Sponsor Licence Compliance Guide

This guide explains sponsor licence compliance under the UK’s points-based immigration system. It sets out what compliance means in practice, the records sponsors must keep, what changes must be reported to UKVI and when, and how audits and inspections are carried out. It also covers the most common breaches, the sanctions employers can face, and practical measures to help ensure your organisation is audit-ready. The article is designed for HR leaders, Authorising Officers, and anyone responsible for day-to-day licence management and right to work checks.

Sponsor duties apply continuously for as long as the licence remains valid, and UKVI takes a strict approach to enforcement. Even where there is no intent to breach, administrative oversights can still result in licence penalties. Employers must maintain accurate records in line with Appendix D, report most worker changes within 10 working days and most organisational changes within 20 working days, and ensure that roles continue to meet the relevant skill and salary thresholds. Some reporting duties require careful attention, such as when a worker’s normal work location changes, or when a salary reduction takes place. Hybrid working patterns usually do not require reporting, but a permanent switch to remote working does. The Home Office can conduct announced or unannounced audits, including digital compliance checks, and expects sponsors to be able to produce evidence on demand. Non-compliance can lead to licence suspension, revocation, civil penalties of up to £60,000 per illegal worker, and reputational damage that disrupts business continuity and recruitment. In short, compliance is not optional but an operational necessity that underpins access to the global labour market.`

Section A: What is Sponsor Licence Compliance?

Sponsor licence compliance is the ongoing legal obligation on UK employers to manage and monitor each sponsored worker’s immigration status, role, location, and remuneration; to keep specified records; and to report defined changes on time. UKVI assesses compliance against the Immigration Rules, sponsor guidance, and supporting appendices. Meeting these standards requires both appropriate policies and evidence that those policies operate consistently in practice.

1. Eligibility & Pre-Licence Readiness (Appendix A)

Eligibility focuses on whether the organisation is genuine, actively trading, and capable of meeting sponsor duties. Typical evidence includes Companies House registration, PAYE and VAT details, business bank statements, employer’s liability insurance, and documents that show active trading (such as leases, contracts, or invoices). UKVI may conduct a pre-licence compliance visit to test systems for tracking sponsored workers and to verify the business premises and operations. Failure to provide the correct document set or to demonstrate readiness can lead to refusal.

2. Record-Keeping (Appendix D)

Once licensed, you must maintain a defined set of records for every sponsored worker and make them available promptly on request. Core items include identity and right to work evidence (using the online share-code route for eVisa holders; physical BRPs are not acceptable proof), a signed contract, job description with the correct SOC 2020 code, salary/payment evidence, and attendance/absence logs. You should also retain recruitment evidence (for example, advert copies if used, interview notes, shortlist outcomes) or, if there was no formal advertising, a clear explanation of how the worker was identified to help demonstrate there is a genuine vacancy. Keep records until the earlier of one year after sponsorship ends or until a compliance officer has examined and approved them.

3. Ongoing Sponsor Duties & Reporting (Part 3)

Report most worker changes via the SMS within 10 working days (for example, job title/duties/contracted hours changes, normal work location changes including a move to fully remote, salary reductions from the CoS level, resignation/dismissal, or 10+ consecutive working days of unauthorised absence). Report most organisational changes within 20 working days (for example, changes to address, ownership, mergers/acquisitions). Notify UKVI as soon as reasonably practicable if you know or suspect a breach of a worker’s visa conditions. Ensure the role continues to meet the route’s skill and salary thresholds throughout sponsorship. Hybrid patterns typically do not require reporting, but you must keep records and still report any change to the worker’s normal work location.

Section Summary. Compliance is evidence-driven. Before and after grant, UKVI tests whether your organisation can prove control over sponsored roles, records, and reporting. Appendix A establishes eligibility; Appendix D defines what to keep; Part 3 sets the ongoing duties and deadlines. Designing processes around these sources is the foundation for an audit-ready licence.

Section B: Sponsor Licence Compliance Duties

Once a sponsor licence is granted, the organisation assumes a series of ongoing duties set out in the Immigration Rules and sponsor guidance. These duties are legally binding and extend across record-keeping, reporting, monitoring, and cooperation with the Home Office. They apply for the entire period the licence is valid, and lapses are treated seriously by UKVI regardless of intent. Compliance requires strong HR systems and trained staff capable of meeting deadlines and producing evidence on request.

1. Record-Keeping Duties

Appendix D specifies the documents that sponsors must keep for every sponsored worker. These include a copy of the worker’s current passport or eVisa status check, their biometric residence permit (where issued), signed employment contract, job description with SOC 2020 code, salary and payment evidence, and records of absences. Employers must also retain evidence of how the worker was recruited, even where the route does not require a formal advertising process, with at least one item to show how the individual was identified and selected. Records may be stored electronically or on paper but must be accessible at short notice for inspection. Documents must be retained until the earlier of one year after sponsorship ends or until examined by a compliance officer.

2. Key Personnel

Every sponsor must nominate specific individuals as part of their licence management framework. These roles are legally significant and must be kept up to date on the Sponsorship Management System (SMS):

• Authorising Officer (AO): The most senior person with authority over recruitment or HR, legally responsible for ensuring compliance. Must be UK-based, a paid employee or office-holder, and free from unspent criminal or immigration offences.
• Key Contact: The main liaison with UKVI, responsible for responding to correspondence and document requests. This role may also be held by the AO or a Level 1 user.
• Level 1 User: Responsible for the daily management of the SMS, including assigning CoS, reporting worker and organisational changes, and monitoring key deadlines. At least one must be a paid employee or office-holder based in the UK.
• Level 2 User: May perform limited SMS functions such as running reports or updating contact details, but cannot assign CoS. May be an employee or an approved third party with restricted access.

If any of these roles are vacated and not replaced promptly, the sponsor risks enforcement action. UKVI expects at least one Level 1 user and an Authorising Officer to be in place at all times.

3. Monitoring Duties

Sponsors must actively monitor sponsored workers’ attendance, job duties, and visa status. HR systems must track absences, confirm that work undertaken matches the CoS description, and identify upcoming visa expiries. Hybrid patterns of working should be documented, and any permanent change to a worker’s normal work location must be reported. Employers must also ensure that sponsored roles continue to meet skill and salary thresholds set out in the Immigration Rules.

4. Reporting Duties

Reporting through the SMS must be accurate and timely. Most worker-related changes, such as job title amendments, contractual changes, resignations, dismissals, or unauthorised absences of 10 consecutive working days, must be reported within 10 working days. Most organisational changes, such as new trading addresses, mergers, or acquisitions, must be reported within 20 working days. Salary reductions from the level stated on the CoS must also be reported; increases generally do not require reporting unless specifically required for the visa route. Sponsors must also notify UKVI as soon as reasonably practicable if they know or suspect a breach of visa conditions.

5. Cooperation with the Home Office

Sponsors must act honestly in all dealings with the Home Office and comply fully with requests for information or access. Compliance officers must be given access to records and staff during site inspections, whether announced or unannounced, and responses to document requests during digital audits must be complete and timely. Failure to cooperate can itself constitute a breach of sponsor duties.

6. Right to Work Checks

Sponsors remain subject to the same right to work obligations as all UK employers. Checks must be completed before employment begins and repeated in line with visa expiry dates for workers with time-limited status. For eVisa holders, an online share code check is required. IDSP digital checks may only be used for valid British or Irish passports or Irish passport cards. Records of all checks must be retained and dated. Failure to carry out proper checks can result in civil penalties of up to £45,000 for a first breach and £60,000 for repeat breaches per illegal worker.

Section Summary. Sponsor licence compliance duties cover six core areas: record-keeping, key personnel, monitoring, reporting, cooperation, and right to work. Each requires structured systems, timely action, and clear accountability. Even small lapses can trigger enforcement, so sponsors must treat these duties as ongoing business-critical responsibilities.

Section C: How to Comply

Meeting sponsor licence duties is not simply about knowing the rules; it requires building reliable systems and assigning accountability across the organisation. UKVI does not accept ignorance or administrative oversight as an excuse. Compliance must be embedded in day-to-day HR and operational processes so that deadlines are met, records are complete, and issues are identified and resolved before they escalate. This section sets out the practical measures sponsors should adopt to sustain compliance.

1. Internal Systems

Internal systems are the backbone of compliance. Sponsors should implement structures that are both preventative and responsive, ensuring they can detect and address risks promptly. At a minimum, systems should include:

• Compliance calendar and reminders: Use a centralised calendar to track visa expiry dates, CoS assignment deadlines, and right to work re-checks. Automated digital reminders should be shared across HR and compliance teams. Even where external advisers are engaged, the sponsor remains legally responsible for meeting deadlines.
• Internal audits and file spot-checks: Schedule quarterly audits and random spot-checks of worker files. Confirm that contracts, salary evidence, CoS details, and attendance records are complete and accurate. Document findings and remedial action taken, as these logs can demonstrate proactive oversight during a UKVI audit.
• Escalation protocols: Ensure HR and payroll teams have clear rules about when to escalate changes in job duties, salary, or working location to compliance staff for SMS reporting before changes take effect.

2. Training Line Managers

Line managers play a key role in compliance because they often initiate employment changes that trigger reporting duties. For example, a manager might approve a change in work location, alter job duties, or authorise an extended absence. Without proper training, such changes may be implemented without being reported. Sponsors should provide targeted training to managers so they understand which changes affect visa compliance and how to escalate matters to HR or compliance leads. Regular refresher sessions should be scheduled, especially in organisations with high management turnover.

3. Role of Key Personnel

Compliance depends on individuals as well as systems. Sponsors must ensure their key personnel are suitable, trained, and supported:

• Authorising Officer: Must have senior authority, be UK-based, and be directly accountable for ensuring the licence is managed properly. If this role is vacated, a replacement must be reported within 10 working days.
• Key Contact: Serves as the organisation’s communication channel with UKVI. This person must be able to respond quickly to requests for information or documents.
• Level 1 User: Manages daily SMS functions, assigns CoS, and reports changes. At least one Level 1 user must always be in place.
• Level 2 User: Provides restricted support for SMS tasks. Sponsors should clearly brief Level 2 users on their limitations to avoid errors.

Sponsors should review these roles periodically and update UKVI through the SMS whenever personnel change. Having multiple trained users can provide continuity if staff leave or are absent.

4. Embedding Compliance into HR Practice

Compliance should be integrated into routine HR activities rather than treated as a standalone function. Recruitment processes should include steps to evidence a genuine vacancy and ensure SOC codes and salary levels align with the Immigration Rules. Right to work checks should be standardised and audited alongside onboarding. Payroll, HR, and compliance teams should coordinate so that any change in hours, salary, or duties is reported within the correct timeframe. By embedding sponsor obligations into day-to-day operations, organisations reduce the risk of oversight and demonstrate control during audits.

Section Summary. Compliance is sustainable only when supported by systems, trained staff, and integration into daily HR processes. Sponsors should rely on structured calendars, audits, escalation protocols, and trained key personnel. By embedding these practices, organisations can maintain audit readiness and safeguard their ability to sponsor workers.

Section D: Home Office Audits & Inspections

UKVI has wide powers to audit sponsor licence holders at any time during the licence lifecycle. Audits can take place before a licence is granted, during its validity period, or in response to intelligence about potential breaches. Inspections may be announced, unannounced, on-site, or conducted remotely through digital document reviews. Sponsors must therefore be audit-ready at all times and able to produce requested evidence quickly and accurately. A failure to satisfy UKVI during an inspection can lead to licence suspension, revocation, or long-term exclusion from the sponsorship system.

1. Digital Compliance Audits

UKVI increasingly conducts remote audits, often during licence renewal or following intelligence-led concerns. Sponsors selected for a digital audit will usually be given five to ten working days to provide specified documents electronically. Requests typically include identity and right to work evidence for a sample of sponsored workers, signed contracts, job descriptions, salary payment records, and SMS reporting histories. Employers may also be asked to provide absence logs and evidence of recruitment activity to show a genuine vacancy existed. Documents must be clearly labelled, up to date, and cross-referenced with SMS data. Sponsors should review files in advance, address discrepancies, and submit written explanations where needed. UKVI may follow up with additional questions or video calls with key personnel. Failure to provide accurate and complete information can result in suspension or revocation.

2. Site Compliance Visits

Physical inspections remain a core feature of UKVI’s enforcement strategy. Visits may occur before a licence is granted to test whether the business is genuine and has systems in place, or during the life of the licence to assess ongoing compliance. Unannounced visits are common, particularly where UKVI has received complaints or intelligence about non-compliance. During a site visit, inspectors will expect to meet the Authorising Officer or another senior manager, review worker files, and confirm that sponsored workers are carrying out the jobs described in their Certificates of Sponsorship. Inspectors may interview sponsored staff, check absence records, and verify right to work procedures for all employees. Employers must demonstrate that they can produce documents immediately and explain their HR processes in practice, not just on paper.

3. Preparing for Audits

Organisations can reduce audit risk by conducting regular mock audits aligned with UKVI’s approach. HR teams should maintain audit logs that show when checks were carried out and what remedial action was taken. A good practice checklist includes:

• Ensuring each sponsored worker’s file contains complete identity, visa, and employment documents in line with Appendix D.
• Confirming that job descriptions and SOC codes match the role stated on the CoS.
• Maintaining evidence of right to work checks for all employees, not only sponsored workers.
• Keeping up-to-date absence logs, payroll records, and records of any reported changes on SMS.
• Preparing key personnel to explain systems and answer questions during interviews.

Mock audits should also test the organisation’s readiness for unannounced visits, with clear procedures to ensure compliance officers can be given immediate access to records and staff.

Section Summary. UKVI audits—whether digital, on-site, or unannounced—test whether sponsors are compliant in practice. Employers that maintain clear, accessible records, conduct regular mock audits, and train key staff to respond effectively will be better positioned to pass inspections and avoid enforcement action.

Section E: Common Sponsor Licence Compliance Breaches

Most sponsor licence breaches occur not because of deliberate misconduct but due to weak systems, poor record-keeping, or a lack of understanding of how the rules apply in practice. UKVI applies a strict compliance approach: even technical or administrative lapses can trigger serious enforcement. The following are the most common compliance failures identified during audits and site inspections, and the steps employers should take to prevent them.

1. Assigning a CoS Without a Genuine Vacancy

UKVI requires sponsors to assign Certificates of Sponsorship only where a genuine vacancy exists. A genuine vacancy must meet the skill and salary thresholds of the visa route and accurately reflect the role the sponsored worker will carry out. Assigning a CoS for a role that does not exist, or for duties that differ from those stated, is considered abuse of the system and can result in licence revocation. Employers must ensure recruitment records show why the role was required and how the worker was identified, with supporting evidence such as advert copies, interview notes, or a written explanation if no advert was placed.

2. Inadequate Right to Work Checks

Right to work checks are a statutory requirement for all employees, not just sponsored workers. UKVI frequently identifies failures where checks are not completed correctly, are not retained, or are carried out late. Since February 2024, civil penalties can reach £45,000 per illegal worker for a first breach and £60,000 for repeat breaches. Employers must ensure staff responsible for checks are properly trained, use the correct method (manual, share code, or IDSP for British/Irish passports), and keep dated, clear copies of each check. BRPs are no longer acceptable proof of status and must not be relied on in isolation.

3. Failure to Report Changes

One of the most common breaches is a failure to report changes in time. Sponsors must report most worker changes within 10 working days, including job title, duties, contracted hours, work location, salary reductions, and resignations or dismissals. Unauthorised absences of 10 consecutive working days must also be reported. Organisational changes such as new addresses, ownership changes, or mergers must be reported within 20 working days. Hybrid working arrangements generally do not require reporting, but a change to a worker’s normal work location, including fully remote working, must be reported. Failure to report on time suggests to UKVI that the sponsor has lost control of its workforce.

4. Poor Record-Keeping

Appendix D sets out in detail the documents that must be kept for each sponsored worker. Missing contracts, unsigned job descriptions, or incomplete absence logs are common findings during audits. Sponsors must also retain evidence of recruitment activity or, where no advert was placed, an explanation of how the worker was recruited. Inadequate filing, off-site storage, or reliance on third-party providers without ensuring records can be produced on demand will not be accepted by UKVI as a defence. Employers should adopt a digital filing system with clear labelling and regular spot-checks to close gaps before inspections occur.

Section Summary. Common breaches include assigning CoS for non-genuine vacancies, inadequate right to work checks, missed reporting deadlines, and poor document retention. Each of these can be prevented with structured systems, staff training, and proactive monitoring. Sponsors that address these areas reduce the likelihood of suspension or revocation and demonstrate to UKVI that they take compliance seriously.

Section F: Consequences of Non-Compliance

UKVI enforces sponsor licence duties strictly, and even technical breaches can result in significant sanctions. The consequences extend beyond fines or administrative inconvenience and can disrupt business operations, damage reputation, and prevent access to overseas talent. Understanding the potential outcomes of non-compliance is critical for risk management and strategic workforce planning.

1. Licence Suspension

Where UKVI identifies serious or repeated concerns, it can suspend a sponsor licence with immediate effect. During suspension, sponsors cannot assign new Certificates of Sponsorship, though existing sponsored workers usually remain employed. UKVI issues a suspension letter outlining the breaches, and the sponsor typically has 20 working days to respond with written representations and evidence of remedial action. If UKVI accepts the response, the licence may be reinstated or downgraded; if not, revocation may follow.

2. Licence Revocation

Revocation is the most serious sanction. If a licence is revoked, the sponsor loses the ability to employ overseas workers. All unused CoS are cancelled, and sponsored workers are issued with visa curtailment notices, usually allowing 60 days (or until visa expiry, if sooner) to find another sponsor, switch route, or leave the UK. Employers may also be publicly listed as having their licence revoked, causing reputational damage that can affect future recruitment and business relationships.

3. Civil Penalties

Sponsors that employ someone without the right to work can be issued civil penalties. Since February 2024, fines are £45,000 per illegal worker for a first breach and £60,000 for repeat breaches. Civil penalties are often accompanied by reputational harm, particularly in regulated industries. Failure to carry out right to work checks correctly is the most common cause of such penalties, underlining the need for thorough, documented procedures.

4. Cooling-Off Periods

Following revocation, sponsors are usually barred from reapplying for a new licence for at least 12 months. Longer cooling-off periods may apply in cases involving dishonesty, fraud, or repeated failures. Organisations intending to reapply must show that all compliance weaknesses have been addressed and that robust systems are now in place. UKVI often carries out a pre-licence audit before granting a fresh licence to a previously revoked sponsor.

Section Summary. Non-compliance can result in suspension, revocation, heavy fines, reputational harm, and long cooling-off periods that restrict an organisation’s access to overseas recruitment. UKVI applies penalties to protect immigration control and to incentivise robust compliance frameworks. Employers that fail to treat sponsor duties as a business priority risk both operational disruption and long-term exclusion from the sponsorship system.

Section G: Summary

Sponsor licence compliance is an ongoing legal duty that affects every stage of employing overseas workers. It starts with demonstrating eligibility at the licence application stage and continues with maintaining accurate records, reporting changes promptly, and ensuring sponsored roles remain genuine and compliant with the Immigration Rules. UKVI now adopts a proactive enforcement approach, carrying out digital audits, site inspections, and unannounced visits to test compliance in practice rather than on paper. Employers must therefore treat compliance as a continuous process, not a one-off exercise.

Failure to comply carries serious consequences, including civil penalties, licence suspension, and revocation, each of which can severely restrict access to international talent. The disruption caused by enforcement action can affect workforce planning, recruitment timelines, and business reputation. By embedding compliance into daily HR practice, training managers, scheduling audits, and empowering key personnel, organisations can reduce risk and remain audit-ready. Robust internal systems and proactive oversight are the only reliable means of safeguarding the licence and securing long-term access to the global labour market.

Section H: Need Assistance?

Sponsor licence compliance can place significant demands on HR teams and business leaders. The rules are extensive, the evidential thresholds are high, and the consequences of non-compliance are severe. For many organisations, particularly those with limited HR capacity or high levels of staff turnover, maintaining compliance alongside other priorities can be challenging. Larger employers may also face difficulties in ensuring consistency across multiple departments or locations.

External professional support can help businesses manage compliance obligations effectively. Advisers can conduct mock audits, review HR files against Appendix D requirements, and provide training for Authorising Officers, Key Contacts, and Level 1 users. They can also support sponsors in preparing for digital or site audits, advising on SMS reporting obligations, and developing internal policies to integrate compliance into everyday HR processes. For organisations dealing with complex changes such as mergers, acquisitions, or restructures, specialist input can be critical to ensuring reporting obligations are met within strict UKVI deadlines.

Whether you manage compliance in-house or with external support, the key is to ensure systems are proactive rather than reactive. A licence that is well managed provides certainty, reduces risk, and safeguards access to global talent when needed most.

Section I: Sponsor Licence Compliance FAQs

1. What are the main duties of a sponsor licence holder?

Sponsors must keep accurate records for every sponsored worker, monitor their attendance and role, and report defined changes within the required deadlines. They must also ensure that sponsored jobs continue to meet the salary and skill thresholds under the Immigration Rules and that right to work checks are correctly carried out for all staff.

2. Do I have to report minor changes such as hybrid working or a job title adjustment?

Hybrid working patterns do not usually need to be reported, but a permanent change to a worker’s normal work location, including a move to full-time remote working, must be reported within 10 working days. Changes to job titles, contracted hours, or duties must also be reported within the same timeframe. Organisational changes such as new addresses, ownership changes, or mergers must be reported within 20 working days.

3. What happens during a Home Office compliance visit?

UKVI officers may review HR files, interview sponsored workers, check payroll and absence records, and test whether right to work procedures are being followed. They will also verify that the role being carried out matches the Certificate of Sponsorship. Visits can be announced or unannounced, and you must be able to provide documents immediately on request.

4. How often should we audit our sponsor records?

Best practice is to conduct quarterly internal audits and carry out regular spot-checks. Audits should confirm that records meet Appendix D requirements, visa expiry dates are being tracked, and SMS updates have been made on time. Keeping a log of audits and remedial actions taken demonstrates proactive oversight if UKVI inspects your systems.

5. Can I assign a Certificate of Sponsorship before advertising a role?

Only if the route does not require a genuine vacancy test. For most Skilled Worker roles, sponsors must be able to evidence that the role is genuine and meets the skill and salary thresholds. Recruitment evidence, such as adverts and interview records, or a written explanation of how the worker was identified, should be retained to satisfy UKVI requirements.

6. Do we need to re-check right to work documents for sponsored staff?

Yes. If a worker’s permission to work is time-limited, you must carry out a repeat check before the visa expiry date. For eVisa holders, this means conducting an online share code check and keeping a dated copy of the results. BRPs are no longer sufficient evidence and must not be relied on as proof of status.

7. What if our Authorising Officer leaves the company?

You must notify UKVI within 10 working days and appoint a new Authorising Officer who meets the suitability criteria. Failure to maintain this role can trigger compliance action, including suspension of the licence.

8. Can we lose our licence for a first-time mistake?

Yes, depending on the seriousness of the breach. Employing someone without lawful permission to work, or assigning a CoS for a non-genuine vacancy, can lead to immediate suspension or revocation, even if it is the first offence. Less serious breaches may lead to a downgrade or formal warning, particularly if corrective action is taken quickly.

9. What happens to sponsored workers if our licence is revoked?

If a licence is revoked, all CoS are cancelled. Sponsored workers are issued curtailment notices reducing their permission to stay, usually to 60 days or until their visa expiry date, whichever is sooner. During this time, they must secure a new sponsor, switch visa routes, or leave the UK.

10. How long is the cooling-off period if our licence is revoked?

Most sponsors face a 12-month cooling-off period before reapplying. Longer periods can apply in cases involving fraud, dishonesty, or systemic failings. When reapplying, organisations must be able to show stronger compliance systems and may be subject to a pre-licence audit before approval is granted.

Section Summary. FAQs highlight that sponsor duties are detailed and time-sensitive, covering worker and organisational changes, audits, right to work checks, and key personnel requirements. Clear systems, training, and regular audits remain the best defence against compliance breaches.

Conclusion

Sponsor licence compliance is an ongoing responsibility that shapes how UK employers can lawfully access global talent. It is not a one-off exercise but a continuing obligation covering record-keeping, reporting, monitoring, and cooperation with the Home Office. UKVI applies a strict compliance approach, meaning that even administrative oversights can trigger penalties, suspension, or revocation. Civil penalties for illegal working, disruption to recruitment, reputational damage, and long cooling-off periods following revocation underline the risks of neglecting compliance.

Employers that succeed in maintaining compliance typically integrate sponsor duties into daily HR processes, invest in training for key personnel and line managers, and carry out regular internal audits. By embedding compliance into the organisational culture and treating it as a strategic priority, sponsors can safeguard their licence, remain audit-ready, and ensure continuity of access to skilled overseas workers.

Section J: Glossary

Section K: Additional Resources and Links