What Employers Must Know About Expanded Right-to-Work Checks
On November 27, 2025, the UK Home Office released data that sent shockwaves through the gig economy: 171 delivery riders were arrested in a single week-long enforcement blitz, with 60 detained for immediate deportation. Indians, Bangladeshis, and Chinese nationals made up the majority of those caught working illegally—many operating for platforms like Deliveroo, Uber Eats, and Just Eat without any right to work authorization.
But here’s what should alarm most UK employers: this enforcement action reveals a massive compliance gap that now affects you, even if you don’t directly employ delivery riders.
Just one day before these arrests, the Border Security, Asylum and Immigration Act 2025 received Royal Assent (December 2, 2025), fundamentally expanding what “employer liability” means. For the first time, employers can face £60,000 fines per illegal worker, five-year prison sentences for directors, and business closure—not just for direct employees, but for gig economy workers, subcontractors, and platform-based staff they engage.
This blog post explains why 171 arrests matter to your business, what the new legal landscape means for your compliance obligations, and how to protect your company from catastrophic penalties.
The Operation Equalise Crackdown: What Happened?
Between November 14-17, 2025, the UK Home Office Immigration Enforcement teams conducted “Operation Equalise”—a coordinated, nationwide crackdown on illegal working across villages, towns, and cities throughout Britain.
The Numbers:
- 171 delivery riders arrested across the UK
- 60 detained for removal (facing deportation)
- Nationalities affected: Primarily Indian, Bangladeshi, and Chinese nationals
- Duration: Seven-day enforcement blitz
- Locations: High streets in Newham (East London), Norwich city centre (Eastern England), and other UK locations
Specific Cases from Home Office Reports:
November 17 – Newham, East London:
Four delivery riders of Bangladeshi and Indian nationality were arrested for illegal working. All four were detained for removal proceedings.
November 25 – Norwich City Centre:
Three riders of Indian nationality were arrested. Two were detained for removal; one was placed on strict immigration bail (effectively banned from working).
The Broader Context:
This week-long operation represents just a snapshot of accelerating enforcement activity. According to Home Office data, enforcement action against illegal working reached “record breaking levels” in 2025:
- 11,000+ workplace checks (51% increase year-over-year)
- 8,000 arrests (63% increase year-over-year)
- Nearly 50,000 people removed for having no right to remain (since July 2024)
- 33% increase in people smuggling arrests, convictions, and seizures
These statistics aren’t abstract numbers—they represent real businesses facing £60,000+ fines, director imprisonment, and operational shutdown.
Why Delivery Riders? The Compliance Gap Explained
You might be wondering: why are delivery platforms the focus of this enforcement blitz?
The answer lies in a perfect compliance storm: systematic invisibility.
The Account-Sharing Problem:
Asylum seekers and individuals with no work authorization use a technique called “account sharing” to work illegally. Here’s how it works:
- A legitimate delivery rider with proper work authorization creates an account on Uber Eats, Deliveroo, or Just Eat
- They sell or rent access to that account through social media, WhatsApp groups, or word-of-mouth networks
- Multiple individuals without work authorization use that single account to accept deliveries
- The platform sees only one verified user; the illegal workers remain invisible
- When enforcement teams arrive, they find workers without documentation, but the platform’s account verification provides no protection
The key insight: Platform-level verification (checking the account holder) doesn’t catch worker-level violations (who’s actually doing the work).
Why Enforcement is Accelerating Now:
On December 2, 2025, the government moved to close this loophole permanently. The Border Security, Asylum and Immigration Act 2025 expands right-to-work checks beyond traditional employment to include:
- Self-employed contractors
- Gig economy workers and delivery riders
- Platform-based service providers
- Zero-hours workers
- Subcontractors
- Casual workers
For the first time, employers are liable for verifying the right-to-work status of ANY person providing services—not just salaried employees.
This is why the Home Office held meetings with Deliveroo, Just Eat, and Uber Eats in December 2025 to demand:
- Randomized facial recognition checks to catch account sharing
- Access to asylum hotel locations to identify enforcement hotspots
- Stronger worker verification processes
The November enforcement action was a show of force: “This is what happens when you don’t comply.”
The New Legal Landscape: What Changed on December 2, 2025?
The Border Security, Asylum and Immigration Act 2025 didn’t just expand right-to-work checks—it created unprecedented employer liability exposure.
Expanded Scope of “Employer Liability”
Before December 2, 2025:
- Right-to-work checks applied to direct employees only
- Gig economy workers, subcontractors, and casual staff could operate in a legal grey zone
- Liability was limited and often unclear
After December 2, 2025:
- Right-to-work checks apply to ALL worker categories
- No exceptions for gig economy, platform-based, or temporary staff
- Employer liability is absolute and defined clearly in law
New Penalties (Already in Force):
These penalties apply now, not in 2026:
| Penalty | Amount/Duration | Who It Applies To |
|---|---|---|
| Civil penalty | £60,000 per illegal worker | Every employer/business owner |
| Criminal imprisonment | Up to 5 years | Company directors/managers |
| Business closure | Indefinite | Non-compliant employers |
| Additional fines | Unlimited | Persistent violators |
Example calculation: If an employer unknowingly engages five gig economy workers without proper verification, they face £300,000 in fines (5 × £60,000) plus potential director imprisonment and business shutdown.
Implementation Timeline:
The government has not yet announced the exact date these expanded checks become mandatory (expected 2026), but employers should assume compliance is required NOW. Here’s why:
- Civil penalties are already in effect (£60,000 fines active)
- Home Office enforcement is accelerating (Operation Equalise shows real consequences)
- Platforms are already implementing facial recognition (Deliveroo, Uber Eats, Just Eat confirmed)
- Court cases will soon establish precedent (early-adopter compliance becomes legal standard)
Section 48 Expansion: What It Means:
Section 48 of the Border Security, Asylum and Immigration Act 2025 specifically expands the illegal working civil penalty regime to cover non-employees for the first time. This means:
- Your delivery contractor must have right-to-work authorization
- Your subcontractor must have right-to-work authorization
- Your temporary agency worker must have right-to-work authorization
- Your zero-hours staff must have right-to-work authorization
- Your gig economy workers must have right-to-work authorization
Failure to verify ANY of these categories = £60,000 fine.
The Real Risk: Why Employers Face Catastrophic Liability
Let’s walk through a realistic scenario to understand the compliance risk:
Scenario: A Logistics Company Using Delivery Subcontractors
Background:
A mid-sized logistics company in Manchester uses 20 independent delivery contractors. The company assumes the contractors are responsible for their own legal status—a common mistake.
What happens:
- Home Office enforcement teams visit the company
- They conduct spot checks on 5 of the 20 contractors
- 3 contractors cannot produce valid right-to-work documentation
- The company is found liable for failing to verify worker status
Financial consequence:
- 3 × £60,000 = £180,000 in civil penalties
- Director faces potential 5-year prison sentence (if negligence is proven)
- Business may face operational closure during investigation
- Reputational damage: customers and partners lose confidence
Reality: This scenario played out in Operation Equalise. The difference is that the Home Office is now moving from arresting individual workers to pursuing employer liability directly.
Why Verification Falls Through the Cracks:
Most employers fail right-to-work verification not from malice, but from:
- Process gap: No systematic verification process for non-employees
- Documentation gap: Contractors submit documents once; no expiry monitoring
- Turnover gap: New workers added frequently; old verification records lost
- Scope gap: “We only check employees, not contractors”
- Complexity gap: Different document types, expiry dates, renewal timelines
These gaps are exactly what Home Office enforcement teams look for.
How to Protect Your Business: Right-to-Work Verification for All Worker Categories
Compliance requires moving beyond ad-hoc document collection to systematic, auditable verification. Here’s a step-by-step approach:
Step 1: Audit Your Current Worker Categories
List every person providing services for your business:
- ✓ Full-time employees
- ✓ Part-time employees
- ✓ Zero-hours workers
- ✓ Temporary agency staff
- ✓ Independent contractors
- ✓ Subcontractors
- ✓ Gig economy workers (delivery, driving, etc.)
- ✓ Casual workers
- ✓ Freelancers
Critical point: If you cannot list every person, you cannot verify them. This transparency is your first compliance step.
Step 2: Implement Verification for Each Category
For traditional employees (easy):
- Collect and verify right-to-work documents at hire
- Maintain documented proof in personnel file
- Monitor visa expiry dates
For gig/independent contractors (more complex):
- Require right-to-work verification as condition of engagement
- Document verification in writing (email confirmation)
- Request copies of passport, visa, or right-to-work status
- Establish identity through facial verification or in-person meeting
- Maintain all documents in accessible format
Red flags (demand additional verification):
- Contractor cannot produce original documents
- Documents appear altered or forged
- Contractor seems unfamiliar with their own visa status
- Multiple contractors share similar documentation patterns
Step 3: Set Up Document Expiry Monitoring
This is where most businesses fail. Documents expire, but many employers don’t track this systematically.
What you must monitor:
- Passport expiry dates
- Visa expiry dates
- BRP (Biometric Residence Permit) expiry dates
- Right-to-work status change dates
How to track:
- Manual tracking: Spreadsheet with expiry dates, quarterly reviews (error-prone)
- Automated tracking: Compliance software with automated alerts (recommended)
Why automated is critical: Home Office enforcement teams review HR records. A spreadsheet with missed expiry dates signals negligence. Automated systems with documented alerts demonstrate due diligence.
Step 4: Document Everything (For Enforcement Defense)
When Home Office officers visit (and they will), you must be able to produce:
- ✓ Verification documents for every worker
- ✓ Evidence of identity checks (photos, identity verification)
- ✓ Documented hiring process showing verification step
- ✓ Expiry date monitoring records
- ✓ Records of follow-up actions (reminders to renew visas, etc.)
- ✓ Any corrective actions taken
Why this matters: Home Office officers assess not just whether you verified workers, but whether you have a SYSTEM to verify workers. Documented processes demonstrate due diligence and significantly reduce penalty severity.
Step 5: Regular Audits (Quarterly)
Every three months, conduct an internal compliance audit:
- Have any worker visas expired since last check?
- Are new workers being verified correctly?
- Are documents stored securely and accessibly?
- Is the verification process being followed consistently?
Document this audit in writing. Audits demonstrate proactive compliance and are your strongest defense if enforcement action occurs.
The UKVICAS Solution: Automating Compliance
Here’s the challenge: manual right-to-work verification for gig economy, contract, and zero-hours workers across multiple locations is operationally complex and error-prone.
Most employers lack a systematic process because:
- No platform designed for multi-category worker verification
- Documentation scattered across email, spreadsheets, and paper files
- Expiry dates missed because manual tracking is unreliable
- Audit trails incomplete if enforcement questions arise
UKVICAS solves this by automating the entire lifecycle:
What UKVICAS Does:
- Comprehensive Onboarding
- Single portal for all worker categories
- Captures required documents (passport, visa, BRP, right-to-work status)
- Works for employees, contractors, gig workers, subcontractors—all in one system
- Automatic Document Tracking
- System monitors expiry dates automatically
- Sends proactive alerts before documents expire
- Prevents the “missed expiry” scenario that triggers enforcement penalties
- Audit-Ready Documentation
- All verification records instantly retrievable
- Timestamped documentation of when verification occurred
- Evidence of due diligence that satisfies Home Office enforcement questions
- Multi-Category Flexibility
- Handles employees, contractors, gig workers, subcontractors
- Scalable from 5 to 500+ workers
- Reporting dashboard showing compliance status across all categories
Why This Matters in Practice:
When Home Office enforcement teams arrive, UKVICAS provides:
- Instant proof that verification processes exist
- Documented evidence you monitored document expiry
- Clear audit trail showing corrective actions taken
- Professional, systematic documentation that significantly reduces penalty exposure
Example: An employer with UKVICAS documentation showing systematic verification and automated expiry alerts may face reduced penalties (or none) compared to an employer with scattered, manual records.
Action Items: What You Must Do This Week
The 171 delivery riders detained in Operation Equalise are the beginning, not the end. Home Office enforcement is accelerating, and employers are the new target.
This week, take these actions:
Wednesday, December 11:
- Audit your current worker categories (list everyone providing services)
- Identify which worker categories currently lack right-to-work verification
- Review existing verification documents (are they complete, accessible, expiry dates tracked?)
Friday, December 13:
- Schedule internal compliance review meeting
- If you use contractors/gig workers, implement immediate verification for new hires
- Identify any currently employed workers with expiring visas (within next 6 months)
December 20:
- Establish documented right-to-work verification policy for all worker categories
- Begin implementing systematic document storage (not scattered email/paper)
- Consider compliance management platform to automate expiry monitoring
Ongoing:
- Monthly verification audits
- Quarterly review of visa expiry dates
- Documentation of all compliance actions taken
Key Takeaways
- The enforcement escalation is real. Operation Equalise (171 arrests) is a preview of expanded Home Office focus on employer liability, not worker-only enforcement.
- Your liability is now absolute. The Border Security, Asylum and Immigration Act 2025 makes employers liable for right-to-work verification of ALL worker categories—employees, contractors, gig workers, subcontractors, everyone.
- The penalty is catastrophic. £60,000 per illegal worker, plus 5-year potential director imprisonment and business closure. One mistake with five contractors = £300,000+ in fines.
- Documentation is your defense. Home Office enforcement teams assess not just compliance outcomes, but compliance processes. Documented, systematic verification is your strongest protection.
- Automated compliance is now essential. Manual verification for gig economy and contractor workforces is operationally complex and unreliable. Systematic, automated right-to-work verification is now table-stakes.
- Time is running out. The government signaled its intent on December 2, 2025. Enforcement action is accelerating. The question isn’t “will the Home Office visit?” but “are you ready when they do?”
Next Steps
If you employ or engage contractors, gig workers, or zero-hours staff:
Start with a free right-to-work verification audit. Identify your compliance gaps before the Home Office does. UKVICAS automates the verification process across all worker categories, eliminating the manual complexity that leads to penalties.
Related Links – Illegal working activity between 14 to 17 November 2025 and 25 to 27 November 2025