APA x KEEP | Right to Work checks for crew

Further to the guidance we shared on 21 September, we wanted to remind you that, from 1 October 2026, the UK’s right-to-work requirements have been extended to cover freelance workers and subcontractors.

The Home Office’s latest guidance applies to new engagements and contractual arrangements from this date. The key implications are:

• Freelancers: Appropriate right-to-work checks must be completed before work begins, including during the preparation stage.
• Subcontracted labour: Using a diary service, supplier or third party does not automatically remove your responsibility. Productions should obtain reasonable assurance that the necessary checks have been completed.
  

How to complete the checks:
For British and Irish citizens, you should check an acceptable form of identification, such as a passport. A driving licence alone is not sufficient. For individuals using a right-to-work share code, you must enter their share code and date of birth into the GOV.UK right-to-work checking service. The date of the check should be recorded, and evidence of the check should be securely retained throughout the engagement and for two years afterwards.


A simpler option to manage your checks is with KEEP – see pdf attached.

KEEP has developed a system that allows productions to complete right-to-work checks without having to handle or retain copies of crew IDs directly.

Checks are securely stored in a GDPR-compliant manner and retained for the full two-year period required under the legislation.

Using the KEEP infrastructure, productions can also set alerts for when a check needs to be repeated, helping ensure that any required action is flagged to the relevant production team.


For further information or any enquiries, please contact:

Campbell Beaton – [email protected]