Recruiters and platforms need to consider how they connect an identity verified at onboarding with the person who actually performs the work, according to Dr Tarek Nechma, CEO and founder of ComplyCube.
His comments come as updated Home Office right to work guidance takes effect on 1 October 2026. He argues that substitution and account-sharing arrangements can expose weaknesses in relying only on a check at registration.
The biggest change isn't checking more workers. It's proving the person working is still the person you checked.
Dr Tarek Nechma, CEO & Founder, ComplyCube
Responsibilities depend on the arrangement
The Home Office’s final guidance expands the scheme to defined worker, individual subcontractor and online matching arrangements. Extended liability can also apply in specified contractual chains and substitution arrangements.
The guidance says the new provisions are not retrospective simply because work continues after 1 October. It also says a standard agency supply arrangement is not intended to require routine duplication of the employment business’s checks by the hirer. The legal effect of a new or renewed contract needs to be considered.
Why it matters
For recruitment operations teams, the practical issue is establishing clear responsibility and keeping an auditable connection between the worker, the identity evidence and the assignment. Nechma’s call for ongoing identity controls is his recommendation; it should not be read as a blanket requirement for continuous biometric monitoring.
He says a genuine account can still be used by a different person, so an initial registration check does not by itself establish who is carrying out the work months later.
Editorial illustration created for Onrec.
