Increase in UK Home Office compliance action: Key considerations for employers

At a glance

• The UK Home Office has increased checks and visits to combat illegal working, with a significant rise in premises visited and arrests made.
• Employers must adopt Home Office-approved digital verification tools as manual checks are no longer valid for most migrants.
• The Home Office collaborates with His Majesty's Revenue and Customs (HMRC) and the Department for Work and Pensions (DWP) to identify discrepancies in National Minimum Wage compliance, tax records, and benefit claims, which can trigger licence suspensions.
• Sponsor licence compliance has become a top enforcement priority, with record suspensions and revocations of skilled worker visa sponsorship licences. 
• Recent legislative changes include new salary thresholds, visa reforms, prohibition on cost-sharing, and enhanced Right to Rent compliance. 

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The UK Home Office has intensified its compliance regime in 2024 and into 2025, targeting illegal working, breaches of sponsor licence obligations, and increased Right to Rent enforcement. Against a backdrop of sweeping legislative reforms and a change in government, employers face unprecedented regulatory risks. This article provides an overview of the evolving landscape and actionable strategies for compliance.  

Escalating action against illegal working

The Home Office has intensified its efforts to combat illegal working by significantly increasing the number of checks and visits conducted. In January 2025, 828 premises were visited, marking a 48% rise compared to January 2024. The number of arrests made has also had a 73% surge from the previous year.

Between 5 July 2024 and 31 January 2025, the Home Office has issued a total of 1,090 civil penalty notices and employers can face fines of up to GBP60,000 per worker if found liable.

Whilst all sectors are exposed, a significant number of the January 2025 visits were at restaurants, takeaways and cafes in addition to the food, drink and tobacco industry.

Critical risks for employers

Digital right to work checks:

• The mandatory shift to the eVisa system and phase-out of Biometric Residence Permits requires employers to adopt Home Office-approved digital verification tools. Manual checks are no longer valid for most migrants.  

Cross-government data sharing:

• The Home Office now collaborates with HMRC and the DWP to identify discrepancies in National Minimum Wage compliance, tax records, and benefit claims, which can trigger licence suspensions.  

Sponsor licence enforcement: Record suspensions and revocations

Sponsor licence compliance has become a top enforcement priority. Based on the latest Home Office data, in 2024, a total of 3,187 employers had their skilled worker visa sponsorship licence suspended or revoked. This represents a 252% increase from the 906 suspensions and revocations in 2023.

Home Office data:

Skilled worker licences	Suspended	Revoked
2024	1,693	1,494
2023	569	337

 

Under current rules, employer breaches attract a maximum of 12 months sanction. The government is proposing to increase the period for repeat breaches to be at least two years, with final cooling off periods to be announced.

Resource constraints in smaller businesses heighten risks of missed reporting deadlines or record-keeping lapses, important obligations on sponsor licence holders.

Recent legislative changes impacting employers

Salary thresholds and visa reforms

Skilled Worker Visa: Minimum salary threshold increased to GBP38,700 (April 2024), with the Immigration Salary List (ISL) replacing the Shortage Occupation List. Over 70% of roles previously eligible under concessions were removed.  

Health and Care Worker Visa: Care providers must now be Care Quality Commission-registered to sponsor migrants, and care workers cannot bring dependants.  

Prohibition on cost-sharing

Employers are barred from passing sponsorship costs (eg Certificate of Sponsorship fees and the Immigration Skills Charge) to employees. Violations are grounds for licence revocation.  

Family visa income requirements

The minimum income threshold for sponsoring a partner rose to GBP29,000 (March 2024), though further hikes to GBP34,500 were paused pending a Labour-led review.  

Enhanced right to rent compliance

While primarily targeting landlords, the Home Office’s expanded Right to Rent rules have indirect implications for employers providing staff accommodation:  

• Digital verification mandate: Since January 2025, landlords and employers offering housing must use the Home Office’s online checking service for non-British / Irish nationals. Manual checks are invalid.  
• Increased penalties: Fines rose to GBP5,000 per tenant (first breach) and GBP10,000 for repeat violations under the Immigration Act 2024 (Amendment) Regulations.  
• Data sharing: Local authorities now report suspected breaches to the Home Office, with referrals up 40% since October 2024.  

Employer considerations:

• Businesses providing housing (eg care homes, seasonal agriculture) must align with both Right to Work and Right to Rent rules.  
• Third-party accommodation providers require due diligence to avoid vicarious liability.  

Mitigating compliance risks: Proactive strategies

To navigate this stringent environment, employers should:  

• Conduct mock audits: Identify gaps in right-to-work checks, salary reporting, and sponsor licence management.  
• Train key staff: Ensure HR teams understand eVisa systems, ISL requirements, and deadlines for reporting employee changes.  
• Monitor legislative updates: Track Labour’s review of income thresholds and Migration Advisory Committee recommendations. An Immigration White Paper is expected later this year.
• Align recruitment practices: Use Standard Occupational Classification 2020 codes for roles and avoid salary structures that risk underpayment. Monitor any sponsored workers on the 'new entrant' or other discounted rate who may require a salary increase to extend sponsorship.
• Review accommodation policies: If providing housing, integrate automated Right to Rent checks via the Home Office portal and retain digital records for two years post-tenancy.  
• Engage legal advisers early: Seek specialist support ahead of Home Office inspections or licence renewals.  

Conclusion

The UK’s immigration compliance regime is now among the most rigorous globally, with overlapping obligations for employers spanning illegal working, sponsor duties, and increasingly Right to Rent. The Labour government’s focus on enforcement and digitalisation underscores the need for businesses to adopt proactive, tech-driven compliance frameworks. By prioritising audits, training, and expert guidance, employers can mitigate risks while maintaining access to vital overseas talent.  

For tailored advice on sponsor licence compliance, Right to Rent obligations, or Home Office investigations, contact our Immigration team.