Digital ID plans revised – what has changed
The government has now stepped back from its earlier position that workers would be required to sign up to a mandatory digital ID in order to work in the UK. While ministers initially framed digital ID as a hard requirement for employment, the revised position draws a clear distinction between digital right to work checks and individual participation in a standalone digital ID scheme.
The current position is that digital right to work checks will become mandatory over time, with full digitalisation expected by 2029, but individuals will not be required to enrol in a national digital ID programme. Registration for digital ID will be optional. A consultation on the design and operation of digital IDs is expected shortly and will shape how the system is ultimately delivered.
For employers, this clarification matters. The obligation to carry out compliant right to work checks remains firmly in place. What has shifted is the government’s ambition to make a single digital ID credential compulsory for workers themselves.
Digital ID proposals for right to work – updated position
The government continues to develop a national digital identity framework built around GOV.UK One Login and the proposed GOV.UK Wallet. The wallet is intended to allow individuals to store verified identity credentials digitally, potentially including proof of nationality or immigration status.
Earlier statements suggested that digital IDs would become the authoritative and mandatory proof for right to work checks by the end of the current Parliament. That position has now been softened. While digital checks will still become mandatory for employers, individuals will not be compelled to register for a digital ID as a condition of working.
Right to rent has not been confirmed as part of the initial rollout. Ministers have indicated that tenancy checks remain under review, but any extension into right to rent would be subject to further consultation and legislative change.
The upcoming consultation is expected to focus on how digital IDs operate in practice rather than whether they are compulsory. Likely areas of focus include the scope of information held, how the GOV.UK wallet functions, how digitally excluded individuals are accommodated and how any wallet-based system interacts with existing share code processes.
What has not changed for employers
Despite the political shift, the legal position for employers is unchanged.
Right to work checks are already predominantly digital. Employers are required to use online checks where a worker holds digital immigration status, relying on share codes and the Home Office portal. Physical document checks are already restricted, and expired biometric residence permits cannot be used as evidence.
The Home Office has reiterated that mandatory digital right to work checks remain a policy commitment. The criticism it has levelled at the current system, fragmented processes, weak audit trails and scope for abuse, continues to drive enforcement strategy.
Dropping mandatory digital ID registration does not dilute enforcement. Employers remain exposed to civil penalties of up to £45,000 per illegal worker for a first breach, rising to £60,000 for repeat breaches. The statutory excuse still depends entirely on whether the check is carried out in the prescribed way and evidence is retained.
Implications for right to work processes
A single, fully digital checking environment still appears to be the aim. What is changing is the route through which that environment is accessed.
Rather than a single compulsory wallet credential replacing all other methods, employers should expect a period where multiple digital routes coexist. Share codes will remain central for non-British and non-Irish workers. IDSP checks for British and Irish passport holders continue to be permitted. Any future wallet-based credential is likely to sit alongside these processes before becoming dominant.
Employers should plan on managing overlap, not replacement. That means ensuring onboarding processes can flex between share codes, IDSP outputs and any future wallet credentials without creating gaps in evidence or inconsistency in record keeping.
DMS Perspective
The most important point for employers is that liability has not changed or moved. Digital ID was never going to transfer risk away from organisations, and the revised position confirms that reality. Whether a worker chooses to hold a digital ID is irrelevant to the employer’s exposure. What matters is whether the right check is done, at the right time, using the right method.
There is a temptation to see the shift away from mandatory digital ID as a pause or softening. That would be a mistake. Enforcement is intensifying, not easing. Digitalisation increases traceability, and traceability cuts both ways. Employers with weak processes are more visible, not less.
The real strategic opportunity lies in using the consultation window as preparation time. Employers who continue to rely on informal checks, inconsistent storage or poorly trained teams will carry those risks straight into the next system. Employers who take this period to standardise processes, audit evidence trails and train HR teams will be far better placed when digital-only checks become the norm.
Digital ID may now be optional for workers. Digital compliance is not optional for employers. The organisations that treat this as a systems and governance issue, rather than a political headline, will be the ones that reduce risk rather than absorb it.
Need Assistance?
The rules on right to work remain unchanged and employers should continue to follow the employer guidance and retain evidence in the prescribed way. With digital checks becoming universal over the coming years, now is the right time to stress-test processes, review onboarding workflows and prepare for further change.
For advice on right to work compliance, audit preparation or future-proofing your systems for digital checks, speak to our compliance specialists. We can help you assess risk, train teams and ensure your organisation is ready for what comes next.
