Healthcare industry warned of fines and criminal sanctions risk

Healthcare organisations have been warned they face possible fines or criminal sanctions if they fail to properly review their labour supply chains ahead of new legislation.

Mandeep Khroud (c) Irwin Mitchell

Mandeep Khroud (c) Irwin Mitchell

Right to Work rules due to come into force on 1 October 2026 will significantly expand obligations beyond traditional employees and could expose healthcare organisations to civil penalties of up to £60,000 per illegal worker if they fail to carry out the required checks.

Mandeep Khroud, head of immigration at Irwin Mitchell, said: ‘Many healthcare settings operate through subcontractor networks and flexible labour arrangements. From 1 October, they will need to look much more closely at who is actually carrying out work and whether appropriate Right to Work checks have been completed.'

The changes mean businesses may no longer be able to rely on the assumption that individuals classed as self-employed or engaged via subcontracting arrangements fall outside the regime.

Instead, liability could extend across labour supply chains, placing greater scrutiny on how workers are supplied, managed and verified to work.

Right to Work obligations are expected to apply to a wider range of arrangements, including: individual subcontractors; individuals engaged under worker contracts; certain outsourced labour arrangements; platform-based and online matching services; and contracts containing substitution rights.

Failure to comply could result in: civil penalties of up to £60,000 per illegal worker; criminal sanctions in serious cases; suspension or revocation of sponsorship licence; and public naming by the Home Office.

Experts are advising healthcare organisations to use the remaining weeks before the changes take effect to review contracts, assess workforce structures and ensure they have appropriate systems in place to verify the immigration status of anyone carrying out work in their settings.

Regulator considers concerns over presentation of FDP-related data

Regulator considers concerns over presentation of FDP-related data

By Lee Peart 06 October 2026

Concerns over NHS England’s presentation of FDP-related data about patient removals from waiting lists are being examined by the Office for Statistics Regula...

The rarely mentioned threat to maternity care

01 October 2026

Dr Lorin Lakasing, author of Delivering the truth: Why NHS maternity care is broken and how we can fix it together, explains why maternity care litigation is...

BREAKING NEWS: Burnham promises to build a National Care Service

By Lee Peart 29 September 2026

Prime Minister has pledged to build a free at the point of need, National Care Service.


Popular articles by Lee Peart