In an open letter to Jenrick, Carberry praised the digitisation of the process but raised concerns over current implementation.
Concerns cover domestic worker charges for document checking, use of expired passports and standards and certification for identity service providers (IDSPs).
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The REC first raised concerns over the cost of digital right to work checks in January 2022.
In a letter to then parliamentary under-secretary of state for immigration compliance Tom Pursglove, it raised the fact that overseas candidates are able to use a free employer checking service, whereas recruiters would have to pay the charge or ask British candidates to come in with their documents.
Carberry reiterated the confederation’s concerns in November’s letter, adding: “[The current system] takes much longer and disadvantages workers who have to pay – either for the check or for travel and time off work to do the check. Ultimately, it means it is longer to get UK candidates into work.”
Carberry likewise denounced the fact that expired passports – fine for in-person checks – cannot be used as proof of identity for digital checks as inconsistent.
He added: “Recruiters are finding it also acts as a barrier to work-seekers in some communities and among lower paid people, who cannot afford and don’t need a new passport.
“Even where the cost is not an issue, the backlog in issuing new passports is causing some to experience delays of several months.”
A new passport costs £75.50, or as high as £177 if gained through priority processing to bypass a 10-week wait.
This delay, he said, is hurting businesses badly in the face of staffing backlogs.
The government named the Post Office and identity verification platform Yoti as the first certified IDSPs in June 2022 and since then 15 more providers have received certification.
However, Carberry expressed concern over the quality and consistency of the processes used by providers.
The Home Office has not yet prescribed a standard mechanism for the checks and providers use a variety of different technologies and systems which Carberry said causes confusion.
Similarly, while it is recommended that businesses use a government-certified provider, it is not required.
“This leaves businesses, particularly SMEs, vulnerable to unscrupulous and uncertified providers offering non-compliant right to work checks,” said Carberry.
Speaking to HR magazine Gary McIndoe, managing partner and director of immigration law firm Latitude Law, agreed with Carberry.
He said: "The fees quoted for digital identity document validation technology (IDVT) checks may seem minor, but for larger employers with high staff churn rates they will prove a significant cumulative cost to ongoing recruitment efforts.
"An absence of regulation in this area is a further red flag for a new system of this kind."
Victoria Short, CEO at recruitment firm Randstad UK, also shared many of the concerns raised in the letter, and agreed the system needed review.
She told HR magazine: "Until issues such as those raised by REC are addressed, the implementation and execution of the digital right to work checks will continue to have implications on the ability of business and large public sector employers to meet their staffing needs."
Stephan Judge, director of immigration law firm Vialto Partners, however, reminded critics that though there are opportunities to improve the system, it is important to celebrate the merits of the digital process.
Speaking to HR magazine, he said: "The UK has one of the best digital immigration systems in the world and most countries are still trying to catch up with the quality of our systems and tech. I could definitely find improvements, but that shouldn’t take away from how well the new system is working.”
A Home Office spokesperson said: “We are committed to continuing to modernise and digitise the Right to Work Scheme and support employers by simplifying checks and processes."
