How to do it
- Check the worker's right to work before their first clinical or non-clinical shift. — The check must happen before employment begins — not during induction, not on day one. For new starters in healthcare, build the right-to-work check into the pre-employment screening process alongside DBS checks and occupational health clearance.
- Ask whether the worker has a share code. — Workers with a Biometric Residence Permit, settled or pre-settled EU status, or a visa issued digitally will typically have access to a share code via the UKVI online service. Many overseas healthcare workers will fall into this category. Workers without a share code — British and Irish citizens — will need to provide original documents instead.
- Run the online check at gov.uk/check-job-applicant-right-to-work. — Enter the worker's 9-character share code and date of birth. The result page shows their right-to-work status and any expiry date. Save a copy of the result page as your record. This is the quickest and most reliable method for overseas healthcare staff.
- For those without a share code, inspect original List A or List B documents. — British and Irish passport holders and those with biometric documents that predate the online service will present originals. Check the document is genuine and belongs to the person. Copy and date-stamp the copy. Note whether it is a List A (unlimited) or List B (time-limited) document.
- Record the visa type and expiry date for all workers on time-limited leave. — Healthcare Worker visas, Health and Care Worker visas, and Skilled Worker visas in health occupations are all time-limited. Record the exact expiry date shown on the share code result or the document. This is the date by which the re-check must be completed.
- Set a re-check reminder to fire before the visa expiry date. — A re-check must happen on or before the expiry date shown on the List B document or share code result. In a healthcare rota where workers are on irregular shifts, the re-check window can be missed without a system-level reminder. Schedule it at least 4 weeks before expiry to allow for any delays in the worker obtaining a new share code.
Which visa types are most common in healthcare and what does that mean for re-checks?
The Health and Care Worker visa and the Skilled Worker visa (for health and care occupations) are the principal routes through which overseas-qualified doctors, nurses, pharmacists, and allied health professionals enter UK employment. Both are time-limited, typically granted for 3 to 5 years with the possibility of extension or settlement.
Workers on these visas are List B workers. Their right to work expires on the date shown on their visa grant letter or Biometric Residence Permit. When that date arrives, you must have completed a fresh right-to-work check — either via a new share code, or a fresh check of the renewed BRP — or you lose the statutory excuse.
The practical implication for healthcare HR teams is that a proportion of the workforce will have staggered visa expiry dates throughout the year. Without a tracking system, it is easy to miss a re-check for a worker whose visa renews partway through a rota cycle, particularly for bank or agency staff who may not be in a fixed schedule.
How does right to work fit alongside other healthcare pre-employment checks?
Healthcare employers carry out several pre-employment checks that do not apply in most other sectors — DBS enhanced checks for regulated activity, occupational health clearance, registration verification with the relevant professional body (NMC, GMC, GPhC, and so on), and right-to-work checks. These checks typically run in parallel rather than sequentially.
Right-to-work is usually the fastest to complete, particularly for workers using the online share code service. It does not depend on third-party processing times. For this reason, many healthcare HR teams complete it first and record the result in the same file as the DBS and occupational health outcomes.
One area of difference: professional registration renewals are not right-to-work checks and do not substitute for them. A worker whose NMC registration is current may still have an expired visa. The two obligations are separate and both need tracking.
What records should healthcare employers keep?
The same records required of all employers: for online checks, a copy of the result page showing the worker's name, right-to-work status, and the date of the check; for manual document checks, a clear copy of each document with the date of the check written on it.
Records must be kept for the duration of employment and for two years after the employment ends. In healthcare, where staff may work across multiple trusts or organisations during a career, it is worth being clear about which employer holds the check records for the period in question.
Given that healthcare employers are subject to CQC inspection, maintaining well-organised and retrievable right-to-work records matters beyond the statutory requirement. An inspector asking to see staffing records as part of a broader review of safe staffing will find that right-to-work records form part of the picture of workforce management.
How should healthcare employers handle agency and bank workers?
Agency workers present a specific question: who is responsible for carrying out the right-to-work check? The Home Office employer's guide is clear that where a worker is supplied by an employment agency, the business using that worker (the end-user) may be able to rely on the agency having conducted the check, provided certain conditions are met. The agency must have given written confirmation that it has checked the worker's right to work.
In practice, many healthcare organisations carry out their own checks on agency workers as well, rather than relying solely on the agency's confirmation. This is a matter of risk management and internal policy rather than a strict legal requirement.
For bank workers employed directly by the trust or organisation, the employer is responsible for the check in full. Bank workers move between rosters on an irregular basis, which can make re-check tracking harder — a worker who is not on the rota for several months may have an expiry event that goes unnoticed. A central record-keeping system that tracks expiry dates independently of shift allocation is the most reliable approach.