UK immigration – recent and forthcoming changes

Looking beyond the impact of Brexit, UK immigration remains an area of regular change. The recent and proposed changes will impact on all businesses that employ overseas nationals or European nationals in their UK business. In summary:

  • Premium sponsor change of circumstances service – with effect from 7 November the Home Office is offering a new premium service allowing sponsors to pay a £200 fee to expedite a number of administrative sponsor licence related applications, for example to change key personnel or issue additional certificates of sponsorship. This service is welcomed in light of increasing delays in the processing of such applications (up to 18 weeks is the Home Office “service standard”). However as only 20 slots are available each day we anticipate that the service will be well used and the additional cost may be prohibitive for small companies.
  • Tier 2 – on 26 November we will see a number of changes to the Immigration Rules which the Home Office trialled some months ago. For information about these please see our e-alert.
  • Immigration Act 2016 – on 1 December 2016 section 38 of the Act will be rolled out. This allows the Home Office to close a business’s site for 48 hours if there is a history of illegal working (for example, if a civil penalty has been paid in the preceding 3 years) and new illegal working is suspected. This is likely to have particular impact on retail and hospitality businesses which are known to be vulnerable industries to illegal working. Please see our July 2016 e-alert on this topic written when the illegal working provisions were rolled out.
  • Changes to application process for European nationals – on 1 October the Home Office introduced a new online service for European permanent residence and registration certificate applications as well as a passport checking service in connection with the application’s submission. Whilst this service currently has limited application in practice, and its use will not speed up processing times, applicants who are eligible to use the services will not need to submit their original passport or identity card with their application. For further details see our e-alert.

ONS 2016 provisional gender pay gap figures

The Office for National Statistics annual survey of hours and earnings: 2016 provisional resultsindicate that the gender pay gap for full time employees is 9.4% (down from 9.6% in 2015) and when part time employees are included the gap is 18.1% in 2016 (down from 19.3% in 2015).

Modern slavery: transparency in portfolio supply chains

Following publication of the first Modern Slavery Act transparency statements we take a look at the wider and future implications for private equity houses and their portfolio companies.