Immigration

United Kingdom | New updates to right to work checks and acceptable documents

Summary

The Home Office has published its latest updates to the Employer’s Guide to Right to Work Checks on 12 February 2025. Key updates include the decommissioning of biometric cards (including Biometric Residence Permits and Cards) and other physical documents. There has also been an update to the acceptable documents list in Annex A and an update to the Ukraine schemes.

The detail

Changes to Biometric Cards

End of BRPs as an Acceptable Document

• Transition to Digital Right to Work Checks: A key update is the decommissioning of the Biometric Residence Permit (BRP) and similar physical immigration cards as acceptable documents for right to work checks. BRPs were previously used by foreign nationals as proof of their right to work in the UK but they all expired on or before 31 December 2024. 
• eVisa Process: Employees who previously relied on a BRP for proving their right to work must now use the online system to generate a share code which verifies their immigration status and provides evidence of their right to work. This share code is entered by the employer into the UKVI’s online system to verify a worker’s status.

Please note that previous valid checks on file will remain valid and do not need to be completed again.

Changes to Acceptable Documents List

New Acceptable Documents: A few documents have been added or clarified in the list of acceptable documents for right to work checks:

• Birth Certificates: Confirmation that either short or long form birth certificate is considered an acceptable document for British and Irish nationals when combined with official evidence of a National Insurance number for a right to work check to be valid.
• Removal of Clipped Passports: The updated guidance specifies that clipped British or Irish passports are no longer acceptable for right to work checks, as these are now considered invalid for work verification purposes.

Please note that previous valid checks on file will remain valid and do not need to be completed again.

Changes to the Ukraine Refugee Scheme

Ukraine Refugee Scheme and Right to Work

• Eligibility for Work: Ukrainian nationals under the Ukraine Refugee Scheme, who are granted temporary protection status, are permitted to work in the UK. However, as the scheme is not indefinite, employers must conduct repeat right to work checks to verify their eligibility as the expiry date of their status approaches.
• Digital Right to Work Verification for Ukrainians: Similar to other foreign nationals, Ukrainian nationals under the scheme must use the Home Office’s online status checking system to verify their right to work. This reduces reliance on physical documents such as a Biometric Residence Permit (BRP), which may have been issued to Ukrainian nationals.

Removal of the section referring to COVID-19 Temporary Adjustments

Return to Pre-Pandemic Procedures

• End of Remote Checks: During the COVID-19 pandemic, temporary measures allowed employers to conduct right to work checks remotely, using video calls and accepting scanned copies of documents. However, these temporary measures were lifted as of 30 September 2022 and have now been removed from the guidance.
• Reinstatement of In-Person Checks: Since 30 September 2022, employers are required to return to in-person checks for right to work, or, where applicable, to use the online system for verification. Employers can no longer rely on scanned copies, photos, or virtual meetings to verify right to work.

Please note that previous valid checks on file will remain valid and do not need to be completed again.

Actions for employers

Employers must ensure they are fully compliant with the current right to work verification process, using online systems where appropriate and conducting in-person checks for physical documents. Follow-up checks must continue for employees on time-limited visas or temporary protection statuses, such as those under the Ukraine Refugee Scheme. Employers will need to ensure their HR teams are familiar with the digital verification process for both UK citizens and foreign nationals to avoid non-compliance.

Some reminders for employers going forward:

• Stop accepting BRPs/BRCs as right to work evidence; use eVisas instead.
• Train HR teams on the new document rules (e.g., clipped passports no longer valid).
• Update internal policies on record retention, ID verification, and employer compliance (including imposter checks).
• Ensure digital compliance with Home Office online right to work checks for non-British/Irish workers.
• If using an ID Service Provider, confirm they meet the Home Office’s Medium Level of Confidence (LoC).

Contact us

For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:

Lyudmyla Davies  
Partner (Solicitor)

Ian Robinson  
Partner 

Andrea Als  
Director (Solicitor)

Tom Marsom
Director (Solicitor)

Lucy Vaux
Senior Manager (Solicitor)

Want to know when a Regional Alert is posted?

Simply follow our Vialto Alerts page on LinkedIn and posts will be displayed on your feed. To ensure you don’t miss one, once you’re on our LinkedIn page, click on the bell icon under the banner image to manage your notifications.

Further information on Vialto Partners can be found here: www.vialtopartners.com

Vialto Partners (“Vialto”) refers to wholly owned subsidiaries of CD&R Galaxy UK OpCo Limited as well as the other members of the Vialto Partners global network. The information contained in this document is for general guidance on matters of interest only. Vialto is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information is provided “as is”, with no guarantee of completeness, accuracy, timeliness or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose. In no event will Vialto, its related entities, or the agents or employees thereof be liable to you or anyone else for any decision made or action taken in reliance on the information in this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

© 2025 Vialto Partners. All rights reserved.