Background
From 1st September 2021 onwards, the COVID-19 “adjusted” right to work check procedures (whereby employers could check right to work by reviewing scanned documents and verifying these over video call) will end. This means that, from 1st September 2021, employers will need to resume standard procedures (by either requesting, reviewing, copying and checking an individual’s original documents in person or by video call or by using the Home Office’s online right to work check service). A relief to many employers will be the news that it will not be required to conduct retrospective right to work checks for individuals where the COVID-19 adjusted procedure was used between 30th March 2020 and 31st August 2021.
Forward planning
Employers can use the COVID-19 “adjusted” right to work check process until COB 31st August 2021 but they should start planning now to accommodate the return to standard right to work check procedures thereafter, bearing in mind how and when/if offices may be re-opening or whether remote working will continue to some extent.
It would also be worthwhile using this time to review your records and keep a database of all individuals for whom the COVID-19 adjusted right to work check procedures were used and, in so doing, you can review whether all such checks were properly conducted and identify any gaps that need rectifying.
We are available to offer our clients UK immigration compliance advice in this regard.
