Recruitment Agency Compliance Checklist (UK)

Why compliance is the highest-risk part of running a recruitment agency

An agency doesn't just place people — it stands behind every placement as the party that checked the worker was allowed to do the job, before the client ever saw a CV. Get a right to work check wrong and the exposure is a civil penalty, not just an awkward conversation. Get a document expiry missed and a contractor can end up working on assignment with a lapsed visa or an out-of-date certification, and nobody notices until a client audit asks for the file. None of this is optional or occasional — it's the background task that has to run correctly for every worker, every time, for as long as the agency operates.

Right to work checks

What a right to work check actually involves

Before you employ someone, you must check they're allowed to work for you in the UK. Gov.uk sets out two main routes: checking the applicant's right to work online, using a share code they give you, or checking their original documents in person (or via an identity service provider that offers Identity Document Validation Technology). British and Irish citizens can't get an online share code — for them, you check original documents such as a passport, or use an identity service provider instead. See gov.uk — Checking a job applicant's right to work.

When you check original documents, gov.uk's guidance is specific about what's required: the documents must be genuine, original and belong to the applicant; photos and dates of birth must match across documents; and, for a non-British/Irish applicant, you also need to confirm their right-to-work dates haven't expired and that they're permitted to do the type of work (and hours) you're offering. You then make a copy that can't be altered, record the date of the check, and — this is the detail worth building a process around — keep that copy for the duration of the person's employment and for 2 years after it ends.

Following up before documents expire

If a worker's right to work is time-limited, you have to check their documents again before that limit is reached — not after. That's exactly where a spreadsheet-and-reminder process tends to fail at scale: one expiry date, buried in a row among hundreds of others, with no automatic warning before it lapses. It's also precisely the shape of problem a document vault with expiry alerts exists to solve — see below.

DBS checks

"DBS check" means a criminal record check carried out through the Disclosure and Barring Service. As an employer, you can request one for a job applicant, and there are several levels: a basic check shows unspent convictions and conditional cautions; a standard check shows spent and unspent convictions and cautions; an enhanced check adds any information local police hold that's considered relevant to the role; and an enhanced check with barred lists adds whether the applicant is on the list of people barred from doing that role. See gov.uk — Check someone's criminal record.

A DBS check has no official expiry date — any information in it is accurate as of the date the check was carried out, and it's up to the employer to decide when a repeat check is needed. If the person has signed up to the DBS update service, you can check online whether their certificate is still current rather than requesting a fresh one.

Which level of check a role qualifies for depends on the nature of the work — standard and enhanced checks aren't available for every role, and the eligibility rules are specific enough that they're worth confirming against the live gov.uk guidance for a given placement rather than assumed from a similar one.

Other compliance documents agencies typically track

Right to work evidence and DBS certificates sit alongside a longer list most agencies end up tracking per contractor: professional qualifications or registrations relevant to the role, employer or personal references, and insurance certificates (public liability, professional indemnity) — either the agency's own, or evidence of a limited-company contractor's or umbrella's cover. Each of these has its own renewal or expiry rhythm, which is exactly what turns "a compliance document" from a one-time check into an ongoing tracking problem.

A simple compliance checklist template

For each contractor, before their first day on assignment:

• Right to work check completed and evidenced (online share code, or original documents copied and dated)
• Right to work expiry date logged, if time-limited
• DBS check completed at the level the role requires, if applicable
• Professional qualifications or registrations verified and copies held
• References obtained
• Insurance evidence held (agency's own cover, and the contractor's or umbrella's where relevant)
• IR35 status determined and, where required, a Status Determination Statement received — see our IR35 Status Determination Statement guide
• AWR week-count tracking started for the assignment — see our AWR 12-week rule guide

And on an ongoing basis: every document with an expiry date gets a review before it lapses, not after.

How Templio's compliance document vault handles expiry tracking automatically

Templio's document vault holds each contractor's compliance documents — right to work evidence, DBS certificates, insurance and qualifications — against the contract they relate to, and flags an upcoming expiry with warnings at 60 days, 30 days and on the day itself, so a renewal is chased before it becomes a gap rather than after. To be precise about what this does and doesn't do: Templio tracks the documents and their expiry dates — it doesn't perform the right to work check or the DBS check itself, and it doesn't replace the legal responsibility to carry those checks out correctly. It sits alongside AWR week-count tracking and IR35 status on the same contract record, as part of our timesheet software for recruitment agencies, on the same pricing, with no separate compliance module to buy.

FAQs

What documents prove someone's right to work in the UK? Either an online share code the applicant gives you (not available to British or Irish citizens), checked via gov.uk's online service, or original documents — such as a passport — checked in person and copied. See gov.uk's guidance for the current detail on both routes.

How often do I need to re-check right to work status? Only when the right to work itself is time-limited — you must check again before that limit expires. If the original check confirmed an unlimited right to work, no follow-up check is required.

What's the difference between a standard and enhanced DBS check? A standard check shows spent and unspent convictions and cautions. An enhanced check shows the same, plus any information local police hold that's considered relevant to the role, and can also include whether the applicant appears on a barred list. Eligibility for each level depends on the specific role.

Do temporary/agency workers need the same right to work checks as permanent staff? Yes — the requirement to check right to work applies before you employ someone, regardless of whether the engagement is permanent, temporary or contract.

What happens if a compliance document expires while a contractor is on assignment? It depends on the document and the specific legal requirement it evidences — but in practice, an expired document is a compliance gap the moment it lapses, which is why tracking the expiry date in advance, not just the document itself, is the part that actually prevents a problem.

This guide is general information, not legal advice. Right to work and DBS-check rules are updated by gov.uk and the Disclosure and Barring Service from time to time — check the live guidance before relying on a specific detail for a real placement.