- Key Takeaways
- Introduction
- Enforcement in 2026: The Numbers Behind the Headlines
- £74 Million in Penalties: The Cost of Getting It Wrong
- Why the Home Office Might Visit Your Business
- What Actually Happens During an Enforcement Visit
- After the Visit: The Civil Penalty Process Step by Step
- How Much Is the Fine and How Is It Calculated?
- Beyond the Fine: Closure Notices, Licence Reviews and Criminal Liability
- The Statutory Excuse: Your Only Real Defence
- If You Hold a Sponsor Licence, the Stakes Are Higher
- A Practical Readiness Checklist
- How Can WorkPermitCloud Help?
- Conclusion
- Glossary
- Frequently Asked Questions
Key Takeaways
- Immigration Enforcement carried out 7,270 illegal working visits between 1 January and 30 June 2026, resulting in 4,756 arrests. Visits rose by 31% and arrests by 20% compared with the same period in 2025, making it the busiest start to a year on record.
- More than 1,200 businesses were issued with an illegal working civil penalty in the first half of 2026, facing fines of over £74 million between them. Penalties are charged per worker, so one visit can produce a six figure bill.
- Enforcement now goes well beyond fines. In the same six months the Home Office pursued 10 closure notices and 55 alcohol and late night refreshment licence reviews, which can shut premises and put a drinks licence at risk.
- Visits are intelligence led and sector focused. Warehousing, distribution and delivery visits rose 147% and construction visits rose 150% year on year, while restaurants, takeaways and cafes remain the single most visited category.
- The only reliable defence is a statutory excuse, which means a correct right to work check completed before employment begins, properly evidenced, and repeated before any time limited permission expires.
- A civil penalty notice gives you just 28 days to pay or object, so knowing the process before a visit happens is what protects your business.
- WorkPermitCloud helps UK employers prepare for and respond to enforcement action, from our Right to Work Check service and Home Office compliance visit support to civil penalty defence, sponsor licence suspension advice and UKVI compliant HR software. You can also run a free HR Compliance Audit and use our Right to Work Check tool.
Introduction
Most UK businesses never expect a knock at the door from Immigration Enforcement. The reality in 2026 is that thousands do get one, and very few are ready for what follows. On 7 August 2026 the Home Office published its latest illegal working and enforcement activity data, covering the first six months of the year. It shows enforcement running at the highest level ever recorded, with more visits, more arrests and more money being taken from employers than at any point in the history of the regime.
What the statistics do not explain is what actually happens on the day officers arrive, what you are required to hand over, and what the process looks like in the weeks that follow. That is where most employers get into trouble. A business that understands the sequence, keeps calm and can produce clean right to work records will usually walk away without a penalty. A business that cannot evidence its checks is facing a fine of up to £60,000 per worker, and in serious cases a closure notice, a licence review or a criminal prosecution.
This guide walks you through both sides of the story. First, the enforcement and penalty numbers from the latest Home Office release and what they mean for your sector and region. Second, a practical, step by step account of an enforcement visit and the civil penalty process that follows, so you know exactly where you stand and what to do at each stage.
Enforcement in 2026: The Numbers Behind the Headlines
The headline is simple. Between 1 January and 30 June 2026, Immigration Enforcement carried out 7,270 illegal working visits across the UK and made 4,756 arrests. Compared with the same six months in 2025, that is a 31% increase in visits and a 20% increase in arrests. The Home Office describes it as the most successful start to a year on record for illegal working enforcement.
Illegal working enforcement activity, first half of 2025 compared with first half of 2026
| Illegal working enforcement | Jan to Jun 2025 | Jan to Jun 2026 | Change |
| Visits carried out | 5,554 | 7,270 | +31% |
| Arrests made | 3,969 | 4,756 | +20% |
| Warehousing, distribution and delivery visits | 257 | 635 | +147% |
| Construction visits | 107 | 268 | +150% |
Source: Home Office, Illegal working and enforcement activity to the end of June 2026, published 7 August 2026.
Looked at over a longer period, the shift is even clearer. In the two years from 1 July 2024 to 30 June 2026, Immigration Enforcement carried out almost 25,000 visits and made more than 17,000 arrests, roughly double the two years immediately before.
Two year enforcement comparison
| Two year comparison | Jul 2022 to Jun 2024 | Jul 2024 to Jun 2026 | Change |
| Illegal working visits | 11,724 | 24,793 | +111% |
| Illegal working arrests | 7,713 | 17,114 | +122% |
| Returns following a visit | 1,570 | 2,357 | +50% |
| Warehousing, distribution and delivery visits | 285 | 1,557 | +446% |
Source: Home Office, Illegal working and enforcement activity to the end of June 2026.
For employers, the practical meaning of these numbers is that an enforcement visit is no longer a remote possibility reserved for the worst offenders. It has become a routine part of doing business in certain sectors, and the chance of being visited has roughly doubled in two years.
£74 Million in Penalties: The Cost of Getting It Wrong
Enforcement visits are only the start. The financial consequences arrive later, in the form of civil penalties issued to employers found to be employing people without the right to work. In the first half of 2026, more than 1,200 businesses were penalised and the combined value exceeded £74 million.
Illegal working civil penalties, licence reviews and closure notices, 2026
| Period | Penalties issued | Value (£m) | Alcohol and late night licence reviews | Closure notices |
| 2026 Q1 | 561 | £32.6m | 25 | 4 |
| 2026 Q2 | 677 | £42.0m | 30 | 6 |
| Total, first half of 2026 | 1,238 | £74.6m | 55 | 10 |
Source: Home Office, Illegal working and enforcement activity to the end of June 2026.
That works out at an average of roughly £60,000 for every penalty notice issued. A penalty notice can cover more than one worker, so the total for a single business depends on how many people were found without the right to work. For many small and medium sized employers, a bill of this size is not an inconvenience. It is an existential threat.
Two points are worth understanding about this data. First, penalties issued in a given quarter often relate to visits carried out months or even years earlier, because cases take time to be referred, considered and decided. Second, not every penalty follows an enforcement visit at all. Some arise from intelligence referrals by other departments, and some come from routine data sharing between the Home Office and HMRC. In other words, you do not need to have been raided to be fined.
Why the Home Office Might Visit Your Business
Immigration Enforcement describes its activity as intelligence led, which means visits are targeted rather than random. The most common triggers include:
- A report from a member of the public, a former employee or a competitor through the GOV.UK report immigration crime service.
- Data sharing between the Home Office and HMRC, where payroll records do not match the immigration status of the people being paid.
- Referrals from other government departments, local authorities, licensing teams or the police.
- Sector profiling, where a business operates in an industry with a known history of illegal working.
- Previous non-compliance, including an earlier penalty, a warning notice or a sponsor licence compliance issue.
- Joint operations with police forces targeting the wider grey economy.
That last point is increasingly relevant. Between 15 and 20 June 2026, Immigration Enforcement joined 39 police forces in a nationwide crackdown on organised immigration crime. Officers visited more than 900 businesses and engaged around 4,000 individuals. The results included 326 arrests, £1 million in cash seized, 73 civil penalty referral notices, and the seizure of 92 cars and 31 e-bikes and scooters. If your business sits anywhere near the informal economy, you should assume that immigration compliance is now being checked alongside tax, licensing and employment standards. We looked at how this campaign began in our earlier article on the UK's largest crackdown on illegal workers.
Which sectors are being visited most
The Home Office publishes visit and arrest figures by business category. This is the clearest guide available to where your own risk sits.
Illegal working visits and arrests by business category
| Business category | Visits Jan to Jun 2025 | Visits Jan to Jun 2026 | Change | Arrests 2026 |
| Restaurants, takeaways and cafes | 1,675 | 2,195 | +31% | 1,589 |
| Food, drink and tobacco retail | 1,029 | 1,409 | +37% | 389 |
| Beauty industry (nail bars, salons, barbers) | 779 | 1,041 | +34% | 648 |
| Warehousing, distribution and delivery | 257 | 635 | +147% | 635 |
| Car washes | 330 | 404 | +22% | 277 |
| Retail (non-food) | 245 | 343 | +40% | 127 |
| Construction | 107 | 268 | +150% | 331 |
| All other categories | 1,132 | 975 | -14% | 760 |
| Grand total | 5,554 | 7,270 | +31% | 4,756 |
Source: Home Office, Illegal working and enforcement activity to the end of June 2026. The 'all other categories' row combines residential and all other visit types.
Two figures stand out. In warehousing, distribution and delivery services, 635 visits produced 635 arrests in six months, which is an arrest for every single visit carried out. Construction visits rose by 150%. Both sectors rely heavily on subcontractors, agency labour and app based work, which is precisely the model that the new right to work rules are designed to capture from 1 October 2026. We explain that change in full in our guide to right to work checks for gig economy and construction workers.
Where visits are happening
Enforcement is spread across the whole of the UK, but the growth is uneven. London remains the single busiest region by a wide margin.
Illegal working visits by region
| Region | Visits Jan to Jun 2025 | Visits Jan to Jun 2026 | Change |
| London | 1,260 | 1,814 | +44% |
| South West | 556 | 895 | +61% |
| West Midlands | 593 | 884 | +49% |
| Wales | 544 | 756 | +39% |
| North West | 801 | 752 | -6% |
| South East | 518 | 660 | +27% |
| East of England | 233 | 341 | +46% |
| Scotland | 272 | 287 | +6% |
| East Midlands | 274 | 282 | +3% |
| Yorkshire and The Humber | 210 | 280 | +33% |
| North East | 221 | 216 | -2% |
| Northern Ireland | 72 | 103 | +43% |
Source: Home Office, Illegal working and enforcement activity to the end of June 2026.
What Actually Happens During an Enforcement Visit
This is the part employers most often ask about, and the part least covered by official guidance. The following describes the typical shape of an illegal working enforcement visit. Every visit is different, but the pattern is consistent.
Step 1: Officers arrive, usually without warning
Visits normally take place during trading or working hours, often at the busiest time of day, because that is when the largest number of workers will be on site. Officers arrive as a team, frequently with police present, and may attend more than one of your premises at the same time. You should expect no advance notice.
Step 2: Powers and paperwork are explained
Officers will identify themselves and explain the basis on which they are attending. This may be with your consent, under a warrant, or under statutory powers of entry. You are entitled to see identification and to be told the legal basis for the visit. Ask for it politely and make a note of the officers' names and the time of arrival.
Step 3: Staff are spoken to and identity is checked
Officers will speak to people who are working on the premises and ask about their identity, their immigration status and who they work for. They may run checks against Home Office systems in real time. Anyone found to have no right to work, or to be working in breach of their conditions, can be arrested and detained on the spot. In the first half of 2026, 297 people were detained and 272 people returned following illegal working visits.
Step 4: Your records are requested
You will be asked to produce your right to work records for the people on site and, potentially, for your wider workforce. This is the moment that decides whether you face a penalty. If you can immediately produce a dated, compliant check for each worker, you are in a strong position. If your records are in a filing cabinet at another site, on a personal laptop or simply do not exist, you are not.
Step 5: The visit is documented and a referral may follow
Before leaving, officers will record what they found. If they believe illegal working has taken place, your case is referred to the civil penalty team. You may be issued with a civil penalty referral notice on the day, or you may hear nothing for weeks. Either way, the process has started.
What your team should do
- Stay calm and cooperate. Nominate one senior person to act as the point of contact for officers.
- Ask for identification and note the legal basis of the visit, the names of officers and the time.
- Provide the records you are asked for, promptly and accurately.
- Take your own written note of what happened, who was spoken to and what was handed over.
- Contact your immigration adviser immediately, ideally while officers are still on site.
- Tell staff to answer questions honestly and not to guess or speculate on behalf of others.
What you must never do
- Obstruct officers, refuse entry where they have lawful authority, or ask staff to leave the premises. Obstruction is a criminal offence in its own right.
- Alter, backdate, create or destroy any right to work record. This turns a civil penalty into a criminal matter.
- Coach employees on what to say, or answer questions on their behalf.
- Assume the matter is closed because nobody was arrested. A referral can still follow.
- Ignore correspondence that arrives afterwards. Deadlines in this process are short and strictly applied.
After the Visit: The Civil Penalty Process Step by Step
Once a case is referred, the civil penalty process runs to a fixed sequence with tight deadlines. Understanding it in advance is what allows you to respond properly rather than react in panic.
The illegal working civil penalty process
| Stage | What it means | Your window |
| Civil penalty referral notice | Notice that your case is being considered for a penalty. No amount is stated yet. | None, but start gathering evidence now |
| Information request | The Home Office asks for your right to work records and any explanation you wish to give. | As stated in the request, usually short |
| Outcome decision | One of three results: no action, a warning notice, or a civil penalty notice. | Not applicable |
| Civil penalty notice | States the amount payable per worker, how to pay and how to object. | 28 days to pay or object |
| Objection to the Home Office | You can object on the grounds that you are not liable, that you have a statutory excuse, or that the amount is too high. | Within the 28 day period |
| Objection outcome notice | The Home Office maintains, reduces, increases or cancels the penalty. | Not applicable |
| Appeal to the court | Appeal to the county court in England and Wales, or the sheriff court in Scotland. | 28 days from the objection outcome |
| Enforcement and publication | Unpaid penalties can be enforced as a debt and your business details may be published as a warning to others. | Ongoing |
Source: GOV.UK, Penalties for employing illegal workers, and Home Office civil penalty guidance for employers.
The single most important line in that table is the 28 day window. Miss it and you lose the right to object, regardless of how strong your case would have been. If you receive a civil penalty notice, treat it as urgent from the day it arrives. Our civil penalty service and immigration compliance team can review the notice, assess whether you hold a statutory excuse and prepare the objection on your behalf. Full official guidance on the process is on GOV.UK at penalties for employing illegal workers.
How Much Is the Fine and How Is It Calculated?
Civil penalties for illegal working tripled in February 2024 and remain at that level. The penalty is applied per illegal worker, not per business, which is why totals escalate so quickly.
Illegal working penalties for UK employers
| Breach type | Maximum penalty | Notes |
| First breach | £45,000 per worker | Starting point before any reduction for mitigating factors |
| Repeat breach within three years | £60,000 per worker | The figure GOV.UK quotes as the maximum civil penalty |
| Knowingly employing an illegal worker | Unlimited fine and up to 5 years in prison | A criminal offence, not a civil penalty |
| Additional consequences | Closure notice, licence review, director disqualification, sponsor licence action | Can apply alongside a financial penalty |
Source: GOV.UK, Penalties for employing illegal workers, and the Home Office code of practice on preventing illegal working.
The Home Office can reduce a penalty where certain mitigating factors are evidenced. These include reporting suspected illegal working yourself, actively cooperating with the investigation, and having effective right to work checking practices in place across the rest of your workforce. Where it is a first breach and all mitigating factors apply, the Home Office may issue a warning notice instead of a financial penalty. There is also a reduction available for prompt payment.
The reverse is also true. Employers with a previous penalty, poor records or a lack of cooperation should expect to sit at the top of the range. Read the full codes of practice for employers on GOV.UK for how the calculation works in detail.
Beyond the Fine: Closure Notices, Licence Reviews and Criminal Liability
A civil penalty is not the worst outcome available to Immigration Enforcement. In the first six months of 2026 the Home Office pursued 10 closure notices and 55 alcohol and late night refreshment licence reviews. Both can stop a business trading far faster than a fine.
Illegal working closure notices
An immigration officer of at least chief immigration officer rank can issue an illegal working closure notice where they are satisfied on reasonable grounds that an employer at the premises is employing someone who does not have permission to do that work. The notice prohibits access to the premises and prohibits paid or voluntary work there, other than by people who habitually live at the address. The maximum period is 24 hours, rising to 48 hours where the notice is issued by an officer of immigration inspector rank.
The Home Office can then apply to the court for an illegal working compliance order. Where an employer cannot show that right to work checks were carried out, the court can require continued closure for a period and impose ongoing compliance conditions, including inspections and mandatory checks, as a condition of reopening. For a restaurant, takeaway or retail unit, even a short forced closure can be more damaging than the fine itself.
Alcohol and late night refreshment licence reviews
Where a business holds a premises licence, the Home Office can trigger a review of that licence following an illegal working finding. Licensing authorities can attach conditions, suspend the licence or revoke it entirely. For pubs, restaurants, takeaways and late night venues, losing the licence usually means losing the business.
Criminal liability and director consequences
If you knew, or had reasonable cause to believe, that someone did not have the right to work, this is a criminal offence carrying an unlimited fine and up to five years in prison. Directors can also face disqualification proceedings, and the Home Office may publish the details of penalised businesses as a warning to others. If you hold a sponsor licence, an illegal working finding will almost certainly trigger suspension or revocation as well.
The Statutory Excuse: Your Only Real Defence
GOV.UK puts it plainly: you will not have to pay the civil penalty if you can show you made the correct right to work checks. That protection is called a statutory excuse, and it is earned before employment starts, not after officers arrive.
The three compliant ways to establish a statutory excuse
| Type of check | How it works | Best used for |
| Online share code check | The worker generates a share code, which you verify through the GOV.UK employer service and match to their photograph. | Anyone with an eVisa or digital immigration status |
| Digital identity check via an IDSP | A certified identity service provider verifies the person's identity document digitally. | British and Irish citizens with a valid passport |
| Manual document check | You see the original document, check its validity in the person's presence, and keep a clear dated copy. | The limited cases where an online check is not possible |
Source: GOV.UK, Right to work checks: an employer's guide.
To hold the excuse, four things must be true. The check was completed before the person started work. It was one of the prescribed methods above. You kept a clear, dated record of it for the duration of employment and for two years afterwards. And where the person has time limited permission, you carried out a follow up check before that permission expired.
It is also essential to apply the same process to everyone. Checking only people who look or sound foreign is discriminatory and unlawful, and it will not protect you. Full guidance is available in the Home Office employer's guide to right to work checks, and you can verify an individual's status through the GOV.UK view a job applicant's right to work details service.
Remember that from 1 October 2026 these duties extend to gig economy, agency, casual and self-employed workers for the first time, so the population of people you need to check is about to grow significantly.
If You Hold a Sponsor Licence, the Stakes Are Higher
Sponsor licence holders sit under a second layer of scrutiny. An illegal working finding does not just produce a fine, it puts your entire ability to employ overseas workers at risk. The Home Office took 3,486 separate enforcement actions against sponsors in the first quarter of 2026 alone, including 1,712 Skilled Worker licence suspensions and 1,545 revocations, both record highs. We covered that data in detail in our analysis of UK immigration enforcement in Q1 2026.
If a visit results in a suspension, you cannot assign new Certificates of Sponsorship while the investigation runs, and you normally have 20 working days to respond to the suspension letter. If it results in revocation, your sponsored workers have their permission curtailed, usually to 60 days, and there is no right of appeal, only judicial review. Our sponsor licence suspension service and sponsorship duties support are designed for exactly this situation, and our guide to preparing for a Home Office compliance visit sets out what UKVI officers examine.
A Practical Readiness Checklist
The businesses that come through an enforcement visit unscathed are the ones that prepared before it happened. Work through the following:
- Audit every right to work record you hold and identify anyone with a missing, incomplete or undated check.
- Store checks digitally so they can be produced within minutes at any site, not retrieved from a cabinet later.
- Diarise follow up checks for every worker with time limited permission, with reminders well before expiry.
- Map every working relationship beyond payroll, including agency staff, subcontractors, casual workers and platform workers, ready for the 1 October 2026 changes.
- Write a short enforcement visit protocol naming who leads on the day, where records are held and who to call.
- Brief managers at every site, not just head office, because visits happen where the work is.
- Run a mock audit at least once a year so gaps are found by you rather than by an officer.
- Review your contracts with agencies and subcontractors so responsibility for checks is clearly allocated in writing.
Sponsor licence holders should work through this alongside our step by step guide to passing a UKVI Home Office compliance visit, because the two inspections look at overlapping records.
If you would like an independent view of where you stand, our free HR Compliance Audit tool gives you a fast assessment, and our HR compliance service provides the ongoing support to close any gaps it finds.
How Can WorkPermitCloud Help?
WorkPermitCloud is a legal and HR-tech company specialising in UK business immigration and employer compliance. With enforcement visits and penalties at record levels, we help you get ahead of the risk and deal with it if it arrives. Our Right to Work Check service and Right to Work Check tool make compliant checks quick and properly evidenced, our immigration compliance and Home Office compliance visit services prepare you for a visit, our civil penalty service supports you through an objection or appeal, and our sponsor licence suspension team acts fast if your licence is at risk. Our UKVI compliant HR software keeps every check, expiry date and record audit ready, and you can start today with a free HR Compliance Audit. You will find more employer guidance across our blog library.
To speak with one of our specialists or to book an appointment, visit our contact page. 📞 Call us: +44 020 8087 2343 |
Conclusion
The message from the latest Home Office data is impossible to miss. Enforcement visits are at their highest ever level, arrests have doubled in two years, and employers paid out more than £74 million in illegal working penalties in just six months. Alongside the fines sit closure notices, licence reviews, criminal liability and, for sponsors, the loss of the licence itself.
None of this needs to become your problem. Every one of these outcomes is avoidable with the same basic discipline: check everyone properly before they start, record what you did, repeat the check before permission expires, and be able to produce all of it within minutes. If officers arrive tomorrow, the question is not whether you have anything to hide. It is whether you can prove what you have done.
If you are not confident of the answer, now is the time to fix it rather than after a visit. Speak to WorkPermitCloud and we will help you get your right to work records, your sponsor duties and your HR systems into a position where an enforcement visit is an inconvenience rather than a crisis.
Glossary
| Term | Definition |
| Illegal working visit | An unannounced visit by Immigration Enforcement to premises suspected of employing people without the right to work in the UK. |
| Civil penalty referral notice | A notice telling an employer that their case is being considered for a civil penalty following a finding of illegal working. |
| Civil penalty notice | The formal notice stating the amount payable for employing an illegal worker, with 28 days to pay or object. |
| Statutory excuse | The legal protection an employer gains by carrying out and evidencing a correct right to work check before employment begins. |
| Right to work check | A prescribed check confirming a person's permission to do the work in question, carried out online, through a certified digital identity provider, or manually. |
| Share code | A code generated by a worker that allows an employer to verify their immigration status online through the GOV.UK service. |
| Illegal working closure notice | A notice issued by a senior immigration officer prohibiting access to and work at premises for up to 24 hours, or 48 hours where issued at inspector rank. |
| Illegal working compliance order | A court order that can follow a closure notice, imposing continued closure and ongoing compliance conditions on a business. |
| ALNR licence review | A review of an alcohol or late night refreshment premises licence triggered by an illegal working finding, which can lead to conditions, suspension or revocation. |
| Warning notice | An outcome issued instead of a financial penalty where it is a first breach and all mitigating factors are evidenced. |
| Employer Checking Service | The Home Office service used to confirm a person's right to work where an online or manual check is not possible. |
| Sponsor licence suspension | A temporary Home Office measure that stops a sponsor assigning new Certificates of Sponsorship while compliance is investigated. |


