Informational, not legal advice, and nothing here is about any individual's immigration status. Every rule links to the gov.uk page it came from, all consulted on 25 September 2026. Penalties and procedures change by government decision; the links, not this page, are the authority.
The duty, and who carries it
If you employ someone without the right to work in the UK, you may have to pay a civil penalty of up to £60,000 for each illegal worker — the figure published on gov.uk as at 25 September 2026.
That penalty lands on the employer. For a Delivery Service Partner, the employer is you. Not Amazon, not the station, not the agency that sent the driver over — a point worth being clear about internally, because the assumption that someone further up the chain has handled it is exactly how this goes wrong.
The protection against the penalty is called a statutory excuse, and it is earned by carrying out a correct check before the person starts work. Done properly, the check is your defence. Done sloppily, or done afterwards, it is paperwork.
The three ways to check
GOV.UK sets out three methods.
Online, with a share code. The applicant gives you a share code and you check it online. Note the limitation that catches people out: British and Irish citizens cannot obtain a share code, so this route does not cover a large part of your workforce.
Manually, with original documents. You ask for the original documents and satisfy yourself that they are, in gov.uk's words, "genuine, original and unchanged and belong to the person who has given them to you." You keep copies, and you keep them for two years after the employment ends.
Through an identity service provider, using Identity Document Validation Technology. This is the route most relevant to an operation hiring at volume, because it does not require someone in your office to be an expert in document examination.
The word doing the work in the manual route is satisfy yourself. A photocopy in a folder is not a check. A check is a person having looked at an original, compared it to the human in front of them, and recorded that they did.
Self-employed drivers: the rules are different
This is the part that matters most in this industry and gets the least attention.
GOV.UK is explicit: the right-to-work provisions apply to employees, and "the rules are different if you want to take on someone with another type of employment status, such as agency staff, freelancers, consultants and contractors."
Read that carefully, because it cuts both ways. It does not mean a self-employed driver is a way around the duty — it means the duty attaches differently, and the question of who is genuinely self-employed is decided by the reality of the working relationship rather than by the label on the contract.
And there is a second liability that arrived this year and sits right next to it. Since 6 April 2026, where an umbrella company employs workers in your supply chain, the agency or end client is responsible for making sure PAYE is operated correctly — and HMRC can recover an underpayment from them. If part of your workforce reaches you through an umbrella, you now hold a liability you may have believed you had passed on.
Two different rules, two different government departments, one operational question: do you actually know how each driver on your rota is engaged?
Time-limited permission, and the date that bites
Where a person's right to work is time-limited, gov.uk says plainly that you "need to check their documents again when it's due to expire."
That single sentence is where most well-intentioned operations fail, and the failure is never dramatic. Nobody decides to employ someone without permission. What happens is that a visa expiry sat in a folder, the folder was not looked at, and a driver who was entirely legal in January was not in September.
A statutory excuse earned at hiring does not extend past the expiry date. The follow-up check is a new check, and it has to happen before the date, not after someone notices.
Which means the only thing that actually protects you is that the expiry date is attached to the person, visible ahead of time, and owned by somebody. A date that exists only inside a scanned PDF is not a control.
Where this belongs in onboarding
The check is not a stage of onboarding. It is the gate onboarding exists to get through.
Put concretely: everything else in bringing a driver on — the induction, the kit, the route familiarisation, the first rota slot — is wasted effort if the gate fails afterwards. So the order matters. Collect and verify first, invest second.
The practical failure is almost never a refusal. It is a driver who was asked for documents on day one, sent two of the four, was chased on day three, started on day five anyway because a route needed covering, and whose file was completed on day nine by someone who no longer remembered what had actually been seen.
Nothing in that sequence involves bad faith. It involves a depot under pressure and a process that lived in someone's head.
"The agency handled it"
Worth naming because it is the most common way an operator ends up exposed.
When drivers arrive through an agency or an umbrella company, it is natural to assume the checks came with them. Sometimes they did. The question is whether you can demonstrate it — and whether, given the employment-status rules above and the PAYE liability that arrived in April, the duty you are relying on somebody else to have discharged was ever theirs to discharge.
The answer is specific to your contracts, which is exactly why it is worth asking someone qualified rather than assuming. What is not specific to your contracts is the record-keeping: if a third party carried out a check that protects you, you should hold evidence of it, not a belief that it happened.
What to keep, and for how long
Copies of the documents you checked, kept for two years after the employment ends, per gov.uk. Add to that, as a matter of practice rather than law: the date the check was done, and who did it.
The reason for those two extras is simple. If you ever have to demonstrate a statutory excuse, you are demonstrating that a correct check happened before the person started. A copy of a passport proves a document existed. It does not prove when anyone looked at it.
Three habits that carry most of the weight
Check before the start date, without exception. The excuse is earned before work begins. A check completed on the Tuesday of week one does not retrospectively cover the Monday.
Treat the follow-up date as an operational date, not an admin date. It belongs next to the rota, because its consequence is a driver who cannot take a route.
Apply the same process to everyone. Beyond being the fair thing, it is the defensible thing: a process applied selectively is a process you will struggle to describe as a process.
Sources
All consulted 25 September 2026.
- Penalties for employing illegal workers — the £60,000 figure
- Check a job applicant's right to work — the three methods, the two-year retention, the employment-status carve-out and follow-up checks
- PAYE rules for labour supply chains that include umbrella companies from 6 April 2026
How WaveGo helps with this
DBS, Right to Work and DVLA checks in one record — five seats free, no card and no contract.