Right to Work Document Translation UK: Employer Compliance Guide
What employers need to know: when right to work checks need a certified translation, which documents to translate, and how to keep a statutory excuse against the £60,000 civil penalty.
The Legal Framework: Why Every Employer Must Check Right to Work
Right to work checks are not optional. Under the Immigration, Asylum and Nationality Act 2006, every UK employer must check that each new employee has the right to work in the UK. You must do this before the job starts. The duty applies to every employer, whatever your size — from a sole trader hiring one person to a large company with thousands of staff.
The rule itself is simple. You must not employ someone who has no permission to work in the UK. You must also not employ someone who is breaking a condition of that permission. In practice it gets harder. Candidates from overseas often bring identity documents, qualifications, and work records that are not in English. You need a certified translation before you can judge them properly.
What if you do not run a proper check, or do not get and keep the right translations? Your business can face a civil penalty of up to £60,000 per illegal worker. Repeat breaches or deliberate breaches can also lead to criminal charges. Directors and managers then face an unlimited fine and up to five years in prison.
Civil Penalty: The £60,000 Risk
From January 2024, the top civil penalty for employing an illegal worker went up sharply:
- First offence: up to £45,000 per illegal worker
- Repeat offence: up to £60,000 per illegal worker
- Penalties are worked out per worker, not per incident — five undocumented workers could cost you up to £300,000
- A statutory excuse is a complete defence against the civil penalty. You get one by doing a proper right to work check and keeping the evidence
When Employers Need Certified Translations
Many right to work documents are in English, or are bilingual, so they need no translation. A Romanian passport, for example, shows the holder's name, date of birth, and nationality in both Romanian and English on the bio page. A Biometric Residence Permit (BRP) is printed entirely in English.
But plenty of identity and immigration documents come in other languages. In those cases you must be able to read what the document says. You also need to check that it matches the right to work the person claims. You need a certified translation in these cases:
- National identity cards from EU/EEA countries where the key fields are not in English — especially Hungarian, Polish, Romanian, Bulgarian, Czech, and Slovak cards, where work conditions or status notes appear only in the national language
- Foreign birth certificates used to back up passport evidence, or with a List A document that depends on confirming nationality
- Immigration status documents from a foreign government that explain why a person could enter or live in another country, where you are using them to set out their UK immigration history
- Overseas qualifications and professional certificates sent in with right to work documents to meet the rules of bodies such as the NMC, GMC, HCPC, SRA, or RICS
- Overseas police certificates used in place of an enhanced DBS check, where the issuing country does not produce an English version
- Foreign court documents or immigration tribunal decisions that change a person's current right to work
Home Office Guidance on Translations
The Home Office Employer's guide to right to work checks says this: if a document is not in English, you should get a certified translation. The translation must:
- Be done by a qualified professional translator
- Include a signed statement from the translator. It must confirm the translation is accurate and that they know both languages well
- Be kept with a copy of the original document for the whole job, plus two years
- Be ready to show if the Home Office audits you
List A vs List B Documents: Translation Requirements
Right to work documents fall into two lists. It matters which list a document belongs to. The list sets how often you must re-check, and how long your statutory excuse lasts.
List A: Unlimited Right to Work
List A documents show an unlimited right to work. In other words, there is no time limit on the person's right to work in the UK. One proper check at the start of the job gives you a statutory excuse for the whole job. You do not need follow-up checks.
| Document | Language | Translation Needed? |
|---|---|---|
| UK passport (current or expired) | English / French (standard) | No |
| EU/EEA national ID card with Settled Status | National language of issuing country | Yes, if the key fields are not in English |
| UK full birth certificate + NI number | English | No |
| Certificate of registration / naturalisation as British citizen | English | No |
| Foreign passport with indefinite leave to remain stamp | Passport language + English stamp | The bio page is usually enough. Other pages not in English may need translation |
| Irish passport | Irish / English | No |
List B: Time-Limited Right to Work
List B documents show a right to work with a time limit. A statutory excuse from a List B document only lasts until the expiry date on the document. If there is no expiry date, it lasts 6 months (Group 2 documents). You must do a follow-up check before that excuse runs out.
| Document | Language | Translation Needed? |
|---|---|---|
| BRP card (Biometric Residence Permit) | English | No — BRPs are issued in English |
| Foreign passport with limited leave to remain visa | Passport language; UK visa in English | Not the visa page. Other pages not in English may need translation |
| Home Office letter / immigration status document | English | No |
| Application Registration Card (ARC) | English | No |
| EU Settlement Scheme digital status (eVisa) | English (digital) | No — checked via online right to work service |
| Frontier Worker permit | English | No |
Important: EU/EEA National ID Cards After Brexit
Since 1 October 2021, EU/EEA and Swiss nationals cannot use their national ID card on its own to prove their right to work. They must show their immigration status through the EU Settlement Scheme (Settled or Pre-Settled Status) or another immigration route.
An EU/EEA national ID card can still be used as extra proof of identity, or together with a digital EUSS status check. If the card is not in English and holds information that matters, get a certified translation and keep it on file.
Online vs Manual Right to Work Checks
The Home Office now has an online right to work checking service. Many checks can be done online, with no paper documents at all. So it helps to know where translations fit into each type of check.
Online Right to Work Checks
Online checks are available for:
- EU/EEA nationals with EU Settlement Scheme status
- People with an eVisa, which replaced visa stamps and BRP cards on most routes from 2024
- British and Irish citizens who have a valid UK passport and consent to a share code check
If the online check works, you do not need to keep any paper documents and no translation is needed. The digital record from the Home Office system is your statutory excuse. You do still need to save a clear screenshot or PDF of the result. It must show the person's name, the date of the check, and the right to work confirmation.
Manual Right to Work Checks
You still need a manual check when someone brings paper documents from List A or List B and has no share code. This covers many workers from outside the EU who hold BRP cards (now being phased out) or visa stamps in a passport. It also covers British citizens who do not want to use the online service.
For a manual check, you must:
- Get the original documents, not photocopies
- Check that they are genuine and belong to that person
- Take a clear copy of every page that holds relevant information
- Write down the date you did the check
- Get a certified translation of any document that holds relevant information and is not in English
- Keep copies of the documents and translations for the whole job, plus two years
What Standard of Translation Is Acceptable?
The Home Office does not keep a list of approved translators. But a translation must still meet a standard to count in a right to work check. For right to work, a certified translation must include:
- A full, accurate translation of the whole document, not just a summary or a part of it
- A signed statement from the translator. It must say the translation is accurate and complete as far as they know, that they know both languages well, and that they have no personal interest in the matter
- The translator's full name and contact details, so you can check their credentials if the Home Office asks
- The date of the translation
- A reference to the original document, with the document type and its reference number if it has one
Best Practice for Employers
The Home Office does not require translators to belong to any particular body. Even so, many employment law solicitors suggest using a member of the Chartered Institute of Linguists (CIOL) or the Institute of Translation and Interpreting (ITI). A professional service that gives you a signed certification on headed paper leaves the clearest paper trail for a Home Office audit.
Do not rely on AI-generated translations, or on a bilingual member of staff translating informally. That is not acceptable and will not give you a valid statutory excuse.
Professional Registration Translations: NMC, GMC, HCPC, SRA, RICS
Some sectors are regulated — healthcare, law, engineering, and surveying. Employers there must check two things: that the candidate has the right to work in the UK, and that they are registered with the right professional body. For staff who qualified abroad, this usually means their qualifications and registration certificates need certified translation twice over: once for the registration body, and again for your own HR records.
Nursing and Midwifery Council (NMC)
Nurses and midwives trained abroad must register with the NMC before they can work in the UK. The NMC asks for certified translations of:
- Nursing or midwifery qualification certificates
- Academic transcripts showing the subjects studied and the grades
- Registration certificates from the overseas nursing regulator
- Good standing certificates from previous regulators
- Competency assessment results, if they were done in another language
If you hire for an NHS Trust or a care home, ask for copies of the translated pack the nurse sent to the NMC. Keep it with your right to work records. That gives you one full HR file. It shows you meet both immigration law and the Care Quality Commission's fit and proper person rules.
General Medical Council (GMC)
Doctors trained abroad must show the GMC that their main medical qualification meets its standards. These documents usually need certified translation:
- Medical degree certificate
- Academic transcripts from medical school
- Internship or foundation year completion certificates
- Good standing letters from overseas medical councils
- Specialty training certificates, for doctors joining the Specialist or GP Register
NHS Trusts and private hospital groups that hire doctors trained abroad should keep copies of every translated document sent to the GMC. You may be asked for them at Revalidation or during a Care Quality Commission inspection.
Health and Care Professions Council (HCPC)
The HCPC registers 15 health and care professions. They include physiotherapists, occupational therapists, paramedics and radiographers. Social workers in England are registered by Social Work England instead, and have been since December 2019. Applicants who qualified abroad usually need translations of their qualification certificates, transcripts, and good standing certificates from overseas regulators.
Solicitors Regulation Authority (SRA)
Law firms that hire lawyers trained outside England and Wales must check their SRA authorisation. Some of those lawyers qualify here through the Solicitors Qualifying Examination (SQE), or transfer from a recognised country. In both cases you may need copies of their translated qualifications and overseas bar association certificates.
RICS (Royal Institution of Chartered Surveyors)
If you hire surveyors who qualified abroad, check their RICS membership with RICS directly. If they used overseas credentials in their membership application, ask RICS to confirm that the translated documents were accepted. Keep that confirmation in the employee's HR file.
| Body | Professions | Typical Translated Documents | Employer Action |
|---|---|---|---|
| NMC | Nurses, midwives | Qualifications, transcripts, registration, good standing | Copy NMC PIN confirmation + retain translated credential file |
| GMC | Doctors | Medical degree, transcripts, internship certificates, good standing | Verify GMC number + retain translated documents for Revalidation |
| HCPC | 15 allied health professions | Qualifications, registration, good standing | Verify HCPC registration number on public register |
| SRA | Solicitors | Law degree, overseas bar membership | Verify SRA number + check practising certificate annually |
| RICS | Surveyors | Overseas surveying qualifications, experience records | Verify RICS membership online + retain credential file |
Agency Workers and Contractor Compliance
Agency workers and contractors are one of the most common compliance gaps. Many businesses assume the agency carries the whole right to work duty, because the staff are not their own employees. That is not always true.
Under UK immigration law:
- Employment agencies that supply workers must run the right to work checks themselves. They must also get any translations needed before they place a worker with a client
- End-user businesses can rely on the agency's check for their own statutory excuse. But only on two conditions. The agency must confirm in writing that the check is done and the worker has the right to work. And you must get and keep that confirmation before the worker starts
- Umbrella companies are the employer of record for contractors. They carry the full right to work duty, translations included
- Personal service companies (PSCs) are contractors working through their own limited company. This case is less clear-cut. You usually do not need to check the right to work of a PSC director, because the deal is commercial rather than a job. But if the working set-up looks like employment under IR35, ask an employment law adviser to review it
Agency Worker Checklist for Employers
- Get written confirmation from the agency that it checked the right to work of every worker it sends you
- Ask whether the agency got certified translations of any documents not in English
- Ask for a copy of the check confirmation and file it before the worker starts
- Set a diary reminder to ask for fresh confirmation before any time-limited right to work runs out
- Do not rely on the agency's word alone — keep the evidence in your own HR system
DBS Check Translations: Overseas Police Certificates
Some roles need an enhanced Disclosure and Barring Service (DBS) check. The DBS only reports convictions held on the Police National Computer. That covers England, Wales, Scotland, and Northern Ireland. It does not cover criminal records from other countries.
So think about candidates who have lived outside the UK for six months or more in the past five years. For work with children or vulnerable adults, and in some other regulated industries, ask each of them for an overseas police certificate or criminal record check from every country involved. Many of these certificates come only in the national language, so you need a certified translation before you can assess them.
Police certificates from these countries often need certified translation for UK employment:
- India — Police Clearance Certificate (PCC) issued by the Passport Office
- Poland — Krajowy Rejestr Karny extract
- Romania — Cazier Judiciar
- Philippines — National Bureau of Investigation (NBI) Clearance
- Nigeria — Police Character Certificate
- Pakistan — Character Certificate issued by district police
- Bangladesh — Police Clearance Certificate
- Ghana — Criminal Record Certificate
- Kenya — Certificate of Good Conduct
- Sri Lanka — Police Clearance Certificate
Employers in education, healthcare, social work, and financial services meet this need most often. The translation must be certified. Get it before the person starts work in a regulated activity.
Overseas Police Certificates: Key Points
- An overseas police certificate is not a substitute for a DBS check. The DBS treats it as an extra document
- These certificates need a certified translation. Self-translated or informal versions are not enough
- Some countries issue bilingual certificates (South Africa, for example), which may need no translation
- Check the Home Office's country-by-country guidance on overseas criminal record checks for the right process
- Keep translated certificates in the employee's HR file for the whole job, plus any period the law requires
Frequently Asked Questions
Do I need a certified translation for a Polish national ID card presented for right to work?
A Polish national identity card shows key details in Polish: the holder's name, date of birth, and expiry date. Since October 2021, Polish nationals cannot use the card on its own. They must show their EU Settlement Scheme status or another immigration route. If you keep the card as extra proof of identity next to an online EUSS check, a certified translation of the key fields is wise. It keeps your HR record complete. And if the card carries work conditions or status notes that matter, you need a full certified translation.
Can I use Google Translate to translate a right to work document?
No. Machine translations — Google Translate and other AI tools — are not accepted for right to work checks. The Home Office wants a certified translation. It must carry a signed statement from a qualified human translator, confirming the translation is accurate and that they know both languages well. A machine translation gives you no valid statutory excuse. It will not protect you from a civil penalty if the document turns out to have been misread.
How long must I keep translated right to work documents?
Keep copies of all right to work documents — certified translations included — for the whole time the person works for you, and for two years after they leave. This applies however the job ended: resignation, redundancy, dismissal, or anything else. Store the documents securely, in line with your GDPR duties. Two years is a minimum, not a maximum. Many HR teams keep records for longer, because a Home Office audit can come years later.
My employee presented a BRP card. Do I need a translation?
No. Biometric Residence Permits are issued in English, so they need no translation. The card shows the holder's name, date of birth, nationality, permission to work, and the expiry date of their leave. From 2024, most BRP cards are being replaced by eVisas, which are digital. If your employee has an eVisa, do the check on the Home Office's online service using their share code. There is no paper document, so there is nothing to translate.
What happens if I accept a document I didn't realise needed translation?
Say you accept a document that is not in English and get no certified translation. If the employee later turns out to have no right to work, you have no valid statutory excuse. You could then face the full civil penalty of up to £60,000 per illegal worker, even if you acted in good faith. If you spot the gap later, get the certified translation at once and file it with your right to work records. That does not fix the gap. But it shows you tried to stay compliant, and it may reduce a penalty if one is issued.
Need a Certified Translation for Right to Work Compliance?
Our certified translation service gives you compliant translations with a full translator declaration. They are accepted by the Home Office, professional registration bodies, and DBS providers. Fast turnaround, fixed prices, no hidden fees.
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