Sponsor Licence Compliance Review & Audit Support

02

Sponsor Licence Review

A Sponsor Licence Health Check for existing sponsors, reviewing your systems and records against current duties.

HR systems and right-to-work records
Sponsored worker files, contracts and job descriptions
Salary records, payslips and absence records
SMS reporting, key personnel and CoS records
Business changes and reporting procedures

Book a Sponsor Licence Review

An open filing cabinet drawer of carefully organised records

03

Home Office Compliance Visit Preparation

A clear, structured process to help you feel prepared before a Home Office compliance visit.

Document review
HR systems review
Sponsored worker file review
Mock compliance interview
Corrective action report
Follow-up review

Prepare for a Compliance Visit

Four business professionals in a serious discussion in a modern office lobby

04

Sponsor Licence Management

Ongoing support to help you manage your licence and stay compliant as your business changes.

Key personnel changes and SMS support
Reporting obligations and sponsored worker records
Compliance calendar and right-to-work checks
Absence monitoring, salary and role changes
Business structure changes and licence maintenance

Discuss Ongoing Support

Two colleagues reviewing documents together at an office desk

Section C

Ongoing SponsorDuties

Holding a licence isn't a one-off event — sponsors take on continuing duties to report changes and cooperate with the Home Office for as long as the licence is held.

1

Report worker-related changes

Reportable via the Sponsor Management System (SMS) "report migrant activity" function.

The worker doesn't start their job — GOV.UK guidance uses a 28-day non-start trigger
Unauthorised absence of more than 10 consecutive working days
Salary drops below the level stated on the Certificate of Sponsorship
Significant change to job role, title, duties, or normal work location
The worker resigns or you stop employing them

2

Report organisational changes

Generally reportable within 20 working days of the change.

Changes to key personnel
Change of registered address or trading name
Structural changes — mergers, takeovers, insolvency proceedings
Relevant criminal convictions involving key personnel or the organisation

3

Cooperate with the Home Office

Allow Home Office staff full access to any premises or site under your control, on demand
This duty extends to third-party sites where a sponsored worker is based
Do not act in an abusive, intimidating, threatening, or discriminatory way toward Home Office staff

Reporting windows can change

Reporting windows shown here (10, 20 and 28 working days) reflect current GOV.UK guidance and can change — always confirm the exact current trigger and deadline for your situation in Part 3 of the sponsor guidance before acting.

Section B

Record Keeping &Appendix D

Sponsors must keep specified records for every sponsored worker, and be able to produce them to the Home Office quickly — sometimes with little or no notice.

Identity & immigration documents

Copy of the worker's current passport (photo page and relevant visa/entry stamps)
Biometric Residence Permit (BRP) or eVisa record
Entry clearance documentation, where applicable

Right to work evidence

Copy of the right to work check carried out — manual document check or online share-code check
National Insurance documentation

Contact details

Up-to-date UK address
Personal email address and telephone number
Kept current throughout the period of employment

Employment documents

Signed contract or written statement of employment particulars
Job description matching the sponsored role
Working hours and salary records

Salary & payment evidence

Payslips
Proof of payment into the worker's bank account
Evidence of any allowances paid

Qualifications & other route-specific records

Degree certificates or professional registration, where the role requires them
DBS check copies, where relevant
Absence records and, for some Global Business Mobility routes, the underlying contracts

Retention

Keep records for the whole sponsorship period, and until the earlier of: one year after sponsorship ends, or the date a compliance officer has examined and approved the records (if that is sooner).

Right to work check records generally need to be retained for the duration of employment plus a further period after it ends — the exact period sits under the separate right to work checks guidance, not Appendix D itself, so confirm it there.

Inspections

UKVI can inspect sponsor records at any time, with little or no notice. Records must be legible, attributable, and readily retrievable — delay in producing them can itself be treated as a compliance issue.

Section D

Key Personnel

Every sponsor licence needs specific named people responsible for managing it. The same person can hold more than one role.

01

Authorising Officer (AO)

The senior, competent person with overall responsibility for the actions of everyone who uses the SMS on your behalf, and for compliance with sponsor duties generally. Must be an employee, partner, director, or a settled worker, generally UK-based most of the time. Being AO doesn't automatically grant SMS access — they must be separately appointed as a Level 1 or Level 2 User to use the system.

02

Key Contact

Your organisation's main point of contact with UKVI — receives communications such as licence updates, requests for further information, and notice of compliance visits or licence changes.

03

Level 1 User

Handles day-to-day management of the licence in the SMS: assigning or requesting Certificates of Sponsorship, reporting changes, and adding or removing other SMS users. At least one Level 1 User must be an employee, partner, director, or settled worker, UK-based most of the time.

04

Level 2 User (optional)

Has more limited SMS permissions than a Level 1 User — for example, cannot withdraw a Certificate of Sponsorship. Can be appointed after the licence is granted to help with routine administration.

Eligibility applies to every role

Across all key personnel roles: generally must be UK-based most of the time, not a short-term contractor brought in solely for the role, not subject to bankruptcy restrictions or a debt relief order, and free of relevant unspent convictions, UKVI penalties, or involvement in a previous licence revocation. A licence will be revoked if it lacks an eligible Authorising Officer and Level 1 User at any time.

Section E

Audits & Inspections

The Home Office can check a sponsor is meeting its duties at any point — before a licence is granted, and at any time afterwards.

What officers typically check

Accuracy of the information given in your licence application and subsequent SMS reporting
That your organisation is genuinely and lawfully trading or operating
That sponsored workers genuinely exist in the roles described, and are eligible
Record-keeping compliance under Appendix D
Right to work checks for your whole workforce, not only sponsored workers
Criminal record and civil penalty checks on key personnel and associated individuals

Announced or unannounced

Home Office compliance visits can take place on an announced or an unannounced basis, and can be carried out in person or digitally. There's no fixed public duration — it depends on the size of your organisation and the scope of the check.

Visits can happen before or after a licence is granted

A pre-licence compliance visit can take place before a decision is made on a new application. Visits can also recur at any point during the life of a live licence.

Interviews may be included

Officers may interview sponsored workers directly, and staff involved in recruitment or HR, as part of a visit.

Section F

Common Breaches

Most compliance issues are avoidable process failures rather than deliberate wrongdoing. Knowing the common patterns helps you manage the risk.

Failing to report an unauthorised absence of more than 10 consecutive working days within the required window

Failing to report salary reductions, or changes to a worker's job role, title, or location

Incomplete record-keeping under Appendix D — missing payslips, contracts, or right to work evidence

Employing sponsored workers without properly conducted right to work checks

Sponsoring a role that isn't genuinely eligible — for example, one that doesn't meet the skill or salary threshold, or doesn't reflect a genuine vacancy

Workers actually performing duties that don't match the occupation code or job description on their Certificate of Sponsorship

Wider non-compliance with UK employment law or sector regulatory requirements

Context, not a warning

Most compliance problems come from process failures — late reporting, thin record-keeping, a role drifting from its Certificate of Sponsorship — rather than deliberate wrongdoing. Treat this list as a set of risks to actively manage, not a list of things employers commonly do wrong.

Consequences Ladder

How compliance action escalates

The Home Office generally moves through a graduated set of responses, from a correctable action plan up to the most serious outcome, revocation. It's a progression to actively avoid, not a fixed sequence every sponsor faces.

1Stage 1 of 4

Action plan & B-rating

For relatively minor or moderate issues, the Home Office can downgrade your licence from A-rated to B-rated. While B-rated you cannot issue new Certificates of Sponsorship until you complete a Home Office action plan (which carries its own fee) and are upgraded back to A-rated. A licence can only carry 2 B-ratings before it is lost.

2Stage 2 of 4

Suspension

For a significant or systematic failing, or a serious threat to immigration control, the licence can be suspended. While suspended you cannot assign new Certificates of Sponsorship and the licence is removed from the public register, though existing sponsored workers generally keep their valid permission unless revocation follows.

3Stage 3 of 4

Revocation

Applied for serious breaches — for example, workers performing duties that don't match their Certificate of Sponsorship, employing illegal workers, deception in the application, or conduct not conducive to the public good. Sponsored workers may have their permission cancelled as a result.

4Stage 4 of 4

Reapplication bar

After revocation, your organisation generally cannot reapply for a new licence for at least 12 months from the date of notification — or 24 months if revoked more than once.

A separate, related track: civil penalties

Employing someone without the right to work — sponsored or not — sits on a related but separate enforcement track: a civil penalty of up to £60,000 per illegal worker, and potential criminal prosecution (up to 5 years' imprisonment and/or an unlimited fine) if the employer knew or had reasonable cause to believe the person lacked the right to work. A civil penalty also generally blocks holding or obtaining a sponsor licence for at least 12 months after it's paid in full (up to 5 years for repeat penalties).