1 October 2026: what changes for cleaning companies

1 October 2026 is a big date for cleaning companies. The biggest change is that right-to-work checks now reach far beyond your own employees. This guide sums up what changes, who it affects in a typical cleaning business, and what to do this week.

Right-to-work checks now cover your whole workforce

Section 48 of the Border Security, Asylum and Immigration Act 2025 comes into force on 1 October 2026, for work arrangements that start on or after that date. Until now, the duty to check someone's right to work in the UK mostly applied to your employees. From 1 October 2026 it also covers:

Self-employed cleaners who work on your contracts.
Agency cleaners and people booked through apps and platforms.
Cleaners supplied by another cleaning company you subcontract to.

If someone working for you isn't allowed to work in the UK and you didn't check them properly, the civil penalty is up to £45,000 per person, or up to £60,000 per person for a repeat breach within 3 years. A proper check, done before someone starts and kept on file, gives you a defence if they turn out not to be allowed to work.

Who this affects in a typical cleaning business

Who	Before 1 October 2026	From 1 October 2026
Employees and casual staff on your payroll	You check	You check (no change)
Self-employed cleaners you use directly	No duty	You check before they start
Agency or app-booked cleaners	The agency's duty	Covered too: agree in writing who checks, and ask to see it
Another cleaning company's staff on your contracts	Their duty	Covered too: agree in writing who checks, and ask to see it

For the details, see self-employed cleaners and agency and app-booked cleaners.

What to do this week

List everyone who cleans on your contracts, and how each person is engaged.
Check anyone new before their first shift, including cover, trial shifts and one-off jobs. No check, no shift.
Write to your agencies, apps and subcontractors asking them to confirm they check everyone they send, and that you can see the evidence.
Save every check with the date and who did it, so you can show an inspector or a client.

The right-to-work checklist goes through each step.

Other employment changes around now

1 October 2026: the time limit for most employment tribunal claims goes up from 3 months to 6 months.
30 October 2026: employers must take all reasonable steps to prevent sexual harassment at work, including harassment by clients and members of the public. That matters for cleaners working alone in other people's buildings.
Since 6 April 2026: Statutory Sick Pay is paid from the first day off sick, and holiday records must be kept for 6 years. See timesheets and clocking in.
January 2027: the qualifying period for unfair dismissal protection drops from 2 years to 6 months.

Coming next: guaranteed hours and shift notice

The Employment Rights Act 2025 also brings rights for zero-hours and low-hours workers to guaranteed hours, reasonable notice of shifts and pay for short-notice cancellations. They aren't in force yet, but they depend on records you can start keeping now. See guaranteed hours for zero-hours cleaners and shift notice and cancellation pay.

How RotaProof helps

RotaProof is right-to-work software made for cleaning contractors. You record each check once, including for self-employed and agency cleaners. It reminds you before anyone's permission runs out, stops unchecked people going on the rota, and gives you an inspection pack in one download. You can try it free for 30 days.

Try the demo, no sign-up needed Start free trial

Sources

This guide explains the rules as we understand them on the date above. It isn't legal advice. The Home Office's guidance and code of practice are the final word, and if your arrangements are complicated, get advice from an immigration or employment lawyer.