On 26 September 2025 the government announced plans to introduce a digital identity card for all UK citizens and legal residents. The credential will be free of charge, stored in a GOV.UK digital wallet on a smartphone, and will hold core details such as name, date of birth and residency/immigration status. It will be available to everyone aged 16 and over by the end of this Parliament.
At that point, the government intends to make the digital ID mandatory for all right-to-work checks. Employers will be required to use it when onboarding new staff and when carrying out follow-up checks. The stated aim is to remove the prospect of unlawful employment for individuals without the right to work and to deter irregular migration.
According to the Home Office:
For now, nothing changes. Employers must continue to follow existing right-to-work requirements: checking original documents, or for non-British/Irish citizens with digital status, using the online share-code service. Civil penalties for non-compliance remain up to £60,000 per illegal worker.
Looking ahead, key points for employers to note are:
Future compliance model: By the end of this Parliament, employers will no longer be able to rely on multiple forms of documentation. A digital ID will become the single route for proving right to work.
Potential cost savings: Employers who currently use paid identity verification providers for British and Irish passport holders may see efficiencies if the government system becomes the default, though details on implementation are still awaited.
Greater oversight: With the Home Office able to track in real time whether checks have been conducted, employers should expect closer scrutiny of compliance.
Minimal disruption for the compliant: For employers who already carry out checks correctly, the main change will be the way checks are undertaken rather than the obligation itself.
Next steps
The digital ID scheme is not yet in force. A public consultation will be launched before legislation is introduced, and details of how employers will access the system are still to be clarified. In the meantime, businesses should maintain existing processes and ensure their right-to-work checks are fully compliant.
We will continue to monitor developments and provide updates as further detail emerges.
If you would like to discuss these proposals further or need help ensuring compliance, please get in touch with our immigration team here.
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