Labour Inspection: Cross-Checks on a Temp Worker File

A temp worker file is complete when the same facts (legal name, start date, role, employer, right to work end date) agree across the assignment paperwork, the right to work record, the timesheets and the agency invoice. Inspectors rarely fail a file for one missing page. They ask why two documents disagree, and the file either answers that question or it does not. This article sets out the cross-checks, what a mismatch looks like and what the reviewer does next.

The mechanisms below are UK ones. Check each against the linked official source before building them into your procedure, because guidance changes.

Who inspects a UK temp worker file, and what do they look at?

Since April 2026 the Fair Work Agency is the main labour market enforcement body for agency work. GOV.UK describes it as acting "to protect workers, support fair competition and ensure employers comply with the law" (Fair Work Agency, GOV.UK). Press and trade-body coverage says it took over the work of the Employment Agency Standards Inspectorate and the Gangmasters and Labour Abuse Authority, with National Minimum Wage enforcement still with HMRC during a transition (REC, Fair Work Agency launches). Sources differ on exact dates and on the timing of later transfers, so confirm the current remit on GOV.UK.

In practice an inspection of a temp worker file compares paperwork with what happens on the shop floor: who is on site, who employs them, what they are paid and whether they may work. Home Office right to work enforcement is separate, and the hirer and the agency each need to be able to show their part.

Which six cross-checks matter most?

Six comparisons cover most of what a reviewer can defend. Each sets one field on one document against a field on another document or record.

What does the right to work record need to show?

It needs to show that a check was done before work started, on which date, and on what evidence. The official process is set out on GOV.UK: check a job applicant's right to work, including online checks via a share code and manual checks of original documents. The guidance requires you to keep a copy and to record the date of the check. Read the current guide for the retention period rather than relying on a figure from memory.

The cross-check is straightforward. The name on the share code result must match the name on the contract. The date of the check must precede the first timesheet entry. If permission has a time limit, its end date must be on or after the assignment end date, or a follow-up check must be diarised.

A positive result tells you the person has permission to work as shown at that date. It does not confirm that the photo document you were shown is genuine, and it does not cover later changes of status. For foreign workers, see our walkthrough on work permit checks before an assignment.

How do agency and hirer paperwork have to line up?

The hirer and the agency each hold half of the picture, and the halves have to agree. The agency's records on the worker, the terms of the assignment and the hirer's records of attendance and cost are where inspectors look for contradictions. The rules on how employment agencies and employment businesses must operate are in the Conduct of Employment Agencies and Employment Businesses Regulations 2003; read the current text for the record-keeping duties that apply to you.

What to compare on the hirer side:

1. Assignment start and end dates against the dates on the timesheets. A worker on site before the stated start date is a mismatch.
2. Role description against the work seen. A request for a forklift driver filled by someone without the relevant training record is a gap, even if every document is individually valid.
3. Legal entity on the invoice against the entity named in your agreement with the agency.
4. Worker identity on timesheets against the identity on the right to work record; shared logins or initials-only timesheets cannot be tied to a person.

For a broader view of what agencies hold, see staffing agency compliance requirements by country.

What do site managers actually ask on forums?

Questions that come up repeatedly on HR and staffing forums are practical. We summarise them without quoting anyone.

"The agency says it did the right to work check. Do I need to see it?" Ask for the record, not a reassurance. You are comparing the date and the name with your own site records. How responsibility splits between agency and hirer depends on the contract and the facts, so take advice for your arrangement.

"What happens if a worker's permission runs out during the assignment?" The follow-up date should already be in the file. If it is not, the worker should not continue until the position is confirmed.

"Is a photo of the document on my phone enough?" It records what was shown. Whether it meets the standard depends on the check route used; follow the GOV.UK process for the route.

What should the reviewer do when documents disagree?

Treat a mismatch as a question first. Three outcomes cover nearly all cases.

• Clerical error: typo, date format, hyphenated surname. Correct it with supporting evidence and note who changed it and when.
• Missing cover: permission ending, check done late, role not matching training. Pause the affected work until resolved and log the reasoning.
• Unexplained: different employer, different identity, hours that cannot be reconciled. Stop, record what you saw, notify the agency's compliance contact and seek advice before any further payment.

Keep the trail: which field, compared with what, by whom, when, with what decision. A dated file answers an inspector's question. A recollection does not.

Where does automation help, and where does it stop?

Reading six fields across five documents for forty workers on a Monday morning is where errors creep in. A document validation tool extracts names, dates, reference numbers and employers, compares them across documents and flags the rows that disagree. It compares data. It does not establish that a document is genuine, and the decision stays with a person.

CheckFile's temp staffing and recruitment solution is built around those comparisons; see also the industry verification guide and our security page for how files are handled.

Frequently Asked Questions

What is the first cross-check an inspector is likely to run?

Whether the person on site is the person in the file: name and date of birth on the right to work record against the contract and timesheets. Mismatches there undermine everything that follows.

Does a share code result prove the worker's documents are genuine?

No. It shows the permission recorded by the Home Office for that person at the time of the check. It does not authenticate any physical document.

Who keeps which documents, the agency or the hirer?

Both keep records for their own part of the arrangement. Your agreement should say who holds the right to work evidence and how you can see it.

How often should the checks be repeated?

At each renewal or extension, and before the earliest of the permission end date and the assignment end date. Diarise the date when the file is created.

What if the invoice and the timesheet disagree?

Hold the disputed line, ask the agency for its source records and compare them with your site access data. Record the resolution in the file.