From 8 April 2026, the Skilled Worker salary rules became more granular for Certificates of Sponsorship assigned on or after that date. Paragraph SW 14.3B of Appendix Skilled Worker now allows UKVI to look not only at the annual salary stated on the CoS, but also at whether the worker is paid correctly across defined pay periods.
If you sponsor Skilled Workers and your payroll includes variable hours, unpaid leave, bonuses, deductions or salary sacrifice, this is now a serious compliance issue. A salary that looks compliant on paper may still create risk if the pay records do not support it.
What changed and why it matters
Before these changes, sponsors often focused mainly on the annual salary figure on the Certificate of Sponsorship and employment contract. That is no longer enough for new CoS assigned from 8 April 2026.
Under SW 14.3B, the salary paid in each pay period must equal or exceed the relevant going rate for every hour worked in that pay period. In addition, the worker’s pay must meet the required proportion of the annual salary over the relevant averaging period.
For monthly-paid workers, pay over any 3-month period must be at least one quarter of the required annual salary. For weekly or more frequent pay, the test is any 12-week period. Where the worker has an irregular working pattern, a 17-week averaging period may apply, provided the working pattern is properly confirmed.
This makes payslips, working hours records and payroll reports central to sponsor compliance. During a UKVI compliance visit, inspectors can compare those records against the salary rules and the information on the CoS.
The current salary thresholds
From 22 July 2025, the standard Skilled Worker salary threshold for many roles became £41,700 per year, or the going rate for the occupation code, whichever is higher. Lower thresholds may apply in specific cases, including certain health and education roles, new entrant rules, PhD discounts, transitional provisions, and roles on the Immigration Salary List or Temporary Shortage List.
The minimum hourly floor is also important. Where the calculated going rate is below £17.13 per hour for many standard roles, £17.13 is treated as the applicable minimum hourly rate. Sponsors should check the exact occupation code and salary option before assigning a CoS. Our guide to skilled worker sponsorship salary rules explains the thresholds in more detail.
Where sponsors are getting caught out
Unpaid leave
Unpaid or reduced-pay leave can create risk if it brings pay below the required level. Some absences, such as statutory family leave, sick leave, jury service or permitted humanitarian leave, are treated differently, but sponsors still need to understand the reporting duties. Our article on managing unpaid leave for sponsored workers explains this in more detail.
Bonus-heavy pay structures
Bonuses, overtime, shift pay and similar additional payments generally do not count towards the Skilled Worker salary requirement, even if they are expected or regular. A base salary below the required threshold cannot usually be rescued by a later bonus. Sponsors should structure sponsored roles so the guaranteed salary alone meets the relevant requirement.
Salary sacrifice and deductions
Salary sacrifice is not automatically prohibited, but it must be handled carefully. The rules distinguish genuine optional benefit arrangements from deductions or payments connected to business costs, immigration costs, loans or investments. Sponsors should check whether the salary recorded on the CoS and the worker’s qualifying pay remain compliant after any arrangement is applied.
Four-weekly payroll
Four-weekly payroll can create mistakes because there are 13 four-week periods in a year, not 12. Sponsors should not simply divide a monthly salary by 12 and apply that figure to a four-week cycle. Payroll settings must match the actual pay frequency.
How UKVI identifies non-compliance
The Home Office can check salary compliance through sponsor compliance visits and HMRC payroll data. Sponsor guidance confirms that UKVI may regularly check whether workers are being paid at least the salary stated on the CoS or any later change notification.
If your licence is already at risk, our guide to sponsor licence suspension and revocation explains what can happen and how to respond.
What sponsors should do now
Audit every sponsored worker’s pay against the salary stated on the CoS, the occupation code, the applicable going rate and the worker’s actual hours.
Review bonus, overtime and allowance arrangements to confirm what can and cannot count.
Check unpaid leave, reduced pay and working pattern changes against the reporting rules in the Sponsor Management System.
Make sure any reportable salary or role changes are notified within the required timescale. Our article on sponsor duties and compliance explains these duties.
Keep payroll records by pay period, not just annual summaries. UKVI may want to see payslips, hours data and evidence that the pay-period tests have been met.
The Certificates of Sponsorship guide is worth reviewing alongside this if you are assigning new CoS or updating existing sponsored roles.
A note on the wider context
The pay-period rule sits within a broader tightening of Skilled Worker sponsorship. Since 22 July 2025, most newly sponsored Skilled Worker roles must be at RQF Level 6 or above, unless the role falls within an eligible list or transitional provision. The Immigration Salary List and Temporary Shortage List are time-limited and currently due to be reviewed before the end of 2026.
If you are preparing a sponsor licence application, reviewing your existing licence, or budgeting with the sponsor licence costs guide, salary compliance should be part of the planning. Employers entering the UK market should also understand the UK expansion worker visa, while owner-managed businesses considering a self-sponsorship visa need to treat payroll compliance with particular care. Structural changes should be checked against business changes that trigger sponsor reporting.
FAQs
Does the April 2026 rule apply to existing sponsored workers?
The new SW 14.3B wording applies to CoS assigned on or after 8 April 2026. Existing sponsorships may be affected by transitional provisions, but sponsors should still review ongoing pay, salary reductions and reporting duties carefully.
Do bonuses count towards the salary requirement?
Usually no. Bonus pay, overtime, shift pay and similar additional payments are generally excluded from the salary calculation.
Can sponsored workers use salary sacrifice?
Yes, but only if the arrangement is structured correctly and does not create a salary compliance issue. Take advice before applying sacrifice arrangements to sponsored workers.
What should sponsors prepare for a compliance visit?
Keep CoS records, payslips, working hours data, payroll summaries, right-to-work checks and SMS reports in order. UKVI may review salary compliance by pay period, not just annually.
Get Your Compliance in Order
The pay-period rules are now in force for new sponsorship under the updated rules. If you have not reviewed sponsored workers’ payroll against the current requirements, do it before UKVI asks.
The team at Garth Coates Solicitors advises employers on skilled worker immigration in the UK, from licence applications to compliance audits and enforcement responses. Contact us today to arrange a consultation.
