What’s happening?
The UK government has launched its most extensive crackdown on illegal working to date. Under ‘Operation Sterling’, Immigration Enforcement carried out over 11,000 raids between October 2024 and September 2025, resulting in more than 8,000 arrests. The focus has been on sectors with high levels of illegal working, including takeaways, beauty salons, car washes, and gig economy platforms.
Under the Border Security, Asylum and Immigration Bill 2025 (the Bill), the Government is intending to roll out mandatory digital ID checks to verify right to work status and prevent document fraud. The intention is to create a simpler and more consistent way for employers to check someone’s right to work.
Why is this important?
The Bill will significantly expand employer obligations. Previously, only traditional employment relationships required right to work checks. Under new laws, it is expected that casual workers, zero-hour workers, individual subcontractors and other temporary arrangements will now be covered.
Failure to comply could result in:
- Fines of up to £60,000 per illegal worker
- Criminal liability (up to 5 years in prison)
- In serious cases, business closure
Before implementing the new rules, the Government has launched a consultation to give employers the opportunity to shape how they will be applied and enforced. The Government is also working with major platforms like Deliveroo, Just Eat and Uber Eats to strengthen ID verification and share data to identify illegal working.
What should you do?
- Review your right to work processes, especially for non-traditional working arrangements.
- Prepare for digital ID implementation – this will become the standard method for verifying right to work.
- Engage with the government’s consultation on the new rules, which is seeking input on recruitment practices and supply chain arrangements: Prevention of illegal working: Extending the Right to Work Scheme to other working arrangements – GOV.UK. Consultation closes at 11:59 on 10 December 2025.
- Audit your supply chains to ensure compliance across all tiers.
- Stay informed – guidance is expected to follow the consultation to clarify when and how checks should be carried out.
This is a major shift in enforcement and compliance expectations. Employers should act now to mitigate risk and ensure they’re ready for the new regime.
