Employers will still be free to choose between the prescribed manual, Home Office online and digital Right to Work routes after 1st October 2026.
A new requirement applies where the employer chooses to use a digital verification service provider. The provider must be registered with the Office for Digital Identities and Attributes and listed as able to conduct Right to Work checks.
Registration should be the first procurement check. It is not the last.
Check the service, not only the company name
The government register lists individual digital services, their providers, certified role types, supplementary codes and certification dates.
Employers should confirm that the exact service they intend to use carries the Right to Work supplementary code. A provider may offer several identity services with different permissions, so a company appearing somewhere on the register is not sufficient on its own.
Rightcheck’s registered service, for example, is listed with Identity, Attribute, Orchestration, Holder and Component roles, together with supplementary codes for Right to Work, Right to Rent and DBS.
Digital checks remain optional
The October guidance does not require every employer to move to a digital provider.
Manual document checks and Home Office online checks remain valid prescribed routes where they are appropriate for the worker. People who have been issued with an eVisa will normally prove their status through the Home Office online service using a share code.
A digital provider can support identity verification and, where offered, facial matching. It does not replace the Home Office online status result for an eVisa holder.
Understand which documents and routes are supported
The draft code says registered Right to Work providers may verify valid British and Irish passports, including Irish passport cards, and passports up to six months beyond expiry where the prescribed requirements are met. It also introduces the ability to verify certain acceptable documents supplied digitally by a government department, initially including official evidence of a worker’s name and National Insurance number.
Services vary between providers. Employers should ask which documents, nationalities and checking routes are covered and what happens when a digital check cannot be completed.
A provider that performs well for biometric passport holders may still leave the recruitment team to manage eVisas, ECS referrals, manual documents and technical failures elsewhere.
Questions to ask a provider
Certification confirms that a service has met prescribed requirements. Procurement teams should also ask how the service performs in their actual recruitment environment.
Useful questions include:
- Is this exact service listed for Right to Work on the government register?
- Which candidate documents and checking routes does it support?
- How are eVisa and Home Office online checks handled?
- What happens when the candidate cannot complete the preferred digital route?
- How does the employer confirm that the person starting work matches the check?
- What evidence is retained, where is it stored and how quickly can it be retrieved?
- How are follow-up checks and time-limited permissions managed?
- What completion, retry and manual-intervention data can the provider supply?
- How does the service support candidates who need accessibility adjustments?
- How will the provider update the service when final October guidance is issued?
Employers do not need to choose between certification and performance. They need a registered service that also works reliably for the people and checking routes they encounter.
Join our October 2026 webinar for a walkthrough of the new provider requirements and the responsibilities employers retain when using digital verification.
