online matching service right to work checks 2026

Direct answer. Since 1 October 2026, an online matching service that connects an individual service provider with customers may fall within the UK's right to work scheme. The platform's precise duty depends on the contracts and how the service operates. In the final Home Office guide, a platform matching a cleaner who personally performs the work is an example of an online matching service treated as the employer for a direct prescribed check. A different model, where the platform matches a service-provider business to a customer and that provider engages the worker, can bring extended liability and a pre-commencement written statement, assurance and identity-control requirements. The customer of an independent business does not automatically inherit a check duty. Platform labels or app terms alone do not determine the result. Home Office final Employer's guide to right to work checks, 1 October 2026.

This is a UK platform-operator guide, not a blanket statement that every marketplace or booking site must collect passports. Analyse each supply model and get advice where the contractual chain is complex.

Why the platform model matters more than its label

“Online matching service” can describe very different businesses. One app engages individuals to carry out tasks personally and controls access to assignments. Another introduces independent service firms to customers and never engages the workers that firm deploys. A third takes a contract to provide a service and subcontracts its fulfilment. The final Home Office guide asks who engages or arranges the individuals, who contracts with the customer and worker, whether the task is personal labour or an independently delivered service, who may substitute or further subcontract, and what happens in practice. No single factor is determinative. Final guide, pages 12–16.

Draw three separate lines before designing a check flow: commercial contract (who owes the customer the work), worker contract (who engages the person who does it) and assignment control (who decides who may appear). Record how payment, substitution, identity and complaints work. If contracts say the cleaner is independent but the platform signs them up, assigns jobs and pays per job, the Home Office's direct-check example is more relevant than an “advertising marketplace” label. If a named cleaning company contracts with and supplies workers, ask who performs its direct checks and whether the platform's own arrangement falls within extended liability. Final guide, examples 3, 4 and 8.

The new-category civil penalty rule applies to relevant engagements starting on or after 1 October 2026; extended-liability prescribed contractual requirements apply where the relevant arrangements were entered into on or after that date. Do not treat the 2026 rules as a reason to backdate checks on every historic marketplace transaction. Final guide, pages 13–14.

Model one: the platform engages the individual directly

The Home Office's example of a homeowner booking a cleaner through an online matching service says the service may be treated as the cleaner's employer under the scheme and is responsible for the prescribed right to work check. Its delivery-platform example similarly treats a platform engaging an individual paid per delivery as responsible. The key task is to complete a prescribed check before the individual starts and keep the evidence. If the person has time-limited permission, plan the required follow-up. A checkbox where a worker promises that they are eligible, a photograph in an app profile or a customer rating is not one of the prescribed Home Office routes. Final guide, examples 3–4, direct-check section.

The platform needs a route-selection workflow. The final guide gives manual original-document, Home Office online and registered Right to Work Digital Verification Service provider routes. An eVisa holder generally uses the official online employer service; the employer must view the profile, match the person and work restrictions, and retain the dated output. Manual documents must be inspected and copied in the prescribed way; a video image of a physical passport is generally not enough. A registered RtW DVSP may perform eligible digital identity checks, but the platform must inspect and keep required output and remains responsible for the prescribed process. Where a check cannot be completed by those routes, the Employer Checking Service may be appropriate in specified cases. Final guide, pages 18–38; current Home Office checklist.

This check must relate to the actual individual who takes assignments. If a courier account is shared, a successful check on the account holder tells you little about the person delivering the next order. Identify how a person is onboarded, how an account is tied to that person, how substitutions are authorised and how the platform responds to a mismatch. Do not claim that face-recognition technology is legally mandatory in every situation; the final guide describes proportionate identity measures and specific requirements when that technology is used. Final guide, pages 52–56.

Model two: the platform matches a provider business to a customer

The final guidance gives an extended-liability example where an online matching service matches a service provider with a client, and the provider contracts with that client and separately engages individuals to deliver the work. The provider with the direct relationship to the worker retains the direct right to work check duty. The matching service may nevertheless need to establish a separate statutory excuse against extended civil-penalty liability through prescribed contractual and operating controls. That is not satisfied merely by telling suppliers to obey the law. Final guide, pages 44 and 48–52.

For in-scope matching arrangements, a written statement before work begins needs to set out terms requiring the provider's prescribed checks, prior written consent and equivalent obligations for further subcontracting, audit rights, enforcement action when illegal working is found without an excuse, and cooperation with a Home Office investigation. The platform must be able to show proportionate steps that the arrangements operate effectively. Supplier assurances may be part of that evidence if the platform reasonably satisfies itself that they are reliable. Contract text without an assurance process is weak. See the proposed extended-liability written-statement guide for that task; this link is an integration dependency until both proposed routes exist. Final guide, pages 49–52.

Some marketplaces may operate both models in different categories or customer groups. Classify each flow rather than setting one scheme-wide flag. A shift from individual providers to supplier companies can change the legal owner of the direct check and the evidence a platform needs. Version the model and contract terms so an auditor can see which arrangement applied to a particular assignment.

Model three: an independent business sells its own service

The final guide also describes work outside the scheme's direct-engagement model. An independent plumber advertising services to multiple customers and directly repairing a household tap is its own business; the homeowner does not carry out a prescribed right to work check. A client company buying a designer's project from the designer's own personal service company is another example where that client is not the direct statutory employer. These examples stop a simplistic rule that every marketplace customer must collect an immigration document. An intermediary may still alter the analysis; look at the actual contracts and control. Final guide, pages 15–16.

If your platform only lists independent service businesses, document why it is outside the specific matching or direct-engagement provision instead of marking the entire estate “exempt.” A future change to booking, payment, worker assignment or substitution could change the answer. Keep a review trigger for new categories and contract versions.

Build the platform workflow

1. Segment the supply models. List each service category and contract flow; identify direct individual engagements, provider-business matches and independent listings. Have legal, operations and product owners agree the classification before writing onboarding screens.

2. Attach the correct check owner. In a direct model, assign the prescribed check to the platform's accountable team before activation. In a provider-business model, document the provider's check responsibility and the platform's upstream assurance requirements. Avoid an interface that merely asks the worker to self-certify.

3. Block work until prerequisites are met. The exact pre-work gate depends on the model: a prescribed check and dated evidence for the direct individual, or the required written statement and effective contract/assurance controls in the extended-liability model. A pending document, unresolved identity mismatch or unapproved substitute should route to human review, not silently become “ready.”

4. Keep a worker-to-assignment trail. Record who was checked, by whom, through which prescribed route, on what date, what restrictions apply and which person completed each assignment. For supplier-managed labour, record the party supplying the person and how the platform has tested its assurance. Set appropriate access controls: the platform should not reflexively copy every passport if its legal role requires an assurance file rather than holding the direct employer's full check output.

5. Revisit changes. New subcontracting tiers, account sharing, substitute use, different countries of work or a platform acquiring a provider's business can change the classification. A UK right to work check does not govern work performed outside the UK, and a worker's permitted hours or role can affect a changed assignment.

The Home Office's final guide asks employers to give all prospective workers a reasonable opportunity to prove right to work through an available method and not discriminate on protected grounds. Design accessible alternatives to a biometric or app-only flow. The 1 October 2026 discrimination code is the relevant primary source. A registered DVSP route is an option in eligible circumstances, not a legal instruction that every platform must use face recognition.

A common operational example

Suppose a home-service app signs up individual cleaners, sets assignment rules and pays them per job. Its onboarding should identify each cleaner, perform the prescribed check before work and retain the correct record. If a cleaner's account allows someone else to take a booking, the platform needs a substitution and identity-control process; simply relying on the original cleaner's check would miss the person who arrives.

Now suppose the same app adds a category in which incorporated cleaning firms contract with customers and supply their own staff. The firm may be the direct checker. The app should examine whether it now falls within the online-matching extended-liability provision and, if so, ensure the required statement and assurance controls exist before the firm fulfils bookings. One app can therefore have two different legal and evidence workflows. The examples illustrate decision-making, not a legal ruling for a real platform.

Mistakes to avoid

• Calling every app a neutral marketplace without reading contracts and observing who engages and controls the worker.
• Assuming every customer of an independent business must check that business's staff.
• Treating a worker's self-declaration or uploaded image as a prescribed check.
• Letting an account holder lend access to a substitute who has not been checked.
• Failing to separate the direct employer's check from the platform's extended-liability assurance.
• Using a written statement that was not in place before work began, or never testing the promises it contains.
• Assuming an ordinary onboarding product or Complys is a registered RtW DVSP.
• Building a digital-only flow that leaves eligible applicants no reasonable alternative or handles groups inconsistently.

Where Complys fits

Complys Right to Work compliance software is a record and follow-up proposition for worker evidence, not a checking service. It does not inspect Home Office status, query share codes, act as a registered DVSP or decide whether a platform has a statutory excuse. A platform can assess whether Complys helps organise dated evidence and follow-up records within its verified implementation. It still needs its own legal classification, prescribed check or upstream statement, and real-world identity controls. Where a platform engages individuals directly, the adjacent individual-subcontractor check guide explains that task; this is a proposed integration link until the route is created.

Next step: choose one booking category, draw its customer–platform–provider–worker contracts and trace one real assignment from onboarding to completion. Identify the direct check owner and any extended-liability controls before promising the category is compliant.

Primary sources

• Home Office, final Employer's guide to right to work checks: 1 October 2026, especially scope examples 3–9, direct checks and section 3 on extended liability.
• Home Office, Employers' right to work checklist, 1 October 2026.
• Home Office, Code of practice on avoiding unlawful discrimination, 1 October 2026.

Reviewed 4 October 2026. General UK information; classification and statutory excuse depend on the specific contractual and operating facts.