Immigration firm Fragomen released a client alert on 17 November analysing the business implications of the government’s asylum overhaul and related compliance changes. The alert highlights five areas where sponsors must prepare for new obligations:
1. Right-to-Work Expansion – Checks will extend beyond PAYE employees to sub-contractors and gig-economy workers, with mandatory digital identity verification.
2. Protection Work & Study Route – Employers may be asked to sponsor refugees who switch status; certificates of sponsorship will be capped, driving competition for allocation.
3. Visa Penalties – Firms with operations in countries targeted by the ‘emergency brake’ could face sudden talent pipeline disruptions.
4. Digital Status – All physical BRP cards will be obsolete by June 2026; HR systems must integrate with the Home Office API.
5. Conduct & Suitability Tests – Caseworkers gain more discretion to refuse visas if applicants have prior immigration breaches.
![Fragomen Alert: What the UK Asylum Reforms Mean for Employers and Global Mobility Teams]()
Fragomen recommends that employers audit current sponsored populations, budget for higher Immigration Skills Charges (+32 % from April 2026) and update onboarding workflows for contractors. It also urges early dialogue with endorsing bodies to secure scarce CoS under the new protection route.
The briefing underscores that asylum reform is not just a humanitarian issue but a compliance challenge for any company moving talent into the UK. Forward-planning now can avoid costly delays when the new rules phase in from mid-2026.
1. Right-to-Work Expansion – Checks will extend beyond PAYE employees to sub-contractors and gig-economy workers, with mandatory digital identity verification.
2. Protection Work & Study Route – Employers may be asked to sponsor refugees who switch status; certificates of sponsorship will be capped, driving competition for allocation.
3. Visa Penalties – Firms with operations in countries targeted by the ‘emergency brake’ could face sudden talent pipeline disruptions.
4. Digital Status – All physical BRP cards will be obsolete by June 2026; HR systems must integrate with the Home Office API.
5. Conduct & Suitability Tests – Caseworkers gain more discretion to refuse visas if applicants have prior immigration breaches.
Fragomen recommends that employers audit current sponsored populations, budget for higher Immigration Skills Charges (+32 % from April 2026) and update onboarding workflows for contractors. It also urges early dialogue with endorsing bodies to secure scarce CoS under the new protection route.
The briefing underscores that asylum reform is not just a humanitarian issue but a compliance challenge for any company moving talent into the UK. Forward-planning now can avoid costly delays when the new rules phase in from mid-2026.
