Two dates to keep apart
The right to work and right to rent supplementary codes 1.1 took effect on 2 September 2026, alongside DVS Trust Framework 1.0. They replaced the 1.0 codes published in June, which never came into force. The framework itself stays at 1.0.
The related Home Office changes (SI 2026/700) took effect on 1 October 2026. Since then, employers and landlords using a DVS for these checks need a service certified and registered against the framework and the relevant code to obtain a statutory excuse: protection against a civil penalty when the required checks are carried out properly, not an automatic benefit of buying a service. It is also when the new options, such as recently expired passports, became usable. See OfDIA's September update.
What changes in practice
The codes cover the digital route for British and Irish passports and Irish passport cards. The right to rent scheme applies to residential lettings in England. The table compares the superseded 1.0 codes with 1.1; it is not a complete Gamma 0.4 transition checklist.
| Area | 1.0 codes | 1.1 codes |
|---|---|---|
| Documents Both codes | Unexpired documents only. | Documents expired by up to six months can qualify, with their cryptographic features validated. |
| Outputs Both codes | GPG 45 profile met and, for holder service checks, GPG 44 authenticator quality. | Registration and code-compliance confirmations, plus a link to the register entry. |
| Holder services Right to work only | A stored identity used for a new check. | Also confirming that a worker is the person with an existing, successful and still-valid right to work check. |
In both codes, an expired passport or card must have expired no more than six months before the check, and its cryptographic security features must be confirmed as genuine, which, as OfDIA puts it, means reading the chip as part of validating the document. Every document must be valid under GPG 45 and not visibly clipped, and both checks still need at least medium identity confidence. See section 3 of the right to work code and the right to rent code.
Update the report your customer receives
Section 4 of both codes adds separate confirmations that your service is certified and registered, and that the check followed the code, plus a link to your service's register entry. "Given name(s)" stays, "Middle name(s)" is added where the person has one, and "Family name(s)" becomes "Surname(s)". The confirmations and the identity result take yes or no, or a clear equivalent.
The identity profile and authenticator quality no longer appear in the output, but the requirements behind them still apply. The required images and details still go in a clear record that cannot be altered, and employers and landlords keep their own matching and record-keeping duties. Check your templates against the full tables in both codes.
A further option for right to work holder services
Section 5 of the right to work code now lets a holder service confirm that someone doing work is the same person as a worker with a successful, still-valid right to work check. The certified service must cover both the identity and holder roles, with at least medium protection using medium-quality authenticators. Sharing matching images is optional, needs the user to understand it will happen, and needs a retention period agreed with the relying party. The right to rent code does not add this matching route.
What to do next
- Review the expiry limit and chip validation before offering the expired-document route.
- Update your report fields, and confirm registration at the time each check is made.
- Confirm your holder service scope, and explain the limits of reuse to customers.
- Agree CAB timing and customer communications. Gamma 0.4 services move directly to codes 1.1 with framework 1.0 under the transition arrangements; a valid Gamma 0.4 certification did not end on 1 October.
Use our transition note to prepare for that discussion, alongside OfDIA's transition guidance.
Official sources
- OfDIA's 1.1 update
- Dates and regulatory context, 3 September 2026
- Right to work code 1.1
- The full rules, on GOV.UK
- Right to rent code 1.1
- The full rules, on GOV.UK
- Transition from Gamma 0.4
- OfDIA, 3 September 2026