How to run right to work checks at volume in a cleaning or FM company

A cleaning or facilities management company runs right to work checks at volume by separating the two halves of the job. Gathering the evidence, booking the check, filing the record and watching the dates is administration, identical for every starter. The check itself is a person's, before the first shift. When a check is late, look at the first half first: the share code that never came, the passport left at home.

Four points of the Home Office guide that catch this trade

The Home Office's employer's guide to right to work checks, edition of 1 October 2026, applies across the UK. Our explainer, what is a right to work check, covers the kinds of check. Four points bite where starters are many.

• Before the first shift. The check is done before the worker commences employment.

• Originals in hand. A manual check needs the original documents in the checker's possession, with the holder present in person or by live video link. A scan or screenshot is not a check.

• Your own accountable staff. The employer is responsible for carrying out the check. Staff acting for it and accountable to it can do so; an outside party may only support it, with gathering information and the technical side.

• Follow-up by the date. Where permission to work is time-limited, the next check falls on or before the date it ends.

The guide says an employer found to be employing someone illegally, without the prescribed checks, may face sanctions including a civil penalty of up to £60,000 per illegal worker.

The job, step by step

At volume, starters are named by area managers, not HR, checkers are rarely where the starter is, and people leave as steadily as they join.

1. The trigger: a name and a start date. The area manager sends both to one address when a cleaner is offered work.

2. Ask each starter within an hour of the name arriving. One message for everyone, British citizens included, because the guide expects consistency: a work share code with their date of birth, or the originals they will produce.

3. Test the reply before the appointment. A work share code begins with W and lasts 90 calendar days. One starting R or S cannot be used.

4. Book the check. A named checker, before the first shift. An online check compares the photograph on the result with the person, in person or by video, and needs no documents; a manual one needs the originals with the checker first.

5. Carry out the check. Is the evidence genuine, is it this person's, and does it allow this work, including any limit on hours such as a student's in term time?

6. File it. The copy or online result, the date and the checker's name go on the worker's record. The guide has copies kept for the employment and two years afterwards, so add a leaving date when they go.

7. Diarise the follow-up. Every time-limited permission gets a date and a booking before it.

When a contract transfers

Win a contract and its staff may come with it under TUPE. The guide advises a fresh check on workers acquired this way, because a check the outgoing employer did wrongly leaves the incoming one liable, and because it may be the only way to learn each follow-up date. It gives a grace period of 60 calendar days from the date of the transfer, and none for later follow-up checks. Run that countdown worker by worker from the first day of mobilisation.

When your cleaners are self-employed

The same edition widens who counts as an employer for these checks. Besides employees, the guide covers people engaged under a worker's contract and individual sub-contractors. It defines an individual sub-contractor as someone who contracts with you to provide work or services that you have contracted with a third party to provide, where the individual has no contract with that third party. A self-employed cleaner you engage to work on a client's contract may be one. The guide says the scheme applies according to the objective features of the arrangement, not the label given to it, and that for these arrangements a civil penalty may only be imposed where the employment commenced on or after 1 October 2026. A self-employed person running an independent business for many customers is outside the scheme, by the guide's own example. This article does not advise on where a particular arrangement falls.

When you subcontract

The same edition reaches beyond your own payroll. Where you are under contract to provide a service and contract with another employer whose workers carry out all or part of it, the guide says you may be treated as their employer and may be liable for a civil penalty if one is found working illegally. The direct employer remains responsible for the check. A statutory excuse against this extended liability rests on prescribed requirements for the contractual arrangements, where those were entered into on or after 1 October 2026. This article does not advise on them.

Which steps can an AI worker take on?

In this job it can send the request the moment a starter is named, see whether a code is a work code inside its 90 days, ask again where it is not, and put the check in a checker's diary ahead of the start date. Each morning it can list who starts this week unchecked. It can file what the checker saved, keep the follow-up register and the 60-day list after a transfer, and remind ahead of each date. The role is set out under right-to-work checks, and the rest of the starter's file under new starter and HR admin.

What waits for a person, and why

The check itself stays with your people, because the guide makes it the employer's. These stay with your people too:

• Any mismatch or restriction.

• Any case for the Home Office's Employer Checking Service.

• Any decision to delay a start or stop someone working.

• Any phone call to a starter who has gone quiet. That list goes to the area manager in time to find cover.

What to have ready before you start

• One approved message for all starters.

• A named, trained checker for each contract or area, and a deputy.

• A written rule: nobody on a rota until the check is recorded.

• One register of follow-up dates, not one per area manager.

None of the four needs new software. Our page for facilities management and cleaning lists the other roles, and the wider argument is in scaling a cleaning or FM business without hiring.

An AI worker at a cleaning or FM company would have each starter's evidence in before a shift is promised and run the 60-day list after every contract win, and your trained checkers would carry out each check. A starter who reaches site before the check is recorded is working without a statutory excuse. Talk to our agent.