A massively expanded right to work regime is coming into force following the Border Security, Asylum and Immigration Act 2025 Act which, when enforced, will affect all employers.
Right to work checks and the massive financial penalties they provide protection from are to be broadened to “employment and other working arrangements”.
The Act extends right to work checks to workers not engaged in an employer-employee arrangement. The government’s consultation on how to enforce this ended in December with no timeline to implementation. Expanding the civil penalty regime may take more parliamentary legislation this year.
However, HR teams with sponsor licences now have an early indication of how onerous the new regime may be as new sponsor guidance and rules changes in March and April greatly expand right to work duties among other new requirements for organisations licenced to sponsor workers.
The backdrop to this massive expansion of red tape is a ramping up of Home Office enforcement action. The number of UK employers losing their licence to sponsor migrant workers tripled at the end of 2025 to the highest since records began in 2012. Common issues are underpayment, poor record-keeping and worker exploitation – all issues that new guidance for sponsors outlined below (and effective immediately) is targeting.
Major expansion of right to work checks for sponsors
Employers with a sponsor licence must check that any worker they engage – whether sponsored or not – has the right...
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