Closed consultation

Extending the Right to Work Scheme to other working arrangements: consultation questions (accessible version)

Published 29 October 2025

Questions

Do not provide personal data when responding to free-text survey questions. Any personal data included will be removed prior to analysis of these responses and will not be considered in the consultation outcome.

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About You

1. In what capacity are you replying?

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• In a personal capacity
• As an employer
• As a representative of employers
• As a representative of employees
• Other (please specify): Please type your response here

2. If you are a representative of employers or employees, who do you represent?

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• A trade union
• An industry or employer association
• Other (please specify): Please type your response here

3. Which sector do you work for or represent?

The ‘gig economy’ is defined as: where employers and employees exchange money for labour on a per task basis usually via digital platforms that link workers with short-term tasks. 

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• Private sector
• Public sector
• Charity or volunteering
• Gig economy
• Other (please specify): Please type your response here

4. How many people work for your organisation?

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• Micro business (0-9 employees)
• Small business (10-49 employees)
• Medium business (50-249 employees)
• Large business (250+ employees)
• Not applicable (not a business)

5. Which of the following types of workers does your business currently use?

A sub-contractor is a person who has agreed to carry out operations for a contractor by themselves individually, or by their employees or own sub-contractors.

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• Individuals under a contract of employment
• Self-employed individuals
• Freelancers
• Agency workers
• Individuals on zero-hours contracts
• Individual sub-contractors

6. Does your business match service providers to customers? This could be a website or online platform that provides details of service providers to customers.

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• Yes
• No
• Not applicable

7. Do you think the change in legislation will mean your business model will now be brought into scope of right to work checks?

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• Yes
• No
• Not applicable

8. Would your business need to invest in new systems, training, or staff to comply with the expanded requirements?

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• Yes
• No
• Not applicable

9. Do you believe the change in legislation will help to reduce illegal working in your industry?

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• Yes
• No
• Not applicable

Right to Work checks

10. Do you already undertake Right to Work checks as part of your onboarding process?

Select one answer from below

• Yes, I undertake checks on my employees only
• Yes, I undertake checks on employees and other types of workers that I use
• No, checks not undertaken as not required
• No, not aware of legal requirement prior to this point
• Not applicable as not a business

11. Do you conduct right to work checks for any of the following individuals?

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• Self-employed individuals working for your business
• Freelancers
• Service providers who you match with customers
• Sub-contractors
• Substitutes

12. Who conducts right to work checks for your business?

Digital Verification Service (DVS) is a service that enables people to digitally prove who they are, information about themselves or their eligibility to do something. Digital verification services can be used by employers to conduct digital right to work checks on holders of valid British and Irish passports (or Irish passport cards).

The term DVS is also used to describe Identity Service Providers (IDSPs) and Identity Document Validation Technology (IDVT). 

IDVT are forms of technology operated for the purpose of verifying the identity of a person, where a digital copy of a physical document relating to that person is produced for verification of the document’s validity, and where that person is the rightful holder of the document. The Home Office previously published guidance on the use of IDVT for this purpose. 

An IDSP is a provider of identity verification services using IDVT. 

 Delete those which do not apply

• The business owner, Director or other partner
• Human Resources team, or other specific internal team
• Line managers
• Regional / site managers
• External recruitment or staffing agencies
• Licensing Authority
• Home Office.
• HMRC
• Digital Verification Service (DVS)
• Don’t know
• Other (please specify): please type your response here

13. If applicable, what challenges would your business face in carrying out right to work checks?

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14. How many right to work checks did you conduct in 2024?

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15. How many right to work checks did you conduct from 1 January to 31 August 2025?

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16. Where do you go for guidance and support to carry out right to work checks?

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• Employer’s Guide to Right to Work checks.
• Illegal Working Penalties: Codes of Practice for Employers
• Internal guidance / policy
• Do not know / do not use the guidance

17. What additional support or guidance would help you comply with the extended requirements?

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18. Do you think sufficient guidance / advice / support is available to ensure you are able to conduct right to work checks currently?

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19. How long does a right to work check take your organisation to complete on average?

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20. What type of right to work check do you use the most?

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• A manual check of original, acceptable documents
• A check using a DVS
• A Home Office online check

21. Do you use a DVS for right to work or onboarding checks?

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22. Does a DVS provide any benefits to onboarding of employees?

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23. How much does a DVS check cost your organisation per employee / worker?

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24. Are there further services that the DVS provides, that support your business’s right to work checks?

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25. Will the change in legislation require your business to conduct right to work checks in circumstances not previously required?

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26. How do you ensure that you establish or retain a statutory excuse?

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27. Do you agree that the Home Office should determine liability within a supply chain or where there is a chain of contracts for the provision of work or services, by focusing on the point of failure that has allowed illegal working to take place?

Please share your views on:

• what impact this would have on your business?
• how you ensure that individuals working in your supply chain or providing work or services in your name via another business have the right to work in the UK?
• what steps you already take to ensure compliance where you are the primary contractor or the sub-contractor in a supply chain?

Please type your response here

Equality

28. What, if any, unintended consequences or unfair impacts do you think this change in legislation could have on particular businesses or groups of workers?

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