Our advocacy work
If there is one thing we learnt from providing frontline advice over the years, it is that the issues experienced by our clients are never simply the outcome of individual vulnerabilities. They are also an expression of policy choices that limit worker power, and allow non-compliance to continue unchecked.
Much of our work in 2025 was focused on supporting migrant workers on employer-sponsored visas, who were at the sharpest edge of exploitation. But this was also a time of momentous transformation to labour enforcement - which made this our busiest year yet.
Migrant workers’ exploitation by their visa sponsors
Our November 2023 report ‘Systemic drivers of migrant worker exploitation’ was among the first to expose the risks derived from an immigration system that puts employers in charge of migrant workers’ visas, and an employment enforcement system that is fragmented and under-resourced.
The issues documented in this report turned out to be just the tip of the iceberg. Our frontline team was subsequently inundated by enquiries from migrant workers who were abused by their visa sponsors.
In 2025 as many as 227 people who contacted the charity were migrant workers on the Health and Care Worker visa, and another 79 were on the Skilled Worker visa. Of 306 clients on these visas, whom we supported with employment matters, the most common workplace issues cited were non-provision of work (36% of enquiries), non-payment of wages (43%), dismissal (30%), and holiday pay entitlement (20%). Notably, 26 clients were in the National Referral Mechanism (NRM) for victims of modern slavery.
While our frontline teams provided workers with legal advice, our policy team strived to raise awareness of the changes needed to address the power imbalance underlying the work sponsorship system.
Our first report of the year, ‘No Match’, found that the government’s plan to fund job-finding hubs to rematch exploited care workers with new sponsors had a mere 3.4% success rate. A more nuanced approach to immigration reform was needed.
In our second major report, ‘Safeguarding Migrant Workers’, we looked at the immigration policies of six other countries to highlight achievable, evidence-based measures that can curb the power of sponsoring employers. This included:
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Giving migrant workers more time to change employers before their visas expire
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Instituting an Australian-style Workplace Justice Visa for victims of labour exploitation
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Imposing tougher sanctions on non-compliant employers
This report was accompanied by an open letter to the Home Secretary, which was signed by over 130 migrant rights’ experts, academics, lawyers and other practitioners.
We were pleased to see the government commit to “explore” these measures in the Immigration White Paper in May, and many policymakers agree with our proposals (see our campaigns page for details). But despite this silver lining, we were deeply alarmed by the general direction of immigration policy.
Countering a worrying direction in work migration policy
Focused on reducing immigration at all costs, the white paper promised, among other things, to:
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Increase the costs of sponsorship for businesses (consequently making it harder for sponsored workers to change jobs). This was enacted in July 2025.
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Remove many medium-skilled jobs from the list of occupations eligible for Skilled Worker roles (placing some on an even more precarious Temporary Shortage list). Also enacted in July 2025.
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Implement the most radical restrictions to settlement in a generation. Announced in November, we expect this to be enacted from April 2026, following a public consultation.
Throughout the year, we opposed the government’s ill-thought-out plans and generated scrutiny that otherwise may not have materialised. For example, we submitted evidence to the Secondary Legislation Scrutiny Committee on two occasions and, with this intervention, secured an important impact assessment showing how the government’s July changes would cost the Treasury up to £10bn. We were also pleased to see the committee organise an oral evidence scrutiny session with the new immigration minister Mike Tapp MP.
Similarly, throughout the year we briefed MPs on changes to the immigration system and provided material that was used in various parliamentary debates. In particular, in November we hosted a drop-in event in Westminster Hall in collaboration with Neil Duncan-Jordan, alongside UNISON and IPPR, on the government’s immigration changes.
Even as the year drew to a close, we were firing on all cylinders. On the 16th of December we launched a new campaign, encouraging our communities to speak up against the damaging proposals to restrict routes to settlement. We were pleased to see Neil Duncan-Jordan and 50+ MPs sign an Early Day Motion to oppose the retroactive application of these changes - and we expect this fight to carry on well into 2026.
Employment Rights Bill and the new Fair Work Agency
In contrast to the changes to immigration policy, the government’s employment rights agenda contains several welcome provisions. The Employment Rights Bill significantly widens protections for vulnerable workers, including by introducing guaranteed hours for many zero-hours workers, and giving all workers protection from unfair dismissal after six months (down from the current two years). The bill institutes the Fair Work Agency, a new body responsible for the enforcement of labour rights - with a wider remit, stronger powers, and a tripartite Advisory Board, which we applied to join.
Much of our time was spent influencing the remit and operations of the Fair Work Agency. In the spring and summer months we collaborated with Centre for London and partners on principles that should guide the new agency, and later in the year we attended several private roundtables hosted by the Department of Business and Trade, focused on how the agency would operate in practice. Following a collaboration with ILPA, FLEX and LAWRS, Baroness Hamwee was also able to stimulate debate on the topic of secure reporting by submitting a probing amendment on this issue - though this was ultimately not included in the bill.
Granted, there is more we would have liked to achieve, and much more that is yet to be decided. We were particularly concerned by an announcement in the November 2025 Budget, that the Fair Work Agency would have a hidden economy focus. Prioritising immigration enforcement over workers’ rights would be a mistake. We would also have liked to see more protections for Seasonal Workers, who are not covered by the new rules on unfair dismissal. We will continue to focus closely on ensuring that the Fair Work Agency is inclusive of migrant and vulnerable workers, and will monitor the government’s broader plan to Make Work Pay.
Seasonal Workers
As part of the Seasonal Worker Interest Group, which we formed with colleagues at FLEX, Worker Support Centre, TUC, Landworkers Alliance and other organisations, we managed to secure a meeting with then immigration and farming ministers Seema Malhotra and Daniel Zeichner, to express our concerns about the ongoing treatment of workers on the Seasonal Worker visa. We also regularly met with civil servants at DEFRA and UKVI, and fed into multi-stakeholder discussions about the potential implementation of the Employer Pays Principle. Finally, we engaged with the EFRA Committee on bringing operational issues to the attention of the new Minister, Angela Eagle, and will be delivering a briefing for the committee in the new year.
Frustratingly, policymakers were less receptive to our recommendations than we’d have liked. The Employer Pays Principle has not been implemented. There also remain issues with reporting matters to government bodies for investigation, and enforcing Home Office guidance to protect workers’ rights. This is why, while we continue to engage with policymakers in good faith, we are increasingly supporting workers with litigation.
In 2025 alone, we took on 6 new cases of seasonal workers for representation in the Employment Tribunal that challenge systemic practices across the scheme - including non-payment of wages, discrimination, harassment, victimisation and other mistreatment of workers complaining about their rights, and failure of labour providers to actively investigate exploitation when it arises.