By Padraig Reilly, Founder & CEO, Boxcore

Construction workforce compliance is about to become more demanding for UK contractors. From 1 October 2026, Right to Work checks will extend beyond employees to cover subcontractors, agency workers, and other non-standard arrangements common on construction sites.

For an industry built on subcontractors, specialist trades and layered supply chains, this matters. The practical question for contractors is becoming simple: do you know exactly who is working on your site, and can you demonstrate that they are approved and compliant to be there?

Increasingly, answering that question takes more than a spreadsheet or an approved worker list. Contractors need to connect digital onboarding, inductions and training records with reliable identification of the person actually attending site. This is where facial recognition can play an increasingly important role.

What changes from October 2026

The Border Security, Asylum and Immigration Act 2025 expands the UK’s Right to Work framework beyond traditional employees to include people engaged under worker contracts and individual subcontracting arrangements. This is particularly relevant to construction, where labour is regularly delivered through multiple subcontractors and different contractual structures.

Home Office guidance includes a construction example involving a developer using contractors and subcontractors to supply labour to a project, reflecting how construction supply chains commonly operate.

The financial exposure is significant. Civil penalties for illegal working can reach £60,000 per worker where the required statutory excuse has not been established. That does not mean every principal contractor automatically becomes responsible for every worker in its supply chain; the contractual position still matters. What it does mean is that contractors need better visibility over the people working on their projects.

Right to Work checks are only part of the picture

Completing the prescribed Right to Work check is one part of workforce compliance. Knowing who physically arrives on site is another. A contractor may hold hundreds of approved worker records, but that does not confirm who is physically present on the project today. Equally, an approved worker list does not prove that the person arriving at the gate is the individual whose records were reviewed.

Contractors increasingly need to know, for each worker, whether they have completed their digital induction, hold the appropriate CSCS card, have completed project- and task-specific training, have current competency records, have any documents approaching expiry, and are actually on site. The strongest workforce management processes connect all of this to a single verified worker profile.

Start with digital onboarding

Ideally, the process begins before the worker ever reaches the gate. Digital onboarding lets contractors and subcontractors collect the required information in advance, rather than resolving gaps at the site entrance. A worker can be added to a project, complete their induction, and have CSCS cards, training records and competency information reviewed before their first day. That creates a clear approved worker record.

But onboarding on its own doesn’t answer the next question: is the person who was approved the same person now attending site? Connecting onboarding with facial recognition closes that gap, linking the physical person at the gate to the digital workforce record already held against them.

Facial recognition brings identity into workforce compliance

Facial recognition brings identity into workforce compliance. Cards, fobs and sign-in sheets can be lost, shared or used by someone else, creating room for buddy punching and inaccurate attendance. Facial recognition links attendance directly to the worker’s profile, so contractors can confirm who’s approved, whether they’re compliant, and whether they’re actually on site without replacing the prescribed Home Office Right to Work check itself. Boxcore applies this with or without turnstiles: on turnstile projects, identity and compliance status feed the access process; on sites without them, standalone devices still give real-time attendance and visibility. Either setup runs the same underlying process onboarding, induction, compliance approval, facial recognition, attendance, so contractors aren’t forced into one physical setup regardless of project size.

Ease of adoption is essential

Technology only works if site teams and subcontractors actually use it. Construction teams are under constant programme pressure and have little patience for complicated software or lengthy training. A contractor might need to onboard five workers one day and a hundred the next, and the process has to hold up at both scales — inductions that are easy to complete, subcontractor information that doesn’t require extensive training to submit, and compliance status that a site manager can check in seconds. If the process is difficult, people build workarounds, information drifts back into email and spreadsheets, and the single workforce record a contractor was trying to build falls apart. Ease of adoption isn’t just a software preference here; it directly determines the quality of the compliance data a contractor ends up with.

One worker profile, not separate records

The real opportunity isn’t simply digitising more documents – it’s connecting the information around the worker. A better model starts with the worker: onboarding creates the profile, induction and training records establish whether project requirements are met, and facial recognition connects that approved identity to physical attendance. Site teams can then see who is present and whether their records are compliant, in one place. That shifts workforce management from retrospective checking to active control, catching an expired training record before work starts, rather than discovering it afterwards.

What to check before October

Ahead of 1 October, it’s worth reviewing both legal process and how workforce information actually operates on site:

Can you identify everyone currently working across your projects, and which subcontractor each person belongs to? Have the required Right to Work checks been completed, and have workers finished the correct induction before starting? Can you check CSCS cards and project- or task-specific training instantly, and flag records that have expired or are about to? Can you reliably confirm that the person on site is the worker who was approved, and do you have an accurate real-time attendance record? And critically – is the process simple enough that site teams and subcontractors will actually use it, on projects with turnstiles and without them?

Those questions separate holding records from having real control over workforce compliance. October’s changes are the legal trigger, but the operational gap they expose isn’t new and it’s one worth closing regardless of the deadline. Building that visibility now is far more manageable than reconstructing it under pressure once the rules are already in force.