Updated: 2 July 2026
The Home Office has updated its quarterly list of UK employers that received civil penalties for illegal working. The latest publication covers the period from 1 October to 31 December 2025 and was updated on 1 July 2026, when one business was removed from the list.
The separate Home Office anonymous national report for the same quarter records 525 civil penalties, 620 illegal workers found and a gross penalty value of £26.47 million. The recoverable amount may later be reduced following objections or appeals, but the figures still show the scale of current enforcement.
For licensed sponsors, the risks go beyond the financial penalty. A defective right-to-work process can also lead to a wider Home Office investigation, sponsor licence suspension or revocation, disruption to sponsored workers and long-term damage to the business.
Has your business received a Civil Penalty Notice, an Information Request or a sponsor licence enforcement letter? Deadlines can be strict. Contact E&S Consultancy for a confidential assessment before responding or making payment.
What the latest Home Office report actually shows
The Home Office publishes two related quarterly reports, and the distinction matters.
The anonymous national report gives the overall number of penalties issued, the number of illegal workers identified and the gross value of the penalties. It does not identify the businesses involved.
The named UK employer report is narrower. It includes employers who have not paid, or are not making regular payments towards, a penalty 28 days after exhausting their objection or appeal rights. It also includes employers that received a second or further penalty after those rights were exhausted, regardless of whether payment has been made.
The named list is therefore not a complete record of every civil penalty issued during the quarter. Nor is it a list of revoked sponsor licences. It identifies the liable party, the business where illegal workers were encountered, the relevant address and the final value of the penalty after appeal rights were exhausted.
Civil penalty liability and sponsor licence enforcement are connected but separate. A listed business should not be described as a revoked sponsor unless that has been verified.
Latest illegal-working penalty figures
For the period from 1 October to 31 December 2025, the Home Office anonymous national report records:
| Home Office measure | Recorded figure |
|---|---|
| Civil penalties issued | 525 |
| Illegal workers found | 620 |
| Gross value of penalties issued | £26,470,000 |
The named report includes penalties ranging from five-figure amounts to substantial six-figure liabilities. Every UK employer has a duty to prevent illegal working, whether or not it holds a sponsor licence.
How much can an employer be fined?
Under the current civil penalty scheme, the starting penalty is up to £45,000 for each illegal worker where the employer has not been found to be employing illegal workers within the previous three years. For a repeat breach within three years, the penalty can be up to £60,000 per worker.
The final amount is not always the headline maximum. The Home Office considers whether the case is a first or repeat breach and whether any relevant reductions apply. A Civil Penalty Notice should therefore be reviewed carefully rather than treated as a fixed demand that cannot be challenged.
Publication of the employer’s details can also create reputational damage and prompt questions from clients, commissioners, insurers, lenders and commercial partners.
There is also a separate criminal offence where an employer knows, or has reasonable cause to believe, that a person is working illegally. In serious cases, this can lead to prosecution, an unlimited fine and imprisonment.
The statutory excuse: the employer’s main protection
An employer can protect itself from civil penalty liability by establishing a statutory excuse. In practical terms, that means completing the prescribed right-to-work check correctly, before employment starts, and retaining the required evidence.
The Home Office employer guide to right-to-work checks provides three main checking routes.
A manual check may be used where the worker has an acceptable original document. A Digital Verification Service may be used for an eligible British or Irish citizen with a valid passport or Irish passport card. A Home Office online check is generally used for non-British and non-Irish citizens whose immigration status can be checked digitally.
The correct process depends on the worker’s nationality, documents and immigration status. Simply seeing a passport or accepting a document by email is not necessarily enough.
For an online check, the employer must use the employer section of the Home Office service, enter the worker’s right-to-work share code and date of birth, and view the result produced for the employer. It is not sufficient to rely on a screenshot or status page shown by the worker. The employer should verify that the photograph matches the person, review any restrictions and save the result showing the date of the check.
The evidence must normally be kept for the duration of employment and for two years afterwards. Where the worker has time-limited permission, the employer must carry out the required follow-up check before the statutory excuse expires.
Our guide, Right-to-Work Checks in 2026: What Every UK Employer Must Do, explains the manual, digital and online checking routes in more detail.
Why employers fail even when documents are on file
A recurring problem is that an employer has documents in the personnel file but cannot show that the prescribed process was followed at the correct time.
One example is a check completed after the employee started. The later check may confirm that the person currently has permission to work, but it does not normally create a statutory excuse retrospectively for the earlier period.
Another problem is incomplete online evidence. Employers sometimes save only the worker’s share code email or a screenshot that does not show the photograph, restrictions or date of the employer check. That may not be enough to demonstrate that the prescribed process took place.
Expired physical Biometric Residence Permits are another area of risk. Current Home Office guidance confirms that an expired physical BRP is not acceptable proof of right to work for a manual check. In most such cases, the employer should use the worker’s eVisa details to complete the appropriate online check.
Employers can also be exposed where they overlook work restrictions. A student may have limited working hours during term time, while a person with a pending application may require confirmation through the Employer Checking Service. The key question is whether the person is permitted to carry out the specific work offered.
In larger organisations, inconsistency creates further risk. One branch may complete online checks correctly while another accepts screenshots. One manager may record the date of a manual check while another does not. The Home Office will look at what the employer actually did, not what its policy says should have happened.
What happens when the Home Office suspects illegal working?
An employer may first become aware of a problem through an Immigration Enforcement visit, a request for information or contact following a separate investigation. The Home Office may ask for right-to-work evidence, contracts, payroll records, rotas, attendance records and information about how the worker was recruited.
The employer should preserve the original records immediately, including online check results, document copies, recruitment notes, payroll material and relevant correspondence.
Records should never be altered, recreated or backdated to make the file appear compliant. Doing so can damage the employer’s credibility and make the position considerably worse.
Where the Home Office concludes that an illegal worker was employed and the employer has not established a statutory excuse, it may issue a Civil Penalty Notice. The notice should explain the amount, the reasons, the payment arrangements, the objection procedure and the deadline for responding.
The deadline stated on the notice must be taken seriously. Employers should not wait until the final days to obtain advice or gather evidence, particularly where records are held across different sites or by external providers.
Should the employer pay or object?
There is no single answer. Some employers have proper grounds to object; others do not. The correct approach depends on the evidence and the way the Home Office calculated liability.
An objection may be appropriate where the employer is not liable, held a statutory excuse or believes the penalty was calculated incorrectly. The identity of the liable employer can also matter where several companies or group entities are involved.
Before deciding whether to pay or object, the employer should identify the correct employing entity, examine the worker’s immigration position at the relevant time, review the original checking evidence and test the penalty calculation against the civil penalty scheme.
The quality of the evidence is often decisive. A complete online profile saved before employment began is very different from an undated screenshot supplied by the worker. A properly prepared objection should address the facts, evidence and legal basis of the penalty rather than simply state that the employer acted in good faith.
A weak objection may add cost without improving the outcome.
Civil penalties and sponsor licence consequences
For a licensed sponsor, an illegal-working issue should never be treated as an isolated employment matter.
Current sponsor guidance requires sponsors to check that every worker they wish to sponsor or otherwise employ has the appropriate immigration permission to work in the UK and to perform the job in question before work starts. This applies to sponsored and non-sponsored workers.
The guidance also states that failing to carry out the correct right-to-work check, or a required follow-up check, is a breach of sponsor duties. Where a sponsor receives a civil penalty, or otherwise fails to complete the correct checks, the Home Office says it will normally revoke the sponsor licence.
Revocation can cause immediate operational damage. The employer loses the ability to assign Certificates of Sponsorship. Pending applications may be affected. Existing sponsored workers may have their immigration permission shortened, usually to no more than 60 days where they were not involved in the breach.
A sponsor facing a civil penalty should examine the wider compliance position at the same time, including whether similar failures exist elsewhere and whether payroll, sponsored-worker records and Certificate of Sponsorship information match.
Our guides on how to avoid losing a sponsor licence and what to expect during a UKVI sponsor compliance visit explain the wider enforcement risks in more detail.
Why a retrospective compliance audit can be valuable
A retrospective audit cannot create a statutory excuse for a check that was never completed. It can, however, establish the true position, confirm whether current employees are permitted to work, locate evidence that already exists and prevent the same error from being repeated.
A meaningful review should cover the whole workforce rather than focusing only on sponsored workers. It should examine the checking method, the date of the check, the evidence retained, any work restrictions and the need for follow-up action.
For licensed sponsors, the review should go further. Right-to-work records should be reconciled against contracts, payroll, job descriptions, salaries, working hours, attendance records, contact details, Certificates of Sponsorship and Sponsor Management System reports.
Our Sponsor Licence Compliance Review Findings 2026 identified recurring weaknesses across ten UK organisations, including late or incomplete checks, weak visa-expiry monitoring, inconsistent records and gaps between HR, payroll and sponsorship information.
E&S Consultancy provides immigration compliance and sponsor licence audit services online and on site. The purpose is to give the employer a realistic assessment of its current exposure, a prioritised remedial plan and systems that can be maintained after the review.
The audit should produce a clear written record of the weaknesses found, the action required and the person responsible for completing it. This does not erase an earlier breach, but it can show that the problem was identified and addressed.
Practical steps employers should take now
Employers should not wait for an enforcement visit before reviewing their files. A sensible starting point is a representative sample from different immigration categories, sites and recruiting managers. Each file should show that the correct check took place before work began and confirmed permission for the actual role.
Any time-limited permission should be monitored through a reliable diary or alert system, with responsibility assigned to a named person. Businesses operating across several sites should use one written procedure and one evidence standard.
The process should apply consistently to all new starters. Employers should not make assumptions about someone’s right to work based on their name, accent, appearance or perceived nationality. Consistent checking is both safer and less likely to result in unlawful discrimination.
Sponsors should also compare employee files against payroll, contracts and SMS records. A right-to-work review often reveals wider issues, such as unreported changes in salary, hours, job title, work location or employment status.
Employers can use our free Sponsor Licence Compliance Risk Calculator for an initial indication of potential weaknesses. Organisations requiring ongoing support can also consider our ongoing sponsor compliance management service and ComplianceGuard for visa-expiry monitoring, right-to-work records and compliance tracking.
Frequently asked questions
Is every employer that receives a civil penalty named publicly?
No. The named quarterly list applies the Home Office publication criteria. The anonymous national report provides the wider quarterly totals without identifying individual employers.
Can a late right-to-work check protect the employer?
A later check may confirm the worker’s current position, but it does not normally create a statutory excuse retrospectively for an earlier period when no prescribed check had been completed.
Can one civil penalty lead to sponsor licence revocation?
Yes. Current sponsor guidance states that the Home Office will normally revoke a sponsor licence where a sponsor receives a civil penalty or otherwise fails to complete the correct right-to-work checks. The action will depend on the facts and applicable guidance.
Is a compliance audit worthwhile after a penalty has been issued?
Yes. An audit may identify relevant evidence, reveal whether the same problem exists elsewhere and reduce the risk of further penalties or sponsor enforcement. It must be an honest review and not an attempt to recreate evidence that did not exist.
How E&S Consultancy can help
E&S Consultancy UK Limited advises employers on illegal-working civil penalties, right-to-work compliance, sponsor licence enforcement and Home Office audits.
Our work may include reviewing a Civil Penalty Notice, assessing the evidence, advising on whether there are proper grounds for objection, examining the sponsor licence consequences and conducting a wider workforce compliance review.
We also assist with mock Home Office inspections, sponsored-worker file checks, corrective action plans, staff training and ongoing sponsor compliance management. Reviews can be carried out remotely or, where appropriate, through an on-site visit.
The latest Home Office figures show that illegal-working enforcement remains a substantial business risk. A compliant employer should be able to prove not only that its workers have permission, but that the prescribed checks were completed correctly, on time and in a form that can be produced without delay.
Contact E&S Consultancy to arrange a confidential civil penalty assessment or employer compliance audit.