Law firm Clyde & Co’s latest UK Immigration Update (6 July) highlights two employer-critical developments: a draft Code of Practice that re-defines who counts as an “employee” for Right-to-Work (RTW) checks, and detailed Home Office guidance on the forthcoming Earned Settlement route. Under the draft Code, the obligation to verify RTW documents can extend beyond direct employees to subcontractors, gig-economy workers placed via online platforms and even substitute staff provided under service contracts. Failure to apply the checks correctly may expose the commissioning company – dubbed the ‘Extended Employer’ – to civil penalties of up to £45,000 per illegal worker for a first breach.
![Right-to-Work overhaul and ‘earned settlement’ centre stage in July immigration update]()
For organisations that need hands-on assistance in meeting these expanded verification duties, VisaHQ offers a streamlined suite of RTW and visa-support services. Its UK platform enables HR teams to run real-time document checks, schedule in-person biometric appointments and access expert advice, helping employers stay on the right side of an increasingly demanding compliance regime.
The note also sets out the Home Office’s three-tier pathway to settlement: five years for salaries above 2.5 × the national median, seven years for those meeting standard Skilled-Worker thresholds, and ten years for lower-paid roles. Individuals will need to accrue ‘integration points’ through continuous tax contributions and no unspent convictions. Transitional rules will moderate the impact on existing staff when the scheme launches in April 2027. Businesses are advised to audit labour-supply chains, refresh subcontractor clauses and budget for the higher legal-compliance workload. HR teams should also prepare communication plans for foreign staff concerned about the longer settlement horizon. While still subject to parliamentary approval, the proposals indicate the direction of travel: tougher compliance for employers alongside a clearer, salary-linked route to permanent residence.
For organisations that need hands-on assistance in meeting these expanded verification duties, VisaHQ offers a streamlined suite of RTW and visa-support services. Its UK platform enables HR teams to run real-time document checks, schedule in-person biometric appointments and access expert advice, helping employers stay on the right side of an increasingly demanding compliance regime.
The note also sets out the Home Office’s three-tier pathway to settlement: five years for salaries above 2.5 × the national median, seven years for those meeting standard Skilled-Worker thresholds, and ten years for lower-paid roles. Individuals will need to accrue ‘integration points’ through continuous tax contributions and no unspent convictions. Transitional rules will moderate the impact on existing staff when the scheme launches in April 2027. Businesses are advised to audit labour-supply chains, refresh subcontractor clauses and budget for the higher legal-compliance workload. HR teams should also prepare communication plans for foreign staff concerned about the longer settlement horizon. While still subject to parliamentary approval, the proposals indicate the direction of travel: tougher compliance for employers alongside a clearer, salary-linked route to permanent residence.
