Keep Your Sponsor Licence Compliant
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What is Sponsor Licence Compliance?
The 4 sponsor duties
- Keep accurate records for every sponsored worker.
- Report changes to the Home Office within the set deadlines.
- Keep track of the people you sponsor: their hours, their pay, their visa dates.
- Run a right-to-work check before anyone's first day.
Why regular checks matter
Until April 2024, licences had to be renewed every four years. That renewal process prompted many businesses to sit down and thoroughly review their sponsor licence records and compliance.
That prompt has now gone, making regular compliance checks even more important.
Are you meeting your Sponsor Duties?
You are likely compliant if:
- Every sponsored worker had a right-to-work check before their first day, and the evidence is still at hand
- HR files are comprehensive, current, and held in one place where the authorised team members can reach them
- Worker changes are reported to UKVI within 10 working days, and organisational changes within 20
- Each sponsored worker's salary meets the required rate in each pay period, month by month
- Your SMS is up to date, and your Authorising Officer and Level 1 Users understand and carry out their responsibilities
- An assigned team member reviews the files on a set schedule that is documented
You may be at risk if:
- Right-to-work checks were missed or checked after someone had already started working
- A sponsored worker left, and the Home Office was not notified
- Records sit on spreadsheets, or on different systems or locations
- A salary shortfall in one pay period was treated as something that could be corrected by a later bonus
- Nobody has logged into SMS in months
- Your key personnel were appointed years ago and no training has been provided
Client Testimonial
AY&J conducted a compliance audit that identified issues we hadn't spotted. Their proactive approach potentially saved our sponsor licence. Now we have proper HR processes in place. Invaluable service for any sponsored employer!
Michael Roberts, Trustpilot Review
What are your Sponsor Duties?
Record keeping
Sponsor licence record-keeping exists because the Home Office needs to see that every worker was properly recruited and paid. You will be responsible for maintaining these records, set out in Appendix D of the sponsor guidance. These include passport or eVisa details, National Insurance number, contract, job description, payroll evidence, absence records, and recruitment paperwork.
Reporting worker changes: 10 working days
You will need to notify the Home Office within 10 working days where there are specific changes to a migrant worker's circumstances. That covers resignation, dismissal, job title, salary, and work location. It also covers promotion and any unauthorised absence of ten working days or more.
Reporting organisational changes: 20 working days
Most significant business changes must be reported within 20 working days. That includes mergers, acquisitions, a change of registered address or trading name, and any change to your key personnel. If your Authorising Officer leaves, that is still a reportable change.
Right to work checks
You will need to complete the prescribed right-to-work checks before every worker starts their first day, every time. Most sponsored workers, including anyone on Skilled Worker route, use the Home Office online service with a shared code. A correctly completed check can provide a statutory excuse against a civil penalty for illegal working.
Salary compliance
The Home Office checks that migrants/sponsored workers are paid what the Certificate of Sponsorship says. To prove this, you will need to meet the required rate in each pay period, month by month. If you run variable hours or have anyone on unpaid leave, that is where it can go quietly wrong.
SMS and key personnel
The Home Office expects sponsors to have listed key personnel who are responsible for the sponsorship process and can be held accountable for the sponsor duties. Your Authorising Officer is responsible for overall compliance, and the Level 1 and 2 Users handle day-to-day tasks in SMS. When an Authorising Officer leaves, it is standard procedure to take their access away the same day ideally.
What happens in a Home Office Compliance Visit?
A UKVI compliance visit is the Home Office conducting an audit on your company to ensure you have the right procedures in place to remain compliant. It can be announced or unannounced, on-site or entirely digital.
How a visit is triggered
All compliance visits are risk based and must be treated with the same precautions, and they are getting triggered by data. That could be payroll, which does not match the salary on a CoS. It could also be a Companies House filing that does not fit, or a gap in your SMS history.
The desktop audit
The first indication is usually an email from the Home Office requesting specific documents or further information, often with a short deadline of around five to ten working days. These can be employee folders, right-to-work evidence, and payroll. So you will want to start the day it lands in your inbox. If you approach us early, we will help organise it with you.
Arrival on site
If the Home Office does visit, they will ask for your Authorising Officer or Level 1 User. They will also need a suitable workspace and access to your files. We would suggest conducting a mock audit before a real one takes place.
The records review
This would be the bulk of the visit: compliance officers working through your HR files, worker by worker. They check right-to-work evidence and its date, contracts, job descriptions, payroll against the CoS salary, and absence logs. What they are really checking is whether the role you described matches the job that actually exists.
Interviews
Officers speak to your Authorising Officer, Level 1 User, HR, and often the line managers. They may interview sponsored workers too. They are checking what migrants' job duties are against the paperwork.
The report
Officers do not decide anything on the day. Findings are written up and passed to a caseworker who decides what happens next. They do not make the final judgement on the day, and it can take several weeks.
The outcome
After the compliance visit, the caseworker will decide one of four things. No action, which is the most common outcome for compliant sponsors. The 3 other enforcement actions include: an action plan with a B-rating, a suspension while UKVI looks further, or revocation.
What happens if you fail your Sponsor Licence Compliance Audit?
Your licence stays, but your rating drops. You will need to work through a 3-month action plan before you can sponsor anyone new. Your business name will be removed from the public register of licensed sponsors.
Hard fact: You will have 10 working days to pay the £1,476 fee.
Your sponsorship will be frozen while the Home Office investigates. You cannot assign new Certificates of Sponsorship, though your existing sponsored workers can continue to work lawfully. We can help you build those representations from the day the letter arrives.
Hard fact: You will have 20 working days to respond in writing.
The licence is officially cancelled, and every Certificate of Sponsorship you have assigned becomes invalid. There is no appeal, and you will not be able to apply again for at least 12 months. We would start with a pre-action protocol letter, which resolves most cases without going to court.
Hard fact: Your sponsored workers' permission is curtailed to 60 days.
A civil penalty is separate from your licence, so it can arrive alongside any of the others. Employing someone without the right to work carries a penalty of up to £45,000 per worker. That rises to £60,000 for a repeat breach within three years.
Hard fact: £45,000 or £60,000 per worker.
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What are the penalties for non-compliance?
You might not be aware of these figures, but it is worth knowing what sits behind a failed visit. First-breach penalties can reach £45,000 per worker, rising to £60,000 for a repeat breach. What you would actually pay depends on the number of workers involved and any previous penalties.
These are Home Office figures as of 2026.
Why does our compliance mock audit cost less than the penalties?
Our sponsor licence compliance audit runs the same checks an officer would, in the same order. The difference is that you see the findings first, while there is still time to act on them.
7 of 7
had record-keeping or evidential gaps
6 of 7
had weaknesses in right-to-work or immigration-status checking
So businesses are usually doing the work, but cannot always evidence it in the form UKVI expects.
Source: seven anonymised case studies from our sponsor licence compliance audit.
Cost Breakdown
6–15 workers: £695/month
16+ workers: Contact us | £100 per additional sponsored worker
Multi-site uplift: +£500 per additional site | | Add-ons | Refresher session: £500
Upgrade within 60 days: £500 credited off Shield or Care | Suspension triage & response: from £2,500
Licence variations/change advisory: £1,000–£2,000
High-volume CoS handling: priced per scope
Skilled Worker Visa: £1,000 + VAT/applicant (standard £1,500) | Extra file reviews: £200/file
Onsite visit (2 associates): from £1,000 + travel
Annual mock audit refresh: £750
Restructure/TUPE/M&A advisory: £1,000–£2,000 | Prices are current as of 2026.
Streamline Sponsor Compliance: Free HRMS & Expert Support to Simplify Your Sponsor Duties
Managing sponsor compliance manually can be time-consuming, error-prone, and high-risk — leading to missed deadlines, costly fines, and added stress on HR teams. Our integrated HRMS software solves these problems by automating compliance tasks and saving you time and resources.
Here's how our powerful HRMS works for you:
Attendance Tracking
Intuitive check-in and check-out system to maintain accurate logs.
Leave Management
Effortlessly manage employee leaves and approvals with built-in workflows.
Employee Records
Centralise all employee details and documents in one secure place.
Compliance Management
Seamlessly meet UKVI requirements with structured processes.
Automated Alerts
Never miss a compliance deadline — get proactive reminders for SMS reporting, right-to-work checks, and licence renewal dates.
Manual spreadsheets and fragmented systems leave room for costly mistakes. Our HRMS integrates compliance into your daily operations, freeing up HR resources and reducing the risk of Home Office penalties.
In our clients' own words.
“Yash and his team were exceptionally motivated, and they gave us honest legal advice throughout. They worked tirelessly to get our sponsor licence duties back in line with UKVI requirements. Our licence was reinstated as a result. We would recommend AY&J to anybody looking for high-quality legal advice.”
“After our ILR rejection, AY&J pursued our case through Administrative Review and Judicial Review. The team was open, honest, knowledgeable and attentive to every detail. They kept us informed at every stage, supported us throughout an extremely difficult journey and helped us regain confidence in our case.”
Frequently Asked Questions
Penalties and revocation
Normally, a minimum of 12 months, rising to 24 months, during which the same key personnel were involved. The exact period is set out in your decision letter.
Penalties and revocation
Their permission is cut to 60 days, or whatever is left of it if that is shorter. They will need a new sponsor or another route within two months.
Penalties and revocation
Up to £45,000 per worker for a first breach, and £60,000 for a repeat within three years. A correct check before somebody's first day is the only real defence.
Penalties and revocation
Yes, and UKVI increasingly moves straight to revocation without suspending first. Get your representations underway from the day a letter lands.
Penalties and revocation
Minor issues result in a B-rating and an action plan costing £1,476, whereas serious findings lead to suspension or revocation. What you are facing depends on what the officers found.
Audits and UKVI visits
Your Appendix D files, right-to-work evidence with its date, and payroll matching the CoS. Also, your absence logs and SMS history are all kept in one place.
Audits and UKVI visits
There is no fixed cycle, and visits are risk-based. A higher-risk sector with a payroll discrepancy is more likely to see one than a settled sponsor with clean records.
Audits and UKVI visits
The Home Office's own estimate is two to three hours, though a larger business can take considerably longer. Keep your Authorising Officer free for the whole day.
Audits and UKVI visits
Yes, and unannounced visits are becoming more common. You need a system that holds up on any given day.
Audits and UKVI visits
Officers work through your HR files worker by worker and interview your key personnel. They usually speak to the sponsored workers too, so perform your own sponsor licence compliance audit first.
Records and reporting
You will need to complete the right-to-work checks for every worker before their first day. From 1 October 2026, that duty widens beyond employees, so review any agency or subcontracted labour you use.
Records and reporting
Yes, averaging across the year is not enough. Since April 2026, UKVI cross references HMRC payroll data against the CoS, so a shortfall can surface without a visit.
Records and reporting
Late reporting is one of the most common findings on a visit, and even a few days count as late. A system that flags the deadline works better than a person who remembers it.
Records and reporting
Ten working days for anything affecting a sponsored worker, twenty for changes to the business itself. Someone needs to be watching for these as they happen.
Records and reporting
Appendix D, the Home Office's list of sponsor licence record-keeping, sets out what you hold for each sponsored worker. Keep the full file for the sponsorship period, plus a year after their last day.
Sponsor duties
Yes, the UK sponsor duties come with the licence itself. Your HR systems, key personnel and reporting need to be in place from day one, sponsored or not.
Audits and UKVI visits
A visit is the Home Office checking your systems, and it can lead to enforcement action. So you will want your own audit first, while there is time to fix things.
Sponsor duties
Your Authorising Officer carries overall responsibility, and your Level 1 User does the day-to-day work. Officers expect both to answer for it, so both need sponsor licence compliance training.
Sponsor duties
The UK sponsor duties start the day your licence is granted. All licences valid and expiring on or after April 6, 2024, received an automatic 10-year extension from their original expiry date.
Sponsor duties
Sponsor licence compliance has four duties: records, reporting, monitoring, and right-to-work checks. They run for the life of the licence.
Sponsor Licence Compliance Success Stories
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How can we help?
