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Digital checking is useful but the Home Office guidance still draws firm boundaries around where it works and where it does not. The June 2025 employer guide says a digital verification service can be used for British and Irish citizens who hold a valid passport or Irish passport card. It also says that a manual or Home Office online check carried out by a DVS, outside that prescribed route, does not establish a statutory excuse for the employer.
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The draft discrimination code adds a second constraint. Employers may encourage applicants to use the online service or a DVS, and they can help with access to hardware or the internet. What they cannot do, except where a worker has been issued an eVisa, is insist on a digital route. British and Irish citizens also cannot use a share code to prove their Right to Work, so employers still need to be able to deal with original documents or an approved IDVT route where appropriate.
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A digital-first journey is still worth having. It just cannot be the only journey that works properly. Employers need a process that can also absorb manual checks, Home Office online checks, ECS cases and candidates whose lawful route is valid but less straightforward. That is what keeps a fast process from becoming a brittle one.
Sources: UK digital verification services trust framework (1.0) pre-release (Updated March ’26)
This is the third in a 6-part series. You can subscribe here to be notified of future changes to Right to Work Compliance based on HMRC updates and Gov.uk sources.
You can also find the other parts here:
- Click here for part 1 on how the Home Office’s draft 2026 code shifts Right to Work compliance.
- Find out how Right to Work is moving beyond employees in part 2 here.
- In part 4, we cover how rechecks have been causing employers to become unstuck with regards to their right to work compliance.
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