25 July 2025

Illegal Working - Right to work checks

According to published government information, in the period 1 October 2024 to 31 December 2024, 489 civil penalties were issued for illegal working, 771 illegal workers were found, and the gross value of penalties issued was £29,200,000. The recoverable value will be lower due to adjustments made following objections and / or appeals.

 

 

An employer is liable for a civil penalty under section 15(2) of the Immigration, Asylum and Nationality Act 2006 where the employment commenced on or after 29 February 2008.  In England and Wales,

such penalties are recoverable as if they were payable under an order of the county court - section 19(1A).

The government has published a Code of Practice on preventing illegal working (February 2024). This begins - 

JMW Solicitors have published Right to work checks: Be compliant (23 July 2025) and Proposed Right to Work changes impacting casual workers (31 March 2025).

Clauses in the Border Security, Asylum and Immigration Bill are aimed at extending right to work checks to any organisation engaging self-employed contractors. 

UK government 27 August 2024 - Hundreds of rogue employers targeted in illegal working crackdown.

Civil penalties can be considerable - Daily Mail 25 July 2025. Whether the civil penalties imposed have actually been paid is not stated and, if they have been paid then how. It is obviously difficult (maybe impossible) for a small business to absorb a large civil penalty? 

Other links

The Immigration Act 2016 sections 34 to 38 provided additional powers.

BBC News 19 July 2025 - Arrests as immigration raid target workers

Border Force 



 


 

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