Taxi and private-hire operators using certain platform, subcontracting or driver-matching arrangements could face expanded right-to-work responsibilities from 1 October 2026 under new Home Office guidance.
The changes extend illegal-working enforcement beyond conventional employment contracts to people engaged under a worker’s contract, individual subcontractors and qualifying online matching services. The statutory expansion was made by section 48 of the Border Security, Asylum and Immigration Act 2025, which amended the Immigration, Asylum and Nationality Act 2006.
The Home Office’s draft implementation guidance, published on 16 July 2026, states that the new arrangements and related civil-penalty exposure will apply from 1 October. It says penalties in the newly covered worker-contract, subcontractor and online-matching cases can apply only where the relevant engagement starts on or after that date.
An online matching service is defined for the scheme as one that keeps a register of service providers, allows prospective clients to make online enquiries for matching, and charges a fee or commission. Holding a private-hire operator licence alone will not automatically bring an operator or booking platform within scope. Coverage depends on whether its driver and customer arrangements meet the statutory definitions.
Where a qualifying online matching service supplies a service provider’s details and that provider contracts with the customer after the match, the service may be treated as the employer for illegal-working liability purposes.
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To obtain a statutory excuse against a civil penalty, the responsible business must carry out a prescribed right-to-work check before work begins. The permitted routes are a manual document check, a Home Office online check, or use of a registered right-to-work digital verification service provider.
The guidance stresses that using a digital verification provider does not transfer responsibility. The employer remains responsible for ensuring that the prescribed check has been completed properly.
Businesses operating online-matching or subcontracting models must also have proportionate measures to establish that the person doing the work is the same person whose right to work was checked. The Home Office says supporting evidence can include check records, contracts, identity-verification records, audit activity, and records showing who carried out work and when.
The maximum civil penalty listed in the guidance is £60,000 for each illegal worker where prescribed checks have not been completed. In serious cases, knowingly employing an illegal worker, or having reasonable cause to believe that someone does not have permission to undertake the work, can result in prosecution, an unlimited fine and up to five years’ imprisonment.
The guidance also identifies possible wider consequences of illegal-working non-compliance, including director disqualification, loss of migrant-sponsorship capability and business closure orders. For taxi and private-hire businesses, it lists review and possible revocation of a relevant licence among potential enforcement consequences.
Operators should assess their contractual and booking arrangements before the October start date, including driver identity controls, right-to-work checking processes and recordkeeping.
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