Picture this: you’ve been looking for the perfect candidate for a hard-to-fill role for six months. You’ve finally found the one, they’ve accepted the offer, and you’re off to background checks.
But they’ve got a six-month gap in their CV that’s sounding alarm bells in your head. What do you do?
Gaps in employment history are often misunderstood, and their treatment in background screening processes has long been inconsistent, especially in the UK.
At Zinc, we believe it's time to reframe the conversation around employment gaps and offer a more modern, compassionate, and compliant approach.
That’s why we’re diving deep into:
- The difference between gap analysis and gap verification
- The origins and purpose of gap checks
- Where gap checks are still used and how regulation has changed
- The pitfalls of outsourcing gap verifications
- The best practice approach for employers using Zinc
Let’s get started.
What’s the difference between gap analysis and gap verification?
First things first: some definitions.
Gap analysis is identifying and reviewing periods in a candidate’s employment history that are not accounted for by verifiable employment, registered unemployment, study, or other activity.
Gap verification is when you attempt to find evidence or assurance about those periods. This often means asking for travel documents, medical notes, personal references, or even bank statements to explain what the candidate was doing during that time.
In simple terms:
- Gap analysis = identifying a gap
- Gap verification = evidence gathering to prove the reason for the gap
Zinc allows employers to capture explanations directly from the candidate - a transparent, respectful, and effective approach.
A brief history of gap checks
Like queuing and moaning about the weather, gap checks are a UK-born phenomenon, with little significance outside of UK hiring.
We can trace it back all the way to the 1980s:
- When US financial institutions expanded into the UK, they brought expectations around background checks.
- At the time, UK criminal record and credit checks were either unavailable or rarely used.
- As a workaround, ex-police officers and private investigators were tasked with reconstructing employment timelines to check for potential hidden criminal activity.
- The logic: if someone had a “gap,” and you couldn’t say what they were doing, it was a potential risk.
Checking for gaps in employment became an established practice in the UK despite its subjectivity, intrusiveness, and inefficacy. Gaps in employment history became stigmatised, and gap verification was here to stay.
Where are gap checks still commonly used?
Gap checks are not common outside of the UK but they persist in a few UK-regulated sectors, including:
- Private security: Under BS7858:2019, employers must verify continuity of activity, including gaps exceeding 31 days.
- Aviation: For workers needing airside access, under CAA regulation gaps over 28 days need to be covered by personal references (if they can’t be evidenced by HMRC, JSA or Universal Credit statements).
- Some financial services institutions: Requirements are often misunderstood or overstated. The FCA does not impose gap checks on firms as part of assessing Fitness and Propriety under the Senior Managers and Certification Regime (SMCR). This used to be a recommended approach for Approved Persons when financial services in the UK were regulated by the Financial Services Authority (FSA). Confusion abounds because the outdated practice has been maintained by some Bank Panels who still insist on gap verifications for the firms that they advise, and for their supply chain.
Elsewhere, including healthcare, education, and most regulated roles, employers are usually expected to ask candidates about gaps during interviews, but are not automatically required to verify via documents or obtain personal references.
Regulatory changes and current requirements
Gap verification is no longer a regulatory necessity in most UK sectors. Key examples:
- FCA (post-2013): It’s no longer a requirement to verify gaps over 31 days. The only expectation is that firms provide an explanation for any gap in the 10-year history of a Senior Manager, but even that does not require evidence.
- BPSS (May 2024 update): Employers must only enquire about gaps exceeding six months (consecutive or cumulative) in the past three years, demonstrating the lack of interest and associated risks related to gaps in employment.
- There’s no explicit requirement for gap evidence under NHS, teaching, or many other public sector frameworks. The requirements focus on obtaining explanations for such gaps rather than formal verification.
Regulators have moved on. But many outsourced screening providers have not, because more checks = higher profits, regardless of how effective they are.
Why outsourced gap verifications are problematic
Outsourcing gap checks might seem like a great solution (who doesn’t love less admin?), but it’s rarely the right one. Here’s why:
1. They’re deeply intrusive and often inappropriate
During standard outsourced gap verifications, candidates are routinely asked to supply documents for distressing life events. This can include being asked to provide medical notes, death certificates, or explanations around miscarriages, gender reassignment, or mental health issues.
These requests can be dehumanising, especially when routed through third parties focused on SLA fulfilment, not compassion.
2. They’re wide open to fraud
Fake documents are easy to purchase or forge. Screening providers cannot reliably validate authenticity of documents used as evidence of activity unless they inspect originals, which isn’t always possible. Best practice is for employers to view original documents instead on a case-by-case basis.
Character references, when used, are functionally meaningless (obviously, no candidate will offer a reference who won’t confirm their story).
3. There’s no regulatory justification
In most cases, there’s no legal or regulatory requirement to obtain or retain documentary proof of gaps.
4. It’s bad for your candidate experience
Gap checks are consistently one of the most frustrating elements of background screening for candidates. Gap verifications cause more delays and candidate complaints than any other element of a background check programme.
The personal nature of many employment gaps (bereavement, illness, parenting, etc.) demands sensitivity, compassion and flexibility, not administrative box-ticking.
What’s the best way for employers to approach employment gaps?
The short answer? Act like a normal, compassionate person who understands that everyone’s life path is different.
At Zinc, we recommend a modern, human-centred approach:
1. Ask, don’t demand
Use the Zinc platform to simply ask the candidate to explain any gaps that appear in their history. Most will be happy to do so and offer a reasonable explanation.
2. Avoid document collection where not needed
Only request supporting documentation if:
- You genuinely need it to satisfy a regulatory requirement and
- You are handling it yourself, with proper care and empathy and
- You are going to inspect any original documents in order to mitigate fraud
3. Use interview time wisely
Discuss employment gaps in interviews, as part of assessing the candidate’s journey and context. This builds trust and understanding, and lays the ground for employment screening.
4. Stay up-to-date with regulation
Don’t rely on outdated practices or provider templates. Zinc ensures its platform and guidance align with the latest regulations.
Final thoughts: Why Zinc doesn’t support outsourced gap verifications
Gap verifications, when misapplied, erode candidate trust, cause extensive delay, offer dubious risk mitigation, and fail to reflect current best practice.
Zinc takes a different approach:
- Transparent, candidate-driven disclosures
- A process built around efficiency and dignity
- Opportunity for case-by-case employer review when appropriate
By shifting from outdated verification practices to candidate-owned explanations, employers actually reduce fraud risk, minimise delays, and deliver a better experience without compromising on diligence or compliance.
Still have questions?
If you're unsure how to approach employment gaps in your hiring or compliance processes, we’re here to help. Zinc can guide you to stay compliant while delighting your candidates and treating them with empathy and professionalism.
