News · End-Hirers & Recruitment Agencies · OPRaaS Platform
Right to work checks are usually treated as an immigration formality, a box an employer ticks before someone starts. Refugee Week, marked across the UK from 16 to 22 June 2026, is a good moment to see the check the other way round. For a refugee who has been granted status, the right to work is something they hold, and the check is the door that opens to it.
Done carelessly, that same door is where someone with the right to work is wrongly turned away, or where exploitation slips quietly into the labour supply chain.
The ground under that check is moving. The Fair Work Agency, established under the Employment Rights Act 2025, is due to stand up on 7 April 2026, pulling the Gangmasters and Labour Abuse Authority, the Employment Agency Standards Inspectorate and HMRC’s National Minimum Wage enforcement into one body, with its enforcement powers expected to follow on a date still to be confirmed.
Separately, the Home Office has indicated that right to work checks will extend beyond employees to individual subcontractors and gig and platform workers, a change legal commentators widely expect to take effect from around 1 October 2026, subject to regulations.
For board directors at end-hirers and recruitment agencies, that turns a familiar task into a live question. The check is no longer just about whether one person can work. It is about whether your whole labour supply chain can show fair treatment, on the day someone asks.
Why Refugee Week puts right to work checks in focus
People who have been granted refugee status or leave to remain have the right to work in the UK, often in sectors that lean heavily on temporary and agency labour. That is the welcome side of the story. A check done well lets an employer say yes with confidence to someone who has every right to the job.
It cuts the other way too. According to legal analysis of the Home Office civil penalty regime, employers can face penalties of up to £45,000 per worker for a first breach and £60,000 for repeat breaches, so a check skipped or fudged carries real weight.
The point for Refugee Week is that the same moment serves two ends at once. It opens fair work to people who hold the right to it, and it is the first place exploitation of the more vulnerable can be caught.
From the GLAA to the Fair Work Agency
The body behind that second job is changing its name and widening its reach. The story starts on a beach. The Gangmasters and Labour Abuse Authority traces back to the Gangmasters (Licensing) Authority, set up after the 2004 Morecambe Bay tragedy, in which more than twenty cockle-pickers drowned while working for an unlicensed gangmaster. Its job was to license labour providers in agriculture, shellfish and food processing, and later to investigate labour abuse more widely.
That legacy now moves up the chain into the Fair Work Agency. On the government’s published account, the new body will hold a single set of powers to investigate and act against businesses that break the rules across the minimum wage, holiday pay, statutory sick pay, modern slavery, agency conduct and umbrella arrangements. The licensing-and-enforcement instinct that started on a Lancashire beach becomes a broad labour-market remit.
What the new enforcement landscape expects of employers
The shape of the change matters more than any single rule. Where checks once stopped at the contract of employment, they are set to follow the work itself, into the agencies, subcontractors and platforms an organisation actually relies on. An end-hirer that engages workers three tiers down, through a chain it has never mapped, is the one least able to answer when scrutiny arrives.
With an enforcement body holding consolidated powers, the practical test is simple to state and harder to pass. Could you show, today, that every worker reaching your sites or your clients had a right to work check, was verified properly, and is being treated fairly? The firm that can answer from records is in a calm conversation. The firm answering from memory is not.
Where a right to work check meets exploitation
This is the territory Module 5 of the OPRaaS Labour Supply Chain Assurance course covers under its topic on the signs of modern slavery in the supply chain. Several of those signs sit right next to the right to work moment.
- Workers recruited through false promises, or made to hand over their passport or biometric residence permit to a third party.
- Wages paid into an account the worker does not control, or swallowed by recruitment fees that create debt bondage.
- Heavy reliance on third-party labour contractors that blurs who is responsible for the people doing the work.
- Precarious legal status used as leverage, leaving someone too frightened to speak up.
The course is careful on a point that matters. A single indicator does not prove anything; it is several together that should trigger escalation. A right to work check carried out in person, against the genuine document, with the worker actually present, is the moment many of those signs first become visible. Treated as a paperwork exercise, it catches little of this.
Turning the right to work check into a kept record
The fix is not a harder check. It is a kept one. An online right to work check produces a clear result and a share-code trail, and the discipline is to store that evidence, note any time limit on the person’s leave, and run the right to work check again before it expires rather than after.
The course frames this kind of risk work in four steps: map the supply chain, assess where the risk sits, carry out supplier due diligence, and watch for the red flags.
It also points employers to a free tool many have never used. The UK Government’s Modern Slavery Act 2015 sits behind the Modern Slavery Assessment Tool, offered through the Supplier Registration Service, which lets an organisation grade its suppliers and focus attention where the risk is highest. This is not exotic. It is the ordinary right to work check, kept and repeated, with a named owner behind it.
How the OPRaaS Virtual Compliance Director holds the evidence
The OPRaaS Virtual Compliance Director (OPRaaS VCD) platform is built to hold that record as a standing control rather than a folder pulled together once an inspector calls. It embeds senior governance leadership into an end-hirer, a recruitment agency or a public sector buyer without the cost of a full-time director.
Two examples make it concrete. Where a worker is onboarded, the OPRaaS VCD platform records the online right to work result and share code, flags any time limit on their leave, and prompts the re-check before that date, so the evidence stays current instead of going stale in a drawer.
Each agency on the preferred supplier list is then re-audited on a set cadence and monitored against Companies House for director and ownership changes, and against Creditsafe for credit-risk moves such as county court judgments and financial-strength downgrades, with the findings written into the audit and evidence summary the platform produces on demand.
OPRaaS, On-Pay-Roll-as-a-Service, is a systemised governance and workforce management partner for organisations that rely on temporary, freelance, contractor, interim and consultant labour, from end-hirers and recruitment agencies to umbrella companies, managed service providers and public sector buyers. It is approved on the UK Government Commercial Agency (formerly Crown Commercial Service) frameworks including RM6310 Audit & Assurance Services (Lots 2 & 4), RM6219 and RM6237 Learning & Training Services DPS.
The right to work check confirms that someone can work. Whether they are then treated fairly is decided by what happens after the box is ticked.
What boards and agencies can do this week
Refugee Week is a fitting moment to make the right to work check worth more than a tick. The practical move is modest. Name the agencies and subcontractors your workers actually reach you through, and ask one question of the chain. Can we show that each worker had a proper right to work check, that the evidence is kept, and that nobody is being held in place by a withheld document or an unpayable debt?
Where the answer is yes, an employer is ready for the Fair Work Agency and, more to the point, is a place a refugee with the right to work can be hired fairly and treated well.
The operational version of this discipline lives in Module 5 of the OPRaaS Labour Supply Chain Assurance course and the audit instance a buyer can run from the platform, which walk through the signs to watch, the evidence to keep and the escalation route when something does not add up.
Compliance is your asset. Evidenced daily.
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“Own your compliance as an asset.“
Drawing on Refugee Week, marked from 16 to 22 June 2026; the Employment Rights Act 2025 and the published Fair Work Agency factsheet; the Border Security, Asylum and Immigration Act 2025; the Modern Slavery Act 2015; the history of the Gangmasters (Licensing) Authority; and the OPRaaS LSCA Self-Certification Course Module 5.
Talk to OPRaaS about your supply chain.
Use the contact form in the sidebar to the right of this article, or email info@opraas.co.uk.
This article is editorial commentary by OPRaaS Limited (On-Pay-Roll-as-a-Service), drawing on published reporting and government guidance. It is general information, not legal, tax, employment or immigration advice. Obligations vary by organisation and engagement. Speak to a qualified professional before acting on any specific position.