Legislation in Focus: UK digital ID (“BritCard”) and what it means for employers, Right to Work, DBS and more

Overview

The UK Government has confirmed a state-issued digital ID that will become mandatory for Right to Work checks by the end of this Parliament. Ministers say a public consultation will open this year, with legislation to follow. The ID will be free, phone-based, and the Government says there will be inclusive alternatives for people without smartphones. The programme sits alongside the GOV.UK Wallet work to make official credentials available digitally (for example, a digital driving licence).

What’s proposed

The digital ID is expected to hold core identity and immigration-status data (name, date of birth, nationality or residency status, and a photograph). For employers, the key change is that proof of Right to Work will need to be provided using the digital ID by 2029. Officials have also indicated it is not an on-demand “show me your papers” system: the mandate is about the way Right to Work is proven, not about carrying ID.

Beyond Right to Work: DBS and wider background checking

Digital identity is already permitted for DBS checks via certified providers under the UK trust framework. As a government digital ID rolls out, expect convergence so a government-issued credential can satisfy the identity step across DBS levels where digital identity is permitted, while conviction content and barred-list decisions remain handled by DBS under existing law.

Other screening touchpoints are likely to follow similar patterns over time (for example, Right to Rent or age-based entitlements), but those depend on future policy decisions and published guidance. At present, the only confirmed mandate is Right to Work by 2029.

What doesn’t change for now

Until the new law and processes go live, employers must keep using the existing Right to Work routes to maintain a statutory excuse: manual document checks where permitted; the Home Office online share-code route for those with an eVisa or online status; and digital checks using a certified provider for British and Irish passport holders. Civil penalties remain up to £45,000 per illegal worker for a first breach and up to £60,000 for repeat breaches (in force since February 2024).

Where IDSPs fit

The UK Digital Identity and Attributes Trust Framework underpins certified providers and the public register of services. Current government messaging and technical work point toward interoperability with that framework rather than an overnight replacement. For employers and screening providers, the practical questions are how the new credential will be presented, verified and evidenced so that the statutory excuse (or DBS compliance) is preserved, and how inclusive fallbacks work for candidates who cannot use smartphones.

Timeline

• 2025 - Government says consultation opens this year; details such as user flows, evidence output, offline and assisted routes will be shaped here.
• 2026 (expected) - Legislation after consultation, subject to parliamentary time.
• By 2029 - Digital ID mandatory for Right to Work; transitional rules will manage the switch-over.

Sector angles worth watching

• Recruitment and staffing: high-volume onboarding stands to gain from standardised checks, but assisted and offline options will be critical to avoid excluding candidates during peak hiring.
• Health, education and regulated roles: digital ID needs to dovetail with DBS/PVG so identity, status and safeguarding checks remain seamless.
• Hospitality, agriculture and logistics: seasonal and shift-based workforces need low-friction flows plus reliable fallbacks to avoid delays.

Risks and the public debate

Ministers present digital ID as a way to curb illegal working, reduce forged documents and modernise services. Opposition has also grown: a petition has passed 2.8 million signatures; critics raise privacy and exclusion risks; industry warns digital ID alone is not a “silver bullet” without stronger enforcement. Devolved-nation dynamics matter too: Scotland is scaling ScotAccount and its First Minister has opposed a mandatory UK-wide scheme, so interoperability and policy alignment will be live issues through consultation.

Open questions to watch

• What is the “evidence of a valid check” under the new model (and how is it stored)?
• How will offline/assisted routes work for people without smartphones, and who can provide them?
• How will devolved services (e.g., ScotAccount) interoperate with a UK-wide Right to Work requirement?
• Will Government preserve open participation by private-sector IDSPs, or centralise checks entirely? (Industry groups caution against a single-channel model.)

Global perspective: how other digital ID systems compare

What tends to work

Countries that get digital ID right usually combine a single, authoritative credential with real-world convenience (multiple ways to prove identity, not just a smartphone), clear and limited data sharing, and an open ecosystem so government and trusted private providers can both participate. Inclusive design and assisted, offline routes are essential to prevent exclusion.

Snapshot examples

Estonia
A long-running model built on a state e-ID card with mobile options (Mobile-ID, Smart-ID). It underpins everyday services and legally robust digital signatures. Choice of channels and strong public trust have produced high adoption. The UK proposal is initially phone-centric for Right to Work, but the Government has promised inclusive alternatives; Estonia shows why those alternatives matter.

Singapore
Singpass is deeply embedded across government and business services, with high usage and a wide relying-party network. The lesson is clarity of use cases and tight integration with both public and private sectors.

European Union
The EU is rolling out an EU Digital Identity Wallet under the updated eIDAS Regulation. It emphasises cross-border acceptance and privacy-preserving credential sharing (e.g., showing only what’s necessary). Compared with the UK, the EU model focuses on a wallet standard used across many countries, not a single national credential.

Switzerland
After rejecting a privately run scheme in 2021, voters narrowly approved a voluntary, state-run e-ID in 2025. Switzerland’s emphasis is on public trust and voluntariness, whereas the UK intends to mandate digital ID specifically for proving Right to Work by 2029. eid.admin.ch

Belgium and the Netherlands
Belgium’s “itsme” app (operated under national trust rules) and the Netherlands’ DigiD show how strong adoption follows when digital ID becomes the simplest way to reach many services, without forcing a single technology path. These also illustrate the value of keeping private-sector participation open.

Germany
Germany’s national eID has existed for years but activation has lagged, with research citing complex setup and limited everyday use. The main takeaway is that user experience and breadth of services determine whether people actually switch.

India
Aadhaar is the world’s largest digital ID. It delivers massive volumes of authentication for public and private services, but court rulings set limits (especially for private-sector mandating), and civil-society groups continue to highlight risks of exclusion and the need for redress. The UK can borrow the scale lessons while avoiding the pitfalls by designing strong safeguards and assisted routes.

United Arab Emirates
Emirates ID is a mandatory, universal card used across government and private services. It shows the efficiency of a single, authoritative credential but it’s a different policy choice from the UK’s “mandatory for Right to Work, with alternatives and no on-demand carry requirement.”

What this means for the UK proposal

• Mandate scope: the UK is proposing a mandate for Right to Work by 2029, not a general “show on demand” ID.
• Inclusion: successful programmes keep assisted and offline channels first-class; UK policy says alternatives will exist but these must be designed well.
• Ecosystem: the trust-framework/IDSP world you use today should interoperate with a government credential; countries with open ecosystems see faster adoption.
• Privacy by design: selective disclosure and clear evidence outputs help employers stay compliant while minimising data handling.
• User experience: activation and day-one usefulness drive uptake. Germany’s experience shows the cost of friction, while Singapore/Estonia show the benefit of convenience.

Practical actions for employers now

1. Map your current Right to Work journey (manual, online/share-code, IDSP) and note pain points and fraud controls; this will inform your consultation response and transition plan.
2. Speak to your IDSP about integration with a government digital ID, assurance levels, evidence outputs (to retain a statutory excuse), and inclusive fallback routes.
3. Build inclusion into your process. Plan assisted channels and non-smartphone flows to avoid discrimination and unintended exclusion as the system phases in.
4. Align your DBS identity-check procedures to the 2025 guidance and track how a government credential could satisfy the identity step where permitted.
5. Refresh DPIAs and retention schedules. Even if wallet-based credentials reduce the documents you hold, robust audit trails of checks remain essential.

Naming note

Government material refers to a “digital ID” and to GOV.UK Wallet; “BritCard” is a media nickname in current reporting rather than an official product name.