In just one week in July 2025, 1,780 delivery workers were stopped by UK police as part of a national clampdown on illegal migrant workers. Following the government’s launch of its flagship national digital ID program, it is likely that last-mile logistics will find itself in the crosshairs once more.
The digital ID announcement has been hitched to the government’s efforts to ‘make it tougher to work illegally in this country’. While it deliberately aligned a controversial policy with the political zeitgeist of illegal migration, the government has done little to explain why businesses and workers would benefit, or how tit is going to push adoption and root out the cases where businesses either ignore, or actively avoid, checking individuals’ right to work (RTW).
What is clear is that the Home Office is tooling up for a showdown with industries where illegal work is commonplace. The consequences of breaches will be hard felt by logistics businesses, especially where they lean on informal or temporary workers. Financial penalties for repeat faults now reach £60,000 per worker. Pavement arrests disrupt operations, creating uncertainty that affects legitimate businesses operating in the same areas. More significantly, reputational damage is hard to undo when end customers discover exploitation in their supply chain – and under UK law, end users remain liable even when working through intermediaries.
Last-mile parcel and post services are ground zero for RTW challenges. Low barriers to entry, easily acquired skill requirements and high workforce turnover create an environment where compliance becomes exponentially harder to maintain. Gig work, which has long since revolutionized ride hailing and food delivery services, creates a vast skeleton workforce which now underpins much of the UK’s rapid last-mile fulfillment carried out by gig-economy delivery platforms. While flexible carrier procurement is table stakes for successful e-commerce and parcel providers, it also creates unique compliance challenges.
Workforces flex daily across bicycle, motorbike, car and van routes. The supplier base is incredibly fragmented. Limited skill, language and compliance requirements lower barriers to entry. Vehicle rentals lower sunk costs. With over 56,000 couriers working in the UK gig economy – 48% of whom are self-employed, the second-highest rate of any sector – thousands of MSMEs, sole traders and agency workers constantly churn in and out of the industry, and seasonal peaks create onboarding bottlenecks where it becomes near impossible to maintain reliable assurance that fleets are compliant with RTW regulations and other crucial requirements, such as vehicle standards and insurance verification. Many last-mile providers turn to two popular strategies – partnerships and digital platforms – to help them deal with the surge.
Partnerships, such as with delivery service providers (DSPs), help providers to aggregate the fragmented supplier base. For large organizations managing hundreds or thousands of drivers, this approach is often operationally necessary; however, it creates blind spots where unknown and potentially non-compliant operators can gain access to delivery networks.
Under UK law, the business ultimately using the delivery services remains liable when RTW breaches occur, regardless of how many layers of subcontracting exist. While this has long been true in principle, enforcement agencies are now actively pursuing this liability chain in practice. The Modern Slavery Act 2015 compounds this risk – businesses face reputational and legal consequences when exploitation is discovered in their supply chains, even several layers removed. Recent investigations into e-bike courier networks have exposed how account-sharing schemes can mask modern slavery, turning what many operators dismissed as a technical compliance issue into a material business risk.
Unlike the DSP model, digital platforms and delivery apps grant businesses direct access to their supplier base. Many platforms enable the ‘right to substitute’ – allowing account holders to send replacement workers – which, while legitimate in principle, has spawned a shadow marketplace of account-sharing platforms where verified accounts are rented to non-compliant workers.
The solution isn’t to eliminate flexibility or substitution rights, but to shine a light into these dark pools. Businesses need frameworks that ensure whoever actually performs the work – substitute or not – meets the same compliance standards. Without this visibility, account sharing enables exploitation of vulnerable workers, some of whom become victims of debt bondage and modern slavery.
Food delivery platforms have committed to collaborating with the government to crack down on abuse: “Efforts by the companies to crack down on illegal account sharing through real-time identity and right to work checks have been successful”, the Home Office claims. “Despite this, there continues to be abuse in the system.”
Unless online platforms have a seamless and scalable way of verifying who is operating in their logistics network for every load, every day, bad actors will find ways to profiteer from loopholes. When the stakes for non-compliance are so high, the prospect of relying on the UK’s typically sluggish public sector to deliver technologically complex, time-sensitive integrations with its national digital ID service is unattractive, to say the least.
The government has set a target for digital ID to be mandatory for RTW checks by the end of this Parliament in 2029. It is not clear whether that deadline will be met. The requirement to build secure systems which build and maintain public trust will be a notable snag: whistleblower reports of “serious data protection failings” in the government’s existing ‘One Login’ ID for public services highlighted data security as one of several issues that might plague the planned rollout.
So, how can last-mile logistics businesses protect themselves from regulatory scrutiny, hefty fines and operational disruption while building customer confidence? The good news is that businesses don’t need to wait for the government’s 2029 deadline. A network of identity service providers already exists, accredited to perform right to work checks under the government’s Digital Identity, Attributes and Trust Framework (DIATF). One-third of the 15 million right to work checks done by UK businesses each year already use DIATF-accredited platforms – proving the technology works at scale today.
The Trustd platform has been built specifically for the complexities of transportation and logistics operations. Trustd understands that verification needs to happen at the speed of parcel delivery, not at the pace of bureaucracy.
For operators ready to move, three practical steps stand out:
- Pick a platform that fits logistics. Look for mobile-first design, API-friendly integrations with driver apps and your TMS, and facial verification capabilities that don’t slow down operations.
- Standardize with your partners. Require DSPs and agencies to use the same verification rails and share status signals upstream, in real time. Fragmented systems create the blind spots that enforcement agencies exploit.
- Start with your highest-risk routes. Pilot in areas with high churn or seasonal spikes. Measure what matters: time-to-onboard, compliance exceptions prevented and audit effort saved. Use those results to build the business case for wider rollout.
The last-mile sector has always thrived on speed and flexibility. Digital identity verification, done properly, enhances both rather than constraining them. The question isn’t whether to adopt these tools – it’s whether your business can afford to be caught flat-footed when the next enforcement wave arrives.
The government has signalled its intentions clearly. Smart operators won’t wait for mandates to act.