Key takeaways
Digital ID scheme aims to streamline compliance
Employers can verify right-to-work status faster and securely.
Concerns remain over accessibility and data security
Businesses must balance efficiency with robust privacy safeguards.
Prepare for phased adoption and regulatory updates
Early engagement helps avoid disruption and compliance risks.
Introduction of the UK Digital ID scheme
The UK Government has announced proposals to roll out a new Digital ID scheme by 2029, aiming to simplifying access to public services and strengthen identity verification processes. As part of this initiative the use of Digital IDs will now become mandatory for employees starting a new role. This is known as the Right to Work checks. This marks a significant shift in how employers verify a British/Irish national’s legal right to work in the UK.
According to the Government, the Digital ID will be free, stored securely on individuals’ smartphones via a GOV.UK digital wallet and include core data such as name, date of birth, nationality and a photo. Officials say the system will reduce fraud and help tackle illegal working, particularly in the gig economy and informal labour market.
Despite these aims, the proposal has sparked widespread public concern. A petition opposing the Digital ID has gathered over 2.87 million signatures. Critics argue the scheme could pave the way for mass surveillance and digital control, disproportionately affecting vulnerable groups and those without access to smartphones.
In response, the Government has clarified that while the Digital ID will be mandatory for certain situations (i.e. employment checks), it will not be a criminal offence to be without one. Individuals will not be required to carry their ID at all times, and a public consultation will be held later this year to address concerns around digital exclusion and privacy.
As the UK moves toward a more digitised identity system, the debate continues over how to balance between efficiency and civil liberties. Whether the Digital ID will deliver on its promises or deepen public mistrust.
Beyond the immediate compliance implications, the introduction of mandatory Digital IDs represents more than just a procedural update, it signals a fundamental shift in how identity is managed in the UK labour market. For employers, this shift offers an opportunity to enhance compliance, prevent illegal working and improve operational efficiency. However, it also requires a proactive approach to digital readiness, ethical data handling and inclusive practices. Organisations must begin preparing now: reviewing onboarding systems and engaging with the upcoming public consultation supports both business needs and broader societal values.
Current Right to Work requirements in the UK
Under the Immigration, Asylum and Nationality Act 2006, employers are legally required to confirm that every employee has the right to work in the UK before new employment begins. This verification is based on an individual’s citizenship, immigration status, or visa conditions. Employers must retain appropriate documentation as evidence of compliance. Failure to conduct these checks correctly can result in civil penalties, reputational damage, and potential consequences for any sponsor licences held.
Currently, British and Irish citizens can demonstrate their right to work by providing one of the following:
A valid British or Irish passport or
An Irish passport card
If these documents are unavailable, alternate evidence may include (but not limited to):
A UK birth certificate and
A Government-issued document (e.g. HMRC letter) showing the individual’s National Insurance number
These documents must be checked and recorded by the employer prior to the start of UK employment manually or using an Identity Document Validation Technology or “IDVT” provided by a certified Identity Service Provider or “IDSP”. However, making digital IDs mandatory is a significant change to this current landscape.
Public consultation
The public consultation is scheduled for later this year to explore:
How individuals without smartphones (e.g. homeless individuals) can access their Digital ID;
Whether citizens and legal residents aged 13 and over (many of whom work part-time) should also be eligible; and
Whether additional personal details should be included in the Digital ID.
This represents a significant shift in how Right to Work checks are conducted and will replace current checks of physical passports. This shift aims to:
Reduce illegal working by eliminating document and identity fraud;
Improve access for legitimate employees; and
Streamline onboarding processes for employers.
Once implemented, the Digital ID will be mandatory for all employees to prove their Right to Work in the UK.
How can we help you?
As the landscape around Right to Work checks continues to evolve, we’re well placed to support you in staying compliant and prepared. We offer tailored Right to Work audits to assess current practices and identify any gaps, as well as training sessions for HR and recruitment teams on the best practices. Whether you’re looking to strengthen internal processes or prepare for upcoming changes like the Digital ID rollout, we can provide practical and hands-on guidance to help you navigate it confidently.
Contact details
If you have any questions on how these changes may affect you, please do not hesitate to contact us in the first instance.
