Right to work and visa rules on gig platforms

Summary

Gig platforms in the UK already carry out right-to-work checks in different ways, and by late 2025 the Home Office was consulting on extending employer-style right-to-work duties more clearly into gig work and self-employed platform work. The biggest risks for workers are using the wrong visa for self-employed app work, letting someone else use the account, or carrying on after immigration permission expires, because that can lead to suspension, loss of income and serious immigration trouble. A simple rule helps: if your visa bans self-employment, you should assume Uber, Deliveroo, Stuart, Amazon Flex or Just Eat self-employed work is not safe unless a regulated immigration adviser says otherwise.

Key facts (UK 2025 to 26)

The Home Office launched a consultation on 28 October 2025 to extend the Right to Work Scheme to gig economy and self-employed working arrangements, with the consultation closing on 10 December 2025.

The purpose of that consultation was to close what the Home Office sees as a loophole where employer-style right-to-work duties did not fully cover modern platform work, self-employed subcontractors and online matching platforms.

In July 2025 the Home Office announced a new operational partnership with Deliveroo, Just Eat and Uber Eats to combat illegal working, saying riders caught sharing accounts with migrants who have no right to work in the UK would be suspended.

Stuart's published right-to-work FAQ says holders of T2, T4 or T5 visas, including Skilled Worker, Student and Temporary Worker visas, cannot work as self-employed couriers on the Stuart platform because those visas do not allow self-employment.

Student visa holders are generally banned from self-employment and business activity, so doing self-employed courier or driver work on apps is a serious immigration risk.

Graduate visa dependants can stay as dependants if they already held dependant status, and dependant partners under student and graduate routes are generally allowed to work unless another restriction applies.

Settled Status and British or Irish citizenship generally allow work without the self-employment bans that apply to Student, Skilled Worker and Temporary Worker routes.

If a platform finds that a substitute rider or driver has no right to work, suspension is now an explicit risk under platform and Home Office anti-fraud measures.

If immigration permission expires during an ongoing platform relationship, the worker can lose access because the platform has to protect itself against illegal-working allegations and enforcement.

Legislation, case law, regulation

Home Office consultation, "Extending the Right to Work Scheme", published 28 October 2025, proposing extension of right-to-work duties beyond standard employment into worker contracts, self-employed contractors and online matching platforms.

Border Security, Asylum and Immigration Bill 2025 impact assessment material, including "Extension of prohibition on employment to other working arrangements", which explains the policy aim of broadening illegal-working controls into new work models.

Home Office operational announcement of 21 July 2025 on a partnership with Deliveroo, Just Eat and Uber Eats targeting account sharing and illegal working.

Platform guidance, including Stuart's published right-to-work document FAQ, which clearly says certain visa types do not permit self-employed courier work.

Home Office visa route guidance on Student visa dependants and Graduate visa dependants, which helps show who can and cannot work, though exact self-employment permissions depend on the underlying route and conditions.

OISC, now the Immigration Advice Authority in practice, regulates who can give immigration advice. GigKiln should signpost workers only to regulated advisers or immigration solicitors where visa conditions are unclear.

How it actually works

From a gig worker's point of view, right-to-work checks happen in two layers. First, the platform checks your identity and immigration status when you sign up or when your documents expire. Second, the platform checks again when there is a substitution request, account review, facial recognition prompt or expiry warning. The exact platform process differs, but the core question is the same: are you personally allowed to do this kind of work in the UK, and is the person using the account the same person the platform checked.

For food delivery platforms, substitution has been a major flashpoint. Some platforms let self-employed couriers use substitutes, but the Home Office and platforms became more aggressive in 2024 and 2025 because account sharing was being used to get around immigration rules. That means the old line you see online, "just get a mate to cover your account", is no longer a harmless bit of app culture. If that substitute has no right to work, or no right to do self-employed work, the account can be suspended and the worker can face much bigger trouble than losing a shift.

Visa type is the key issue. Stuart states this most clearly in public: Skilled Worker, Student and Temporary Worker visa holders cannot do self-employed courier work on Stuart because those routes do not allow self-employment. That is consistent with the wider immigration logic. A Student visa is especially dangerous here, because students may have limited permission to work in employment, but self-employment is a different thing and is generally banned. So a student who thinks "I am allowed 20 hours, so I can do Deliveroo on a bike" can be badly wrong if the platform relationship is self-employed.

Graduate and dependant routes are more nuanced. A dependant partner on a route that allows work will often be able to work more freely, including potentially self-employment, but the worker must still check the exact visa conditions. Spouse visas and dependant visas are often more flexible than Student or Skilled Worker visas, but GigKiln should not tell people "dependants are always fine" without an adviser check, because visa conditions and route changes matter.

Skilled Worker visas are another trap. People often assume "I have a work visa, so I can work anywhere". That is not how it works. Skilled Worker permission is tied to sponsored employment, and self-employment is generally not permitted in the same open-ended way as on settled or unrestricted status. So using an Uber Eats or Stuart account as a self-employed side hustle can be a breach even if the person has a valid visa for their main job.

If your visa expires mid-contract, the practical effect is simple even if the legal wording is messy. The platform will usually ask for renewed right-to-work evidence before or at expiry. If you cannot provide it, access can be paused or terminated because the platform will not want to be accused of facilitating illegal working. Workers sometimes think a pending extension application automatically makes the platform safe to keep using, but this is one of those areas where they need regulated immigration advice, not TikTok.

The 2025 consultation matters because it shows where policy is heading. The government wants employer-style checks to apply more directly to gig platforms, self-employed subcontractors and online matching services. That means more document checks, more re-verification, tighter substitute controls and more suspension risk for anyone whose paperwork is unclear. Platforms will protect themselves first, and workers will often be the ones suddenly locked out.

Self-check flowchart

Are you a British or Irish citizen, or do you have Settled Status with no work restriction? If yes, right-to-work risk is lower, but you still must not let someone else use your account.

If not, what exact visa do you hold right now? Do not guess, check the grant notice or online status.

Is your app work self-employed, not PAYE employment? Most courier and driver platform work is treated that way.

Does your visa allow self-employment or unrestricted work? If no, stop and get regulated immigration advice before doing the work.

Is your visa close to expiry? If yes, assume the platform may recheck or suspend until updated proof is provided.

Do you ever let anyone else use your account, or act as someone else's substitute? If yes, stop and check the platform's substitute rules and that the substitute has their own right to work.

If anything is unclear, speak to a regulated immigration adviser or immigration solicitor, not a WhatsApp group.

Worked example

Take a 19 year old Deliveroo rider in Manchester earning about £180 a week on an e-bike in the 2025 to 26 tax year. He is on a Student visa and sees posts online saying "bike delivery is not a real job, it is just flexible work, so it is fine if you stay under 20 hours". That is dangerous. Stuart's published guidance says Student visa holders cannot work as self-employed couriers, and the same underlying immigration problem can hit across self-employed app work more broadly.

He signs up with a delivery app anyway and later lets a friend use the account for a weekend because he has exams. The friend has no right to work. Under the Home Office operational partnership announced in July 2025, riders caught sharing accounts with migrants who have no right to work are at risk of suspension. If the platform flags unusual device, face or location data, the account can be frozen. The rider may then face not just account loss, but a visa problem because he was doing self-employed work and enabling illegal working through substitution.

Now take a 34 year old Amazon Flex driver fitting work around childcare, on a spouse visa with broad work permission. If that permission really allows self-employment, the immigration position is likely much safer than for the student rider, but the driver still needs to keep status evidence up to date and not lend the account to anyone else. If the visa is due to expire in two months, the worker should assume the platform may request fresh proof and could suspend if it is not provided in time.

What Reddit, TikTok and forums get wrong

Misinformation: "If your visa lets you work 20 hours a week, you can do Deliveroo or Uber Eats as long as you stay under the hours." This gets repeated constantly in student and rider chats. Correction: a Student visa generally bans self-employment, and Stuart's public FAQ explicitly says Student visa holders cannot work as self-employed couriers on the platform. The issue is not just hours, it is the kind of work.

Misinformation: "Substitution makes everything legal because the account holder is self-employed, so it does not matter who actually rides." This shows up in WhatsApp groups and on social media. Correction: the Home Office's July 2025 announcement says riders caught sharing accounts with migrants who have no right to work will be suspended, and the 2024 to 2025 crackdown is specifically aimed at right-to-work abuse through substitution and account sharing.

Misinformation: "If you have a Skilled Worker visa, you can do any side hustle because you already have right to work." This is a common oversimplification online. Correction: Stuart's own guidance says Skilled Worker visa holders cannot use its self-employed courier platform because that route does not allow self-employment in that way. A sponsored work visa is not the same as unrestricted permission for self-employed gig work.

Action steps for the reader

Check your exact immigration status today using your Home Office online status or grant documents. Do not rely on memory or on what someone in a Telegram group told you.

Check whether your platform relationship is self-employed. If it is, and your visa bans self-employment, stop and get advice before carrying on.

Never lend, rent out or "substitute" your account to someone whose right to work you have not checked, because platform suspension and immigration trouble can follow fast.

If your visa expires soon, get your renewal or extension evidence in order and be ready for re-verification by the platform.

If you are unsure, use a regulated immigration adviser or immigration solicitor. For regulated advice, check the Immigration Advice Authority register or use a properly regulated solicitor firm.

If you are already suspended because of right-to-work or substitution issues, do not make up a story. Get immigration advice first, then deal with the platform.

Related tools GigKiln should build

Visa self-check tool that asks immigration status, platform and work type, then flags likely self-employment risks in plain English with a hard warning to get regulated advice where needed.

Document expiry tracker for gig workers, with reminders for visas, share codes and platform re-checks.

Substitution risk checker that explains when platform substitution rules collide with immigration law and right-to-work rules.

Right-to-work appeal checklist for workers suspended by Uber Eats, Deliveroo or Stuart after document or substitution issues.

Related guides

"Student visa and Deliveroo or Uber Eats, why the 20-hour rule does not save you".

"Skilled Worker visa and self-employed app work, the real risk".

"Account sharing, substitution and right-to-work fraud on gig platforms".

"What to do if your visa expires while you are working on a gig app".

Sources

GOV.UK, "Extending the Right to Work Scheme", Home Office consultation published 28 October 2025, accessed 19 April 2026.

GOV.UK, "Extension of prohibition on employment to other working arrangements", Border Security, Asylum and Immigration Bill 2025 impact assessment material, published 8 May 2025, accessed 19 April 2026.

GOV.UK, "New operational partnership with delivery giants to combat illegal working", published 21 July 2025, accessed 19 April 2026.

Stuart Help Center, "Right to Work Documents, FAQs", stating that Skilled Worker, Student and Temporary Worker visa holders cannot work as self-employed couriers on Stuart, accessed 19 April 2026.

GOV.UK, "Graduate visa: Your partner and children", accessed 19 April 2026.

GOV.UK, "Student visa: Your partner and children", accessed 19 April 2026.