How to manage right to work documents and expiry dates for agency temps

An agency keeps its temps' right to work in order by treating it as three jobs, each with its own date: the evidence, gathered at registration; the check, completed before the first assignment; and the expiry, watched against every live assignment and rechecked on or before the day permission ends. Where you engage the temps and supply them to a hirer, the Home Office treats you as their employer, so all three jobs are yours.

What does the Home Office guide say about temps?

The Employer's guide to right to work checks, edition of 1 October 2026, covers the whole of the UK. For the statutory excuse, an employer makes one of three checks before the worker starts: a manual check, with the originals in the checker's hands and the worker present in person or on a live video link; a check through a registered digital verification service provider; or the Home Office online service. What a right to work check is sets each out. Four more points bear on a temp desk. This is what the guide says, not advice.

• An employment business that engages a temp, on a contract for services included, is the employer for the purposes of the scheme and responsible for the check. The civil penalty is up to £60,000 for each illegal worker, and is not payable where the correct checks were made.

• Where a worker continues to be engaged by the same employer, a fresh check is not required before each assignment, provided the employer holds a valid statutory excuse and makes any follow-up check due before permission expires.

• A share code for work begins with W and lasts 90 calendar days. The photograph on the result is compared with the person in person, by video call, or by a registered provider's facial recognition.

• Where permission is time-limited, the follow-up check is made on or before the day it ends; settled status needs none. Copies and the date of each check are kept during the engagement and for two years after, then securely destroyed.

Why is a temp desk different?

An agency registers people weeks before their first assignment, and may then place them tomorrow morning. A share code given at registration can be past its 90 days by the time work turns up. The code need only be in date on the day of the check, so checking at registration avoids that. A student's permission can limit their hours in term time, and the guide requires the employer to obtain and keep their term and vacation dates.

How to track checks, expiry dates and follow-up checks, step by step

1. Ask for evidence at registration. Ask for the share code and date of birth for an online check, or the originals a manual check needs. A recruitment administrator or the consultant asks, then asks again.

2. Book the check. Agree a time with your checker, in person or on a live video link. For a manual check the originals must already be in the checker's hands.

3. Carry out the check. A trained person on your team makes it, or your registered provider does.

4. File the record. Put the copy or the profile page on the candidate's record in the ATS, with who checked, how and on what date.

5. Record the expiry and any restriction in fields you can search.

6. Before each booking, look. Is the check on file, does permission outlast the assignment, do the hours fit any restriction? Today it falls to the consultant, in a hurry.

7. Run the expiry list. List everyone on a live assignment whose permission ends in the coming weeks.

8. Follow up. Ask for a fresh share code, then book the follow-up check and make it before the date.

Which steps can an AI worker take on?

The gathering, booking, filing and reminding can go to an AI worker: steps 1, 2, 5 and 7, the filing in step 4, the asking and booking in step 8, and the preparation of step 6. The role is right-to-work checks.

• It can send every registrant the same request, British citizens included, and chase until the evidence arrives.

• It can test each code as it arrives, a work code and in date on the day the check is booked, and afterwards file the dated copy your checker saved.

• It can keep one register of expiry dates against live assignments, and each week tell the compliance lead whose permission ends soon and who has not replied.

• Before a booking it can tell the consultant what the record shows: check on file or not, expiry date, restriction noted.

What waits for a person, and why

The check itself is carried out by your own trained people, with a registered verification provider where you use one; an AI worker is neither, and the liability is the agency's. Any mismatch, any restriction that might not fit the assignment, and any decision to hold a worker back or take them off one go to your compliance lead: those are decisions about someone's livelihood. A worker who cannot produce evidence on the day may still have permission, and the guide tells employers to give a reasonable opportunity to prove it. That takes judgement and sometimes a phone call, and both stay with your people.

What to have ready before you start

• One request wording for every registrant.

• Named checkers, trained on the current guide.

• Fields in the ATS for check date, checker, type of check, expiry and restriction.

• A lead time for the expiry list, and who receives it.

Compliance is one of the loads in our article on scaling a recruitment agency without hiring. The rest of the desk's admin, from logging applicants and sifting CVs to booking interviews and chasing timesheets, is on our recruitment page, with the role that takes on each.

A temp desk's AI worker would gather the evidence, book the checks, file the records and watch every expiry date, while your people carry out each check and make each decision about a temp. Do your expiry dates live in a spreadsheet? Start there, and talk to our agent.