A visa date is a prompt to review the worker’s position. It does not, by itself, tell you whether their permission has ended or which check your organisation needs to make.
The useful record connects the original check, the permission or restriction shown, the next required action and the person responsible for it. Keep that record current throughout employment.
Start with the check result
Use the current Home Office employer guide to determine the appropriate check method. Record its date, the result, any work restrictions and whether the statutory excuse is continuous or time limited.
For an online check, retain the employer-facing result and confirm it relates to the person doing the work. A share code copied into a spreadsheet is not the check result. A physical biometric residence permit is not a substitute for the appropriate current online process.
Keep passport expiry, immigration permission and an internal review date separate. A passport expiring does not automatically end a person’s right to work. Equally, an uploaded replacement document does not establish that the employer has completed a required follow-up.
Decide whether a follow-up is required
Follow the timing prescribed for the check and the worker’s circumstances. Do not apply one rule to every visa or document type.
The October 2026 guide states that employers do not need to repeat employment right-to-work checks for people with EU Settlement Scheme settled or pre-settled status. Do not introduce recurring checks for those workers simply because an earlier digital result displayed a date. See our follow-up-check guide for the distinction between a legal follow-up and a company review.
Review pending applications before deciding what happens next
An in-time immigration application may preserve existing permission and its conditions under section 3C. The employer’s check obligations still require attention. The Home Office guide explains when the Employer Checking Service is appropriate, the effect of a Positive Verification Notice and the specified circumstances in which an existing statutory excuse can continue for up to 28 calendar days while verification is obtained.
Record the evidence available, the action taken and the next date required by that guidance. Do not assume that a pending application always allows work, or that the original expiry date automatically requires dismissal. Get case-specific advice where the person’s position is unclear.
Make the next action visible
For each time-sensitive record, identify:
- The check method and retained evidence.
- The permission and restrictions relevant to the actual work.
- The follow-up date, its reason and responsible reviewer.
- Outstanding application or verification evidence.
- The completed action and the next decision.
A missed reminder is a process defect to investigate. It is not evidence that the worker was working illegally, and it does not automatically produce a civil penalty.
Certifyd can help your team keep expiry and review dates with workforce evidence. Your organisation remains responsible for the prescribed check and the employment decision. The Fair Work Agency’s labour-market remit is separate from Home Office illegal-working enforcement.