Last reviewed: 17 May 2026
TL;DR: Arrivals with the right to work in the UK can legally start a job before their National Insurance (NI) number is issued. The employer follows the HMRC starter procedure using a Starter Checklist, applies a temporary tax code, and adds the NI number to payroll once it is issued. Tax and NI contributions deducted during the wait are reconciled at that point. The right-to-work check on the immigration document is the binding legal requirement, not the NI number.
Key facts
- Right to work for arrivals is established through the immigration document or eVisa share code, not by the NI number; gov.uk/check-job-applicant-right-to-work sets out the employer check.
- HMRC's new-employee process at gov.uk/new-employee allows an employer to onboard an arrival without an NI number by using the Starter Checklist while DWP processing continues.
- In the absence of a P45 and without the Starter Checklist completed correctly, the emergency tax code 0T applies during the wait, deducting tax at basic, higher, and additional rates with no personal allowance.
- Where Statement A or B on the Starter Checklist is correctly recorded, the emergency tax code applied while waiting for the NI number is 1257L on a Week 1 or Month 1 basis until HMRC issues a full code.
- NI contributions paid before the NI number arrives are reconciled against the arrival's record once the number is on payroll, so contributions are not lost during the wait.
Right to work versus NI number: the binding visa check while waiting for NI
The legal question facing a new arrival offered a UK job is not whether they have an NI number but whether they have the right to work under their visa. The NI number is an administrative identifier used by HMRC and DWP. The right to work is the legal permission granted by immigration status. An employer who hires a worker without checking right to work commits a civil penalty offence; an employer who hires an arrival without an NI number while waiting for NI commits no offence.
For arrivals on a Skilled Worker, Graduate, Health and Care Worker, family, or refugee route, the right to work before the NI number arrives is shown by the eVisa share code from gov.uk/view-prove-immigration-status, a current BRP, or an EUSS share code for those with pre-settled or settled status. The employer follows the check at gov.uk/check-job-applicant-right-to-work, records the result, and that check is sufficient to start work even though the NI number has not yet arrived. For how long the NI side takes, see the companion article on NI number processing time.
The HMRC new-employee procedure for arrivals waiting for NI
HMRC has a long-standing procedure for new starters who have no NI number yet, designed for arrivals in the gap between visa onboarding and DWP issuing the number. The procedure is set out at gov.uk/new-employee. The employer enters the arrival's personal details on payroll, completes a Starter Checklist with the worker, and leaves the NI number field blank on the Full Payment Submission (FPS) sent to HMRC each pay period. Once the NI number is issued by DWP, the arrival tells the employer, who updates the payroll record. From that point onward FPS submissions carry the number and HMRC links the prior submissions back to the same record.
The Starter Checklist and tax codes while your NI number is pending
The Starter Checklist asks the arrival to confirm one of three statements: A, this is the first UK job since the start of the tax year with no other income; B, this is now the only UK job but the worker had another in the same tax year; or C, the worker has another job or pension. The statement determines the starter tax code the employer applies while waiting for the NI number. Statement A or B produces 1257L on a Week 1 or Month 1 basis until HMRC issues a fully cumulative code. Statement C produces the BR code, deducting basic rate on the whole wage with no personal allowance.
If the Starter Checklist is not completed (a common pitfall for arrivals rushed into onboarding), HMRC's default emergency code is 0T on Week 1 or Month 1. This deducts at basic, higher, and additional rates with no personal allowance. The 0T deduction is reconciled later when HMRC issues an updated code or after the tax year end; overpayment is repaid through payroll or by HMRC directly.
NI contributions deducted before your NI number arrives
National Insurance is deducted from the pay of any liable worker, including an arrival who has the right to work but has not yet received the NI number. Contributions are calculated against the band rates and recorded on the FPS with a blank NI number field. Once the NI number is added to the arrival's payroll record, HMRC links the prior contributions to the correct individual's NI record. They count toward State Pension qualifying years, contribution-based benefits, and Maternity Allowance entitlements. Contributions deducted during the wait are not lost.
Payslip implications while waiting for NI
A payslip issued before the NI number is in place typically shows the NI number field blank or as a placeholder generated by payroll software. The placeholder is not transmitted to HMRC as a real number. Some older systems insert a string such as TN followed by date of birth; this is internal and has no validity. As soon as the arrival passes the NI number to payroll, it appears on subsequent payslips.
Right-to-work documents arrivals use before NI arrives
The documents commonly used to evidence right to work for an arrival starting before the NI number are the eVisa share code from gov.uk/view-prove-immigration-status (now the standard route for most visa holders), a current BRP within its validity (BRPs have not been reissued since 31 December 2024, with eVisa replacing the card), an EUSS share code for EU, EEA, and Swiss citizens with pre-settled or settled status, and a visa vignette plus a recent entry stamp where the eVisa or BRP is not yet available. All are accepted before the NI number arrives because the right to work runs off the visa, not the NI record.
What goes wrong for arrivals onboarding before NI
The two most common problems for arrivals starting work before the NI number are administrative. The first is the Starter Checklist being skipped or completed incorrectly in the rush of the first week, leading to the 0T emergency code and inflated deduction during the wait. The fix is to complete the Checklist promptly and ask payroll to update the code. The second is the employer recording an incorrect placeholder in the NI field, which requires a small correction when the arrival passes the real number through. Neither prevents the arrival from being paid, but both can create payslip oddities until DWP processing completes.
When your NI number finally arrives after the wait
When the DWP confirmation letter arrives at the arrival's UK address (or a forwarding employer or sponsor address), the worker passes the number to payroll. It is added to the record and starts appearing on the FPS to HMRC. HMRC links prior submissions made under the blank NI field to the arrival's record using name, date of birth, address, and employer reference, cross-referenced against the immigration record built by the right-to-work check. The personal tax account at gov.uk/personal-tax-account then shows employment details, tax paid during the wait, and NI contributions, closing the loop on the migrant onboarding lifecycle that started at visa grant.
Disclaimer
This article is general information about UK rules and processes at the time of writing. It is not legal, immigration, tax, or financial advice. Rules and figures change. Verify the current position with the relevant authority (gov.uk, HMRC, FCA, or a regulated adviser) before acting on anything here.
Frequently asked questions
Can a UK employer refuse to start an arrival without an NI number?
An employer can choose its own onboarding policy, but there is no legal requirement under HMRC rules to have an NI number before an arrival starts work. Many employers do start arrivals before the NI number arrives, particularly large licensed sponsors of Skilled Worker visa holders.
Will an arrival be taxed more while waiting for the NI number?
Tax depends on the tax code, not the NI number. The Starter Checklist sets the code, and completing it correctly avoids the heavier 0T emergency deduction that otherwise applies during the wait.
Do NI contributions accrue for an arrival before the NI number is on the payslip?
Yes. Contributions deducted before the NI number is on payroll are linked to the arrival's record once the number is added, so qualifying years are not lost during the wait.
What if HMRC issues a refund before the arrival's NI number arrives?
HMRC typically waits until the record is matched to the arrival's NI number before issuing a refund, to ensure the refund is paid to the correct immigration-linked identity.
Is a P45 needed for an arrival starting their first UK job?
No. A P45 is only relevant if the worker had a previous UK job in the same tax year. New arrivals starting their first UK role use the Starter Checklist instead while waiting for the NI number.
