Sponsor licence compliance

Overview

When you are granted a licence, you accept the sponsor duties in the Home Office guidance for sponsors. The idea is simple: the Home Office relies on you to make sure each sponsored worker is doing the job they were sponsored for, on the pay stated, and to tell it when something changes.

If you fall short, the Home Office can downgrade your licence to a B-rating, suspend it or revoke it. Revocation affects every worker you sponsor, not only the one involved, because their permission is normally cut short.

Enforcement has become much stricter. The Home Office reports that 1,948 licences were revoked between July 2024 and June 2025, more than double the 937 in the previous 12 months. It names adult social care, hospitality, retail and construction as the sectors of most concern, and it relies increasingly on data shared across government, including regular HMRC checks of what sponsored workers are actually paid. The guidance also keeps changing: multi-factor sign-in for sponsor system users is being made compulsory in stages from 3 September 2026, no new Level 2 users can be appointed after 9 September 2026, and existing Level 2 user accounts must be converted or closed by 8 March 2027.

Who this is for

This page is for every licensed sponsor, and especially:

• small businesses where one person handles HR, payroll and the sponsorship management system (SMS);
• employers in the sectors the Home Office has identified as highest risk;
• organisations sponsoring for the first time;
• sponsors that have restructured, moved, been bought or changed key personnel;
• employers who have been told a compliance visit is coming.

If you have already been downgraded, suspended or revoked, see our page on sponsor licence suspension and revocation.

Requirements

Right to work checks

You must check every sponsored worker's right to work before they start, and again before time-limited permission runs out. Most workers now have an eVisa, so you must use the Home Office online checking service with a share code from the worker, and keep a copy of the result. Looking at the worker's own view of their eVisa is not enough. Failing to check properly can lead to a civil penalty of up to £60,000 per illegal worker and is likely to lead to revocation. Since 1 October 2026, the rules also cover some workers engaged as individual contractors, not only employees.

Record keeping

Appendix D of the sponsor guidance lists the records to keep for each sponsored worker. They include:

• the right to work check and the date the worker entered the UK;
• recruitment records: the advert, the number of applicants and shortlisted candidates, and how you chose the worker;
• payslips, proof of each salary payment, and the contract;
• a detailed job description and evidence of qualifications or professional registration;
• an absence record and a history of contact details.

Keep them for the whole period of sponsorship and for one year after it ends, or until a compliance officer has examined and approved them, if that is sooner.

Reporting duties

Most changes are reported through the SMS. The main deadlines are:

A suspected breach of a worker's conditions, or information about criminal activity, must be reported as soon as reasonably practicable.

The job and the salary

The worker must do the job on their certificate, and the occupation code and job description must match the real duties. You cannot hire a sponsored worker out to a client, or use them to fill an ongoing routine role for a third party under a contract. A role that does not exist, or was created mainly to obtain a visa, is a mandatory ground for revocation.

You must pay at least the salary on the certificate, at least monthly unless the contract says otherwise. The Home Office checks pay period by period, not only over the year: for a monthly-paid worker, pay over any 3 months must be at least a quarter of the required annual salary. Only guaranteed basic gross pay counts, not overtime, bonuses or most allowances. Paying less than stated without permitted grounds and without telling the Home Office is a mandatory ground for revocation.

Cooperation and costs

You must give Home Office officers access to your premises on demand, make sure any client site where your workers are based will cooperate with an unannounced visit, and follow any action plan. You must pay the certificate fee and the Immigration Skills Charge yourself, and you must not recover the licence fee or related administrative costs from a worker.

How the process works

Compliance checks take several forms: requests for documents, checks by video call, checks with HMRC and other departments, and visits to your premises, which may be announced or unannounced. A visit usually runs like this:

1. Officers arrive and show Home Office identification. If you doubt it, you can call the sponsorship helpline to confirm.
2. They ask about your business, your recruitment and how you manage sponsorship.
3. They inspect records for sponsored workers: right to work checks, payslips, absence records and contracts.
4. They speak to sponsored workers about their duties, hours and pay, and may check other staff for illegal working.
5. They leave without giving a view. You will not be told the outcome on the day.
6. You receive the decision in writing. Minor breaches usually lead to a B-rating and action plan; serious breaches can lead to suspension or revocation.

If the Home Office proposes a downgrade or suspends the licence, you normally have 20 working days to respond in writing with evidence. That response is often your best chance to put matters right.

Costs

There is no Home Office fee for compliance itself, but there are costs when things go wrong. If you are downgraded, you must pay the action plan fee within 10 working days or lose the licence. You may also pay for the priority service to have a change of circumstances processed within 5 working days, as standard requests can take much longer. Each new hire brings a certificate fee and the Immigration Skills Charge. A civil penalty for illegal working can cost far more than any of these. Current figures are on our UK visa fees page.

Timescales

Compliance runs on fixed deadlines: 10 working days for most changes about workers and 20 working days for changes about your organisation. The Home Office gives 20 working days to answer a proposed downgrade or suspension. An action plan lasts three months, and you can be B-rated no more than twice in any four-year period.

We suggest a short monthly review of new starters, leavers, pay changes, absences and visa expiry dates, and a fuller audit once a year or before any restructure, move or sale of the business.

Common problems

• Salary dips. A worker moves to shorter hours, takes long unpaid leave or has a pay cut, and nobody checks the threshold or reports the change.
• Role drift. A worker sponsored as a business analyst gradually becomes the office manager. If the duties no longer match the occupation code, the licence is at risk.
• Incorrect eVisa checks. Staff look at a screenshot from the worker instead of using the employer checking service with a share code.
• Late reports. Absences, resignations and changes of address go unreported because the person who ran the SMS has left.
• Out-of-date key personnel, or SMS logins shared between staff.
• Workers placed full time with one client, which can look like supplying labour to a third party.

How we can help

We carry out compliance audits, on site or remotely, that follow the approach of a Home Office visit. We review your right to work checks, personnel files, payroll against certificates and SMS records, and give you a written report with clear priorities.

We help you put practical systems in place: checklists for starters and leavers, a reporting calendar, and training for your authorising officer and SMS users. Some clients ask us to act as key contact and handle reporting for them.

If a visit has been announced, we help you prepare. If the Home Office writes proposing action, we prepare your response and evidence within the deadline. Not yet licensed? See our sponsor licence application page, or contact us.

Frequently asked questions

How quickly must we report that a sponsored worker has resigned?

Within 10 working days of the employment ending. Report the date of the last working day and keep the resignation letter on file.

Can we reduce a sponsored worker's salary?

Only in limited circumstances, and the new salary must still meet the requirements of the route. Check first whether you need to assign a new certificate, and report a permitted reduction within 10 working days.

Do we have to keep copies of passports?

Not as a general rule. You must keep evidence of the right to work check, which for an eVisa holder is a copy of the online check result showing the photo and the date. Keep the other records listed in Appendix D.

Will the Home Office tell us before a visit?

Not necessarily. Visits can be unannounced, before or after a licence is granted. If your workers are based at a client's site, the client must also cooperate with an unannounced visit.

What if our authorising officer leaves?

A Level 1 user can appoint a replacement through the SMS, and you must then send a signed submission sheet and any documents asked for. Do it promptly: the new authorising officer must meet the same suitability checks.

We no longer sponsor anyone. Should we keep the licence?

The Home Office says the register is for organisations actively using their licence, and invites inactive sponsors to surrender. If you surrender when you are not under compliance action, you can reapply at any time.