Seventeen Thousand Raids, and Nobody Wrote the Rulebook

Immigration Enforcement carried out more than 17,400 raids on British workplaces between July 2024 and the end of last year — nail bars, barbers, car washes, takeaways — and the Home Office wants you to know this is a triumph. Two separate press releases in January, one trailing the other by a day, called it "the highest level in UK history," as though history were a leaderboard and someone had finally beaten the 2019 score. Raids up 77 per cent. Arrests up 83 per cent. Nobody in either release explains who decided that 17,400 was the right number, why a nail bar in one town gets a visit and the identical nail bar three streets over doesn't, or what happens to the businesses that get raided and turn out to be clean.

That last question matters more than it sounds.

Emma Brooksbank, an immigration partner at Freeths, has already told employers the message is "unambiguous": right-to-work compliance is now a frontline regulatory obligation, and penalties can land even where the breach was accidental. An employer with an incomplete file, a badly scanned passport, a National Insurance number typed one digit wrong, sits in exactly the same enforcement funnel as one running a genuine racket. The Home Office counts both as a win in the same press release.

The scope of who's now caught in that funnel just widened. The Border, Security, Asylum and Immigration Act 2025, which received royal assent on 2 December, extends right-to-work checks to gig economy workers — the courier on the e-bike, the driver logging into an app between shifts, the sort of employment relationship that didn't exist in a form immigration law recognised twenty years ago. A new category of worker, a new category of employer duty, a new category of raid, all arriving with a Minister on Sky News telling Sophy Ridge that officers are "working around the clock," which is the kind of sentence that sounds like accountability and contains none of it.

And the case for the raids isn't a weak one. Illegal working genuinely does undercut legitimate businesses, deprive the Treasury of tax and National Insurance, and leave undocumented workers with no protection against employers who know they can't complain. The Home Office's own 2018 inspection said as much in language nobody would dispute: migrants working illegally are "vulnerable to exploitation and abuse by unscrupulous employers," and the scale of the problem has for years been "greater than our capacity to enforce it." On that reading, 17,400 raids isn't overreach. It's a government finally putting resource behind a policy nobody in Parliament seriously opposes, going after the takeaway that pays cash-in-hand and the barber shop nobody checks. Fair enough, as a starting principle.

Except that same 2018 inspection is the reason to be suspicious of the current numbers rather than impressed by them. Back then, inspectors were told the raids were "intelligence-led." No criteria were published. A 2015-16 Cabinet Office estimate of the scale of illegal working was discounted as inaccurate, with the Home Office insisting on the record that no policy had ever rested on it — a tidy way of saying the figures were made up and it didn't matter because nobody checked them anyway. Eight years and one election later, the phrase doing the work is still "intelligence-led," the criteria are still unpublished, and the only external audit of Immigration Enforcement's targeting decisions that anyone can point to is now old enough to vote.

That's the actual story, and it has nothing to do with whether you think the raids themselves are a good idea. A power to enter a workplace, question staff, seize documents and issue civil penalties has expanded by 77 per cent in eighteen months, inside a department that marks its own homework, publishes its results as a press release rather than a report, and answers to a Minister whose only stated metric of success is the size of the increase. There is no independent inspectorate publishing current criteria for who gets targeted. There is no parliamentary committee sitting on the raid figures the way the OBR sits on a fiscal forecast. There is a government minister on a Sunday politics show saying the word "relentless" and calling it oversight.

None of this requires you to think the nail bar owner with the missing document deserves more sympathy than the courier working sixty hours a week with no protection at all. The exploitation is real on both sides of that transaction, and a state that ignored it would be failing at something basic. The complaint is narrower and less comfortable than a side in the immigration argument: a British government department has been handed, by its own admission and everyone else's silence, a scaling enforcement power with no published rulebook for how it's aimed, and the only people asking questions about that are HR consultancies worried about their clients' civil penalties.

Britain has spent a decade building institutions that check the Treasury's arithmetic and none that check the Home Office's targeting list. The Treasury, whatever else is wrong with it, at least publishes the discount rate it uses to devalue your grandchildren's hospital. Immigration Enforcement won't publish the rate it uses to decide which barber shop gets the van outside it on a Tuesday morning, and there is no vote, no tribunal and no committee that can make it.