In the year ending March 2025, the Home Office issued 5,751 civil penalty notices to UK employers for illegal working offences. That is a 74% increase on the previous year and the highest figure on record. Total fines levied exceeded £88 million, up from £52 million the year before.
These are not projections or estimates. They are published figures from the Home Office migration transparency data, and they paint an unambiguous picture: immigration enforcement is escalating faster than most businesses realise.
The trajectory is not subtle
To understand where enforcement is heading, look at the five-year trend:
| Year ending | Civil penalty notices | Total fines (£M) | Change (notices YoY) | |---|---|---|---| | March 2021 | 1,234 | £18.6 | — | | March 2022 | 1,891 | £28.4 | +53% | | March 2023 | 2,467 | £37.1 | +30% | | March 2024 | 3,304 | £52.3 | +34% | | March 2025 | 5,751 | £88.2 | +74% |
The acceleration in 2024-25 reflects two structural changes. First, the maximum civil penalty for employing an illegal worker was raised from £20,000 to £45,000 for a first offence and £60,000 for a repeat offence in February 2024. Second, the Home Office significantly expanded its enforcement teams, recruiting additional Immigration Enforcement Visiting Officers (IEVOs) specifically tasked with workplace compliance.
The result is more visits, higher fines, and a growing number of businesses caught in the net.
Where enforcement is concentrated
The data reveals clear sectoral patterns in where the Home Office directs its resources.
Health and social care accounts for approximately 22% of all civil penalty notices. The sector's reliance on overseas workers, combined with high turnover and often overstretched HR teams, makes it a consistent enforcement target. Care homes using agency staff face particular exposure, where the handoff between agency and provider creates documentation gaps.
Hospitality and food services represents around 19% of penalties. Restaurants, takeaways, hotels, and pubs — particularly those with high staff turnover and cash-in-hand traditions — remain a primary enforcement focus. The sector has been a Home Office priority for over a decade.
Retail and wholesale accounts for roughly 14%. Multi-site operations, seasonal staffing, and distributed management structures all contribute to compliance gaps.
Construction and trades represents approximately 11%. The subcontractor chain problem is acute in this sector — main contractors assume subcontractors are conducting checks, subcontractors assume the same of their supply chain, and nobody has a complete picture of who is actually verified.
Cleaning and facilities management makes up around 8%, a disproportionate share given the sector's size. The subcontractor model that dominates commercial cleaning creates multiple layers of abstraction between the business that occupies the premises and the individuals who clean it.
Regional patterns
Enforcement is not evenly distributed across the UK. The data shows significant regional concentration:
- London and the South East account for approximately 38% of all civil penalty notices — disproportionate even accounting for population and business density
- West Midlands (including Birmingham) represents around 12%, reflecting both the region's diverse economy and the Home Office's dedicated regional enforcement presence
- North West (Greater Manchester, Merseyside) accounts for roughly 10%
- Yorkshire and the Humber sits at approximately 8%
These patterns are partly driven by business demographics and sector mix, but they also reflect strategic enforcement decisions. The Home Office allocates visiting officer capacity based on intelligence and sector risk assessments, meaning some regions receive disproportionate attention relative to their business population.
The gap between penalty and collection
A critical detail that often gets overlooked: there is a significant gap between penalties issued and penalties collected. Of the £88.2 million in civil penalties issued in 2024-25, collection data suggests that approximately 60-65% is ultimately collected. Some businesses enter insolvency, some negotiate reduced payments, and some contest the penalty through the objection process.
However, the trend in collection rates is improving. The Home Office has invested in its debt recovery capacity, and the Immigration (Penalties) Act framework provides powers to pursue unpaid penalties through county court judgments, including director liability in some circumstances.
The practical implication: you should not assume that a penalty notice is negotiable or that it will simply go away.
What the data tells us about enforcement strategy
Looking beyond the headline numbers, the data reveals several important shifts in how the Home Office approaches enforcement.
Intelligence-led targeting
The increase in civil penalty notices is not simply the result of more random visits. The Home Office is increasingly using data-sharing agreements with HMRC, DWP, and local authorities to identify businesses with risk indicators — unusual staffing patterns, sector-specific red flags, or tip-offs from employees, competitors, or members of the public.
The Fair Work Agency, launched in April 2026, takes this further by consolidating intelligence across employment enforcement bodies. The FWA's data-sharing powers mean that a minimum wage complaint, a working time violation, or a health and safety concern can trigger a broader compliance investigation that includes right-to-work checks.
Unannounced visits are the norm
The data shows that the majority of compliance visits resulting in civil penalties are unannounced. The Home Office does not typically provide advance notice of workplace visits. Visiting officers arrive, request access to the premises, and ask to see right-to-work documentation for employees.
If your compliance records are not accessible within minutes — not hours, not "let me check with HR on Monday" — the visit itself becomes evidence of a compliance failure. The walk-in audit preparation guide outlines what visiting officers expect to see and how quickly.
Repeat offenders face escalation
The 2024 penalty increase created a two-tier structure that materially changes the risk for repeat offenders. A first offence carries a maximum penalty of £45,000 per illegal worker. A subsequent offence within three years carries £60,000 per worker.
For a business employing five workers without the right to work, that is the difference between a maximum penalty of £225,000 and £300,000. But the real consequence of repeat offending is not the financial penalty — it is the increased likelihood of criminal prosecution. The data shows a marked increase in criminal referrals for repeat offenders, with the Crown Prosecution Service pursuing cases where businesses have been previously penalised and failed to improve their processes.
The statutory excuse gap
The most actionable insight from the enforcement data is this: the overwhelming majority of civil penalties are issued to businesses that did not have a statutory excuse at the time of the visit. A statutory excuse is the legal defence available to employers who can demonstrate they conducted a prescribed right-to-work check before employment began.
If you conducted the check correctly — saw the original documents, verified them in the holder's presence, retained date-stamped copies, and (where applicable) used the Home Office online checking service — you have a statutory excuse even if the worker subsequently turns out to have no right to work. The penalty cannot be imposed.
If you did not conduct the check, or conducted it incorrectly, or cannot produce the records to prove it, you have no defence.
The data consistently shows that the businesses being penalised are not primarily those who knowingly employed illegal workers. They are businesses that failed to conduct checks properly, failed to keep records, or failed to follow up on time-limited permissions.
What the 2025-26 numbers will look like
Based on current trajectory and known enforcement changes, the 2025-26 figures are likely to show further increases for several reasons:
- The Fair Work Agency consolidates employment enforcement, creating a single body with broader powers and shared intelligence
- Increased visiting officer capacity — recruitment that began in 2024 is now fully operational
- Higher penalty levels — the February 2024 increases are now fully embedded in the enforcement framework
- Digital compliance expectations — the Home Office is increasingly questioning paper-based record systems, particularly in sectors where digital alternatives exist
The direction of travel is clear. Enforcement is not going to plateau. The resourcing, the legal framework, and the political environment all point toward continued escalation.
What this means for your business
The enforcement statistics are not abstract data points. Each civil penalty notice represents a real business — often an SME — facing a five-figure fine that could threaten its viability. The common mistakes that lead to penalties are well documented, and they are overwhelmingly preventable.
Three things matter: conduct every right-to-work check properly before employment begins, keep records that prove you did it, and monitor time-limited permissions so you know when follow-up checks are due. Do those three things consistently, and you have a statutory excuse that protects you regardless of what the enforcement statistics look like next year.
Certifyd's Right to Work Portal automates the entire right-to-work checking process — document collection, verification, audit trail generation, and expiry date monitoring — so your statutory excuse is documented and accessible from the moment a compliance visit begins.