Right to Work Checks are set to change from 1 October 2026, with new requirements expected to extend beyond traditional employees to cover a wider range of working arrangements.
For aesthetic clinics, these changes could be particularly relevant to businesses using agency staff, individual subcontractors or other arrangements to source workers. Understanding the proposed changes now can help clinic owners and managers prepare for their potential responsibilities.
TrustID, part of the Citation Group, has published a free guide explaining the changes, who could be affected and what employers should consider ahead of the proposed implementation date.
What is changing?
The Home Office's draft guidance sets out plans to extend the scope of Right to Work Checks to include workers, individual subcontractors, agency workers and online matching services.
This could bring more gig-economy and platform-based working arrangements within scope, with implications for businesses that rely on third parties to source labour.
For aesthetic clinics, it is worth reviewing how staff and services are sourced, particularly where arrangements involve agencies, subcontractors or online platforms.
Why should aesthetic clinic owners pay attention?
Right to Work requirements are an important part of employment compliance. The proposed changes could have implications for businesses that engage people through arrangements other than conventional employment.
Clinic owners and managers should consider:
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Agency workers: Understand the responsibilities associated with using agency-supplied staff.
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Subcontractors: Review arrangements involving individual subcontractors and clarify who is responsible for completing the necessary checks.
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Third-party providers: Consider how responsibilities may apply when workers are sourced through external businesses or online platforms.
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Compliance procedures: Review existing processes to identify whether they may need updating ahead of the proposed changes.
The concept of extended liability is particularly important. Depending on the circumstances and the final requirements, businesses could face responsibilities beyond those associated with directly employing someone.
What should clinics do to prepare?
Although the final requirements and their application will need to be confirmed against official guidance, clinics can begin reviewing their current procedures.
Practical steps include:
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Review working arrangements. Identify how employees, agency workers and subcontractors are engaged.
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Check existing procedures. Assess how Right to Work Checks are currently completed and recorded.
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Clarify responsibilities. Establish who is responsible for carrying out checks when working with agencies or other third parties.
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Review digital processes. Understand the permitted routes for completing checks and whether existing procedures will remain suitable.
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Stay informed. Monitor official Home Office guidance and seek professional advice where responsibilities are unclear.
Employers should also ensure they understand the circumstances in which a statutory excuse against a civil penalty can be established and maintained.
Read the full guide from TrustID
TrustID, a Right to Work Checks provider and part of the Citation Group, has published a free blog explaining the proposed changes, including who could be affected, how extended liability may apply and the steps employers can take to prepare.
Read the full blog: https://tinyurl.com/mrx9thzc
For ConsultingRoom.com Members who would like further support beyond the webinar, Citation is also offering preferential rates to ConsultingRoom.com Members.
If you contact Citation for more information or a quote, make sure you mention “Consulting Room” to access the preferential rates available through the partnership.
Call Citation on 0345 844 1111 or:
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A note for clinic owners: The changes described are based on draft guidance supplied for this article. Check the latest official Home Office guidance before making changes to your compliance procedures.
