Applies to England. Guidance checked on 24 September 2026.
From 1 October 2026, landlords who use an outsourced digital service for Right to Rent checks must use one certified and registered specifically for that purpose. Manual checks remain available, and the Home Office share-code service remains a separate route.
For HMO landlords, the practical question is whether each adult occupier has the correct check, a retrievable record and someone responsible for any follow-up. A passed tenant reference does not answer all three.
What changes on 1 October?
The government’s explanation of the digital-check changes confirms that an outsourced digital service must be certified and registered against the relevant Right to Rent requirements. General identity verification or registration for another purpose is not enough.
Use the official digital verification services register to check the actual service carrying out the check. A referencing company may use a separate identity provider.
The code taking effect on 1 October 2026 also widens the evidence permitted for digital checks. It includes British or Irish passports and Irish passport cards expired by up to six months, subject to the required chip verification. Confirm that the provider supports the document and the prescribed check.
You do not have to buy a digital check for every applicant.
Which Right to Rent route should you use?
The appropriate route depends on the person’s status and available evidence. These are the three main checking routes:
Manual document check
Check permitted original documents, confirm they belong to the person, and retain the required copies and check date. An emailed passport photo alone is insufficient.
Home Office online check
Use the applicant’s Right to Rent share code and date of birth, check the result and identity match, and save the dated profile. Keeping the share code alone is insufficient.
Registered digital provider
Use a service registered specifically for Right to Rent. Check its result, complete the required person match and retain the evidence.
British and Irish citizens cannot obtain a Right to Rent share code. For applicants who can, use the Home Office landlord checking page, rather than accepting a screenshot of their own immigration account.
If acceptable documents or a share code are unavailable, follow the Home Office guidance on the Landlord Checking Service. It can resolve certain cases, including outstanding applications or appeals. Missing documents do not automatically mean someone has no right to rent.
A tenant reference can pass without completing Right to Rent
During our review of referencing providers at Confidence Property, one provider confirmed that its standard reference did not include the prescribed British or Irish Right to Rent identity and document check. That check was available separately.
This is an easy gap to miss. A reference may cover income, employment and credit history, while Right to Rent evidence sits in a different report or workflow.
When reviewing your own process, ask: “Where is the completed Right to Rent record for this applicant?” A general “reference passed” status is not a substitute.
For an HMO, record completion against each occupier. A property-level tick box can hide a missing check when rooms change hands at different times.
Five checks before your next HMO letting
1. Identify everyone who needs checking
For an ordinary private HMO letting, check each adult aged 18 or over who will use it as their main home, including someone not named on the agreement. The Home Office rules on who to check also explain the scheme’s exceptions.
2. Choose the route and check the timing
Confirm what evidence the applicant can provide and which prescribed route applies. For time-limited permission, the initial check normally needs to fall within the 28 days before the tenancy starts. Build this into the pre-tenancy process.
3. Confirm who is responsible
If an agent handles checks, record that arrangement in writing. Make clear who handles initial checks and any required follow-ups. This matters especially when an agent finds the tenant but the landlord takes over afterwards.
4. Keep evidence you can retrieve
Save the required documents or report, check date and identity-match evidence securely against the relevant occupier. Follow the Home Office retention requirements: retain the required records throughout the tenancy and for one year after it ends.
5. Record any follow-up requirement
Check whether a further check is needed under the current guidance, then record its deadline and owner. Do not rely on someone remembering. The Home Office follow-up guidance is the starting point; requirements depend on the person’s circumstances.
Apply the process consistently. The Home Office anti-discrimination code explains why applicants must have a fair opportunity to use acceptable evidence. Do not make assumptions from someone’s name, accent or appearance, or disadvantage them for using a valid alternative to a digital check.
Do existing tenants need checking again on 1 October?
There is no blanket requirement to repeat a correctly completed check simply because the new code takes effect. Earlier checks are assessed against the rules that applied when they were made.
Any follow-up already required still needs to happen. Use the applicable rules when that check becomes due.
How Confidence Property can help
Right to Rent checks are included in our HMO letting and management services in Manchester. Your service agreement sets out the work we handle.
If you manage the property yourself, use the five checks above to review your next letting. If keeping track of referencing, evidence and follow-ups is becoming difficult, talk to us about the service you need.
You can also read our guide to the workload and costs of self-managing an HMO.
