Effective Right to Work (RtW) compliance is a strategic imperative for HR teams across diverse sectors, helping to streamline recruitment and onboarding while actively mitigating business risk, even in volatile business environments.
Yet, the historical reality is a painful process: HR teams, especially in small- or medium-sized enterprises (SMEs), are often forced to rely on cumbersome, manual, and paper-driven procedures that are highly susceptible to human error and without clear audit trails.
HR teams must focus on getting the RtW process right, not just because the risks are high, with fines for illegal workers doubling in 2024 up to £60,000 per worker, but because the benefits are significant to both employers and employees.
The legal bits and what to do about them
Under the Immigration, Asylum and Nationality Act 2006 (Sections 15–25), employers are legally liable for hiring anyone without the right to work in the UK. The Government provides clear guidance and an employer’s checklist as well as a code of practice on how to avoid doing so, and the law applies to all UK employers regardless of size.
Accurate record-keeping is essential, and employers must avoid discrimination by performing checks for all candidates, regardless of nationality or ethnicity.
Acceptable documents, digital verification tools, and online Government services all support compliance, but when incorrectly implemented or used in isolation, can still be time-consuming, leaving both business and candidate waiting. HR teams must also manage ongoing re-checks for employees with time-limited leave.
There are now automated solutions that simplify RtW checks, seamlessly integrate with approved Digital Verification Services (DVS) and contract systems, and even connect with broader Intelligent Agreement Management (IAM) platforms, helping businesses reach compliant, onboarded status faster and with fewer headaches.
Why this matters more now
The whole space around RtW and related issues has been evolving at pace. A June update to the employer’s guide brought clarification around expired biometric residence permits, digital checks, eVisa use and the online share‑code system. Back in February 2025, a separate update tweaked the acceptable document lists, digital verification, and outlined increased scrutiny.
In September, the new digital ID scheme set out proposals that could make digital ID mandatory for RtW checks by August 2029 – although thay was eventually dropped. These are all significant updates that aim to streamline processes and point to a more digitally-oriented and efficient workflow as new technologies and protocols come online.
In fact, there’s buzz around emerging technology and the digital ID landscape more widely. A recent report from Docusign, ‘The Future of Global Identity Verification’, demonstrates that verification tools reduce fraud, improve customer experiences, and improve safety. Although the report does not focus on RtW, it is relevant because the tools used for the processes discussed in the report and RtW are applicable in both contexts.
Positively, digital identity verification (IDV) has progressed, and the Government works with many DVS to support getting citizens connected to public services. While this helps to remove friction throughout the RtW workflow, employers have continued liability even when using Government-approved third-party checks and services.
And, of course, the cost for non-compliance has risen. As mentioned, fines for illegal workers more than doubled last year, and in some cases criminal liability may even apply. This is not a ‘hire and worry later’ situation. Organisations need to mitigate against and understand the practical risk areas that surround their talent and onboarding pipeline – from complexities with self-employed and contractor status to post-Brexit and immigration status implications.
Implications for HR and talent acquisition
To help protect the business and strengthen governance, RtW compliance can be fully embedded into recruitment and onboarding operations rather than as an administrative afterthought. This means integrating RtW workflows directly into HR processes, systems and recruitment platforms, helping to ensure that checks are automatic, traceable, and consistent at every stage.
Beyond process, compliance depends on up-to-date policy and training. HR teams need to stay alert to changes in legislation and guidance, understand which documents are acceptable, and be confident using digital verification and record-keeping tools. A well-trained team is not only more efficient but also far less likely to expose the organisation to risk.
Strong internal controls and periodic audits are also essential, particularly for employees with time-limited leave or for contractor arrangements. Employers should be able to demonstrate effective supply-chain due diligence, verifying that labour providers and agencies meet the same compliance standards, backed by contractual assurances and audit rights.
At the same time, compliance must go hand-in-hand with fairness. Adhering to diversity and inclusion principles, and applying RtW policies consistently to all candidates, helps avoid discrimination.
Ultimately, getting RtW right is about protecting both reputation and trust. Investing in integrated, modern compliance solutions helps HR leaders safeguard organisations and make doing the right thing the easier and simpler. The technology is a seamless add-on to the existing enterprise application suites, so generally does not represent a major tech project to time and budget conscious firms.
Final thoughts
HR leaders must move beyond a simple cost-benefit analysis and recognise that investing in Identity Verification (IDV) and process automation is an all likelihood a critical mandate for risk reduction and boosting business agility. Partnering with a vendor or consultant who can help firms proactively anticipate and adapt to these changes is invaluable.
The time for policy review and system implementation is now. By building for resilience and future-proofing, firms can remove compliance headaches, accelerate talent onboarding, and ultimately uphold their business brand. This will serve to better position the business for future requirements.
Martin Corry is an accomplished enterprise sales leader with a unique background as a former captain of the England rugby team. Today, he brings the same strategic mindset, resilience, and high-performance culture that defined his sports career into the world of B2B technology sales. At Docusign, Martin supports large organisations in navigating digital transformation -particularly in the areas of process optimization, operational efficiency, and customer experience.
He partners with local ecosystems to drive digital transformation, long-term value and impact in Northern Europe. During his international rugby career, Martin earned 64 caps for England, captained his country and club, and was part of the 2003 Rugby World Cup-winning squad. His ability to unite teams, thrive under pressure, and execute with discipline has become the cornerstone of his leadership in sales. From the pitch to the boardroom, Martin is passionate about building trust, solving complex challenges, and helping customers achieve ambitious goals, together.
