Right-to-work checks
A right-to-work check is quick once everything is to hand. Getting it there is the work: a share code not yet sent, a passport left at home, a visa date in a spreadsheet. This role gathers what each starter must show, books the check before day one and keeps every follow-up date. Your people carry out the check.
The role in brief
Asks every new starter for the right evidence, books the check with your checker before day one, files the record and diarises every follow-up date.
Your HR or payroll system, your applicant tracking system where you have one, and the mailbox starters reply to.
The HR manager or compliance lead. Every check, any document that does not match and any decision to delay or stop someone working go to them.
Starters checked before the first shift, follow-up checks booked before expiry, and records complete.
Who gets the documents in today
An HR or recruitment administrator does it, or the manager who needs someone on site tomorrow. They ask for a share code or a passport, wait, ask again, fit the check in around the start date and note any visa expiry in a spreadsheet. Since 1 October 2026 the UK-wide scheme also covers people on a worker's contract and individual sub-contractors engaged from that date, so the list is longer.
A starter working before the check
A check made after someone has started gives no statutory excuse. If that worker turns out to have no right to work, the civil penalty is up to £45,000 per worker for a first breach, and up to £60,000 for a repeat within three years.
A follow-up date nobody diarised
Where permission to work is time-limited, a follow-up check is due on or before the day it ends. Miss it and the excuse lapses, however well the first check was done. A Positive Verification Notice from the Employer Checking Service lasts six months, so it needs a date of its own.
A check that does not count
A photo of a passport sent by message is not a manual check: the Home Office requires the original in your hands, with its holder present or on live video. Nor can you rely on a recruitment agency's check: the only third party you may hand it to is a registered digital verification service provider.
From job offer to follow-up check, step by step
Every check is carried out by your people, who also decide what happens when something does not match. The asking, booking, filing and reminding go to the agent, working to your checker's diary and the follow-up intervals you set.
Evidence
Sends every starter the same request, British citizens included: a share code and date of birth, or which original documents to bring, or the link to your verification provider.
Nothing, once you have approved the wording.
Booking
Checks each share code is the work kind, nine characters starting with W, chasing a fresh one after 90 days. Books the check with your checker before the start date.
The check itself. A person, or your registered verification provider, confirms the evidence and that it belongs to the starter.
Record
Files the dated copy or the profile page your checker saved, records who checked, how and when, and lists anything missing, such as a student's term dates.
Any mismatch or restriction on work. A person decides whether the starter can begin.
Follow-up
Diarises each expiry date, reminds the worker and the checker by email at the intervals you set, and books the follow-up check before permission ends.
The follow-up check, any phone call to a worker who has gone quiet, and any decision to stop someone working.
Starters checked before the first shift
The share of new starters whose record shows a completed check dated before their first shift or start date. Reviewed with you each month.
Follow-up checks booked before expiry
Of the workers whose permission ends in the period you set, how many have a follow-up check booked, and who has not replied.
Records complete
The share of worker records that hold the copy or profile page, the date of the check and the checker's name, kept for the employment and two years after it.
Facilities management and cleaning
Cleaners starting at short notice across many sites and, after a TUPE transfer, the 60-day window for fresh checks counted down worker by worker.
Construction contractors and trades
Since 1 October 2026 the scheme reaches the individual sub-contractors you engage directly, so their evidence is gathered and each check booked before site induction.
Recruitment
An employment business checks its own temps: share codes gathered at registration, and visa expiry dates tracked in the ATS against live assignments.
Questions owners ask
Can an AI agent carry out a right-to-work check?
No. The check is the employer's, and a person carries it out: comparing the photograph with the person, face to face or on a video call, or using a registered digital verification provider. Home Office guidance lets technology support the steps and leaves the responsibility with you. The agent does the requests, bookings, records and reminders around it.
What changed for employers on 1 October 2026?
The scheme now covers people on a worker's contract, individual sub-contractors and online matching services, not only employees. A business that subcontracts work it is contracted to deliver can also be liable unless written terms, substitution controls and identity verification are in place. Which of your arrangements are in scope is for you and your advisers to decide.
Do British and Irish staff need checking too?
Yes. The Home Office tells employers to check every worker in the same way, whatever their nationality. British and Irish citizens cannot get a share code, so they show original documents such as a passport, or use a digital verification provider. The agent sends everyone the same request, and your checker sees everyone.
We have taken on staff under TUPE. Do we check them again?
The Home Office advises a fresh check on every transferred worker and allows 60 days from the transfer to do it, with no extra time for follow-up checks. The agent works through the transfer list, asks each person for evidence and books the checks. Your people carry them out.