Step 1: Check before day one — not after
The check must happen before the worker starts work. A late initial check — even by one day — means you had an unchecked worker on site. No statutory excuse for that period. Build a hiring process where the Right-to-Work check is the last step before an employment offer is confirmed, not an afterthought.
Step 2: Check the correct document category
Use the Home Office's definitive document list. Don't accept a document that feels right — verify it appears on List A or List B. For any document you're unsure about, use the Home Office Online Check Service (a share code from the worker) rather than relying on physical documents alone.
Step 3: Record the check with a timestamp
The statutory excuse requires you to have a record of the check — what document was presented, when it was checked, and who conducted it. A note in a paper file is better than nothing, but a digital timestamped record is far stronger evidence. Record the document type, any reference number, the check date, and the expiry date of any time-limited documents.
Step 4: Track every re-check date
For every worker with a time-limited right to work (List B), record the date their leave expires and set a re-check date for on or before that date. This is the step most businesses miss. A spreadsheet that you check manually is one person going on holiday away from a missed re-check. An automated system that sends you escalating alerts — and keeps alerting until the re-check is done — removes the human memory dependency.
Step 5: Export an audit trail you can hand over
If a Home Office officer visits, you need to produce records immediately. An audit trail that shows every worker's check date, re-check date, and document reference — with timestamps — is the strongest possible evidence. A spreadsheet that anyone can edit is not credible evidence. A timestamped, append-only log is.