Immigration Enforcement Activity at Record Levels: Employer Impact

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Anne Morris

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Key Takeaways

 
  • Immigration enforcement activity is at record levels in the UK, with the Home Office reporting sharp increases in raids and arrests since July 2024.
  • Heightened activity signals increased likelihood of employer site visits across sectors.
  • Enforcement visits can quickly escalate into civil penalties, sponsor licence scrutiny, wider workforce audits and reputational fallout if right to work records are incomplete or inconsistent.
  • Right to work checks are to be expanded to cover gig, casual, subcontracted and temporary labour, extending compliance exposure.
  • Employers are reminded to ensure right to work check compliance, training staff and retaining adequate records.
 
The Home Office has confirmed that immigration enforcement raids and illegal working arrests are now at the highest level ever recorded in the UK.

For employers, the headline figures matter less than the underlying shift in enforcement posture. Illegal working is no longer treated as a peripheral compliance issue or one limited to certain sectors. Enforcement activity is now evidently sustained, well-funded and increasingly forensic, with officers now routinely equipped with body-worn cameras. Visits are evidence-gathering exercises, designed to support civil penalties, criminal prosecutions and wider compliance action, and employers are warned to be prepared in case the Home Office comes calling.

SECTION GUIDE

 

Home Office Boasts of Record Enforcement Activity

 

The Home Office has published a press release, reporting immigration enforcement activity to be at record levels in the UK.

Between July 2024 and the end of December 2025, raids increased by 77 percent and arrests rose by 83 percent. More than 17,400 enforcement visits were carried out nationally, resulting in over 12,300 arrests. Northern Ireland alone saw 187 raids in 2025, leading to 234 arrests.

Site visits and audits are no longer informal or advisory in tone. They are used to gather evidence to support illegal working allegations or other immigration compliance breaches.

Sectors traditionally associated with higher risk, such as hospitality, construction, car washes, nail bars and takeaway businesses, remain heavily targeted. However, enforcement is not limited to these areas. The Home Office has made clear that illegal working is being pursued wherever it occurs, including through subcontracting arrangements, casual labour models and supply chains where accountability is often assumed rather than verified.

Civil Penalty Referral Notices continue to be issued where illegal working is identified. Financial penalties can be substantial, but fines are rarely the most damaging outcome. Enforcement action frequently triggers follow-on scrutiny, including sponsor licence investigations, wider workforce audits, reputational damage and, in some cases, criminal liability.

The announcement also sits alongside the government’s stated intention to move towards mandatory digital identity and digital right to work verification by the end of the current Parliament. Employers should not treat this as a future problem. Enforcement teams are already operating on the assumption that employers are capable of running robust, auditable and technology-supported checking processes now.

 

Common Employer Errors

 

Illegal working exposure rarely arises from deliberate non-compliance in established businesses. It more commonly stems from weak systems, unintended oversights and outdated assumptions.

Common risk points include inconsistent right to work processes across departments, over-reliance on recruitment agencies without verification, failure to repeat checks where time-limited permission applies and poor record keeping. In many cases, checks were carried out at the outset but cannot be evidenced when enforcement officers attend.

Another recurring issue is the belief that low numbers equate to low risk. Enforcement action is frequently triggered by intelligence, tip-offs or sector-wide operations rather than headcount. A single non-compliant worker is enough to expose your organisation to penalties and investigation.

A significant development for employers is the confirmation that right to work checks are being expanded beyond traditional employment relationships. Through the Border Security, Asylum and Immigration Act, checks are being extended to cover gig workers, casual staff, agency workers and subcontracted labour. Reliance on third parties or assumptions that responsibility sits elsewhere is now a direct compliance risk.

 

DMS Perspective

 

Employers that withstand enforcement scrutiny are rarely lucky. They are prepared. The following pointers focus on control, evidence and accountability rather than box-ticking.

First, right to work checks should be treated as a regulated process, not an HR admin task. Employers should have a single, documented procedure that applies across permanent staff, temporary workers, agency labour and subcontractors. If a worker is on site, there should be a record of who checked their status, when and how it can be evidenced.

Second, records should be audit-ready at all times. Enforcement visits do not allow for explanations after the event. Employers should be able to produce on request document copies, share codes and dates of checks. If records are incomplete or scattered, risk increases sharply.

Third, time-limited permissions require active tracking. Many penalties arise because a follow-up check was not carried out. Employers should have a reliable system to flag upcoming expiry dates and trigger repeat checks well in advance.

Fourth, do not assume third parties have done the checks. Agency agreements and subcontractor clauses do not protect against liability if checks are not actually carried out or cannot be evidenced. Employers should verify processes, carry out spot checks and retain confirmation rather than relying on contractual assurances.

Fifth, prepare for an enforcement visit before it happens. Managers should know what to do if officers attend, who to contact internally and how information should be provided. Panic, inconsistency and over-disclosure during a visit often create avoidable problems that extend the scope of an investigation.

 

Need Assistance?

 

What this Home Office announcement reinforces is that the UK enforcement environment has shifted within government priorities and operations. Illegal working compliance is now treated as part of border control, organised crime prevention and labour market enforcement, leaving employers that treat right to work checks as a background obligation as being increasingly exposed. In the current climate then, being able to evidence what you did, when you did it and why it was compliant is what separates a positive inspection outcome from enforcement action.

If you have a question about immigration compliance, right to work checks and Home Office enforcement, you can book a fixed-fee telephone consultation with one of our compliance specialists for advice specific to your circumstances and needs.

 

About our Expert

Picture of Anne Morris

Anne Morris

Founder and Managing Director Anne Morris is a fully qualified solicitor and trusted adviser to large corporates through to SMEs, providing strategic immigration and global mobility advice to support employers with UK operations to meet their workforce needs through corporate immigration.She is recognised by Legal 500 and Chambers as a legal expert and delivers Board-level advice on business migration and compliance risk management as well as overseeing the firm’s development of new client propositions and delivery of cost and time efficient processing of applications.Anne is an active public speaker, immigration commentator, and immigration policy contributor and regularly hosts training sessions for employers and HR professionals.
Picture of Anne Morris

Anne Morris

Founder and Managing Director Anne Morris is a fully qualified solicitor and trusted adviser to large corporates through to SMEs, providing strategic immigration and global mobility advice to support employers with UK operations to meet their workforce needs through corporate immigration.She is recognised by Legal 500 and Chambers as a legal expert and delivers Board-level advice on business migration and compliance risk management as well as overseeing the firm’s development of new client propositions and delivery of cost and time efficient processing of applications.Anne is an active public speaker, immigration commentator, and immigration policy contributor and regularly hosts training sessions for employers and HR professionals.

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Legal Disclaimer

The matters contained in this article are intended to be for general information purposes only. This article does not constitute legal advice, nor is it a complete or authoritative statement of the law, and should not be treated as such. Whilst every effort is made to ensure that the information is correct at the time of writing, no warranty, express or implied, is given as to its accuracy and no liability is accepted for any error or omission. Before acting on any of the information contained herein, expert legal advice should be sought.