Your new starter gets verified three times. Only two of those can be done digitally.
A nurse joining an NHS trust in England is verified three times over before her first shift. Two of those checks now run through Home Office and DBS rules that permit a certified digital provider. The third belongs to the NHS itself, and it still puts her in a room with her passport in her hand.
The NHS employment check standards treat the three as separate obligations with separate evidence. Her right to work can be confirmed from her phone in the week before she starts, if she holds a British or Irish passport and the trust uses a provider on the government register. The identity component of her DBS application can run the same way.
Neither removes the appointment where someone in HR looks at her original documents and then looks at her. That boundary is the part of this subject worst explained online.
NHS employers in England verify identity against the NHS Employers Identity Checks Standard by seeing original documents in one of two set combinations, either two photographic documents plus one address document, or one photographic plus two address documents. The check is done in person. An in-person likeness check must also happen before the person starts work.
NHS Employers publishes six employment check standards, all carrying a publication date of 23 July 2026: identity, right to work, criminal record, professional registration and qualification, work health assessments, and employment history and references. Identity is the one everything else rests on. The standard calls it “the most fundamental of all the pre-employment requirements, as it forms the basis of all other checks”.
They are not legislation, and NHS Employers is not a regulator. The standards descend from a Department of Health mandate of May 2002 setting six primary checks for all NHS organisations in England, and they bite through CQC registration requirements and the terms written into national framework agreements for agency supply. Coverage reaches locum doctors, trust bank workers, agency-supplied staff and volunteers as well as substantive hires, and section 3.1.1 requires verification before any work or volunteering begins.
Section 2.2.2 sets two acceptable combinations: two forms of photographic personal identification from List 1 plus one document confirming the current residing address from List 2, or one photographic document plus two address documents. Where somebody genuinely holds no photographic identification at all, section 2.2.3 opens a third route: two address documents, two non-photographic documents from List 3, and a passport-sized photograph.
List 1 covers passports, photocard driving licences, HM Armed Forces identity cards, PASS accreditation cards and eVisas. Utility bills, council tax statements, HMRC notifications, bank statements and tenancy agreements sit in List 2.
For the candidate this is the part of onboarding that costs a morning. Assembling three documents that between them prove a face and an address, then getting to an office to hand them over, is where people with irregular housing or a recent name change struggle.
No. A certified digital verification service provider can support document checking during recruitment, and the sighting of originals still happens face to face. NHS Employers states the position in its Employment Check FAQs, last updated 31 July 2026:
“Employers have the option of using a certified digital verification service provider (DVSP) for checking identity documents during the recruitment process. However, in order to meet the NHS Identity Checks Standard employers still need to see, verify and record original documents (in the combinations required) in person when the individual first takes up the position or is required to undertake induction or other type of training, whichever is sooner.”
Two separate obligations survive. Original documents must be seen, verified and recorded in person at the earlier of first day in post or first attendance at induction or training. Employers “must also conduct an in-person likeness check of the individual before they commence work”.
The reason is a gap in certification. NHS Employers says in the same FAQ that it is “in favour of aligning the NHS Identity Checks Standard with the use of DVSPs”, but cannot adopt the Home Office and DBS arrangements because “the type and level of assurances required to prove a persons’ right to work and/or to match to a criminal record could be lower/different to those required for our NHS identity purposes”, so “a certification scheme specific to NHS assurance levels will need to be implemented”. It says it is engaging with NHS England, DHSC and the CQC, and has published no timescale.
Read the standard itself and the absence is striking. As published on 23 July 2026 it does not mention identity document validation technology, digital verification service providers or certification anywhere, and it does not align to a named GPG45 level of confidence. The DVSP permission lives in the right to work standard and the FAQs.
|
Check |
Rulebook |
Can a certified provider carry it |
What still has to happen in person |
|---|---|---|---|
|
NHS identity check |
NHS Employers Identity Checks Standard, 23 July 2026 |
No. No certification scheme for NHS identity requirements exists yet |
Original documents in the required combination seen, verified and recorded in person at the earlier of first day or induction, plus an in-person likeness check before work starts |
|
Right to work |
Home Office Right to Work Scheme, applied through the NHS Employers Right to Work Checks Standard, 23 July 2026 |
Yes, for British and Irish citizens holding a valid passport or Irish passport card. For an NHS employer the provider must be on the OfDIA register with a right to work note against it |
Confirmation that the photographic image provided is a true likeness of the employee. This can be in person or by video call |
|
DBS identity component |
DBS digital identity verification guidance, updated 10 July 2026 |
Yes. Registered bodies and responsible organisations must use a DVS certified by an approved conformity assessment body |
Nothing additional under the DBS rules. The NHS identity check runs separately and still applies |
On right to work, NHS Employers goes further than the Home Office, which lets an employer use an uncertified provider at a minimum medium level of confidence. Section 2.3.2 of the NHS right to work standard removes that latitude: “It is mandatory that when choosing to engage the services of a DVSP to conduct right to work checks, that the DVSP completing the check is registered on the Office for Digital Identities Attributes (OFDIA) register and have a note on the register to confirm that they can provide right to work checks.” Everyone outside the British and Irish passport population uses an original document check or an online share code.
The Home Office code of practice in force since 13 February 2024 sets a starting point of £45,000 per worker for a first breach and £60,000 for a repeat breach within three years, both before reductions are applied. From 1 October 2026 the illegal working regime extends to a wider set of working arrangements under section 48 of the Border Security, Asylum and Immigration Act 2025, and NHS Employers has said the standards will be updated when it takes effect.
Criminal record checks have their own minimum levels of confidence, set by the DBS: medium for a Basic check, high for Standard, Enhanced and Enhanced with Barred Lists. Its guidance, updated 10 July 2026, requires registered bodies and responsible organisations to use a certified provider, the only place in NHS recruitment where certification is a legal requirement.
The identity check, the right to work check and the criminal record check have different owners and different evidence. Where they run one after another, a candidate who cannot get to an HR office quickly holds up the identity file, which holds up the DBS submission and the start date. Nothing in the standards requires that sequence.
The in-person document check is the fixed point. Right to work and DBS identity can both be completed and evidenced before the person arrives. Occupational health can only begin after an offer under section 60 of the Equality Act 2010, so it belongs in the same pre-arrival window. Professional registration is checked directly with the regulator. What is left for the first morning is the document sighting and the likeness check.
Portability will not close the gap. The NHS Digital Staff Passport was retired on 5 December 2025 and nothing has replaced its function. NHS England’s Enabling staff movement toolkit, updated 4 December 2025, sets a lower bar for temporary movement between organisations, requiring at least one form of reliable photo identity, and that allowance does not reach a substantive hire.
The fraud case for keeping the in-person step is the NHS’s own. The NHS Counter Fraud Authority’s Strategic Intelligence Assessment 2025 estimates £27.8 million of staff fraud vulnerability a year. Its employment fraud guidance, reported by NHS Employers on 16 July 2026, names imposter fraud as one of four areas.
The six standards are set for NHS organisations in England. NHS Wales organisations apply them through NHS Wales Shared Services Partnership. NHSScotland runs its own Safer Pre and Post Employment Checks PIN policy, with a minimum of two forms of identification and criminal record disclosure through Disclosure Scotland. Health and Social Care organisations in Northern Ireland run separate arrangements, with criminal record checks through AccessNI.
A statutory floor reaches every provider registered with the CQC in England: Schedule 3 paragraph 1 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 requires proof of identity including a recent photograph.
OneID is listed on the government’s Digital Verification Services register as service ID 286, with supplementary codes recorded against its entry for right to work, right to rent and criminal record checks. Conformity assessment body Kantara issued the certification on 12 June 2026 and it runs to 21 June 2029. The same entry records identity profiles supported at medium, high and very high.
OneID does not carry the NHS identity check, and neither does anything else on that register, because the certification scheme NHS Employers says would be needed does not exist. It does not check professional registers such as the GMC or the NMC. The standards give that job to the employer, working directly with the regulator.
A certified route changes what the new starter has to arrange. A bank nurse finishes her right to work check in a few taps one evening at home, and her DBS identity evidence is captured while she does it. On day one she brings the original documents in one of the two required combinations, and someone in HR examines them and confirms her likeness before she starts the shift. Nothing else in her onboarding has to wait for her to be in the building.
Audit which of your three checks wait on the same appointment. If right to work and DBS identity sit in the same HR diary slot as the document sighting, the NHS employment check standards do not require that, and you are paying for it in start dates. Move the two that can run digitally in front of the arrival date.
Does a digital identity check satisfy the NHS Identity Checks Standard?
No. NHS Employers confirmed in its Employment Check FAQs, updated 31 July 2026, that employers using a certified digital verification service provider for document checking still need to see, verify and record original documents in the required combinations in person, when the individual first takes up the position or attends induction or training, whichever is sooner.
Which documents does the NHS identity check accept?
Three documents, in one of two combinations set by section 2.2.2 of the NHS Employers Identity Checks Standard: either two photographic documents from List 1 with one address document from List 2, or one photographic with two address documents. Candidates who hold no photographic identification at all have a separate route under section 2.2.3, which raises the number of documents required and adds a passport-sized photograph.
Can an NHS employer use a digital provider for right to work checks?
Yes, for British and Irish citizens holding a valid passport or Irish passport card. Section 2.3.2 of the NHS Employers Right to Work Checks Standard, 23 July 2026, makes it mandatory that the provider is registered on the OfDIA register with a note confirming it can provide right to work checks. A likeness confirmation still applies.
Do the NHS employment check standards apply in Scotland, Wales and Northern Ireland?
Not directly. Only NHS organisations in England fall inside their scope, although NHS Wales Shared Services Partnership runs the same set for NHS Wales bodies. Scotland sits outside them altogether, using the Safer Pre and Post Employment Checks PIN policy and routing criminal record disclosure through Disclosure Scotland. Health and Social Care employers in Northern Ireland run separate arrangements and route criminal record checks through AccessNI.
What happened to the NHS Digital Staff Passport?
It was retired on 5 December 2025 and is no longer in use, according to NHS England Digital. No replacement with the same function has been announced. Trusts sharing staff temporarily can rely on NHS England’s Enabling staff movement toolkit, updated 4 December 2025, which accepts at least one form of reliable photo identity for that situation.
Does a member of staff transferring under TUPE need checking again?
NHS Employers’ FAQs, updated 31 July 2026, state that although terms and conditions transfer under TUPE protection, liability for assuring safe working practice sits with the new employing organisation. The new employer should always seek written assurances that the relevant checks were carried out by the previous employer in line with the NHS employment check standards.