A dry statutory instrument has become a live autumn deadline for business. The revised employer and landlord codes apply from 1 October 2026, and the final 1.0 supplementary codes for digital right to work and right to rent checks were updated on 9 June 2026 and can take effect once a conformity assessment body is accredited, no earlier than 1 September 2026. For employers, landlords, online matching platforms and digital verification providers, that leaves a short window to get process, supplier choice and record-keeping into shape. (gov.uk)

The biggest commercial shift sits on the labour side. The Home Office says the existing Right to Work Scheme only applied to employees, which left a gap around workers, self-employed arrangements and other modern hiring models. From October, that reach extends to worker's contracts, individual sub-contractors and online matching services that connect service providers with clients for payment, bringing a broader slice of the gig and outsourced economy into the formal checking regime. (gov.uk)

That helps explain why this matters beyond large HR teams. In the Home Office impact assessment for extending the scheme to other working arrangements, the central scenario models about 3.8 million additional right to work checks in 2026/27 at a total business cost of roughly £9.2 million. Officials also say the cost per check is expected to be small, but that is not the same thing as saying the burden is trivial when onboarding volumes are high or responsibility sits across multiple intermediaries. (gov.uk)

Digital checking is where the legal drafting turns into procurement work. Employers have been able to use digital verification services for British and Irish passport holders since 6 April 2022, and landlords have a parallel digital route for right to rent. But firms choosing that route now need to think in terms of registered DVS suppliers and the supplementary codes rather than generic identity software. That matters because British and Irish citizens cannot use share codes for these checks, so the DVS route remains a practical part of hiring and tenancy screening. (gov.uk)

For landlords and agents, the message is narrower but no less practical. The Right to Rent Scheme still applies only in England, and all prospective adult tenants must be checked before the tenancy starts. GOV.UK says landlords can use original documents, a share code route where available, or a registered DVS for British and Irish citizens, and if they use the online route they must keep the record for the length of the tenancy and for one year afterwards. If a tenant can prove status with accepted original documents, landlords cannot insist on the online service instead. (gov.uk)

The discrimination risk is easy to miss when firms rush to automate. The employer code says checks must be applied consistently and that employers must not favour applicants simply because they have an eVisa, or single out people who seem likely to be migrants. The landlord guidance is just as plain: check all new adult tenants and do not only check people thought not to be British. In other words, the October compliance job is partly a systems task and partly a training task. (gov.uk)

Between now and 1 October, firms have three obvious pressure points to review: where checks sit in recruitment, contractor onboarding and tenancy setup; whether any DVS supplier is aligned with the current supplementary code as certification moves live from September; and how evidence is stored for audit. Employers using digital checks already need to retain clear copies for the duration of employment and for two years after it ends, while landlords keep records for one year after a tenancy ends. For digital verification providers, that shifts the sales pitch away from convenience alone and towards audit-ready compliance. (gov.uk)