From 8 April 2026, updated Home Office sponsor guidance has significantly widened the scope of right to work checks. Introduced without prior notice, the changes impose broader compliance duties on sponsors and raise immediate concerns for many businesses.
Written by Angel Wan, Solicitor
Wider Obligations, Greater Uncertainty
Sponsors must now verify that anyone they intend to sponsor, employ, or “directly engage” has valid permission to work in the UK before work begins. This applies even where an individual appears to be a British citizen or otherwise settled. Failure to carry out checks can result in civil penalties and the loss of a sponsor licence.
The key issue is uncertainty. The term “directly engage” is not defined, leaving employers unclear about how far their responsibilities extend. A cautious approach suggests checks may now be required for individuals beyond traditional employees, such as contractors, LLP members, and zero-hours workers.
These changes go further than the current right to work regime and appear to anticipate a broader enforcement framework that has been legislated but not yet implemented. Their early introduction, before consultation has concluded and without a transition period, has made compliance more challenging, particularly for organisations with complex or flexible workforce structures.
Conclusion
This update marks a notable expansion of sponsor duties, combined with limited clarity on how to comply. Businesses should act promptly by reviewing their right to work procedures and considering whether checks need to be extended to non-employee workers.
In our view, a cautious and proactive approach is essential. Until further guidance is issued, sponsors should prioritise risk management, maintain clear records, and seek advice where needed to avoid potential penalties or licence revocation.
Lisa’s Law have extensive expertise when it comes to providing support for businesses attempting to adhere to their sponsor obligations. Find out more about our corporate immigration services here.
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