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The official penalty data is a useful reminder that Right to Work failures are not rare edge cases. The Home Office’s anonymous national report for 1st April to 30th June 2025 recorded 617 penalties, 831 illegal workers found and a gross penalty value of £34,265,000. Digital checking is useful but the Home Office guidance still draws firm boundaries around where it works and where it does not. The June 2025 employer guide says a digital verification service can be used for British and Irish citizens who hold a valid passport or Irish passport card. It also says that a manual or Home Office online check carried out by a DVS, outside that prescribed route, does not establish a statutory excuse for the employer.
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Those figures sit alongside guidance that is built around statutory excuse and retained evidence. The employer guide states that Right to Work checks are the specific actions an employer can take to prevent liability for a civil penalty. That makes process discipline more than an internal best practice. It is the legal protection employers rely on when something later comes under scrutiny.
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The practical question is not whether most hires are checked most of the time. It is whether each relevant worker was checked through the correct route, whether the evidence was retained, and whether follow-up action was taken where needed. That is usually where ordinary operational weakness becomes expensive.
Sources: Home Office illegal working civil penalties report and current employer guidance.
This is the fifth blog in a 6-part series. You can subscribe here to be notified of future changes to Right to Work Compliance based on HMRC updates and Gov.uk sources.
You can also find the other parts here:
- Click here for part 1 on how the Home Office’s draft 2026 code shifts Right to Work compliance.
- Find out how Right to Work is moving beyond employees in part 2 here.
- Part 3 covered how digital-only Right to Work journeys can leave gaps.
- In part 4, we looked at how rechecks have been causing employers to become unstuck with regards to their right to work compliance.
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