Legislative Alert: Personal Liability for Directors Increased (Jan 2026)

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Business Critical Risk

What Happens When Your
Licence is Revoked?

It is not just a fine. It is the immediate curtailment of your workforce, a freeze on recruitment, and a black mark against your directors.
For many businesses, it is the end.

Protect My Business Now
New Legislation: Jan 2026

Criminal & Civil Escalation

Under The Border Security, Asylum and Immigration Act 2025 (Commencement No. 2) Regulations 2026, the corporate veil has been pierced.
Directors and Key Personnel are now personally liable.

Criminal Liability

For Directors & Key Personnel

  • 5-Year Custodial Sentences The Act cements the penalty for employing illegal workers where you "had reasonable cause to believe" they lacked status.
  • Director Disqualification Automatic referral to the Insolvency Service for disqualification orders (up to 15 years), ending your career as a company director.

Civil Proceedings

Against the Entity

  • Unlimited Fines Statutory caps have been removed for repeat offenders under the new regulations, allowing for business-ending penalties.
  • Asset Seizure (POCA) Proceeds of Crime Act provisions now explicitly cover revenue generated through "non-compliant labour", allowing state seizure of assets.

Operational Consequences

Beyond the courts, revocation halts your daily operations immediately.

Workforce Curtailment

Every worker you sponsor typically has their visa curtailed to 60 days. They must leave the UK or find a new sponsor immediately. You lose your staff overnight.

Key Personnel Flagging

Your Authorising Officer and Key Contact are flagged on the Home Office system. They are often barred from holding these positions at any other company.

12-Month Cooling Off

You cannot simply re-apply. You are banned from holding a sponsor licence for a minimum of 12 months (the "cooling-off period").

Operational Paralysis

You cannot hire any new migrant workers. If you rely on overseas talent (e.g., Care, Tech, Hospitality), your recruitment pipeline freezes.

The Anatomy of a Revocation

How quickly a business unravels after a compliance failure.

1

The Suspension Letter

You receive a notice of suspension. You have 20 working days to respond. Your SMS access is restricted immediately.

2

The Decision

If your representations fail (often due to poor data records), the licence is formally revoked.

3

The Curtailment

The Home Office writes to your sponsored employees. Their visas are cut short (usually to 60 days). They stop coming to work.

4

The Reputational Hit

Contracts with local authorities (Care) or main contractors (Construction) are often terminated due to "breach of compliance" clauses.

Don't Let A Spreadsheet Error End Your Business.

Revocation usually happens because what you told the Home Office doesn't match what is in your files. IRS HR fixes the data gap automatically.

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We don’t provide immigration advice but connect you to our panel of solicitors for immigration advice. The information above is only for informational purposes and shouldn’t be construed as immigration advice.

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