Audit the Provider Behind Hiring Checks
From 1 October 2026, digital verification services for right-to-work checks require purpose-registered providers, beyond generic certification. SI 2026/700 was made on 24 June.
The final guide, added at commencement after September’s draft, governs those checks.
Check the provider and result
Employers need confirmations per check: the provider’s purpose-specific register note and code-compliant delivery. Identify the legal entity behind intermediaries.
The OfDIA guidance, updated on 1 December 2025, links to the register for searching providers, services and certificates. Record when an entry was observed; the guidance date is not its current-status timestamp.
Obtain output; match photograph and biographical details to the worker. Keep clear copies through employment plus two years, then dispose securely. Automated face matching is optional; prescribed comparisons require registered providers.
Right-to-rent remains separate. The related changes took effect then for qualifying residential tenancies in England. A landlord choosing this route needs the corresponding purpose registration; hiring registration alone does not cover lettings. The landlord code explains that scheme.
Keep permitted alternatives
These services are optional. The equality code prohibits penalising permitted physical-document choices. An eVisa may require the separate Home Office online check; manual checking is not universal.
Our recommendations: link procurement records with recruiters’ provider and result. Monitor provider switches; onboarding-only contract review misses them.
Give service failures and image mismatches an owner. Review alternatives and explain acceptable evidence to applicants; technical failure does not establish immigration status.
Primary sources
This article provides operational information, not legal advice.
