Impact assessment

Digital right to work and rent checks for British and Irish citizens: equality impact assessment, 30 June 2026

Published 30 June 2026

Section 1

Expanding digital options for demonstrating eligibility under the Right to Work and Right to Rent Schemes and mandating certification of digital identity verification provider providers (DVSP).

Expanding digital options

This Equality Impact Assessment (EIA) updates the assessment titled ‘Digital right to work and rent checks for British and Irish citizens: equality impact assessment’, completed 10 February 2022. The first iteration was produced on 2 November 2021 and subsequently updated on 10 February 2022. It was completed prior to the introduction of digital right to work and right to rent checks via DVSP providers for holders of a current valid British or Irish passport (including Irish passport cards).

This updated EIA considers only the equality impacts of the changes introduced under the Border, Security, Asylum and Immigration Act 2025, as implemented through updates to the right to work and right to rent checking routes (including use of independently certified and registered Digital Verification Services), secondary legislation and associated codes of practice. The EIA is not an assessment of wider government digital identity policy or programmes.

The changes seek to address current barriers faced by those who are unable to digitally prove their identity for the purposes of right to work or rent checks (particularly some British and Irish nationals) by allowing a broader set of documents and digital credentials to be verified, including through the services of certified DVSP. The intention is to:

• improve access to employment and housing
• give individuals a wider choice
• give individuals control of how they share their personal data
• accelerate onboarding times and
• support government objectives around digital transformation and fraud prevention.

The changes also support everyone involved in the process within evolving working practices such as hybrid or remote models, where face-to-face interaction and the handling of original documents are not always practical or secure. In these circumstances, secure digital checks can help individuals demonstrate eligibility without needing to travel or present physical documents in person, supporting more inclusive access to employment and housing.

Mandating certification

This EIA also considers the implications of mandating that where an employer or landlord (or their letting agent), hereafter referred to as a ‘relying party’, chooses to use a digital identity verification provider(DVSP)  to complete a prescribed digital check, they must use a provider who is registered on the Department for Science, Innovation and Technology (DSIT)/ Office of Digital Identity and Attributes (OfDIA) register to provide the relevant services to obtain a statutory excuse against a civil penalty under the Schemes.

Mandating certification ensures that relying parties have confidence that DVSP providers are independently certified and registered to recognised standards within legislative foundation in the Data Use and Access Act 2025 (DUAA25). It creates a more inclusive, secure, and efficient system for candidates, while ensuring that relying parties can continue to meet their legal obligations.

This EIA assesses the potential impacts of these changes on different groups and considers any risks or mitigations required to ensure fair and equitable access to employment and housing.

Current position

Under the Right to Work and Right to Rent Schemes (the Schemes), individuals currently demonstrate their eligibility to rent or undertake employment through prescribed routes. Relying parties must retain evidence of the check to establish a statutory excuse (defence) against liability for a civil penalty under the Schemes, where the individual is later found to be ineligible to rent or undertake employment by virtue of their immigration status. Since April 2022, a statutory excuse can be established where a prescribed digital identity verification (DVSP) check is completed on a current, valid British or Irish passport (including Irish passport cards) using identity verification technology via a provider. This is an alternative to manual checks. DSIT has supported the Schemes since 2022 through a certification system for DVSP providers, which has been enacted within the DUAA25.

Topic	What happens now	What changes are proposed
Ways to complete checks	Checks can be completed either by a manual document check or via the Home Office online service where the individual has an eVisa. Digital checks using a DVSP are currently limited to British/Irish citizens with a current, valid passport (Inc. Irish passport card).	A wider range of documents/digital credentials will be verified digitally (via DVSP), reducing barriers for those who cannot use the current passport-based digital route. This includes (where permitted) digital versions of acceptable documents verified as originating from a trusted government source and certain British/Irish passports (including Irish passport cards) up to six months after expiry.
Statutory excuse + certification	A statutory excuse is obtained by following the prescribed check routes. If a DVSP digital check is used, it currently provides a statutory excuse only for British/Irish citizens with a current valid passport (including Irish passport cards). Registration is not currently required when using a DVSP, but other prescribed requirements must still be met to obtain a statutory excuse.	Where a relying party chooses to use a DVSP for a prescribed digital check, use of a registered provider becomes mandatory to obtain a statutory excuse.

Section 2

Consideration of aim 1 of the duty: eliminate unlawful discrimination, harassment, victimisation, and any other conduct prohibited by the Equality Act 2010.

a. Direct discrimination

The changes introduced to expand digital identity options and mandate registration of DVSP providers applies equally to all individuals seeking to demonstrate eligibility for employment or rent under the Schemes. There is no evidence that the proposed changes would result in any person being treated less favourably than another on the basis of a protected characteristic (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, or marriage and civil partnership). Therefore, no direct discrimination arises.

b. Indirect discrimination

Age

The Right to Rent Scheme applies to all adults aged 18 and over who enter into a private tenancy agreement in England. This is because government issued guidance states that it is unlikely anyone under the age of 18 would be able to enter into a private rented tenancy agreement. The Right to Work Scheme only applies to people who are aged 16 and over.

In the UK 35–49-year-olds make up 34% of the employed population ^{[footnote 1]} and only 13% of the adult population in England and Wales overall ^{[footnote 2]}. This is therefore the primary age group affected by changes to the Right to Work Scheme, while individuals aged over 64 make up a smaller proportion of the working population and a larger proportion of the adult population overall ^{[footnote 3]}.

In relation to the private rented sector, younger age groups are more likely to be household reference persons, with 25–34‑year‑olds representing the largest group, followed by those aged 35–44 ^{[footnote 4]}.

While the changes introduced to the checking routes apply across age groups, digitalisation processes may create a risk of indirect discrimination where barriers to accessing or using digital systems disproportionately affect older age groups (for example, adults aged around 65 and over). In 2020, 82% of those aged over 16 who had not used the internet in the last three months were aged 65 and over ^{[footnote 5]}. Additionally, a review of five long-term studies from different countries found that over 20% of adults aged over 60 were digitally excluded in each area, including 30% of over 60s in England ^{[footnote 6]}. This may lead to less favourable outcomes compared to younger individuals who are generally more digitally confident.

The government recognises the importance of addressing digital exclusion among older age groups (for example, adults aged around 64 and over) and has a Digital Inclusion Action Plan, published in February 2025 ^{[footnote 7]}. The Plan sets out actions to support individuals who are digitally excluded by improving access to devices and connectivity, building digital skills and confidence, and providing locally delivered support.

Mitigation

To mitigate risks associated with digital exclusion, non‑digital prescribed routes remain available under both Schemes as an important safeguard and will be kept under review as the policy, technology and evidence base develop.

Individuals can continue to demonstrate eligibility through manual document‑based checks (where they apply) and through the Home Office online checking service (where relevant). This ensures that older individuals who cannot access or use digital services are not excluded from demonstrating their eligibility for employment or housing.

Separately, and where a digital route is chosen, expanding the range of documents and digital credentials that can be verified through a Digital Verification Service provider (DVSP) may reduce document‑related barriers for some individuals. Based on the 2021 Census, 77% of the usually resident population in England and Wales held a UK passport, 10% held a non-UK passport and 13% had no passport ^{[footnote 8]}. The intended changes include enabling digital versions of acceptable documents to be used where permitted (and verified as originating from a trusted government source) and allowing certain British or Irish passports (including Irish passport cards) expired by up to six months to be checked digitally by a certified DVSP. These changes may particularly benefit individuals who do not hold a current valid passport and help reduce barriers to accessing employment and housing where a digital route is chosen.

In addition to digital skills and access, some older individuals may face practical barriers to travelling to present physical documents in person, for example due to mobility or health‑related issues. In these circumstances, having secure digital options available (where chosen) may support access where face‑to‑face checks are difficult.

Use of a DVSP is not mandatory under either Scheme. Relying parties and individuals retain choice over how eligibility is demonstrated using the prescribed routes available to them. The department will continue to use stakeholder engagement and feedback to identify any emerging issues relating to age and to inform updates to guidance and mitigations where necessary.

The department recognises that digital identity and digital checking are the longer‑term direction of travel. However, at this stage the policy position is that use of a DVSP is optional and alternative prescribed routes remain available to prevent exclusion and support compliance.

Disability

Disabled people are represented within the populations affected by the Schemes. Disabled people make up around 24% of working‑age adults in the UK ^{[footnote 9]}, and approximately 18% of those in employment ^{[footnote 10]}. In the private rented sector, around 30% of households renting privately in England include at least one disabled person ^{[footnote 11]}.

There is evidence that disabled people are more likely to experience digital exclusion than non‑disabled individuals. In 2020, 59% of people aged over 16 who had not used the internet in the previous three months were disabled ^{[footnote 12]}. Digital products and services may also be less accessible for some disabled users, for example where disabilities affect vision ^{[footnote 13]} or learning ^{[footnote 14]}. The 2023 Consumer Digital Index found that 75% of disabled people in the UK have foundation level digital skills, compared to 90% of non-disabled people ^{[footnote 15]}. Where digital systems are difficult to access or navigate, this may result in less favourable outcomes compared to non‑disabled individuals.

The government recognises the importance of addressing digital exclusion for disabled individuals and has a Digital Inclusion Action Plan, published in February 2025 ^{[footnote 16]}. The Plan identifies disabled people as more likely to be impacted by the digital skills gap and accessibility challenges and sets out actions to improve access to devices and connectivity, build digital confidence and skills, and provide locally delivered support.

For some disabled individuals, barriers to using digital services may be further compounded by intersecting factors, such as affordability of devices or connectivity, low digital confidence, or reliance on support to engage with online services. Where these factors interact, digital routes may be harder to use in practice.

Mitigation

To mitigate risks associated with digital exclusion, use of a Digital Verification Service provider (DVSP) is not mandatory under either Scheme. Individuals and relying parties can continue to use the currently prescribed non‑digital routes, including manual document‑based checks (where they apply) and the Home Office online checking service (where relevant). This ensures that disabled individuals who face barriers to using digital services are not excluded from demonstrating their eligibility for employment or rent.

Separately, and where a digital route is chosen, the changes expand the range of documents and digital credentials that can be verified through a DVSP. This is intended to address a separate barrier, namely difficulties faced by individuals who cannot use the current passport‑based digital route. The intended changes include enabling digital versions of acceptable documents to be used where permitted (and verified as originating from a trusted government source) and allowing certain British or Irish passports (including Irish passport cards) expired by up to six months to be checked digitally by a certified DVSP. These changes may benefit individuals who do not hold a current valid passport and help reduce document‑related barriers to accessing employment and housing where a digital route is chosen.

In addition, some disabled individuals may face practical barriers to travelling to present physical documents or attending face‑to‑face checks, for example due to mobility or health‑related issues. In such circumstances, secure digital routes (where chosen) may reduce reliance on travel and support easier access to employment or housing.

In developing and refining these mitigations, the department will continue to have regard to the principles set out in the Government’s Digital Inclusion Action Plan, including the importance of retaining alternative routes, providing accessible support, and learning from stakeholder feedback to ensure that digital transformation does not disadvantage disabled individuals.

The department recognises that digital identity and digital checking are the longer‑term direction of travel. However, at this stage the policy position is that use of a DVSP is optional and alternative prescribed routes remain available to prevent exclusion and support compliance.

Race (this encompasses nationality, ethnicity, colour and national or ethnic origins)

The working population in England is diverse with 81% of the working age population in England and Wales white, 10% Asian, 4% black, 3% mixed and 2% identifies in some other way ^{[footnote 17]}. Proportions of the employed population and those renting privately are split similarly across ethnic groups ^{[footnote 18]}. ONS internet‑use data indicates that people who are offline are not confined to any one ethnic group and, in 2020, the majority of those who had not accessed the internet in the last three months were white ^{[footnote 19]}. This reflects that digital exclusion is a wider, population‑level issue.

However, the risk assessed here is not limited to whether someone is “offline”. Digitalisation processes may create a risk of indirect discrimination where barriers to accessing or using digital systems (for example limited English proficiency, low digital literacy, or lack of access to suitable devices or internet connectivity) affect some individuals within minoritised/ethnic minority communities. ONS analysis highlights that digital exclusion is not only about whether someone is “offline”, but also about digital skills and the ability to navigate services effectively ^{[footnote 20]}.  While overall internet use is high across ethnic groups, published analysis also indicates that internet use can vary by ethnicity ^{[footnote 21]}.

The government recognises these risks and has committed to addressing digital exclusion through its Digital Inclusion Action Plan, published in February 2025 ^{[footnote 22]}. The Plan sets out actions to address barriers such as limited digital skills, access to devices or connectivity, and confidence in using online services, with the aim of ensuring that individuals who are digitally excluded are supported to engage with digital services where appropriate.

Mitigation

To mitigate risks associated with digital exclusion, non‑digital prescribed routes remain available under both Schemes as an important safeguard, and will be kept under review as the policy, technology and evidence base develop. This will include manual document‑based checks (where they apply) and the Home Office online checking service (where relevant). This ensures that individuals who cannot access or use digital services (for example due to language, digital skills or connectivity barriers) are not excluded from demonstrating their eligibility for employment or housing.

Separately, and where a digital route is chosen, expanding the range of documents and digital credentials that can be verified through a DVSP may reduce document‑related barriers for individuals who cannot use the current passport‑based digital route (including some individuals within minoritised/ethnic minority communities). The intended changes include enabling digital versions of acceptable documents to be used where permitted (and verified as originating from a trusted government source) and allowing certain British or Irish passports (including Irish passport cards) expired by up to six months to be checked digitally by a registered DVSP. These changes could particularly benefit people who do not hold a current valid passport and help reduce barriers to accessing employment and housing where a digital route is chosen.

Use of facial matching (where relevant)

Facial matching is a digital (or manual) comparison of a person’s facial image against a stored reference image to help confirm the person’s identity. Under the Schemes, facial matching may be used only where a relying party chooses to use a prescribed DVSP to carry out a digital check, and only as part of the DVSP provider’s identity verification process in accordance with the relevant checking route.

Where a digital route is used, the reference image used for facial matching may include an image derived from the Home Office system (for example an eVisa), where permitted by the relevant route and legislation. However, the Schemes do not require the use of facial matching, and it is not used where eligibility is demonstrated using manual document‑based checks or the Home Office online checking service.

The department recognises that digital identity verification technologies (including facial matching) may, if not appropriately designed, tested and assured, perform less reliably for some individuals, for example where performance varies across certain protected characteristics (including race, sex or age). Where a relying party chooses to use a DVSP for the purposes of the Schemes, that DVSP must be independently assessed by a certified assessment body against the UK digital verification services trust framework (UKDVSTF). This includes requirements and recommendations relating to inclusion and bias, including to require that DVSP providers evidence compliance with the Equality Act 2010, or equivalent legislation in Northern Ireland, and to require that users be able to retake a check if they fail first time. Acting on behalf of the Secretary of State, the Office for Digital Identities and Attributes (OfDIA) monitor the inclusivity of DVSP that are certified against the trust framework and publishes aggregated findings.

Additionally, use of a DVSP is not mandatory under either Scheme. Individuals retain choice over how they demonstrate eligibility for employment or rent using the prescribed routes available to them. The department will continue to use stakeholder engagement and feedback to identify any emerging issues and to inform updates to guidance and mitigations as needed.

The department recognises that digital identity and digital checking are the longer‑term direction of travel; however, at this stage the policy position is that use of a DVSP is optional and alternative prescribed routes remain available to prevent exclusion and support compliance.

Other Characteristics

Gender reassignment

Where a facial matching process is used as part of a prescribed DVSP route, there is a risk that performance may be affected where an individual’s appearance has changed significantly (for example due to gender reassignment or medical treatment). Facial matching is only used where a relying party chooses to use a DVSP and use of a DVSP is not mandatory under the Schemes. Individuals can continue to demonstrate their eligibility using alternative prescribed routes, including non‑digital checks, where a digital route is not appropriate or does not work for them. Where a DVSP route is used, providers are independently assessed against the UK digital verification services trust framework (UKDVSTF), which includes requirements and recommendations relating to inclusion and bias, including to require that DVSP providers evidence compliance with the Equality Act 2010, or equivalent legislation in Northern Ireland, and to require that users should be able to retake a check if they fail first time or use other available checking routes. Acting on behalf of the Secretary of State, in relation to digital identity verification, the Office for Digital Identities and Attributes (OfDIA) monitor the inclusivity of certified services.

Pregnancy and maternity

No evidence has been identified to suggest that the changes would result in less favourable treatment for individuals who are pregnant or have given birth. The Schemes do not introduce requirements that would disadvantage individuals on the basis of pregnancy or maternity, and non-digital routes remain available under both Schemes as an important safeguard, and will be kept under review as the policy, technology and evidence base develop. Where digital checking routes are used, use of a DVSP is not mandatory, and individuals can continue to demonstrate their eligibility using alternative prescribed routes, including non‑digital checks, where a digital route is not appropriate or does not work for them. This ensures that individuals who may require flexibility or support during pregnancy or maternity are not excluded from demonstrating their eligibility for employment or housing.

Religion or belief

No evidence has been identified to suggest that the changes would result in less favourable treatment on the basis of religion or belief. The Schemes do not require the use of any specific technology, process or checking route that would conflict with religious observance or beliefs. Where digital checking routes are used, use of a DVSP is not mandatory and individuals can continue to demonstrate their eligibility using alternative prescribed routes, including non‑digital checks, where a digital route is not appropriate or does not work for them. This ensures that individuals are not required to engage with digital identity verification methods that may conflict with their religious beliefs or practices.

Sex

No evidence has been identified to suggest that the changes would result in less favourable treatment on the basis of sex. The Schemes do not introduce requirements that differentiate between individuals on this basis, and the prescribed checking routes apply equally regardless of sex. Where digital checking routes are used, use of a DVSP is not mandatory and individuals can continue to demonstrate their eligibility using alternative prescribed routes, including non‑digital checks, where a digital route is not appropriate or does not work for them. This ensures that individuals are not disadvantaged on the basis of sex in how they are required to demonstrate eligibility for employment or housing.

Sexual orientation

No evidence has been identified to suggest that the changes would result in less favourable treatment on the basis of sexual orientation. The Schemes do not introduce requirements that distinguish between individuals on this basis, and the prescribed checking routes apply neutrally regardless of sexual orientation. Where digital checking routes are used, use of a DVSP is not mandatory, and individuals can continue to demonstrate their eligibility using alternative prescribed routes, including non‑digital checks, where a digital route is not appropriate or does not work for them. This ensures that individuals are not disadvantaged on the basis of sexual orientation in how they are required to demonstrate eligibility for employment or housing.

Marriage and civil partnership

No evidence has been identified to suggest that the changes would result in less favourable treatment on the basis of marriage or civil partnership. The Schemes do not introduce requirements that differentiate between individuals on this basis, and eligibility checks are not linked to marital or civil partnership status. Where digital checking routes are used, use of a DVSP is not mandatory and individuals can continue to demonstrate their eligibility using alternative prescribed routes, including non‑digital checks, where a digital route is not appropriate or does not work for them. This ensures that individuals are not disadvantaged on the basis of marriage or civil partnership in how they are required to demonstrate eligibility for employment or housing.

Ongoing monitoring and review

The department will continue to use stakeholder engagement and feedback to identify any emerging issues affecting these protected groups and will update guidance and mitigations where necessary to ensure that individuals are not disadvantaged in how they demonstrate eligibility for employment or housing.

Legitimate Aim

Notwithstanding the particular disadvantages identified above for older people, disabled individuals and some individuals within minoritised/ethnic minority communities, it is considered that the proposed changes are justified and proportionate in pursuit of the department’s legitimate aim to strengthen the integrity and efficiency of right to work and right to rent checks, while supporting secure digital innovation and reducing fraud.

This conclusion draws on the evidence and analysis set out in the preceding sections of this EIA (including the evidence on age, disability and race), which identifies where barriers may arise for some protected groups and the safeguards within the checking framework intended to mitigate those risks.

The changes seek to enable more secure and streamlined identity verification through digital services, which aligns with broader government objectives around digital transformation and fraud prevention. However, the department recognises that digitalisation may present barriers for some protected groups where individuals face access barriers (for example, limited digital skills or confidence, language barriers, disability‑related accessibility needs, or lack of suitable devices or connectivity).

To ensure the changes remain proportionate, the following mitigations have been built into the design:

• Existing prescribed routes remain available under both Schemes as an important safeguard and will be kept under review as the policy, technology and evidence base develop. Individuals will continue to be able to demonstrate eligibility through the currently prescribed routes, including manual document‑based checks (where they apply) and Home Office online checking services (where relevant). This helps ensures individuals are not excluded from demonstrating eligibility if a digital route is not accessible or does not work for them.
• Use of a DVSP remains optional. The changes do not mandate that relying parties or individuals use a DVSP. Relying parties can continue to rely on manual checks of physical documents (where permitted) and other prescribed routes, depending on the individual’s circumstances.
• Expanded range of acceptable documents and digital credentials that can be checked through a DVSP. This may reduce document‑related barriers for individuals who cannot use the current passport‑based digital route, particularly those who do not hold a current valid passport, where a digital route is chosen. Digital options may reduce document‑related barriers where a digital route is chosen.
• Clear anti‑discrimination guidance is in place. The department has produced statutory codes of practice on avoiding unlawful discrimination for both Schemes, which set out how employers and landlords should apply checking processes fairly and consistently (including when using digital routes) and signpost where further help can be found.
• Accessible guidance formats support understanding and compliance. Accessible formats are already available, including an Easy Read version of the Landlords guide to right to rent checks and a Welsh‑language version of the Employers’ guide to right to work checks. These support users with different communication needs and improve accessibility.

Taken together, these mitigations are designed to directly address the risks identified earlier in this assessment and ensure that the policy remains proportionate while pursuing the department’s legitimate aims. The department will continue to monitor the impact of these changes, including through stakeholder engagement and feedback mechanisms. The department will also use what it learns to review the policy periodically and where necessary, adjust guidance, operational processes and support measures to ensure the approach remains fair, inclusive and effective.

Section 3

Consideration of aim 2 of the duty: Advancing equality of opportunity between people who share a protected characteristic and people who do not share it

The changes introduced are not designed as a positive action measure. However, by maintaining the current prescribed checks alongside digital checks, and expanding the range of acceptable documents that can be verified digitally where a digital route is chosen, they are expected to reduce practical barriers for some groups and support equality of opportunity. In particular, the continued availability of manual checks helps ensure people who face barriers to using digital services (for example due to disability, limited digital literacy or language barriers) are not excluded, while the expanded document options may assist those who do not hold a valid passport/passport card.

In particular:

• The changes do not mandate the use of a DVSP, and the continued availability of the currently prescribed manual and non‑digital routes ensures individuals who face barriers to using digital services are not excluded from demonstrating eligibility.
• The expansion of documents, such as the use of expired (up to six months) British and Irish passports (including Irish passport cards) and other digital credentials supports individuals who do not hold passports or cannot afford to buy a new passport which may include some individuals from minority ethnic backgrounds.
• The department will promote support and guidance, including accessible formats and assistance for users who may struggle with digital systems. An easy read guide of the documents used for right to rent checks-for landlords and tenants is already available to support users with learning disabilities, lower reading ability and limited English and has proved helpful in improving understanding and accessibility. A Welsh language version of the Employers guide to right to work checks has also been published to support Welsh speakers. These resources help to ensure that different individuals with different communication needs can access and understand their responsibilities and rights under the Schemes.
• The department is committed to ongoing stakeholder engagement to ensure that the Schemes remain inclusive and responsive to the needs of all users, including those from protected groups. Engagement with Digital Verification Services (DVSP) group, Employers Consultation group with the Home Office (ECHO) and the Landlords Consultancy Panel (LCP) group has helped identify barriers to digital access and inform the development of mitigations such as manual checks, expanded document and digital options and accessible guidance formats. The department will continue to work collaboratively with stakeholders to monitor the impact of digital processes, identify issues and promote equality of access and opportunity. This includes exploring further improvements to accessibility such as translated material and assisted inclusive digital support.

These measures are intended to minimise disadvantage and ensure that individuals from protected groups are not prevented from participating fully in employment or accessing housing. While the changes do not actively encourage participation in public life, it is designed to avoid creating new barriers and to maintain inclusive access for all eligible individuals.

Section 4

Consideration of aim 3 of the duty: Fostering good relations between people who share a protected characteristic and persons who do not share it

The changes introduced are not expected to negatively impact relations between individuals who share protected characteristics and those who do not. The policy applies equally to all relevant individuals, including British and Irish citizens, and does not single out or favour any particular group. However, there is a risk that some individuals, particularly those who are digitally excluded due to age, disability, language barriers, or race, may perceive the increasing use of digital systems as exclusionary or as favouring more digitally literate groups.

To mitigate this, the department has retained the currently available prescribed checks at this time and expanded the range of acceptable documents that can be varied digitally where a digital route is chosen, ensuring that individuals who face barriers to digital access are not disadvantaged. The availability of accessible formats, such as an easy read guide of the documents used for right to rent checks for landlords and tenants and the Welsh language version of the Employers guide to right to work checks, promotes understanding and helps build trust in the system.

Ongoing stakeholder engagement will continue to play a key role in identifying and addressing concerns, ensuring that the policy is implemented in a way that is inclusive and sensitive to the needs of all communities. By maintaining flexibility, offering choice in how eligibility can be demonstrated, and promoting inclusive practices, the department aims to foster confidence in the Schemes and support positive relations between different groups.

Section 5

Ongoing compliance with the PSED

To ensure ongoing compliance with the Public Sector Equality Duty, the department will monitor the impact of the changes introduced to the Schemes on individuals with protected characteristics.

This will include:

• Monitoring impacts through stakeholder forums (ECHO, LCP and DVSP), user feedback/complaints, and operational insights from the Schemes. This will enable us to consider whether guidance or processes need updating in response.
• Monitoring for unforeseen discrimination: We will gather feedback from stakeholders, including relying parties and DVSP providers to identify any instances of direct or indirect discrimination that may arise in practice, particularly in relation to digital exclusion.
• Working with stakeholders and community projects: We will collaborate with stakeholders who are currently involved in projects supporting digital identity. This engagement will help us better understand the needs of specific cohorts such as disabled users, ethnic minorities and older individuals and identify ways in which we can practically support them through the Schemes to improve accessibility to proving their right to work and rent digitally.
• Fostering good relations: We will monitor public and stakeholder perceptions of the policy to ensure it does not contribute to division or misunderstanding between groups and that it continues to promote inclusive access.
• Advancing equality of opportunity: We will assess whether the mitigations such as manual checks, expanded acceptable documents that can be verified digitally, where a digital route is chosen and accessible guidance are effective in enabling individuals from protected groups to participate fully in employment and housing.
• Data collection: We will continue to gather data including feedback from stakeholder engagement forums (ECHO, LCP and DVSP groups) and any complaints or queries received through official channels. Where feasible, we will seek to understand the protected characteristics of individuals affected by the policy, particularly those who experience difficulties accessing digital services.

The policy will be expected to be reviewed 12 months after implementation to assess its impact and effectiveness. This review will inform any necessary adjustments to guidance, operational processes, or support measures to ensure the policy continues to meet its aims in a fair and inclusive manner. As part of the 12‑month review, we will assess whether the mitigations (including the availability of alternative prescribed routes and accessible support) remain appropriate and proportionate as digital uptake and technology evolve.

Section 6

Section 55 duty (for immigration, asylum, and nationality considerations only)

The department has considered its duty under Section 55 of the Borders, Citizenship and Immigration Act 2009 to safeguard and promote the welfare of children in the UK.

The changes introduced relate to identity verification under the Schemes. Right to Work checks apply to individuals aged 16 and over, so 16 and 17-year-olds may be directly affected where they need to demonstrate their eligibility for employment and use one of the prescribed checking routes. The changes do not otherwise directly apply to children. However, we recognise that children may be indirectly affected if their parents or guardians face barriers to accessing employment or housing due to digital exclusion.

For example, if a parent is unable to demonstrate their right to work or rent because they cannot access digital services or do not possess the required identity documents, this could impact the family’s financial stability or housing security, which in turn may affect the welfare of any children in the household.

To mitigate this risk, the department has retained manual document checks and the availability of non‑digital prescribed routes and is expanding the range of acceptable documents that can be verified digitally where a digital route is chosen such as expired (up to 6 months) British and Irish passports (including Irish passport cards). These measures are intended to ensure that individuals who face digital barriers are not excluded from demonstrating their eligibility, thereby helping to safeguard the welfare of children indirectly affected by the policy.

The department will continue to consider the Section 55 duty in any future policy development or operational decisions that may affect families with children.

Section 7

Risks to vulnerable individuals and other groups

The department has considered whether the proposed changes to the Schemes could create or exacerbate risks for vulnerable individuals or groups beyond those covered by the nine protected characteristics under the Equality Act 2010. There is a risk that individuals who are digitally excluded, including those experiencing poverty, social isolation or limited access to technology may face barriers to demonstrating their eligibility for employment or housing.

These barriers could, in turn, increase vulnerability by limiting access to employment or secure accommodation, potentially leading to financial hardship or housing instability. Individuals with limited literacy, mental health challenges or those in precarious living situations may also be disproportionately affected. To mitigate these risks, the department has retained the currently prescribed checks and expanded the range of acceptable documents and digital credentials, ensuring that individuals who cannot access digital services are not excluded. The department is also engaging with community organisations and stakeholders working with vulnerable groups to identify further support needs and co-develop inclusive solutions.

Section 8

Declaration and sign off

I have read the available evidence, and I am satisfied that this demonstrates compliance, where relevant, with section 149 of the Equality Act 2010 and that due regard has been had to the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relations.

This EIA will be reviewed on: 07/05/2026

SCS Name & Title: Rebecca Nugent

Directorate/Unit: Access, Compliance, Removals and Enforcement

Lead contact: Right to Rent team

Date: June 2026

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12. Internet users, 2020, Table 1a: Recent and lapsed internet users and internet non-users, UK, 2013 to 2020, Office for National Statistics, 2021 ↩

13. The accessibility of digital technologies for people with visual impairment and blindness: a scoping review, Discover Computing, Volume 27, Article 24, Hamideh Kerdah, Bachler & Kirchhoff, 2024 ↩

14. Digital inclusion and participation of people with intellectual disabilities during COVID‐19: A rapid review and international bricolage, Journal of Policy and Practice in Intellectual Disabilities, Volume 19, Issue 3, pages 242-256, Chadwick et al, 2022 ↩

15. Consumer Digital Index, Spotlight: those with an impairment, Lloyds Bank, 2023 ↩

16. Digital Inclusion Action Plan: First Steps ↩

17. Working age population, Ethnicity facts and figures, 2025 ↩

18. Renting from a private landlord, Ethnicity facts and figures, 2025 ↩

19. Internet users, 2020, Table 4a: Recent and lapsed internet users and internet non-users by ethnicity, UK, 2013 to 2020, Office for National Statistics, 2021 ↩

20. Exploring the UK’s digital divide, Office for National Statistics, 2019 ↩

21. Internet users, 2020, Table 4a: Recent and lapsed internet users and internet non-users by ethnicity, UK, 2013 to 2020, Office for National Statistics, 2021 ↩

22. Digital Inclusion Action Plan: First Steps ↩