Monday 19 January 2026

Last year laid the groundwork for the UK Government’s robust approach to tackling illegal working, the exploitation of migrant workers and abuse of the sponsorship system. The proposals set out in its White Paper signal a significant shift towards stricter enforcement, particularly within high-risk sectors such as the gig economy and social care. However, all sectors will be impacted in some way by the tougher controls. Central to this approach is a growing reliance on technology to improve oversight of immigration controls and enhance real-time enforcement.

Whilst the proposals are subject to consultation, recent enforcement activity indicates that the Government’s efforts are already underway. For example, as of September 2025, Home Office compliance visits to businesses have increased by 51% compared to the previous year and arrests for illegal working increased by 63%.  As of July 2025, there was an alarming 108% increase in sponsor licence revocations.

In this article, we look at the key enforcement proposals in the White Paper, explore the potential implications for employers and migrant workers, and suggest steps that employers and migrant workers can take now to mitigate the risk of enforcement action.

Enforcement proposals
The White Paper sets out the following proposals regarding enforcement.

• targeting enforcement in key sectors: focusing resources in key sectors where illegal working is taking place, such as the gig economy. This will include Immigration Enforcement raids, supported by eVisa and modern biometric technology and redeploying 1,000 staff into enforcement and returns;
• introducing new financial measures, penalties and sanctions: the aim is to incentivise improved sponsorship practices;
• establishing a Fair Work Agency: to ensure more unified action can be taken against exploitative employers, building on the stringent rules currently in place;
• reforming the civil penalty system: the civil penalty system is to be strengthened and expanded to ensure any employer facilitating illegal working faces immediate penalties;
• expanding enforcement powers: new procedures will allow the Home Office to more easily take enforcement action and revoke visas for a wider range of offences, including those resulting in non-custodial sentences.

Potential implications for employers and migrant workers
These proposals represent a significant tightening of immigration control mechanisms and data driven enforcement with far-reaching implications.

The expansion of enforcement powers means that the Home Office can take swifter and more decisive action against non-compliant sponsors and migrant workers. Whilst there has been an increase in compliance visits, the government’s growing reliance on advanced technologies, recent introduction of a new digital ID scheme, and real-time data sharing with other government departments will give enforcement teams immediate access to employment, tax and immigration records. This shift may ultimately reduce the need for compliance visits, with enforcement action alternatively being more algorithm-driven. Whilst this may streamline enforcement, there is the risk that not only deliberate breaches but also administrative oversights or one-time errors in right to work checks or submitting Home Office reports could result in civil penalties or suspension of sponsorship licences, with limited opportunity for sponsors to provide context.

For migrant workers, increased data sharing may allow the Home Office to remind individuals when their immigration permission is due to expire or has already expired, however this may come at the cost of increased surveillance. It is also indicated that non-custodial criminal offences can result in penalties and visa revocations for migrant workers. This raises serious concerns around proportionality and due process, especially where the conduct/breach involved is minor or non-violent. The Home Office can therefore make decisions without full consideration of an individual’s circumstances.

However, the proposals also introduce some positive changes for migrant workers. Notably, the increased flexibility for switching between licensed sponsors could reduce the risk of exploitation by giving workers greater control over their employment relationships. Workers who find themselves in unsuitable or exploitative roles may be better positioned to leave without jeopardising their immigration status. This reform, if implemented properly, could help balance the power dynamic between employers and workers and offer a degree of protection against coercive employment practices.

The White Paper also signals a potential widening of the compliance framework. Employers who rely on overseas workers, particularly in shortage or lower-skilled sectors, may be expected to demonstrate stronger commitment to investing in domestic recruitment and training. The government has proposed to explore restrictions on sponsors who do not meet these expectations, hinting at a broadening of what ‘compliance’ means – from formal immigration duties to more policy-aligned behaviours, with the Home Office looking to use conditions and deterrents before enforcement is needed.

Preparing for enforcement measures: practical steps for employers and migrant workers
Employers should now take proactive steps to ensure they are fully compliant with existing duties and well-prepared for upcoming changes. These steps include the following:

• reviewing and undertaking a thorough audit of their current sponsorship systems to identify and address any gaps in processes as soon as possible. Employers should ensure that all migrant records are up to date, right to work checks are carried out at the correct times and recorded appropriately, and that procedures are in place to ensure changes to a worker’s and/or the business’ circumstances are reported within the relevant timeframes. Audits will also help prepare for compliance visits;
• assessing future recruitment and sponsorship needs. This includes identifying roles that may require sponsorship in the next 12 months and considering how to meet those needs in light of changing Home Office expectations. Employers in shortage or lower-skilled industries should begin to document and strengthen their efforts to recruit and train from the domestic workforce, in the event future sponsorship is made conditional on such commitments. This can include training current staff, engaging with apprenticeships or participating in local workforce initiatives; and
• considering investing in technology to support compliance, such as facial recognition for right to work checks, fraud detection tools and digital HR systems that alert teams to permission expiry dates and reporting deadlines. Companies such as Deliveroo and Uber Eats have already implemented enhanced verification tools, which may become more common or even expected especially in high-risk sectors.

For migrant workers, the proposed reforms reinforce the importance of maintaining a clear understanding of their immigration permission and the attached conditions. Workers should ensure they keep accurate records of their sponsorship status, permission expiry dates and employment details, and regularly check that their eVisas are up to date. Incorrect or outdated records could lead to wrongful enforcement action. Migrant workers and employers should also take care to maintain clear and open communication to ensure any changes in personal and employment details are reported appropriately.

What lies ahead
In summary, the proposals in the White Paper reflect a much more proactive and data-driven approach to enforcement. Employers face increased scrutiny, not only of their legal compliance but also their broader workforce practices, including investing in domestic recruitment. At the same time, migrant workers may benefit from greater flexibility but also face increased surveillance and stricter consequences for even minor breaches of the immigration rules.

With the Home Office increasingly relying on real-time data, eVisas and digital IDs, enforcement action may start occurring without traditional compliance visits. This raises concerns about fairness and proportionality, especially with the potential for penalties to be triggered by simple administrative errors or data mismatches.

In this changing landscape, sponsors and migrant workers should take the necessary steps to protect their positions – by reviewing HR systems, understanding their obligations and ensuring immigration records and eVisas are accurate and up to date. Early preparation will be essential in navigating a system that is becoming stricter and far less forgiving.

Get in touch
Laura Devine Immigration offers a range of sponsor compliance services which can assist your business with its ongoing immigration compliance and ensure that your sponsor licence and HR systems are in order.

For further information or if you have any questions about how these proposals may affect you, your business or your family, please contact your dedicated LDI lawyer or enquiries@lauradevine.com.