Monday morning, 7am. A warehouse in Birmingham. Five agency workers arrive for a shift. The site manager has a list of names from the staffing agency. Four of them match. The fifth says, "Dave couldn't make it. I'm covering for him."
The site manager looks at his clipboard, looks at the queue forming behind, and makes the decision that thousands of managers make every day across the UK. He hands over a lanyard and points to the floor. "Bay 12. Start with the pallets."
No ID check. No verification call to the agency. No record beyond a first name scrawled on a sign-in sheet.
That man worked an eight-hour shift, had full access to the facility, and left at 3pm. Nobody knows who he actually was.
1.1 Million Workers in the Shadows
The UK has approximately 1.1 million agency and temporary workers at any given time. They work in warehouses, construction sites, offices, factories, care homes, and logistics centres. They keep the economy moving when permanent staff can't fill the gaps.
But here's the problem: businesses invest significantly in verifying permanent employees. Background checks, right-to-work documentation, references, onboarding processes. For temporary and agency workers, the verification burden is assumed to sit with the agency.
And the agency assumes the client will check at the point of arrival.
The result? A verification gap wide enough to drive a forklift through.
Same Fines, Different Standards
The Fair Work Agency, launching in April 2026, doesn't distinguish between permanent employees and temporary workers. The penalties are identical: up to £60,000 per illegal worker, regardless of whether they're on your payroll or an agency's.
Let that sink in. If an unverified agency worker on your site turns out to have no right to work in the UK, you face the same fine as if you'd directly hired them without checking. The "we relied on the agency" defence has never held up well. Under the FWA's consolidated enforcement model, it won't hold up at all.
Yet the verification standards applied to temp workers remain dramatically lower than those applied to permanent staff. It's the biggest compliance gap in UK employment, and it's hiding in plain sight.
The "Dave Couldn't Make It" Problem
The substitution scenario isn't hypothetical. It happens constantly. Agencies fill shifts at short notice. Workers swap among themselves. Someone's car breaks down, someone else covers. The agency may not even know about the swap until after the shift is complete.
For the business, the person who shows up is essentially unverified. They present themselves as the person the agency sent. The site manager, under pressure to get the shift running, takes them at their word.
This creates three distinct risks:
Compliance risk. If the substitute worker doesn't have the right to work in the UK, you're liable. Not the agency. You. Because the worker was on your site, under your supervision.
Security risk. An unverified individual now has physical access to your premises, your stock, your equipment, and potentially your data systems. You have no verified record of who they are.
Safety risk. If there's an incident — an injury, an accident, a safeguarding concern — your records show "Dave" was on shift. But Dave wasn't there. And you can't identify who was.
Why SMEs Bear the Biggest Risk
Large enterprises often have managed service provider agreements, biometric access control, and dedicated compliance teams to manage agency worker verification. It's imperfect, but there's infrastructure.
SMEs have none of this. A typical small business using agency workers relies on the agency's assurance that workers have been vetted. There's no independent verification at the point of arrival. No technology layer. Just trust.
And here's the cost problem: traditional background checks run between £50 and £200 per person. For a business that cycles through 20 agency workers a month, that's an annual cost of £12,000 to £48,000 — just for background checks on people who might work a single shift.
Most SMEs simply can't afford that. So they don't do it. And the loophole stays open.
Closing the Gap: Affordable, Real-Time Verification
The solution isn't to make background checks cheaper, though that would help. The solution is to verify identity at the point of arrival — every time, every worker, every shift.
When the agency worker arrives on Monday morning, they scan a QR code. In 30 seconds, their identity is verified against their Certifyd profile. Their right-to-work status is confirmed. A timestamped record is created linking that specific person to that specific site at that specific time.
If "Dave couldn't make it" and someone else shows up, you know immediately. Not because you called the agency and waited on hold. Not because you checked a spreadsheet. Because the person standing in front of you either verifies against a known profile or they don't.
No lanyard until they verify. No exceptions. No loopholes.
The cost? A fraction of a traditional background check — because you're not re-running a full vetting process. You're confirming, in real time, that this person is who they claim to be and has the credentials they need.
For every business that relies on temporary workers, this is the difference between compliance theatre and actual compliance. Between hoping Dave's replacement is legitimate and knowing.
If your business uses agency or temporary workers, see how Certifyd closes the verification gap.