Megan Moorhouse

From 1 October 2026, significant changes to the UK’s Right to Work (RTW) regime will come into force. The reforms expand RTW obligations beyond traditional employment relationships and bring a wider range of labour arrangements within the scope of the illegal working regime. The changes have been introduced to combat illegal working within a variety of labour models including outsourced labour, temporary and contract workers and subcontracting structures. Sectors such as construction,...

A civil penalty for illegal working can expose an employer to a fine of up to £60,000 per illegal worker. Although effective Right to Work checks are the first line of defence, employers must also be aware of how to respond if the Home Office issues a penalty. This article outlines the process following a Civil Penalty Notice and sets out the steps employers can take to challenge such notices. Identifying a breach: What steps will the Home Office take? The Home Office draws on a range of...

The Home Office has introduced a number of important updates to the Sponsor Guidance which will impact how organisations manage their sponsor licences and SMS users. Key changes sponsors should be aware of include: ✅ Level 2 Users New Level 2 users can only be added to a sponsor licence until 9 September 2026. Existing Level 2 users must be converted to Level 1 users (where eligible) or deactivated by 8 March 2027. ✅ Inactive SMS Users SMS users must access their accounts regularly and keep...