How identity document validation technology fits into right to work — who it is for, the certified-provider requirement, and why identity is not the same thing as immigration status.
For British and Irish citizens who hold a valid passport, an employer can meet the right to work check using identity document validation technology (IDVT) through a certified provider, instead of manually examining the passport. The provider checks the passport is genuine and compares its image with an image of the person — typically a photo or short face capture — to confirm the document belongs to them. It is a route to satisfy the identity element of the check remotely, which is why it suits high-volume or remote onboarding.
Digital identity is one of the three prescribed routes, alongside the manual document check and the online share-code check. The digital-identity route is specifically for British and Irish passport holders; people who are not British or Irish generally prove their status through the online share-code service. Choosing the right route for each person is part of getting the check right.
From 1 October 2026, where the digital identity route is used for right to work, the identity element must be carried out by a registered Right to Work Digital Verification Service provider meeting the relevant certification requirements — that is how the statutory excuse is obtained through this route. See the 1 October 2026 changes. Until then, confirm the current arrangements; and after commencement, confirm the final Home Office and digital-identity codes.
This distinction matters. Identity verification confirms a person is who they say they are. Right to work is about whether they are permitted to work. An immigration decision is a matter for the Home Office. A digital identity check on a British or Irish passport establishes identity as part of the right to work process — it does not, on its own, make an immigration-status determination, and no provider or software should be described as doing so.
In an identity document validation check, the individual submits an image of their passport and a photo or short face capture of themselves through the provider’s app or web flow. The technology checks the document is genuine and unaltered, reads its chip or data where available, and compares the document photo with the live capture — often with a liveness step to confirm a real person is present rather than a photograph of a photograph. The provider then returns a result the employer keeps as evidence. It is a way to complete the identity element remotely and at scale.
Not any identity app will do. Providers are expected to be certified against the government’s digital identity trust framework and, for right to work specifically, the framework distinguishes a registered Right to Work Digital Verification Service provider. From 1 October 2026, where the digital identity route is used for right to work, using such a registered provider is how the statutory excuse is obtained. Check a provider’s current status before relying on it — and note that Complys is not such a provider.
A simple way to think about it: British and Irish passport holders can be checked by a certified digital identity provider or manually; everyone else generally proves their status through the online share-code service; and where a status cannot be confirmed (outstanding application, appeal, certain documents) you use the Employer Checking Service. Picking the correct route for each person is itself part of doing the check correctly.
Keep the output the provider gives you — the evidence that the identity check was carried out and its result — with the date, securely and unaltered, for the duration of employment plus two years, the same as any other route. See our record-keeping guide.
The digital identity route exists because so much hiring now happens remotely. For a British or Irish new starter who never visits an office before day one, a certified provider lets you satisfy the identity element without posting a passport around or delaying the start. For high-volume employers — recruitment, hospitality, logistics — it turns a manual, in-person bottleneck into a consistent, auditable step. That convenience is only compliant, though, when the provider is properly certified and you keep the result.
The digital identity route is not for everyone. It applies to British and Irish citizens with a valid passport; it is not the route for other nationalities, who prove status through the online share-code service, nor a way to resolve an unconfirmed status, which needs the Employer Checking Service. Using it for the wrong person does not create a statutory excuse. And however slick the technology, it establishes identity— it does not turn into an immigration decision or a substitute for checking the person is entitled to the specific work.
Onboarding a worker can involve three distinct steps that modern tools sometimes bundle together: verifying identity (are they who they say they are?), checking right to work (are they permitted to work?), and, for eligible roles, a DBS check (are they suitable?). They can share the same identity evidence and the same onboarding flow, but they remain legally separate with different rules and outcomes. A certified digital identity check can support the identity element of right to work — and can also support the identity stage of a DBS application — but it does not merge them into a single “cleared” result. See DBS vs Right to Work.
Whatever technology you use, the consistency principle still applies: you should not steer some candidates to a digital identity check and others to a manual one based on how they look or sound, or their nationality. Choose the route by what the law allows for that person’s documents, apply your process evenly, and keep only the evidence the check requires. Digital identity should make right to work easier and fairer, not a way to treat groups of candidates differently.
If you use the digital identity route, the provider matters. Look for one whose certification/registration status is current for right to work — and, from 1 October 2026, that is a registered Right to Work Digital Verification Service provider — not merely an identity app. Check that it returns clear evidence you can keep (a result you can store, dated), that it handles personal and biometric data proportionately and securely, and that it is straightforward for a genuine applicant to complete on a normal phone. The employer keeps responsibilities in the process even when a provider performs the identity element, so understanding exactly what the provider does — and what remains yours — is part of choosing well.
Complys keeps the output of your checks — the evidence and its dates — in the worker record with expiry reminders. Connecting a specialist identity/verification provider so a result can flow into that record is on our roadmap as a coming, provider-dependent capability. Today, the verification itself is done by the certified provider and the official routes, not by Complys. See Right to Work compliance software.
General information for UK employers, not legal advice. Digital identity provider certification and the right to work route are set by the Home Office / relevant government bodies; confirm current and post-1-October requirements against official guidance. Reviewed 26 September 2026.
