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STOP PRESS: When section 48 of the Border Security, Asylum and Immigration Act 2025, is brought into full force on 1 October 2026, it will insert section 14A into Immigration, Asylum and Nationality Act 2006 (IANA 2006). Section 14A establishes that references to ‘employing another person’ in IANA 2006, ss 15–24 include engagement under a worker’s contract or of individual sub-contractors (where an individual contracts to provide work or services that the engaging person has itself contracted to provide to a third party). Accordingly, the illegal working provisions and the requirement to carry out right to work checks will then extend to cover those who engage workers or a ‘sub-contractor’. In addition, new section 15A extends liability under IANA 2006, s 15 by treating certain persons as employers even if they are not in direct contractual relationships with the individuals actually performing the work. This applies either where a person is contracted to provide work or services and sub-contracts this to another person or where a person employs an individual to provide work or services and the contract permits that individual to substitute their...

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