
We wanted to make you aware of changes to the Home Office’s Right to Work [RTW] Scheme that came into effect on 1 October 2026. The changes are intended to strengthen safeguards against illegal working while keeping compliance requirements proportionate for businesses. The updated guidance clarifies how the RTW Scheme applies across a wider range of working arrangements, including some models used in the taxi and private hire vehicle [PHV] sector.
These changes do not alter existing driver licensing arrangements. Licensing authorities will continue to undertake immigration status checks as part of the driver licensing process. However, depending on their contractual and operating arrangements, some operators may also have responsibilities under the Right to Work Scheme and should consider whether the Scheme applies to their business model. Licensing checks undertaken by local authorities do not replace any separate obligations that may apply to operators under that Scheme.
For many operators, the practical impact may be limited. The impact will depend on an operator’s business model and existing onboarding arrangements, but where operators already carry out identity verification and onboarding processes for drivers, the new requirements may build on existing procedures rather than require entirely new systems.
Operators should therefore review their arrangements and, where the RTW Scheme applies, ensure they have appropriate processes in place. In practice, this means:
• Reviewing contractual and operating arrangements to determine whether the RTW Scheme applies to drivers engaged through their business.
• Carrying out an RTW check before a driver begins working where required under the Scheme.
• Keeping a record of the completed check in line with Home Office guidance.
• Having a process for any follow-up checks where a driver’s right to work is time limited.
• Ensuring they can be satisfied that the person checked is the individual carrying out the work.
Importantly, the Home Office has confirmed that the changes are not retrospective. Existing contractual arrangements entered into before 1 October 2026 will generally not require a new RTW check solely because they continue beyond that date. Operators should therefore focus primarily on new arrangements entered into from 1 October onwards.
The Department for Transport and the Home Office recognise the importance of minimising burdens on operators. The guidance sets out a number of acceptable ways to conduct checks and retain records, allowing businesses to incorporate RTW checks into existing onboarding processes where appropriate rather than adopt a prescribed approach.
Further information can be found in the Home Office’s updated Right to Work Checks: Employer’s Guide on GOV.UK and the guidance for licensing authorities on preventing illegal working in the taxi and private hire vehicle sector. We encourage operators to familiarise themselves with both pieces of guidance and, if they have any questions, contact: righttorentandrighttowork@homeoffice.gov.uk.
Thanks
Taxi and Private Hire Vehicle Policy Team

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