For most pharmacy and optometry employers, being “compliant” has meant having the right paperwork on file for the people directly on your books.

From 1 October 2026, that picture is changing.

Right to Work responsibilities are expanding beyond traditional employer-employee relationships to cover a wider range of working arrangements, including third-party agencies, locum platforms, and subcontracted staff.

That matters because responsibility may no longer stop with the business that directly engaged the worker. A gap elsewhere in the process could potentially become your problem too. The change comes under Section 48 of the Border Security, Asylum and Immigration Act 2025, which has been confirmed for commencement on 1 October 2026. The detailed statutory Code of Practice is still being finalised, so some of the operational detail may change before October.

Legal commentary has already highlighted the potential scale of the risk, with penalties for non-compliance potentially reaching up to £60,000 per illegal worker.

For pharmacy and optometry employers, that raises a practical question:

If someone asked you today for a complete compliance record across everyone working in your business — direct hires, locums and people brought in through third parties — could you produce it?

For many businesses, the answer is maybe…

The records exist, but they may be spread across different systems, held by different people or subject to different checks depending on how someone entered the workforce.

And that fragmentation is the real risk here — not just the new rules themselves.

Getting ahead of the October changes means understanding where responsibility sits across your entire workforce and whether you can actually evidence compliance when asked.

Compliance pull-out box

But with 1 October approaching, now is the time to find them — rather than discovering them when you're already being asked to prove your compliance.

Next in the series, we'll break down the five compliance checks every pharmacy and optometry employer should be able to evidence on demand, so stay tuned. In the meantime, if you'd like to talk to our team about workforce management, then drop us a line here.

Further reading and sources

Thanks for reading, have a great day!
Locate a Locum Team