UK right to work compliance audit

12th September 2025 | Nelli Shevchenko | Immigration, Case Study, Work Compliance Audit

As Home Office scrutiny intensifies and right to work penalties rise, businesses can no longer afford gaps in their immigration compliance systems. Our UK immigration team recently completed a right to work audit for a multinational e-commerce business. It is a timely reminder of why every employer should proactively review their processes.

Background

Immigration compliance is at the centre of UK Government policy. The Home Office has stepped up enforcement through unannounced visits, digital audits, and tougher penalties. All employers, whether sponsor licence holders or not, face heightened risk.

The figures are stark:

Civil penalties for illegal working have tripled since 2024, now up to £60,000 per illegal worker.
Recent cases include headline news:
- St Albans and Radlett businesses fined £100K for employing illegal workers”, 5 December 2024
- “Liverpool firms fined £165,000 over illegal staff”, dated 24 June 2025
In Sept 2025, the Government announced a record numbers of visa sponsor licences revoked for rule breaking.

While usual high-risk sectors such as construction and hospitality remain under scrutiny, enforcement has widened to cover finance, consultancy, professional services, and e-commerce.

Case study: e-commerce business audit

As a result, our client became concerned with the potential impact of an unannounced Home Office visit or digital audit. The only way to avoid civil penalties for illegal working is by having robust processes and records to demonstrate that the necessary checks have been carried out. The company wanted assurance that its existing procedures would protect the business and clarity on where improvements could reduce risk.

This concern is far from unique. An official Home Office report (April 2025) reveals alarming findings:

Few employers know how to carry out Right to Work (RTW) checks correctly
Many wrongly assume recruitment agencies are responsible for verification
62% of small businesses and 42% of medium/large businesses incorrectly believe driving licences are valid RTW documents

Following discussion about the main areas of concern, the catered scope of work for this case included:

Audit of 500 employee files across the UK workforce
Focused reviews of:
1. 20% student visa holders
2. 10% sponsored workers

Findings included:

Missing or incomplete documentation
Incorrect reliance on third-party digital platforms, such as recruiters or IDSP
Expired work authorisations not re-verified
Missing data or documents for student workers (e.g. university term dates)
Student visa breaches (exceeding permitted working hours)

We delivered a full risk assessment with clear High/Medium/Low rankings, identified system gaps, and provided a practical action plan. The business now has a robust compliance framework to withstand scrutiny and protect its sponsor licence.

We are increasingly instructed by businesses and family offices to reduce compliance risk. Our services include:

UK right to work audits
Independent sponsor licence compliance audits
Specialist training for Authorising Officers and HR teams
Boardroom/QA training for senior management

Please email Nelli Shevchenko for further information, or contact us via the Immigration page.

Key takeaway

With the Home Office pursuing a stricter, more proactive compliance strategy, businesses must act. The financial, operational, and reputational risks are higher than ever. Regular audits, robust systems, and targeted training are no longer optional – they are essential.