Which UK Industries Get Hit With the Most Illegal Working Fines
And Why Yours Might Be Next

By ZH Team

Illegal working enforcement in the UK is no longer a peripheral risk. Home Office figures show that between July 2024 and the end of December 2025, raids on businesses increased by 77% and arrests by 83%, reaching record levels. Employers operating outside the sectors that attract the most publicity may still be tempted to regard this as somebody else’s problem. Increasingly, that is an unsafe assumption.

Which industries is the Home Office actually targeting?

Home Office operations have consistently focused on sectors it describes as vulnerable to exploitation and non-compliance, including:

nail bars and beauty salons
car washes
barbershops and hairdressers
restaurants and takeaway premises
construction sites
warehousing, packaging and distribution
mini-marts, convenience stores and vape shops

A single month-long operation across these sectors alone resulted in over 1,700 business visits and close to 700 arrests. London recorded the highest number of arrests of any region in 2025, with a sharp year-on-year increase.

Does that mean other industries are safe? No.

A civil penalty does not depend on deliberate wrongdoing, nor on whether an employer operates in a sector currently attracting enforcement attention. The essential question is whether the employer can establish a valid statutory excuse in respect of the worker concerned. Any business that has failed to embed the prescribed right to work check properly into its onboarding process is therefore exposed, regardless of sector.

There is also a broader reason why employers should not assume that today’s enforcement priorities will remain fixed. Right to work obligations are expanding. Reforms under the Border Security, Asylum and Immigration Act extend checking requirements beyond traditional employees to areas such as gig-economy, self-employed and platform work, arrangements which many businesses outside hospitality and retail may not previously have associated with right to work compliance.

Enforcement priorities also evolve with policy, resources and operational focus. The sectors attracting the most attention today were not always at the forefront of enforcement, and there is no reason to assume the present list is exhaustive or permanent.

What a penalty actually costs beyond the fine itself

The financial penalty is only part of the exposure. A civil penalty can trigger:

placement on the Home Office’s public register of penalised employers
increased likelihood of follow-up or unannounced visits
sponsor licence action for businesses that hold one, including suspension, downgrading or revocation
reputational damage with clients, landlords and suppliers who check that register

For sponsor licence holders in particular, the knock-on consequences to the licence itself can be more damaging to the business than the initial finding.

How to protect your business, regardless of sector

Audit your existing right to work records now, rather than waiting until an enforcement visit or compliance issue exposes gaps.

Pay particular attention to non-standard working arrangements, including agency staff, casual workers, subcontractors and gig workers, which can more easily fall outside conventional onboarding processes.

Make sure every check is carried out using the correct prescribed method and at the correct time. A check completed retrospectively will not cure a failure to establish a statutory excuse before employment begins.

Retain the required evidence throughout the individual’s employment and for a further two years after it ends.

Diary follow-up checks for anyone whose permission to work is time-limited, so that expiry dates are identified and acted upon before they become a compliance problem.

Treat right to work compliance as an ongoing business process, not a one-off HR exercise or a response to whichever sectors happen to be attracting enforcement attention at the time.

How ZH Law can help

ZH Law advises employers across all sectors on illegal working risk and civil penalty exposure. We can assist with:

Auditing existing right to work checks and records, identifying weaknesses before they are exposed during an enforcement visit;
Advising on agency, subcontractor and gig-worker arrangements, including where responsibility for checks may not sit neatly within standard onboarding processes;
Preparing businesses for Home Office compliance visits, including reviewing records, systems and internal procedures in advance;
Advising sponsor licence holders on the wider regulatory and sponsorship consequences of compliance concerns; and
Challenging civil penalties where a penalty has already been issued.

Frequently Asked Questions

Which industries are most exposed to illegal working enforcement in the UK?

Home Office enforcement has focused particularly on sectors such as nail bars, car washes, barbershops, restaurants and takeaways, construction, warehousing and logistics, and convenience retail. These are sectors in which cash-based trading, high staff turnover and casual or flexible labour arrangements are more common.

If my business is not in one of these sectors, do I still need to be concerned?

Yes. Enforcement priorities indicate where the Home Office is concentrating its resources; they do not limit the scope of the law. Every employer must carry out the prescribed right to work check, regardless of sector.

Are gig economy and self-employed workers now covered by right to work checks?

Reforms under the Border Security, Asylum and Immigration Act are extending right to work obligations beyond traditional employees to certain gig-economy, self-employed and platform-working arrangements. This significantly widens the compliance landscape for businesses that may not previously have regarded these workers as falling within right to work checking requirements.

Do I need to carry out right to work checks for British and Irish citizens?

Yes. The Home Office publishes details of employers who have received civil penalties for illegal working. Those records are publicly accessible and may also attract adverse press or reputational attention.

What is the most common compliance weakness across higher-risk sectors?

A recurring problem is the use of agency, subcontracted or casual labour without a consistent and properly documented right to work checking process. Compliance systems must account for the whole workforce structure, rather than focusing only on conventional direct employees.

Unsure whether your industry, or your business specifically, is exposed?

Speak to ZH Law today.

London: 0203 887 7306 | Leicester: 0116 365 6400 | enquiries@zh-law.co.uk

This article is provided for general information only and does not constitute legal advice. Immigration law and Home Office guidance are subject to change. Advice should be obtained on the particular circumstances of each case.

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