Christmas Temps Need Papers Too - Right to Work checks just got bigger
Since 1 October, Right to Work rules reach well beyond your payroll. Agency staff, contractors and last-minute cover are all in scope.

Managers, a quick one before you start lining up the Christmas army. As of 1 October 2026 the Right to Work Scheme no longer stops at people on your payroll, The Caterer reports. It now stretches to agency workers, contractors, seasonal temps and that mate-of-a-mate who covers a Saturday double.
That's a big deal for an industry that runs on flexible labour. A single hotel or events business might use several agencies, outsourced cleaners, temp chefs and casual waiting staff in one busy week. Each of those arrangements now needs checking to work out who is actually responsible for doing the checks.
The advice is to map every type of worker you use, not just employees. Look again at any agency or supplier contracts signed on or after 1 October, and make sure they spell out who checks what, who can audit it and how substitutions are handled. Crucially, a line saying "the agency deals with it" won't necessarily protect you if something goes wrong.
So what for hospo people? If you're picking up temp shifts this winter, expect a few more ID requests and don't take it personally. If you're doing the hiring, sort this out now. December is not the time to be digging through contracts.
Source: The Caterer (opens in a new tab)
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