out precisely how the expanded regime will operate. It covers contractual chains, sub-contracting and the responsibilities of online platforms. Updated rules on digital identity verification using government-approved providers come into force on the same day. Enforcement begins in October, aligned with the standard commencement window for business regulation.
The cost of past complacency
For too long British governments tolerated a system riddled with gaps. Modern labour practices, celebrated by some as innovative flexibility, frequently served as cover for unchecked illegal working. Supply chains stretched across multiple tiers. Platforms matched workers to jobs with little regard for immigration status. Each layer diluted accountability. The result was predictable: depressed wages for British citizens, strained public services and eroded trust in the state's willingness to defend its own people.
