Right-to-work checklist for cleaning contractors

Use this checklist to get your cleaning business ready for the right-to-work changes that start on 1 October 2026. It follows the order most contractors find easiest.

1. Know who works for you

• List everyone who cleans on your contracts, including employees, casual staff, self-employed cleaners, agency staff and people booked through apps.
• Note how each person is engaged: directly by you, through an agency, through an app, or through another cleaning company.
• Mark who is now in scope. Most self-employed cleaners working on your contracts will be. See self-employed cleaners.

2. Check before anyone starts

• Adopt a simple rule: no check, no shift. This covers trial shifts, cover for sickness and one-off jobs.
• Decide which method you'll use for each person: a Home Office online check with a share code, a manual document check, or a digital verification service for British and Irish passports.
• Check everyone the same way, whatever their nationality. Checking selectively risks unlawful discrimination.
• Make sure supervisors know they can't put someone on a site until their check is done.

3. Keep proof of every check

• For each check, save the document copy or online result, the date and who did it.
• Store it securely. These are sensitive personal documents.
• Keep records for the whole engagement plus two years, then delete them.
• Tell your cleaners how you handle their documents. A short privacy notice is enough.

4. Don't miss a recheck

• Record when each person's permission to work ends, if it's time-limited.
• Set a reminder well before that date, and do the follow-up check before it passes.
• Note conditions such as students' limited working hours, and make sure rotas respect them.

5. Sort out agencies, apps and subcontractors

• List every agency, platform and cleaning subcontractor you use.
• Put written terms in place before work starts: they do the checks, no further subcontracting without your consent, audit rights, and cooperation with the Home Office. See agency and app-booked cleaners.
• Ask for confirmation of each person's check before their first shift, and spot-check suppliers every few months.

6. Control stand-ins

• If cleaners can send a substitute, make sure every substitute is checked by you or the supplier, never left to the cleaner.
• Have a way to confirm that the person on site is the person who was checked, such as ID badges, a photo check at clock-in, or regular identity re-checks.

7. Be ready to prove it

• Make sure you can produce the evidence for everyone at any site quickly, within an hour if possible.
• Test it once: pick a site and pull every record for last week.
• Expect clients to ask for the same evidence at tenders and renewals. See what to show an inspector.

How RotaProof helps

RotaProof is right-to-work software made for cleaning contractors. You record each check once, including for self-employed and agency cleaners. It reminds you before anyone's permission runs out, stops unchecked people going on the rota, and gives you an inspection pack in one download. You can try it free for 30 days.

Try the demo, no sign-up needed Start free trial

Sources

• Home Office: illegal working penalties, codes of practice for employers
• Home Office: an employer's guide to right to work checks
• GOV.UK: check if someone can work in the UK