Key Takeaways
- What does the Borders Act 2025 change for Right to Work obligations?
The Act broadens the scope of Right to Work (RTW) obligations, so they extend across all worker types, including employees, contractors, agency staff, and contingent labour. Although the relevant section of the Act has not yet been implemented, organisations may consider next steps to ensure compliance with the Act. - Who remains accountable for Right to Work checks under the Act?
Accountability for RTW checks continues to sit with the organisation engaging the worker, even when suppliers or third-party intermediaries carry out checks. - How does workforce verification fit into governance frameworks for financial services organisations?
In financial services, workforce verification supports operational risk and compliance efforts. It helps organisations align with regulatory expectations and encourages shared ownership across HR, compliance, and risk functions. - What role can digital verification play in managing these responsibilities?
Digital verification tools can help support consistent, scalable, and auditable verification processes across multiple engagement and employment types.
The UK’s Border Security, Asylum and Immigration Act 2025, commonly referred to as the Borders Act 2025, represents a significant development in the country’s approach to immigration compliance. While the legislation is framed as a broader modernisation of border and immigration controls, it has critical operational implications for UK employers.
For financial services organisations, effective workforce governance supports core objectives around trust, regulatory expectations, and operational risk. As workforce models continue to evolve, the Act reinforces a shift in how organisations approach Right to Work verification and oversight.
The Borders Act reflects a broader view of the workforce. It brings new considerations for hiring practices, onboarding processes, supplier oversight, and enterprise risk management. Understanding these considerations can help organisations evaluate how workforce verification fits into broader workforce compliance frameworks.
Why the Borders Act 2025 matters for UK employers
Workforce structures have changed significantly in recent years. Many organisations now rely on a combination of permanent employees, contractors, consultants, and third-party providers to complete work deliverables. Recent research highlights a growing reliance on mixed workforce models, with 58% of UK finance and accounting firms planning to increase permanent hiring and 43% planning to hire contract or interim talent.
The Borders Act addresses this reality directly. It clarifies that Right to Work checks are not confined to individuals hired under standard employment contracts. Instead, verification expectations extend to anyone performing work on behalf of an organisation, regardless of how the contractual relationship is structured.
This approach aligns with broader regulatory principles already in place within many financial services organisations. For instance, oversight, accountability, and control across operational activity are central themes within frameworks such as the Senior Managers and Certification Regime (SMCR). The Borders Act reinforces workforce verification as part of this wider governance landscape.
Although no implementation date of the relevant section of the Act has been confirmed, in light of these expanded verification expectations, financial services employers may wish to consider how gaps or inconsistencies in verification processes could contribute to regulatory risk and potential reputational exposure. Financial penalties associated with non-compliance with immigration requirements add a further layer of consideration, particularly in a sector subject to such close scrutiny.
Learn more about how Right to Work checks fit into workforce verification strategies.
Extending Right to Work checks across the workforce
The Borders Act 2025 emphasises consistency across workforce models and reinforces organisation-wide accountability for Right to Work verification. Rather than tying checks to job titles or employment status, the Act draws attention to everyone carrying out work on behalf of an organisation. This includes agency workers, gig workers, consultants, and certain supply chain roles that may not previously have been included within a single verification approach.
For many organisations, this expanded scope shifts attention towards verification across the full workforce ecosystem. In financial services, where work often spans across internal teams and external suppliers, this broader view highlights the need for alignment across different parts of the organisation.
Strengthening governance and cross-functional oversight
The idea that workforce oversight extends beyond HR and talent acquisition teams is reinforced by the Act. In fact, effective governance often involves coordination across multiple functions, each with a unique role in managing enterprise risk and accountability. For example, compliance, risk, legal, procurement, and vendor management teams may all contribute to how the organisation approaches workforce verification and monitoring.
In regulated environments like financial services, clear audit trails play an important role in how internal audit and risk teams review verification activity across the organisation. Consistent, documented processes and oversight of third-party workforce arrangements can help support that review.
Lastly, aligning workforce verification activity with existing governance frameworks may also help organisations assess how immigration compliance fits into wider regulatory expectations, including those set by the Financial Conduct Authority.
Integrating screening and onboarding workflows
As verification expectations extend to a wider range of worker types, organisations can benefit from integrating Right to Work checks and identity verification into broader screening and onboarding workflows. Integrating these elements can help reduce process gaps and support a more consistent approach across traditional and nontraditional hiring models.
Integration also becomes especially important when filling roles that involve system access, sensitive data, and regulated activities. Such an approach can be particularly relevant in scenarios such as:
- Contractor onboarding
- Statement of Work (SoW) engagements
- Third-party workforce onboarding
- Project-based hiring
Explore background screening services in the UK that support safer hiring decisions.
Managing compliance risk across the labour supply chain
Under the Borders Act 2025, accountability for Right to Work compliance remains with the organisation engaging the worker, even when third-party suppliers carry out checks. This distinction places greater emphasis on how organisations maintain oversight across complex labour supply chains.
To reinforce accountability across different labour arrangements, organisations might consider a range of oversight measures, including:
- Supplier due diligence and onboarding controls that clarify how verification responsibilities operate in practice
- Risk-based audits and targeted spot checks
- Contractual verification requirements that help set clear expectations with third-party partners
- Defined escalation and remediation processes for addressing potential issues
The role of digital verification in scaling compliance
As workforces become more distributed, manual verification processes can be harder to apply consistently at scale. In contrast, technologies such as Identity Document Verification Technology (IDVT) and certified digital identity services can help support more consistent and auditable verification practices across different worker types. For financial services organisations managing fluctuating workforce volumes and multiple engagement models, these digital solutions can offer a practical way to balance operational efficiency with verification requirements.
When integrated into broader screening and onboarding workflows, digital verification tools can help organisations:
- Standardise verification processes across worker types and geographies
- Strengthen auditability and recordkeeping through consistent digital records
- Track document validity and expiry dates more effectively
- Support efficient onboarding, particularly amid fluctuating volumes and tight timelines
Moving towards enterprise-wide workforce governance
The changes introduced by the Borders Act reflect a shift in how organisations view workforce verification. Rather than existing as a standalone compliance task, Right to Work checks are increasingly part of a broader governance conversation that spans factors such as workforce composition, supplier oversight, regulatory alignment, and operational risk.
For financial services organisations, the shift aligns with longstanding priorities around trust, transparency, and accountability. Viewing workforce verification through an enterprise-wide lens can help organisations connect workforce compliance with existing risk management practices. This perspective also supports a more resilient and coordinated approach as regulatory expectations continue to evolve.
First Advantage supports financial services organisations with identity verification and background screening solutions designed for the full employee lifecycle, including contingent and supply chain labour. Contact us to learn how First Advantage can support your workforce screening strategy.
Frequently Asked Questions
- What is the Borders Act 2025?
The Borders Act 2025 is UK legislation that, in particular, expands employer responsibilities for immigration compliance, including Right to Work checks across different types of workers. Although the relevant provisions have not yet been implemented, the Act reflects a shift in how organisations may approach workforce eligibility. - Do Right to Work checks apply to contractors?
Yes. The Act clarifies that organisations are expected to apply Right to Work checks across contractors, agency workers, and other non-traditional labour arrangements. - Who is responsible for Right to Work checks?
The organisation engaging the worker remains responsible, even when suppliers or third parties are involved. - How does the Borders Act impact financial services firms?
It increases expectations around governance, auditability, and workforce oversight, aligning immigration compliance with frameworks such as the Senior Managers and Certification Regime (SMCR). - How can organisations manage Right to Work checks at scale?
Organisations can use digital verification tools and structured workflows to improve consistency, auditability, and operational efficiency.
