What an EAS audit actually looks for, and how to keep your records ready for one

An Employment Agency Standards Inspectorate visit, whether prompted by a specific complaint or a routine check, tends to focus on a small number of concrete questions: was a document issued at the right point, does the paperwork on file match what the worker was actually told, and can the agency produce the relevant record quickly when asked. None of this rewards good intentions on their own — it rewards being able to show the work.

What tends to get asked for first

In practice, an inspection usually starts with a sample of recent placements rather than a full review of everything an agency has ever done. For each one, the questions are consistent: was a Key Information Document issued before terms were agreed, is there evidence of a right to work check completed and dated, and do the terms on file match what the worker and the hirer actually operated under.

Why speed of retrieval matters as much as the record existing

A record that technically exists somewhere but takes half a day to locate doesn't function well under inspection pressure, even though it's technically compliant. The practical bar isn't just "do we have this" — it's "can someone who wasn't involved in the original placement find it within minutes." Building records against a consistent, predictable structure per worker, rather than scattering them across email, a CRM and a shared drive, is what makes that possible.

What consistently causes problems

• –Records that exist but were never dated, so it's impossible to demonstrate a KID or right to work check happened at the right point in the sequence.
• –A generic document template that doesn't reflect the specific engagement, discovered only when an inspector asks a specific question about a specific worker's pay structure.
• –Paperwork that's technically retained but spread across several systems with nobody able to produce a complete picture quickly.
• –A gap discovered for one placement that turns out, on closer look, to reflect a pattern across several others, rather than being genuinely isolated.

Treating an internal audit as a dry run

The agencies that handle a real inspection calmly tend to be the ones that periodically run their own version first — pulling a handful of recent placements and honestly checking whether each step was completed, evidenced, and dated in the right order. This isn't about distrust of the team running placements; it's the same logic as any operational quality check, applied before an external party has a reason to look.

What good remediation looks like if a gap is found

Finding a gap during a self-audit is a far better outcome than an inspector finding it first, but only if it's actually acted on — completing the missing step immediately, checking whether the same gap exists elsewhere, and, where the gap points to a process weakness rather than a one-off, fixing the process itself rather than treating it as one placement's bad luck.

Record retention as a standing habit, not a response to pressure

It's tempting to think about record-keeping discipline only once an inspection or a specific dispute is already live. By then there's no time left to build a better filing system — the practical response is treating consistent, dated, retrievable records as a standing operational habit, in the same way right to work evidence specifically needs a clear retention approach, rather than a project to tidy up if and when something forces the question.

Complete records that cannot be produced

Most agencies hold more than they can retrieve. Candidate documents in one system, references in an inbox, timesheets with a payroll provider, client contracts on a shared drive, and compliance evidence attached to a placement record nobody can find once the consultant who made it has left.

The test worth applying is a single placement: produce everything relating to it — candidate checks, references, contract, timesheets, evidence of right to work — within an afternoon. If that requires several people, the records exist but retention does not.

Common mistakes

• –Evidence spread across systems, inboxes and personal drives
• –Records tied to a consultant rather than held by the business
• –No single view of everything relating to one placement
• –Retention periods not defined, so records are kept or discarded arbitrarily
• –Deleting on departure rather than retaining for the required period
• –Discovering the gaps only when a client requests a specific file