Mock Sponsor Licence Audit: Prepare for a Home Office Inspection

Mock Sponsor Licence Audit: At a Glance

A mock sponsor licence audit tests whether an employer’s sponsorship arrangements would stand up to Home Office scrutiny. It should examine the records, systems, reporting controls and working practices that support the sponsor licence and identify weaknesses while there is still an opportunity to investigate and remediate them.

The exercise should go beyond checking whether policies and documents exist. Employers need to establish whether information held on the Sponsor Management System (SMS) remains accurate, whether sponsored worker records correspond with actual employment arrangements and whether the people responsible for compliance understand how the organisation’s controls operate in practice.

Home Office sponsor compliance activity can include requests for information and documents, verification activity, digital checks, interviews and onsite visits. Visits and interviews may be announced or unannounced.

This guide explains how to carry out a mock sponsor licence audit, what to test, how to identify isolated and systemic weaknesses and how to turn findings into targeted remediation and re-testing.

 

Section A: What Is a Mock Sponsor Licence Audit?

 

A mock sponsor licence audit is a structured internal or independently commissioned review designed to test how an organisation’s sponsorship arrangements would perform under external scrutiny.

The review will typically examine a sample of sponsored worker files, SMS information, right to work evidence, payroll, absence and contact records, HR procedures and reporting history. It should also test whether key personnel, HR teams, managers and sponsored workers can explain how sponsorship operates in practice.

The purpose is to establish whether the organisation can evidence that its sponsorship arrangements are accurate, controlled and supported by reliable records. A useful framework is to test four connected elements:

 

• Policy: Does the organisation have an appropriate process?
• Process: Is that process actually being followed?
• Evidence: Can the organisation demonstrate that it has been followed?
• Reality: Does the documentary record correspond with what is actually happening in the workplace?

 

Weaknesses often appear where those elements diverge. An HR procedure may require changes in sponsored workers‘ circumstances to be escalated to the Level 1 User, but the audit should test whether managers understand that requirement and whether relevant changes actually reach the sponsorship team.

Likewise, a worker file may contain a job description that matches the Certificate of Sponsorship, while the employee’s current duties, salary, hours or work location have changed. The audit should reconcile the documentary record with employment reality and establish whether any changes were identified and assessed at the appropriate time.

This is why a meaningful mock audit should combine document review with evidence reconciliation and interviews. The objective is to determine whether the organisation’s compliance framework works in practice and whether any gaps point to an isolated error or a wider control failure.

 

1. Mock Audit Versus a Home Office Compliance Check

 

A mock sponsor licence audit does not have the status of a Home Office compliance check and completing one does not prevent UKVI from carrying out its own compliance activity.

During official scrutiny, the Home Office may review documents and systems, conduct digital or verification activity, interview relevant personnel or sponsored workers and visit the organisation’s premises. It may assess whether the sponsor continues to meet the requirements of its licence and comply with its sponsorship duties, including relevant right to work obligations.

A mock audit uses that potential scrutiny as the benchmark for internal testing. It should expose weaknesses, inconsistencies and gaps that could become significant during Home Office compliance activity.

Where an issue is identified, the employer should establish what happened, assess the relevant sponsor requirement, determine whether corrective action is needed and address the process that allowed the issue to arise.

 

2. Mock Audit Versus a Routine Sponsor Compliance Review

 

Routine sponsor compliance reviews and mock audits overlap, but a mock audit is more deliberately testing in approach. Routine monitoring may check whether records, SMS information, reporting activity and worker files remain in order as part of normal governance.

A mock audit asks a harder question: would those controls and the evidence they produce withstand external scrutiny?

That can involve selecting worker files for detailed sampling, reconciling Certificates of Sponsorship against HR and payroll records, tracing reportable events through internal processes, testing key personnel knowledge and interviewing sponsored workers about their actual roles and working arrangements.

The result should give the employer a realistic view of inspection readiness and identify where further investigation, remediation or re-testing is required.

 

 

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Section B: Why Conduct a Mock Sponsor Licence Audit?

 

Sponsor licence holders are subject to ongoing compliance duties. Weaknesses can develop as the sponsored workforce grows, employees change roles, managers change, HR systems evolve or responsibility for sponsorship moves between personnel.

Problems frequently arise from ordinary business events rather than deliberate non-compliance. A sponsored worker may move location, assume different responsibilities, experience a salary change or period of absence, while changes within the organisation itself can also have sponsorship implications.

The compliance risk is often whether the organisation has effective systems for identifying these events, assessing their significance and taking any action required under the sponsor regime.

A mock sponsor licence audit tests whether those systems work before they are subjected to external scrutiny.

 

1. Identifying Compliance Weaknesses Before Home Office Scrutiny

 

A mock audit provides a controlled environment in which inconsistencies can be identified and investigated.

This allows the employer to establish not only what has gone wrong, but why.

For example, the audit may identify a change in a sponsored worker’s normal work location that was not escalated to the sponsorship team.

The immediate question is whether the change engaged a reporting obligation and, if so, what action is now appropriate.

The wider audit question is why the information did not reach the people responsible for sponsorship.

If the manager responsible for the worker did not know that changes of this nature needed to be escalated, correcting the individual record does not resolve the underlying weakness.

The same control failure could affect other sponsored workers.

A useful question throughout the audit is therefore:

Is this an isolated error, or evidence of a wider control failure?

 

2. Testing Whether HR Records Match Employment Reality

 

A sponsor’s records should provide an accurate account of its sponsored workers and relevant employment arrangements.

A mock audit should therefore reconcile information across different sources rather than reviewing documents independently.

Depending on the worker and the issue being tested, this may involve comparing:

 

• Certificate of Sponsorship information;
• SMS records;
• personnel files;
• employment contracts;
• job descriptions;
• payroll information;
• salary payment evidence;
• absence and attendance records;
• work-location information;
• manager evidence; and
• the sponsored worker’s own account of their employment.

 

The existence of a correct job description on the personnel file does not resolve a compliance concern if the worker is performing materially different duties in practice.

Similarly, a salary figure stated in the contract or Certificate of Sponsorship should be tested against payslips and evidence of what the worker has actually been paid.

Where information does not correspond, the discrepancy should be investigated rather than automatically treated as either harmless or non-compliant.

The mock audit should establish the facts and determine whether any sponsorship requirement is engaged.

 

3. Testing Whether Sponsor Duties Work in Practice

 

Written procedures are only useful if the organisation can operate them consistently.

A mock audit should therefore test how sponsorship information moves through the business.

Questions can include:

 

• How does HR know when a sponsored worker’s role changes?
• Who identifies whether a salary change has sponsorship implications?
• How are changes in normal work location communicated?
• Who monitors unauthorised absence?
• How are changes to workers’ contact details captured and retained?
• Who decides whether an event needs to be reported through the SMS?
• What happens if the principal Level 1 User is absent?
• How are changes affecting the sponsoring organisation escalated?
• How are changes to sponsored workers’ duties or working hours assessed?
• Who ensures that actions identified during previous compliance reviews have actually been completed?

 

The sponsor should have a functioning compliance system rather than one individual who happens to know how the licence works.

This becomes particularly important where experienced sponsorship personnel leave, responsibilities move between teams or the organisation expands.

 

4. Preparing Key Personnel for Scrutiny

 

A mock audit should test whether the people responsible for sponsorship understand their roles and can explain how compliance is managed within the organisation.

The Authorising Officer should have meaningful oversight of the sponsor licence and the activities of the organisation’s SMS users.

Current Home Office sponsor guidance requires the Authorising Officer to be responsible for the activities of SMS users and requires the sponsor to have a system for checking those activities. Home Office guidance also recommends that the Authorising Officer checks Certificates of Sponsorship assigned to workers at least monthly.

The distinction is important: meaningful oversight of SMS-user activity is part of the sponsor’s governance responsibilities, while the monthly CoS check is a Home Office recommendation for maintaining that oversight.

Level 1 Users should understand the sponsorship administration they perform and how relevant events are brought to their attention.

HR personnel and operational managers should understand the parts of the compliance process relevant to their responsibilities, including when changes involving sponsored workers need to be escalated.

The audit should not be used to provide personnel with scripted responses.

Differences in understanding can themselves be valuable findings because they may expose unclear responsibility, inadequate training or a process that is not operating as management believes it is.

 

5. Testing Current SMS User Governance

 

SMS user governance should now form a specific part of mock audit testing because of changes introduced during 2026.

From 9 September 2026, sponsors can no longer add new Level 2 Users. Existing active Level 2 Users can continue temporarily, but sponsors should identify any remaining Level 2 accounts and ensure they are dealt with in accordance with the Home Office transitional arrangements before the role is withdrawn.

Existing Level 2 Users will need either to be converted to Level 1 Users, where the applicable requirements are met, or deactivated by the relevant Home Office deadline of 8 March 2027.

The audit should therefore establish:

 

• whether any existing Level 2 Users remain active;
• whether those accounts are still required;
• whether the users would be eligible to become Level 1 Users;
• whether conversion or deactivation has been planned; and
• whether the organisation will retain sufficient Level 1 User coverage following the transition.

 

The audit should also review multi-factor authentication arrangements for SMS users. Mandatory MFA rollout began on 3 September 2026 and applies immediately to organisations granted a sponsor licence on or after 9 September 2026.

Level 1 Users should have accurate date of birth, mobile number and email details recorded for authentication purposes, while any remaining Level 2 Users should have an accurate email address. Passwords, user IDs and one-time passcodes must not be shared.

Inactive accounts also require attention.

Under the current Home Office arrangements, an SMS account can be treated as inactive where the user has not accessed the system for 12 months. Affected inactive Level 1 Users are normally given 3 months to log in and check or update their details before the account can be deactivated.

This is particularly important where inactivity could leave the organisation without adequate active Level 1 User coverage. If no active Level 1 User remains, the licence can be suspended and the sponsor given 28 days to nominate at least one eligible Level 1 User, with revocation normally following if the position is not corrected. The Home Office recommends that a Level 1 User accesses the SMS at least once a month.

 

6. Establishing Inspection Readiness

 

Compliance evidence may exist without the organisation being able to retrieve or explain it effectively.

A mock audit should therefore test practical inspection readiness.

This can include:

 

• retrieving sponsored worker records;
• identifying the organisation’s current sponsored workforce;
• reconciling SMS activity with underlying employment events;
• producing payroll and salary-payment evidence;
• identifying who is responsible for dealing with Home Office enquiries;
• testing whether records are accessible across multiple sites;
• checking whether key personnel can explain sponsor governance arrangements; and
• testing whether managers and sponsored workers describe employment arrangements consistently with the documentary evidence.

 

The central question is:

If the Home Office examined the organisation today, could the sponsor demonstrate what it does, why it does it and where the supporting evidence is held?

Where the answer is uncertain, the mock audit should identify what needs to be investigated or improved.

 

 

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Section C: When Should Employers Conduct a Mock Sponsor Licence Audit?

 

There is no universal timetable for conducting a mock sponsor licence audit.

The appropriate timing will depend on the size of the sponsored workforce, the organisation’s operating model, the volume of sponsorship activity, previous compliance issues and the degree of organisational change.

Employers should therefore think in terms of events and compliance risk rather than assuming that completing an audit at an arbitrary interval is sufficient.

 

1. Before an Anticipated Home Office Compliance Visit

 

Where an employer knows that a Home Office compliance visit or other compliance activity is expected, a mock audit can be used to assess the organisation’s current position.

The purpose should be to identify genuine weaknesses and determine whether remediation is required.

It should not be used to manufacture records, alter the historic position or coach personnel to provide predetermined answers.

Where deficiencies are identified, the organisation should establish what actually happened and take appropriate corrective action.

Detailed guidance on the procedure for an actual Home Office compliance visit belongs within the separate DavidsonMorris guidance on Sponsor Licence Compliance Visits.

 

2. Following Rapid Growth in the Sponsored Workforce

 

Compliance systems that work effectively for a small number of sponsored workers may not scale automatically as sponsorship activity increases.

Rapid recruitment can place pressure on HR administration, reporting processes, document retention, payroll controls and line-manager communication.

A mock audit following significant growth can test whether the organisation’s controls have developed alongside its sponsored workforce.

Sampling should consider whether weaknesses are concentrated within particular departments, managers, sites or periods of rapid recruitment.

 

3. After Changes to HR or Sponsor Key Personnel

 

Changes involving the Authorising Officer, Level 1 Users, experienced HR personnel or others responsible for sponsorship can create compliance risk.

The audit should establish whether responsibilities have transferred effectively, whether SMS access remains appropriate and whether outstanding compliance matters have been handed over.

This is particularly important where the organisation previously relied heavily on one individual to manage sponsorship.

The review should also identify inactive SMS accounts and any legacy Level 2 User accounts requiring conversion or deactivation under the 2026 transitional arrangements.

 

4. Following Business or Organisational Change

 

Mergers, acquisitions, restructuring, changes of ownership, new branches, changes of premises and other corporate events can have sponsorship implications.

A mock audit following significant organisational change can test whether those implications were identified and whether the sponsor licence continues to correspond with the organisation’s current structure and operations.

The detailed legal consequences of corporate change should be considered separately under the applicable sponsor rules. The purpose of the mock audit is to establish whether the event entered the organisation’s sponsorship compliance process and whether appropriate action was considered.

 

5. Where Potential Reporting or Record-Keeping Failures Have Been Identified

 

One identified failure can justify wider testing.

If an employer discovers that a particular change was not reported, the audit should consider whether similar events involving other sponsored workers were handled correctly.

If required records are missing from one worker file, the employer should determine whether the problem reflects an isolated filing issue or a wider weakness in document retention.

Material historic issues should be investigated carefully. Employers should not attempt to correct the appearance of the historical record by creating inaccurate evidence or backdating documents.

 

6. Where Sponsorship Operates Across Multiple Sites

 

Multi-site organisations can face additional compliance risk because central policies may not be applied consistently by local management.

A mock audit should consider sampling sponsored workers and managers from different locations.

The purpose is to determine whether central HR understands what happens locally and whether local teams understand when events need to be escalated to those responsible for sponsorship.

This is particularly relevant where different sites maintain their own attendance, personnel or operational records.

 

7. After Material Changes to Sponsor Requirements

 

Changes to the Immigration Rules, sponsor guidance, right to work requirements or Home Office systems can require employers to alter their existing compliance arrangements.

The audit should test practical implementation rather than merely confirm that updated guidance has been circulated.

For example, changes during 2026 affecting SMS user arrangements, multi-factor authentication, inactive accounts, the phase-out of Level 2 Users and right to work requirements may require changes to internal processes and audit checklists.

The relevant question is whether the organisation has translated the new requirement into an operational control.

 

8. As Part of Ongoing Sponsor Governance

 

Mock audits can also form part of the sponsor’s wider compliance assurance programme even where no immediate problem or Home Office visit is anticipated.

The appropriate frequency should be risk-based.

Factors can include the size of the sponsored workforce, frequency of recruitment, number of sites, complexity of employment arrangements, previous findings and the rate of organisational change.

A useful governance model combines:

Periodic assurance → event-triggered review → targeted remediation → re-testing.

This approach recognises that sponsor compliance is an ongoing organisational responsibility rather than an exercise carried out only when external scrutiny is expected.

 

 

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Section D: How Should a Mock Sponsor Licence Audit Work?

 

A mock sponsor licence audit should be evidence-led. It should not primarily consist of completing a questionnaire or confirming that the organisation has written sponsorship policies.

The exercise should work from the sponsor licence through to individual sponsored workers and then back through the systems responsible for managing them. This allows the auditor to identify both individual discrepancies and the organisational processes that caused them.

The precise methodology should reflect the organisation’s size, sponsorship activity and risk profile, but a comprehensive mock audit can follow the steps below.

 

1. Step 1 — Define the Scope of the Mock Audit

 

The first stage is to determine what the audit will examine.

The scope should be sufficiently broad to provide meaningful assurance while reflecting the organisation’s sponsorship arrangements and known areas of risk.

Relevant factors can include:

 

• the number of sponsored workers;
• the immigration routes used;
• the number of sponsoring entities;
• the number of business locations;
• recent recruitment activity;
• changes to sponsor key personnel;
• previous compliance concerns;
• corporate or organisational changes;
• the complexity of HR and payroll systems;
• remote, hybrid or client-site working arrangements;
• the organisation’s use of different HR teams or business units; and
• any known potential sponsor compliance issues.

 

The employer should define the period being reviewed, the systems and locations within scope, the worker population to be sampled and the personnel who will be interviewed.

Where a known concern exists, the scope should not be artificially restricted in a way that prevents the organisation from determining whether the problem is wider than the individual case.

If one worker has an unexplained salary discrepancy, for example, the audit may need to consider whether other sponsored workers have experienced similar changes.

The audit should distinguish between an isolated error and evidence of a systemic control failure.

 

2. Step 2 — Review the Sponsor Licence and SMS Information

 

The sponsor licence and Sponsor Management System should provide the administrative baseline for the review.

The auditor should compare the information held for sponsorship purposes with the organisation as it operates today.

This can include reviewing:

 

• the sponsoring legal entity;
• relevant organisation details;
• addresses and operating locations;
• sponsor key personnel;
• SMS user arrangements;
• the sponsored worker population;
• Certificate of Sponsorship activity;
• relevant reporting history; and
• significant organisational changes.

 

Information that was accurate when the sponsor licence was granted may no longer correspond with the organisation’s circumstances.

New or closed premises, changes to key personnel, changes in ownership or structure, changes to work locations and other business developments should therefore be identified and assessed.

The audit should also examine current SMS user governance.

This should include checking whether access remains appropriate, whether former personnel have been removed where necessary, whether there is sufficient Level 1 User coverage and whether relevant SMS-user details are current for multi-factor authentication purposes.

Any inactive SMS accounts should be identified. Under current Home Office arrangements, an account can be treated as inactive where the user has not accessed the SMS for 12 months, making dormant-user management an important part of current sponsor governance.

The sponsor should also identify any existing Level 2 Users. New Level 2 Users can no longer be appointed from 9 September 2026, and existing Level 2 Users are subject to transitional arrangements under which they must be converted to Level 1 Users, where eligible, or deactivated by 8 March 2027.

The audit should ensure that the organisation has a plan for this transition and will retain appropriate SMS coverage.

 

3. Step 3 — Select Sponsored Workers for Detailed Testing

 

Where the organisation has too many sponsored workers for every file to be reviewed, the sample should be selected intelligently.

A risk-based sample can include:

 

• recently sponsored workers;
• long-serving sponsored workers;
• workers who have changed role or duties;
• workers whose salary or working hours have changed;
• workers whose normal work location has changed;
• remote or hybrid workers;
• workers operating at client sites;
• workers with significant absence history;
• workers sponsored under different routes;
• workers based at different locations;
• workers managed by different departments or managers; and
• workers whose records have previously raised compliance questions.

 

Risk-based sampling can be combined with a random sample.

Random selection helps prevent the audit from becoming limited to files that HR already knows are well maintained.

The purpose is not to demonstrate that the organisation can produce a collection of compliant files. It is to discover what an external reviewer could find if different workers and records were selected for scrutiny.

If the initial sample identifies a recurring problem, the sample should be expanded where necessary to determine the extent of the issue.

 

4. Step 4 — Review Sponsored Worker Records

 

Each sampled worker should be reviewed as a complete sponsorship and employment record rather than as a collection of unrelated documents.

Depending on the worker’s circumstances and the applicable requirements, relevant records can include:

 

• identity information;
• immigration status evidence;
• right to work evidence;
• evidence of the worker’s date of entry to the UK where required under Appendix D;
• current and historic contact information;
• relevant recruitment records;
• Certificate of Sponsorship information;
• employment contracts;
• job descriptions;
• salary and payroll information;
• evidence of salary payments;
• working-hours information;
• work-location records;
• absence and attendance records;
• records relating to changes during sponsorship; and
• relevant SMS reporting history.

 

Current Appendix D requirements should be used to determine precisely which records must be retained for the worker being reviewed.

The existence of a document is not sufficient in itself.

The audit should compare the evidence.

If the job description describes duties that differ materially from the worker’s actual responsibilities, the discrepancy should be investigated.

If the salary recorded on the Certificate of Sponsorship differs from payroll or salary-payment evidence, the employer should establish why.

If the organisation holds an address for the worker, the audit should consider whether the required history of the worker’s UK residential address and other required contact details has also been retained and kept up to date.

A useful worker-level question is:

Does the evidence demonstrate a coherent and accurate account of this worker’s sponsorship and employment?

 

5. Step 5 — Compare the Certificate of Sponsorship With Employment Reality

 

The mock audit should compare the basis on which the worker was sponsored with their actual employment.

Depending on the circumstances, the review should consider:

 

• job title;
• occupation classification;
• substantive duties;
• salary;
• working hours;
• normal work location;
• employment dates; and
• other material information relevant to the sponsorship.

 

Jobs can evolve over time and not every employment change creates a sponsor compliance problem.

The relevant question is whether the organisation has a system capable of identifying changes with sponsorship implications and whether the appropriate assessment was made.

Particular care is required where the worker’s role or duties have changed materially.

Where a worker is actually performing a role that does not correspond with the occupation code or job description on the Certificate of Sponsorship, and the change is not permitted under the sponsor rules, this can amount to a mandatory ground for revocation.

The employer should distinguish between changes that can be dealt with through the applicable sponsor reporting process and changes that may require a new Certificate of Sponsorship and a change of employment application before the worker can continue in the changed role.

The mock audit should therefore examine both the worker’s present circumstances and the process through which relevant changes were assessed.

 

6. Step 6 — Test Sponsor Compliance Systems

 

The next stage is to test the systems responsible for maintaining sponsor compliance.

These can include processes for:

 

• right to work checks;
• maintaining worker contact details;
• monitoring immigration permission;
• recording and escalating absence;
• identifying changes to duties;
• identifying salary or working-hours changes;
• monitoring changes to normal work location;
• identifying changes in employment status;
• dealing with termination of employment;
• identifying relevant organisational changes;
• SMS reporting;
• record retention;
• SMS user access and security;
• multi-factor authentication;
• inactive SMS-user management; and
• oversight of sponsorship activity by the Authorising Officer.

 

The auditor should follow information through the organisation.

For example, where a line manager agrees a change affecting a sponsored worker, the audit should establish how that information reaches HR, how HR identifies the worker as sponsored, how the sponsorship team assesses the change and how any required action is recorded.

This process-tracing approach is generally more informative than checking whether a written policy exists.

The audit should also test the Authorising Officer’s oversight of SMS activity. The sponsor should have a system for checking the activities of SMS users, while current Home Office guidance recommends that the Authorising Officer checks Certificates of Sponsorship assigned to workers at least monthly.

 

7. Step 7 — Interview Key Personnel, HR and Managers

 

Interviews should test whether the organisation’s documented procedures correspond with the understanding of the people responsible for operating them.

Depending on the organisation, interviewees can include:

 

• the Authorising Officer;
• Level 1 Users;
• existing Level 2 Users during the transitional period;
• HR personnel;
• recruitment personnel;
• payroll personnel;
• line managers; and
• other employees with responsibilities relevant to sponsor compliance.

 

Questions should reflect the person’s actual responsibilities.

The Authorising Officer should be able to explain how sponsorship is governed and how SMS-user activity is overseen, but would not necessarily be expected to carry out every administrative function personally.

Level 1 Users should understand the sponsorship activity they perform and how relevant information reaches them.

Managers do not necessarily need detailed knowledge of the Sponsor Management System, but they should understand which events need to be escalated internally.

The auditor should compare answers between different personnel.

Where HR believes managers notify it of every relevant change but managers do not understand the escalation process, that inconsistency is itself a compliance finding.

 

8. Step 8 — Conduct Sponsored Worker Interview Simulations

 

Sponsored worker interviews can help test whether documentary records correspond with employment reality.

The exercise should not involve coaching workers to provide predetermined answers.

Questions can cover:

 

• job title;
• day-to-day duties;
• line manager;
• working hours;
• normal work location;
• remote or hybrid working arrangements;
• salary and payment arrangements;
• absence-reporting procedures;
• changes to the role since sponsorship began; and
• current employment arrangements.

 

The answers should then be compared with the Certificate of Sponsorship, job description, employment contract, payroll information and management evidence.

Minor differences in terminology do not automatically establish non-compliance. Employees will not necessarily describe their duties using the wording of a formal job description.

Substantive inconsistencies should, however, be investigated.

A pattern of inconsistent answers across several workers can indicate a wider operational problem.

 

9. Step 9 — Record and Classify Findings

 

The audit should result in documented findings rather than a general conclusion that the organisation is “broadly compliant”.

For each material issue, a useful structure is:

Finding → Evidence → Sponsor obligation → Risk → Root cause → Required action.

This helps distinguish between different types of problem.

An isolated administrative error is different from a recurring system failure.

An incomplete document is different from evidence that the worker’s actual employment does not correspond with the sponsored role.

Findings should therefore be prioritised according to their potential significance and the urgency of any required action.

Where the organisation uses categories such as Critical, High, Moderate or Low, these should be clearly identified as the employer’s or auditor’s internal risk methodology.

They are not Home Office compliance classifications and should not be presented as predicting how the Home Office would categorise or respond to a particular issue.

 

10. Step 10 — Remediate and Re-Test

 

The audit should lead to corrective action where weaknesses are identified.

Depending on the findings, remediation can include:

 

• obtaining and organising legitimate missing evidence;
• correcting current internal records;
• assessing whether SMS action is required;
• reviewing an affected worker’s sponsorship position;
• updating internal procedures;
• strengthening escalation routes;
• providing targeted training;
• improving Authorising Officer oversight;
• changing HR or payroll controls;
• reviewing SMS-user access;
• addressing inactive or legacy user accounts; and
• obtaining legal advice where potentially material compliance issues have been identified.

 

Where historic gaps are identified, the employer should not attempt to reconstruct the record inaccurately or create evidence suggesting that an action occurred when it did not.

Legitimate remediation should preserve an accurate account of the historical position.

Significant findings should also be re-tested.

For example, if the audit establishes that managers have been failing to notify HR about changes involving sponsored workers, introducing a new policy is not sufficient evidence that the problem has been resolved.

The revised process should subsequently be tested using actual events to determine whether managers now escalate the relevant information and whether it reaches the sponsorship team in time for appropriate action.

The mock audit process should therefore operate as a compliance cycle:

Test → Identify → Investigate → Remediate → Re-Test → Monitor.

The objective is not simply to correct the files selected during the audit. It is to strengthen the organisation’s underlying sponsor compliance controls.

 

 

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Section E: Sponsor Licence and SMS Audit

 

The sponsor licence and Sponsor Management System should form a central part of the mock audit because they provide the Home Office’s administrative record of the organisation’s sponsorship activity.

The audit should test whether that record continues to correspond with the organisation as it operates today.

This requires more than checking that authorised personnel can log into the SMS. The review should consider whether relevant changes affecting the organisation, its key personnel and sponsored workers have been identified, assessed and, where required, reported.

The audit should also look backwards. Historic SMS activity can help establish whether the organisation’s reporting processes have been operating consistently or whether there are events recorded elsewhere in the business that do not appear to have been considered from a sponsorship perspective.

 

1. Check the Sponsor’s Organisational Information

 

The starting point should be the information held about the sponsoring organisation.

The auditor should compare sponsor records with current corporate and operational information and identify any material discrepancies requiring further investigation.

Depending on the organisation, this may involve considering changes relating to:

 

• the organisation’s legal or trading name;
• registered or trading addresses;
• operating or work locations;
• branches;
• ownership or control;
• corporate structure;
• mergers, acquisitions or disposals;
• relevant registrations or accreditations; and
• other significant organisational changes.

 

The purpose is not to assume that every business change requires the same sponsorship action. It is to establish whether relevant events were recognised, assessed and dealt with appropriately.

Where the business has experienced substantial corporate change, the mock audit should also consider whether the existing sponsor licence remains aligned with the legal entities and organisational structure employing sponsored workers.

Detailed treatment of mergers, acquisitions, restructuring and changes of ownership should remain within the specialist sponsor licence business-change resources.

 

2. Review Sponsor Key Personnel

 

The audit should verify that the organisation’s sponsor key personnel arrangements remain accurate and workable.

This should include the Authorising Officer, Key Contact and relevant SMS users.

The review should establish whether:

 

• the individuals recorded remain in the relevant roles;
• their details are current;
• SMS access is appropriately controlled;
• users have the access required to perform their responsibilities;
• former personnel no longer have inappropriate access;
• responsibilities are clearly allocated;
• suitable cover exists for absences and departures;
• the Authorising Officer has meaningful oversight of sponsorship activity; and
• the sponsor has a system for checking the activities of its SMS users.

 

This is an operational test as well as an administrative one.

A sponsor may have correctly appointed an Authorising Officer but still have weak governance if that individual has little visibility of how the licence is being managed.

The mock audit should therefore examine what oversight occurs in practice.

For example, does the Authorising Officer receive information about sponsored worker numbers, significant reporting activity, compliance concerns or identified breaches? Is there an escalation process for potentially serious issues? Who takes responsibility where there is uncertainty about whether a change requires sponsor action?

Current Home Office guidance recommends that the Authorising Officer checks Certificates of Sponsorship assigned to workers at least monthly. This should be distinguished from the underlying requirement for the sponsor to have effective oversight of SMS-user activity.

The objective is to establish whether sponsor governance functions as a system rather than depending entirely on one administrator.

 

3. Review SMS Access, MFA and User Security

 

Access to the Sponsor Management System should be reviewed as part of the organisation’s wider governance arrangements.

The audit should identify who has access, what responsibilities each user performs and whether that access remains appropriate.

Particular attention should be given to employees who have changed roles or left the organisation.

The auditor should also establish whether there is excessive reliance on a single SMS user. If only one person understands the organisation’s sponsorship administration, their absence or departure can create operational and compliance risk.

Multi-factor authentication should now form part of the audit. Mandatory MFA rollout began on 3 September 2026 and applies immediately to organisations granted a sponsor licence on or after 9 September 2026.

The audit should therefore check that Level 1 Users have accurate date of birth, mobile number and email details, that remaining Level 2 Users have an accurate email address, and that passwords, user IDs and one-time passcodes are not shared.

Security should also be considered more broadly. Access credentials should be controlled appropriately and the organisation should understand who is authorised to undertake activity through the SMS.

 

4. Identify Inactive SMS Accounts

 

Inactive SMS accounts should be identified as a specific part of the mock audit.

Under the current Home Office arrangements, an SMS account can be treated as inactive where the user has not accessed the system for 12 months.

The sponsor should therefore establish:

 

• which SMS users remain active;
• when users last accessed the system;
• whether any Home Office inactive-user notice has been received;
• whether any 3-month remediation period is running;
• whether inactive accounts are still required;
• whether user details remain current;
• whether sufficient active Level 1 User coverage exists;
• whether monthly Level 1 access is being maintained in line with Home Office recommendations; and
• whether action is required in relation to dormant accounts.

 

This is particularly important where inactivity could leave the sponsor without an active Level 1 User.

The mock audit should not wait until loss of access or Home Office intervention exposes the problem. SMS-user continuity should form part of the sponsor’s ongoing governance arrangements.

 

5. Review Existing Level 2 Users

 

Any remaining Level 2 User accounts require specific attention because the role is being phased out.

From 9 September 2026, sponsors can no longer appoint new Level 2 Users.

Existing Level 2 Users can continue during the transitional period, but the sponsor should determine whether those individuals need to become Level 1 Users and whether they meet the relevant requirements.

Existing Level 2 Users must be converted to Level 1 Users, where eligible, or deactivated by 8 March 2027.

The mock audit should therefore establish:

 

• whether the sponsor currently has any Level 2 Users;
• whether those accounts remain necessary;
• whether the individuals are eligible to become Level 1 Users;
• whether conversion or deactivation has been planned;
• whether responsibilities need to be reassigned; and
• whether the sponsor will retain sufficient Level 1 User capacity after the transition.

 

This is a time-sensitive governance issue for sponsors completing mock audits during the transitional period.

 

6. Reconcile Business Events Against SMS Activity

 

One of the most useful tests is to compare actual business and employment events with the organisation’s sponsorship reporting history.

Rather than starting with the SMS and asking what has been reported, the auditor should also work in the opposite direction.

Select relevant events from HR, payroll, corporate and operational records and ask:

Was sponsorship considered when this happened?

For sponsored workers, events could include changes affecting employment, duties, salary, working hours, normal work location or cessation of employment.

At organisational level, they could include changes to key personnel, addresses, ownership or corporate arrangements.

For each sampled event, the audit should establish:

Event → Sponsorship implication → Action required → Action taken → Evidence.

This methodology can reveal failures that would not be apparent from reviewing the SMS alone.

A reporting history can look orderly because it only shows the events that reached the sponsorship team. The greater risk may lie in events elsewhere in the organisation that were never identified as relevant to sponsorship.

 

7. Review Reporting Timescales

 

Where an event is identified as reportable, the audit should test whether the organisation was capable of acting within the applicable Home Office reporting period.

As a general framework, many changes relating to sponsored workers must be reported within 10 working days, while many relevant changes affecting the sponsoring organisation must be reported within 20 working days. Specific requirements and exceptions apply, so the applicable sponsor guidance should be checked for the event under review.

The audit should record:

Event date → Date identified internally → Date escalated → Reporting requirement → Reporting deadline → Date reported → Evidence.

This can identify situations where the Level 1 User acts promptly after receiving information but the organisation’s internal escalation process causes the report to be late.

Where this pattern occurs, remediation should address the information flow rather than treating the problem solely as an SMS-user failure.

 

8. Review Certificate of Sponsorship Activity

 

The mock audit should review the organisation’s use of Certificates of Sponsorship.

The precise scope will depend on the sponsor’s activities, but the exercise should look for consistency between sponsorship records and the employment that followed.

This can involve sampling CoS assignments and comparing the information recorded against recruitment, HR, contractual and payroll evidence.

Relevant tests can include:

 

• whether the worker identified on the CoS corresponds with the employment records;
• whether the sponsored role corresponds with the worker’s actual duties;
• whether salary information corresponds with contractual and payroll evidence;
• whether working hours remain consistent where relevant;
• whether the normal work location remains accurate;
• whether subsequent material changes were identified; and
• whether appropriate sponsor action was considered following those changes.

 

Where discrepancies exist, the auditor should investigate rather than assume that the original CoS information continues to reflect the worker’s current circumstances.

The objective is to determine whether sponsorship information is supported by the underlying employment evidence and whether subsequent changes have been dealt with appropriately.

 

9. Test the SMS Audit Trail and Governance

 

The mock audit should consider whether significant sponsorship decisions can be understood from the available records.

This does not require the organisation to create unnecessary bureaucracy around every routine SMS action.

However, where a significant or unusual issue has arisen, the sponsor should be able to establish what happened, who considered it, what action was taken and what evidence supports the position.

The audit can therefore examine:

 

• who identified the issue;
• who assessed its sponsorship implications;
• whether the Authorising Officer or other senior personnel were involved where appropriate;
• what SMS action was taken;
• when the action occurred;
• what supporting evidence was retained; and
• whether the underlying control subsequently changed.

 

This helps establish whether sponsorship decisions are being made through a controlled governance process rather than through undocumented individual judgement.

 

 

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Section F: Sponsored Worker File Audit

 

The sponsored worker file review is where the mock audit moves from organisational controls to individual evidence.

Each sampled file should be capable of demonstrating a coherent history of the worker’s sponsorship and employment.

The review should not be confined to a single HR folder. Relevant evidence may be distributed across recruitment systems, personnel files, payroll platforms, attendance systems, right to work records, management records and the SMS.

The auditor should therefore reconstruct the worker’s position using all relevant sources and compare them for consistency.

 

1. Identity, Immigration Status and Right to Work Evidence

 

The audit should establish whether the organisation holds the required evidence relating to the worker’s identity, immigration status and right to work.

The right to work element should be tested against the requirements applicable to the individual rather than simply checking that a document, screenshot or electronic record exists.

Where a worker has time-limited permission, the audit should establish whether any required follow-up activity has been identified and controlled.

The review should also take account of the right to work regime in force at the time of the audit. From 1 October 2026, the statutory right to work framework extends beyond conventional employees to specified wider working arrangements, including certain workers, individual subcontractors and specified online matching-service arrangements.

For sponsored workers, the sponsor should in any event ensure that the required right to work checking arrangements have been followed in accordance with the applicable sponsor and right to work guidance.

Any broader weaknesses identified in right to work procedures should be addressed through the organisation’s wider right to work compliance framework rather than allowing the mock sponsor audit to become a substitute for a full right to work audit.

 

2. Check Date-of-Entry Evidence Where Required

 

Appendix D can require sponsors to retain evidence relating to a sponsored worker’s date of entry to the UK where the worker’s current immigration permission derives from entry clearance sponsored by that employer.

The mock audit should therefore identify cases where this requirement applies and test whether appropriate evidence has been retained.

This should be incorporated into the worker-file review rather than assumed to be covered automatically by the right to work record.

The precise evidence required should be assessed against the current version of Appendix D and the worker’s circumstances.

 

3. Contact Details and Contact History

 

Sponsors are required to maintain specified contact information relating to sponsored workers.

The audit should test not only whether the employer holds the worker’s current details but whether the required history of contact information has been retained.

This can include the worker’s UK residential address, personal email address and telephone number in accordance with the applicable sponsor record-keeping requirements.

The information should be kept up to date.

The audit should also test the mechanism through which changes are captured.

If the organisation’s policy requires employees to notify HR when they change address, the auditor should consider whether workers know about the process, whether updates actually reach the appropriate system and whether different HR platforms contain consistent information.

The practical test is therefore:

Can the sponsor demonstrate both the worker’s current contact information and the required history of changes?

 

4. Recruitment and Role Evidence

 

The file review should consider the evidence supporting the sponsored role and how the worker was recruited.

This may include:

 

• recruitment records;
• application or selection information;
• the job description;
• employment contract;
• offer documentation;
• organisational information; and
• other evidence demonstrating the nature of the position and recruitment process.

 

Sponsors should not assume that recruitment evidence is relevant only where a formal advertising requirement applied.

The mock audit should establish how the sponsored worker was recruited and then determine what evidence should be retained under the applicable Appendix D requirements.

The audit should also compare the documentary evidence with the worker’s actual role.

Job titles alone should not be relied upon where the substantive duties tell a different story.

Where responsibilities have evolved, the employer should be able to establish what changed, when it changed and whether the sponsorship implications were considered.

 

5. Salary, Payslips and Payment Evidence

 

Salary should be tested using actual payroll and payment evidence rather than relying solely on the employment contract or Certificate of Sponsorship.

A useful reconciliation is:

Certificate of Sponsorship → Contract → Payslip → Actual salary payment evidence.

The audit should compare the relevant sponsorship information against what the worker has actually been paid.

Any discrepancy should be investigated.

The explanation may be straightforward, or it may raise a more significant sponsorship issue. The purpose of the mock audit is to identify the discrepancy and determine its cause rather than assuming that differences are either harmless or automatically non-compliant.

Where remuneration arrangements are complex, the review should distinguish between different elements of pay and assess them against the applicable sponsorship requirements.

 

6. Working Hours

 

Where working hours are relevant to the sponsored employment and applicable immigration requirements, the audit should compare the information recorded for sponsorship purposes with contractual and actual working arrangements.

Changes in working patterns should be examined where they could affect the basis on which the worker is sponsored.

Particular attention may be required where a worker has moved between full-time and part-time arrangements or experienced another material change in hours.

The audit should compare:

Sponsored position → Contractual hours → HR/payroll records → Actual working arrangements.

Where a material change is identified, the employer should establish whether its sponsorship implications were assessed at the relevant time.

 

7. Work Location, Hybrid and Remote Working

 

Work location should be tested carefully, particularly for organisations operating across several premises or using remote, hybrid and client-site working arrangements.

The auditor should establish where sampled workers actually perform their duties and compare this with the organisation’s sponsorship and HR records.

Current sponsor guidance distinguishes between different types of change.

A change in a sponsored worker’s normal work location can trigger a reporting requirement. This can include relevant changes to the main office or client site at which the worker performs their duties.

A move to a hybrid working pattern does not, by itself, generally require an SMS report simply because the worker divides their time between home and an office. However, relevant changes to the worker’s main office location or a new client site may still need to be reported, and the sponsor should retain appropriate records of the worker’s working pattern.

Where a worker is contractually based wholly or essentially at home, the applicable reporting requirements should also be considered.

Ordinary day-to-day variations in where a worker happens to perform their duties should not be confused with a change to the worker’s normal working arrangements.

The mock audit should therefore establish the substance of the arrangement and whether relevant changes were identified and assessed.

 

8. Absence and Attendance Records

 

The audit should test whether the organisation can monitor attendance and absence in accordance with its sponsor responsibilities.

This can involve reviewing the systems through which absence is recorded, how unexplained or unauthorised absence is escalated and whether responsibility is clear between line managers and HR.

Current sponsor guidance includes specific reporting requirements in relation to unauthorised absence. In particular, where a sponsored worker is absent from work without permission for more than 10 consecutive working days, the applicable reporting requirement and deadline should be considered.

Separate sponsor requirements also apply where unpaid or reduced-pay absence exceeds four weeks in total in a calendar year, or during the sponsor’s period of sponsorship responsibility for a Scale-up Worker. The four weeks may be cumulative and should be assessed against the worker’s normal working pattern. Where a permitted exception applies, the absence must still be reported through the SMS; where no exception applies, sponsorship will normally need to stop.

The mock audit should therefore distinguish between different types of absence rather than treating every period away from work in the same way.

A useful test is to select actual absence events from the records and follow them through the organisation’s process.

Ask:

 

• Was the absence recorded?
• Was it authorised or unauthorised?
• Did the manager take the required internal action?
• Was HR informed?
• Was a sponsorship assessment required?
• Was any applicable reporting deadline identified?
• Was the required action taken?
• Is the outcome evidenced?

 

This approach tests the control itself rather than merely confirming that an absence policy exists.

 

9. Changes During Sponsorship

 

The auditor should review whether significant changes affecting sampled sponsored workers were identified and assessed when they occurred.

Potential examples include changes to:

 

• duties;
• job title;
• occupation classification;
• salary;
• working hours;
• normal work location;
• reporting line;
• employment status; or
• other material working arrangements.

 

The existence of a change does not by itself establish a sponsor breach.

The audit should determine what changed, whether the change engaged a sponsor obligation and what action the organisation took.

For role changes, the sponsor should also consider whether the change could be dealt with within the existing sponsorship arrangements or whether the nature of the change required a new Certificate of Sponsorship and change of employment application.

This is particularly important for longer-serving sponsored workers, since the cumulative effect of workplace changes can result in their current employment looking materially different from the position originally recorded.

 

10. Sponsored Worker File Audit Matrix

 

A structured worker-level matrix can help ensure that the same core questions are tested across the sample while allowing additional investigation where individual circumstances require it.

 

Audit Area	Evidence to Test	Core Audit Question
Immigration status	Status and right to work records	Can the sponsor evidence the worker’s continuing right to work and relevant immigration status?
Date of entry	Applicable Appendix D entry evidence	Where required, can the sponsor evidence when the worker entered the UK under the sponsored entry clearance?
Contact information	HR and personnel records	Are required current details and the relevant history of changes retained?
Certificate of Sponsorship	CoS and SMS information	Does sponsorship information correspond with the worker’s employment?
Recruitment	Recruitment and selection records	Can the sponsor demonstrate how the worker was recruited and retain the applicable evidence?
Job role	Job description, contract, manager and worker interview	Is the worker performing the role for which they are sponsored?
Duties	CoS information, job description and actual working practices	Do substantive duties remain consistent with the sponsored role?
Salary	CoS, contract, payslips and payment evidence	Does actual pay correspond with the relevant sponsorship position?
Working hours	CoS, contract and working records	Are recorded and actual arrangements consistent?
Work location	Sponsor records, HR records and worker interview	Does the sponsor accurately understand the worker’s normal working arrangements?
Attendance	Absence and attendance records	Can the sponsor demonstrate effective monitoring and escalation?
Employment changes	HR records and SMS/reporting history	Were relevant changes identified, assessed and acted upon?
Record keeping	Personnel and sponsor records	Is required evidence retained for the applicable period and readily retrievable?
Reporting	SMS history and underlying business events	Were reportable events recognised and dealt with within the applicable timeframe?

 

The matrix should be treated as a starting point rather than a substitute for judgement.

A strong mock audit follows the evidence. If one discrepancy raises further questions, the auditor should expand the review until the organisation understands what happened and whether the issue is isolated or systemic.

The most useful output is therefore not a percentage of boxes marked as compliant.

It is a clear understanding of where the evidence, systems and reality diverge, why the divergence occurred and what needs to change to prevent it happening again.

 

 

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Section G: Audit Right to Work Compliance

 

Right to work compliance should form part of a mock sponsor licence audit because the Home Office can examine whether the sponsor is meeting its obligations to prevent illegal working as part of wider compliance activity.

The review should not necessarily be limited to sponsored workers. Depending on the scope of the exercise, sampling workers outside the sponsored population can help establish whether the organisation’s wider right to work controls are operating effectively.

The purpose of this part of the mock audit is not to duplicate a comprehensive right to work audit. It is to establish whether weaknesses in the organisation’s right to work processes could create sponsor compliance or illegal working risk.

 

1. Test the Right to Work Checking Process

 

The audit should examine the process through which right to work checks are conducted rather than simply confirm that evidence exists on personnel files.

Depending on the workforce and the methods of checking used, the review should consider:

 

• who is responsible for conducting right to work checks;
• when checks are carried out;
• whether the appropriate checking method is being used;
• whether evidence of the check is retained correctly;
• whether the organisation distinguishes between workers with permanent and time-limited permission;
• whether required follow-up checks are identified and completed;
• how expiry dates and follow-up actions are monitored;
• how cases of uncertainty are escalated; and
• whether relevant personnel understand the organisation’s right to work procedure.

 

The audit should test actual worker records against the process described by HR.

If the organisation states that every check is completed before employment begins, for example, the auditor should sample records to establish whether this happens in practice.

 

2. Account for the Current Right to Work Regime

 

The audit should apply the right to work requirements in force at the time the review is conducted.

From 1 October 2026, the statutory right to work framework extends beyond conventional employees to specified wider working arrangements, including certain workers, individual subcontractors and specified online matching-service arrangements.

Organisations using non-standard working arrangements should therefore ensure that the scope of their right to work controls reflects the current legal framework rather than assuming that checks are relevant only to individuals employed under conventional contracts of employment.

For sponsored workers, the sponsor should also ensure that the required right to work checking arrangements have been followed in accordance with the applicable sponsor guidance.

 

3. Test Follow-Up Controls for Time-Limited Permission

 

Where an individual’s right to work is time-limited, the mock audit should examine whether the organisation has a functioning system for identifying and completing any required follow-up activity.

The audit should not rely solely on calendar reminders or expiry-date fields.

It should test whether:

 

• relevant expiry or follow-up dates are recorded accurately;
• responsibility for follow-up action is clear;
• reminders are generated sufficiently in advance;
• cases are escalated where updated evidence is not available;
• the appropriate checking process is used; and
• evidence of the subsequent check is retained.

 

Where weaknesses are identified, the employer should consider whether they affect other workers with time-limited permission rather than correcting only the sampled file.

 

4. Investigate Missing or Inconsistent Right to Work Evidence

 

Missing, incomplete or inconsistent right to work evidence should be investigated carefully.

The organisation should establish what check was actually undertaken, when it occurred and what evidence exists.

Historic records should not be altered or recreated in a way that inaccurately suggests that a compliant check took place at an earlier date.

Where the available evidence does not establish the historic position, the organisation should preserve an accurate record of what has been identified and assess what action is appropriate now.

Detailed questions concerning the prescribed right to work checking methods, statutory excuse and civil penalty regime should be addressed through the employer’s dedicated right to work compliance framework.

 

 

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Section H: Audit Sponsor Record-Keeping Duties

 

Record keeping is a core sponsor duty and should be tested against the version of the Home Office sponsor guidance and Appendix D in force at the time of the audit.

The practical question is not simply whether the organisation believes that required documents exist.

The mock audit should establish whether the sponsor can actually locate, retrieve and produce the required evidence for the sponsored workers selected for review.

 

1. Test Records Worker by Worker

 

Record keeping should be tested at individual worker level.

Relevant evidence may be held across several systems, including:

 

• recruitment platforms;
• personnel files;
• right to work records;
• payroll systems;
• attendance systems;
• management records;
• document-management systems; and
• sponsorship records.

 

The audit should determine whether the combined evidence satisfies the applicable requirements rather than assuming that all sponsor records must necessarily sit within a single HR folder.

The central test is whether the organisation can reliably produce the evidence required for the worker when it is needed.

 

2. Test Appendix D Requirements

 

The audit should use the current version of Appendix D to identify the records required for the sponsored workers and routes within scope.

Depending on the circumstances, the review can include evidence relating to:

 

• right to work;
• date of entry to the UK where required;
• recruitment;
• employment or engagement;
• job role and duties;
• salary and payslips;
• evidence of salary payments;
• working arrangements;
• contact information and the required history of changes;
• absence;
• relevant professional registration or accreditation; and
• other route-specific evidence.

 

The required evidence depends on the worker’s circumstances and the applicable sponsorship route. A generic document checklist should therefore not replace assessment against the current Appendix D requirements.

 

3. Test Recruitment Records

 

The mock audit should establish whether the sponsor can demonstrate how sampled sponsored workers were recruited and whether the applicable recruitment evidence has been retained.

This should not be approached on the assumption that recruitment records matter only where a formal advertising requirement applied.

The auditor should establish the recruitment circumstances and then test the evidence required under Appendix D.

Where recruitment occurred through an agency, referral, direct application, internal process or another method, the available evidence should provide a coherent account of how the worker came to be recruited into the sponsored role.

 

4. Test Payroll and Salary-Payment Evidence

 

For relevant sponsored workers, the audit should test payroll records and evidence of salary payments.

A useful evidence chain is:

Certificate of Sponsorship → Employment contract → Payslip → Salary payment evidence.

This helps establish whether the remuneration stated for sponsorship purposes corresponds with what the worker has actually received.

Where relevant allowances or other remuneration elements are relied upon, the audit should identify and test the supporting evidence required under the applicable sponsor rules.

Any discrepancy should be investigated and its sponsorship implications assessed.

 

5. Test Contact Information and Historical Records

 

The audit should not merely confirm that the organisation holds the worker’s current contact information.

Appendix D requires sponsors to retain specified contact details and a history of relevant changes.

The audit should therefore test whether the organisation can demonstrate the required history of the worker’s UK residential address, personal email address and telephone number, as applicable.

This can expose weaknesses where an HR system overwrites previous information whenever a worker updates their details.

If historic data is required but the system retains only the latest entry, the organisation may need to reconsider how the required information is preserved.

 

6. Test Whether Records Can Be Retrieved

 

A record that exists but cannot be found reliably can still create significant practical difficulty during Home Office scrutiny.

The mock audit should therefore test retrieval.

The auditor can request selected records without giving HR advance notice of the exact files that will be sampled and record whether the relevant evidence can be produced efficiently.

This can expose problems such as:

 

• documents held in personal email accounts;
• records stored by individual managers;
• inconsistent naming conventions;
• evidence split across systems without clear ownership;
• documents retained only at local sites;
• historic records becoming inaccessible after system changes; and
• uncertainty over which version of a document is authoritative.

 

The purpose is not to require every record to be stored in one location. It is to ensure that the organisation has a reliable system for producing required evidence.

 

7. Test Record Retention

 

The audit should also consider whether sponsor records are retained for the applicable period.

Under the current Appendix D framework, unless a specific requirement provides otherwise, documents relating to a sponsored worker generally need to be retained throughout the period of sponsorship and until the earlier of:

 

• one year after the sponsorship ends; or
• the date on which a Home Office compliance officer has examined and approved the relevant documents.

 

Documents submitted in support of the sponsor licence application generally need to be retained for as long as the organisation holds the sponsor licence.

Other legal, regulatory, tax, employment or organisational requirements may require records to be retained for longer.

The mock audit should therefore test whether the organisation’s document-retention policy reflects the applicable sponsorship requirements without assuming that every category of record is subject to an identical retention period.

 

 

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Section I: Audit Sponsor Reporting Duties

 

Reporting is one of the areas where a sponsor can appear to have an effective process while significant weaknesses remain underneath.

The problem is often not that the Level 1 User does not know how to submit a report through the SMS.

The problem is that the event requiring consideration never reaches the Level 1 User.

A meaningful mock audit should therefore test the entire reporting chain:

Business event → Identification → Internal escalation → Sponsorship assessment → Reporting decision → SMS action → Evidence.

 

1. Start With Events, Not the SMS

 

The audit should select actual events from HR, payroll, management and corporate records and then determine how they were dealt with for sponsorship purposes.

For sponsored workers, events selected for testing can include changes involving:

 

• job title;
• duties;
• salary;
• working hours;
• normal work location;
• remote or hybrid arrangements;
• absence;
• employment arrangements; and
• cessation of employment.

 

At organisational level, the sample can include:

 

• changes to key personnel;
• changes of address;
• new or closed locations;
• changes in ownership or control;
• changes to corporate structure;
• mergers or acquisitions; and
• other significant operational changes.

 

The auditor should then determine whether the event was identified, whether its sponsorship implications were considered and whether any required action was taken.

 

2. Test Reporting Timescales

 

Where an event was reportable, the mock audit should establish whether it was reported within the applicable timeframe.

As a general framework, many reportable changes relating to sponsored workers must be reported within 10 working days, while many reportable organisational changes must be reported within 20 working days.

Specific rules and exceptions apply, so the precise obligation should always be checked against the current sponsor guidance.

For each sampled event, the auditor can record:

Event date → Date identified → Date escalated → Reporting requirement → Deadline → Date reported → Supporting evidence.

This makes it possible to distinguish between an SMS administration problem and an internal escalation problem.

If HR receives the information after the applicable deadline has already passed, the control failure occurred earlier in the organisation.

 

3. Test Unauthorised Absence Reporting

 

Absence reporting should be tested using actual cases rather than simply reviewing the organisation’s absence policy.

Current sponsor guidance requires sponsors to report where a sponsored worker has been absent from work without permission for more than 10 consecutive working days. The applicable report must be made within the required Home Office timeframe following the tenth working day of absence.

The audit should therefore test whether:

 

• unauthorised absence can be distinguished from authorised absence;
• consecutive working days can be identified correctly;
• line managers understand when absence must be escalated;
• HR receives the information promptly;
• the sponsorship team assesses the event; and
• any required report is submitted within the applicable timeframe.

 

The audit should separately consider periods of unpaid or reduced-pay absence because specific sponsorship rules apply where these exceed four weeks in total in a calendar year, or during the sponsor’s period of sponsorship responsibility for a Scale-up Worker. The audit should test cumulative periods, normal working pattern, permitted exceptions, any required SMS reporting and whether sponsorship should have stopped.

Different types of absence should therefore not be treated as though they engage identical sponsor requirements.

 

4. Test Salary Changes

 

The audit should identify salary changes through payroll and HR records and assess whether their sponsorship implications were considered.

Care is required because not every salary change has the same reporting consequence.

A reduction in a sponsored worker’s salary or pay from the amount stated on the Certificate of Sponsorship must be reported through the SMS where the reduction is for a reason not related to absence. The sponsor must also assess whether the revised salary remains permissible under the applicable immigration requirements.

By contrast, an ordinary salary increase does not generally require an SMS report merely because the worker’s pay has increased. A relevant increase must, however, be reported where the sponsor has been sponsoring a pre-registration nurse or midwife who completes registration, in accordance with the applicable Skilled Worker sponsor guidance.

The audit should therefore avoid a simplistic test asking whether “all salary changes were reported”.

Instead, it should ask:

Was the salary change identified, were its sponsorship implications assessed, and was the correct action taken?

Where salary changes can be implemented directly through payroll without involvement from the sponsorship team, the mock audit should consider whether an additional control is needed.

 

5. Test Job Role and Duty Changes

 

Changes to a sponsored worker’s role should be tested carefully because the appropriate immigration response depends on the nature of the change.

The audit should identify changes in:

 

• job title;
• core duties;
• seniority;
• occupation classification;
• responsibilities; and
• other material aspects of the sponsored role.

 

The employer should then determine whether the change could be dealt with within the worker’s existing sponsorship arrangements, whether an SMS report was required or whether the change was sufficiently significant to require a new Certificate of Sponsorship and a change of employment application.

The audit should not assume that updating an internal job description or making an SMS report is sufficient for every change of role.

The relevant immigration requirements should be considered before material changes are implemented where necessary.

 

6. Test Work-Location Reporting

 

The audit should compare actual work locations with sponsorship records and test whether relevant changes were identified.

A change in the worker’s normal work location can trigger a reporting requirement.

The review should therefore consider changes involving main offices, other business premises and client sites where relevant.

Hybrid working should be treated carefully. Moving to a hybrid working pattern does not, by itself, generally require an SMS report simply because the worker works partly from home. However, relevant changes to the worker’s main office or client-site location can still require reporting.

Where a worker is contractually based wholly or essentially at home, the applicable sponsor reporting requirements should also be considered.

Ordinary day-to-day variation should be distinguished from a substantive change in the worker’s normal working arrangements.

 

7. Review Decisions Not to Report

 

Where appropriate, the audit should examine significant events that the organisation considered but decided did not require an SMS report.

The purpose is not to create unnecessary written legal analysis for every routine employment event.

However, where a material or unusual change occurred and the organisation consciously concluded that no report was required, it can be useful to establish whether that decision was based on an accurate understanding of the sponsor requirements.

This can be particularly important for changes involving roles, salary, work location, corporate structure or other matters capable of engaging different sponsorship rules depending on the facts.

 

8. Investigate Historic Reporting Failures Carefully

 

Where the mock audit identifies a potentially late or missed report, the first step should be to establish the facts.

The employer should identify:

 

• what happened;
• when it happened;
• when the organisation became aware of it;
• whether a reporting obligation applied;
• what action, if any, was taken;
• why the normal process failed; and
• whether similar events may have been affected.

 

The organisation should not attempt to disguise a historic failure by backdating records or creating misleading evidence.

Where corrective action is available, it should be taken on an accurate factual basis and in accordance with the applicable sponsor requirements.

Potentially material historic failures may require specialist advice on the appropriate response.

 

9. Look for Patterns and Root Causes

 

The most important reporting finding may not be the individual missed event.

It may be the reason the event was missed.

Examples of systemic causes can include:

 

• line managers not understanding escalation responsibilities;
• HR systems not identifying sponsored workers;
• payroll changes being implemented without sponsorship review;
• location changes being managed locally without HR involvement;
• unclear responsibility between HR and SMS users;
• overreliance on one Level 1 User;
• inadequate handover following personnel changes; and
• business changes occurring without immigration compliance input.

 

Where a pattern exists, remediation should address the underlying control failure rather than correcting only the events found within the audit sample.

This distinction is central to effective mock auditing:

Correcting an SMS record can resolve an individual administrative issue. Correcting the process that caused the issue helps prevent recurrence.

 

 

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Section J: Audit Salary, Payroll and Certificate of Sponsorship Information

 

Salary and payroll testing should form a central part of a mock sponsor licence audit because the information recorded for sponsorship purposes should correspond with the worker’s actual employment and remuneration.

The audit should not rely solely on the salary stated in the employment contract or Certificate of Sponsorship. It should test what the worker has actually been paid and investigate material differences between sponsorship information, contractual arrangements and payroll evidence.

A useful reconciliation is:

Certificate of Sponsorship → Employment contract → Payroll → Payslip → Actual salary payment evidence.

This approach can identify discrepancies that would not necessarily be apparent from reviewing the sponsored worker’s HR file alone.

 

1. Compare Certificate of Sponsorship Salary With Actual Pay

 

For each sampled worker, the audit should compare the salary recorded for sponsorship purposes with the worker’s contractual salary and actual remuneration.

The review should consider, where relevant:

 

• the salary stated on the Certificate of Sponsorship;
• the salary stated in the employment contract;
• the worker’s current salary;
• payslips;
• evidence of salary payments;
• working hours;
• changes in salary during sponsorship;
• periods of reduced pay, including cumulative periods;
• periods of unpaid absence, including cumulative periods; and
• any relevant allowances or other remuneration components.

 

The purpose is not simply to identify whether two figures are different.

Where a discrepancy exists, the auditor should establish why it exists, when it arose, whether it has sponsorship implications and whether any required action was taken.

 

2. Test Salary Changes

 

Salary changes should be assessed according to their nature and the applicable sponsorship requirements.

A reduction in a sponsored worker’s salary or pay from the amount stated on the Certificate of Sponsorship must be reported through the SMS where the reduction is for a reason not related to absence. Absence-related reductions should be assessed under the separate unpaid or reduced-pay absence rules.

An ordinary salary increase, by contrast, does not generally require an SMS report simply because the worker’s pay has increased. A relevant increase must, however, be reported where the sponsor has been sponsoring a pre-registration nurse or midwife who completes registration.

The audit should therefore avoid treating every salary variation as though it has the same reporting consequence.

The appropriate test is:

Was the salary change identified → were its sponsorship implications assessed → was the correct action taken → can that action be evidenced?

 

3. Test Payroll-to-Sponsorship Escalation

 

One of the most important controls is the relationship between payroll, HR and the sponsorship function.

In some organisations, payroll personnel can implement changes without knowing that the affected employee is sponsored. In others, managers may agree salary or working-hours changes before HR becomes involved.

The mock audit should establish whether relevant changes can occur without sponsorship implications being considered.

Questions can include:

 

• Can payroll identify sponsored workers?
• Does payroll know which changes need to be escalated?
• Can managers authorise salary changes without HR involvement?
• Does HR review salary changes affecting sponsored workers?
• Who determines whether a change needs to be reported?
• Is sponsorship considered before a potentially material change takes effect?
• How are periods of unpaid or reduced-pay absence identified?
• Is evidence of the assessment retained where appropriate?

 

If the sponsorship team learns about a salary reduction only after payroll has implemented it, the problem may lie in the organisation’s control framework rather than with the individual Level 1 User.

 

4. Compare Salary With Working Hours

 

Salary should not necessarily be reviewed in isolation from working hours.

Where the worker’s hours have changed, the audit should consider whether the remuneration and sponsorship position remain consistent with the applicable requirements.

The review should compare:

Sponsored hours → Contractual hours → Current working arrangements → Current remuneration.

This can be particularly important where an employee has moved to part-time working, experienced a significant change in hours or entered another working arrangement that differs from the position on which sponsorship was originally based.

The auditor should establish when the change occurred and whether its immigration and sponsorship implications were considered before or at the time of implementation.

 

5. Compare the Sponsored Role With Actual Duties

 

Salary testing should also be considered alongside the worker’s actual role.

A worker may continue to receive the salary recorded for sponsorship purposes while their duties have changed materially.

The mock audit should therefore compare:

 

• the sponsored job title;
• the relevant occupation classification;
• the duties described when the worker was sponsored;
• the current job description;
• the manager’s description of the role; and
• the worker’s description of their day-to-day duties.

 

Where the role has changed, the sponsor should establish whether the change could be accommodated within the existing sponsorship arrangements, whether sponsor reporting was required or whether the worker required a new Certificate of Sponsorship and change of employment application.

An SMS report should not be treated as a substitute for a change of employment application where the immigration rules require the latter.

 

6. Investigate Salary and Payroll Discrepancies

 

A payroll discrepancy should be investigated rather than immediately classified as a sponsor breach.

The audit should establish:

 

• what the worker should have been paid;
• what the worker was actually paid;
• when the difference arose;
• why it arose;
• whether it was temporary or continuing;
• whether working hours or absence explain the difference;
• whether the change was authorised;
• whether sponsor reporting or other immigration action was required; and
• whether similar discrepancies could affect other sponsored workers.

 

This allows the organisation to distinguish an isolated payroll error from a wider sponsorship issue.

Where the discrepancy may affect the worker’s immigration position or the sponsor’s compliance with salary requirements, the organisation should assess the position against the rules applicable to that worker and obtain specialist advice where necessary.

 

 

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Section K: Mock Interviews: Who Should Be Tested?

 

Interviews are an important part of a realistic mock sponsor licence audit because documents cannot demonstrate whether the people responsible for sponsorship understand the systems they are expected to operate.

Interviews can also expose differences between formal records and employment reality.

The purpose is diagnostic. It is not to coach individuals to reproduce identical answers or prepare scripts for a future Home Office compliance visit.

The people interviewed should reflect the organisation’s sponsorship structure and can include the Authorising Officer, Level 1 Users, relevant HR personnel, payroll personnel, line managers and sponsored workers.

 

1. Authorising Officer Interview

 

The Authorising Officer should be tested primarily on sponsor governance and oversight rather than detailed day-to-day SMS administration where those functions are performed by others.

Questions can explore:

 

• the organisation’s sponsored worker population;
• the routes under which workers are sponsored;
• who manages the sponsor licence operationally;
• who has SMS access;
• how SMS-user activity is overseen;
• how Certificates of Sponsorship are controlled;
• how potential sponsor compliance problems are escalated;
• how the Authorising Officer is informed of significant issues;
• how compliance responsibilities are allocated;
• what happens if key sponsorship personnel are absent;
• whether previous audit findings have been remediated; and
• how the organisation obtains assurance that its sponsor duties are being met.

 

The sponsor should have a system for checking the activities of SMS users. Current Home Office guidance also recommends that the Authorising Officer checks Certificates of Sponsorship assigned to workers at least monthly.

The interview can therefore test how this oversight operates in practice.

The Authorising Officer does not necessarily need to carry out every sponsorship task personally. The relevant question is whether there is genuine oversight rather than nominal appointment.

 

2. Level 1 User Interview

 

Level 1 Users should be tested on the sponsorship functions they actually perform and the process through which relevant information reaches them.

Questions can include:

 

• what SMS activities they undertake;
• how they learn about new sponsored workers;
• how they are informed of role changes;
• how salary or working-hours changes reach them;
• how changes of work location are communicated;
• how they become aware of unauthorised absence;
• how they are informed when a sponsored worker leaves;
• how organisational changes are escalated;
• how reporting deadlines are monitored;
• what happens where they are uncertain whether an event is reportable;
• how SMS activity is reviewed by the Authorising Officer; and
• what cover exists during absence.

 

The interview should distinguish between knowledge of how to operate the SMS and the effectiveness of the wider compliance process.

A Level 1 User may understand the SMS perfectly but still be unable to report events correctly if relevant information does not reach them.

 

3. Existing Level 2 Users During the Transitional Period

 

Where the sponsor still has existing Level 2 Users during the 2026–2027 transitional period, their position should be reviewed as part of the audit.

No new Level 2 Users can be appointed from 9 September 2026. Existing Level 2 Users must be converted to Level 1 Users, where eligible, or deactivated by 8 March 2027.

The audit should establish:

 

• what activities the existing Level 2 User currently performs;
• whether those activities remain necessary;
• whether the individual is eligible to become a Level 1 User;
• who will assume their responsibilities if the account is deactivated;
• whether the transition has been scheduled; and
• whether the organisation will retain sufficient SMS-user capacity after the change.

 

This should be treated as a transitional audit issue rather than an enduring sponsor governance model.

 

4. HR Interview

 

HR personnel should be tested on how sponsorship requirements interact with normal employment administration.

Questions can cover:

 

• how sponsored workers are identified within HR systems;
• who conducts right to work checks;
• how time-limited immigration permission is monitored;
• how changes to worker contact details are recorded;
• how the required history of contact information is retained;
• how job changes are identified;
• how salary and working-hours changes are escalated;
• how changes of work location are dealt with;
• how absence is monitored;
• how unauthorised absence is escalated;
• how leavers are communicated to the sponsorship team;
• where sponsor records are retained; and
• who is responsible where HR is uncertain about the immigration implications of a change.

 

The auditor should compare these answers with the procedures described by the Level 1 User and Authorising Officer.

If each person describes a different process, the inconsistency may indicate that the organisation lacks a reliable control.

 

5. Payroll Interview

 

Where payroll is managed separately from HR or the sponsorship team, payroll personnel should be included where appropriate.

The interview can establish:

 

• whether payroll can identify sponsored workers;
• how salary changes are authorised;
• whether reductions in pay are escalated;
• how changes in working hours reach payroll;
• how cumulative unpaid or reduced-pay absence is recorded and monitored against the applicable four-week threshold;
• whether payroll changes can occur without HR review;
• how payroll discrepancies are corrected; and
• what evidence of salary payments can be produced.

 

This can expose a significant control gap where payroll operates correctly from an accounting perspective but changes are implemented without consideration of their sponsorship implications.

 

6. Line Manager Interviews

 

Line managers can be critical to sponsor compliance because they are often the first people to know when a sponsored worker’s circumstances change.

Managers do not generally need detailed knowledge of the Sponsor Management System or immigration rules.

They should, however, understand what information needs to be escalated internally.

Questions can test whether managers know what to do when a sponsored worker:

 

• changes duties;
• moves into a different role;
• changes working hours;
• changes normal work location;
• starts working at a different client site;
• has an extended or unauthorised absence;
• requests a change affecting pay;
• stops attending work; or
• leaves employment.

 

The auditor should compare the manager’s understanding with the process HR believes is operating.

If HR says managers are responsible for notifying it of changes but managers are unaware of that responsibility, the mock audit has identified a system weakness.

 

7. Sponsored Worker Interview Simulation

 

Sponsored worker interviews help establish whether employment reality corresponds with the evidence held by the sponsor.

Questions should be straightforward and relevant to the individual’s employment.

They can include:

 

• What is your job title?
• What do you do on a normal working day?
• Who is your manager?
• Where do you normally work?
• Do you work from home or other locations?
• What hours do you normally work?
• How are you paid?
• Has your role changed since you started?
• Have your duties changed?
• Has your normal work location changed?
• How do you report absence?
• How do you update your address or contact details?

 

The answers should be compared with the Certificate of Sponsorship, employment contract, job description, payroll evidence, work-location information and the manager’s account of the role.

The objective is consistency of substance, not identical wording.

A worker may describe their duties differently from the formal language used in a job description without there being any compliance problem.

Material differences require investigation.

 

8. Avoid Coaching Rehearsed Answers

 

Mock interviews should not be used to train personnel to give predetermined answers to the Home Office.

Identical or obviously rehearsed responses do not demonstrate that the organisation’s compliance systems are functioning.

The value of the interview lies in discovering what people genuinely understand.

If a worker, manager or member of HR gives an incorrect answer, the auditor should ask why they understood the process in that way.

The answer may expose:

 

• unclear policies;
• inadequate training;
• conflicting instructions;
• poor communication between teams;
• an undocumented working practice;
• an employment arrangement that has changed; or
• a difference between formal records and operational reality.

 

Those findings are more valuable than producing a set of polished interview responses.

The aim of mock interview testing is therefore not:

“Can everyone give the right answer?”

It is:

“Do the people, processes, evidence and employment reality tell the same story?”

 

 

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Section L: How Should Mock Sponsor Licence Audit Findings Be Graded?

 

A mock sponsor licence audit should distinguish between findings according to their potential significance. Treating every issue as equally serious makes it difficult for the organisation to prioritise remediation and can obscure the problems requiring immediate attention.

An internal risk-grading methodology can therefore be useful.

However, any categories used by the employer or auditor should be clearly distinguished from Home Office terminology. Categories such as Critical, High, Moderate and Low are an internal audit methodology. They are not official Home Office classifications and should not be presented as predicting how the Home Office would categorise a particular issue or what enforcement action would follow.

The purpose of grading is to help the organisation determine:

 

• which issues require immediate investigation;
• which issues could affect individual sponsored workers;
• which findings indicate wider systemic weaknesses;
• which actions should be prioritised;
• who should take responsibility for remediation; and
• which issues require re-testing after corrective action.

 

1. Critical Findings

 

A Critical internal grading can be reserved for findings that potentially indicate serious or systemic sponsor compliance problems requiring immediate investigation.

Examples could include:

 

• evidence that a sponsored worker’s actual role does not correspond with the occupation code or job description on the Certificate of Sponsorship and the change is not permitted under the sponsor rules;
• a significant unexplained discrepancy between sponsored salary information and actual remuneration;
• an inability to account properly for sponsored workers;
• serious inconsistencies between Certificates of Sponsorship and employment reality;
• potentially serious right to work concerns;
• substantial organisational changes whose sponsorship implications have not been addressed;
• evidence of repeated or systemic failures to comply with sponsor duties; or
• circumstances potentially affecting whether the organisation continues to satisfy relevant sponsor requirements.

 

A Critical classification should not be treated as a conclusion that the Home Office would suspend or revoke the sponsor licence.

It is an internal signal that the issue should be investigated urgently, the facts established and appropriate legal or compliance action considered.

 

2. High-Risk Findings

 

A High internal grading can be used for material compliance weaknesses requiring prompt corrective action but which do not necessarily indicate the same immediate level of concern as a Critical finding.

Examples could include:

 

• repeated failures to escalate potentially reportable events;
• recurring late reporting caused by ineffective internal processes;
• material weaknesses in absence monitoring;
• poor oversight of SMS-user activity;
• recurring deficiencies in sponsored worker records;
• significant gaps in communication between HR, payroll and the sponsorship team;
• inadequate controls around changes to sponsored workers’ roles, salary or work locations; or
• significant weaknesses affecting multiple workers or business locations.

 

The audit report should explain why the finding has been graded as High and what action is required to reduce the risk.

 

3. Moderate Findings

 

A Moderate internal grading can be appropriate where the audit identifies a weakness in compliance controls that should be addressed but which does not currently appear to represent an immediate material threat to the sponsor licence.

Examples can include:

 

• inconsistent document storage;
• unclear internal escalation routes;
• training gaps;
• overreliance on one member of staff;
• inconsistent record-management practices;
• weaknesses in audit trails;
• limited management oversight; or
• processes that operate in practice but are insufficiently controlled.

 

Moderate findings should not simply be left until the next audit. They should be allocated to an owner and addressed within a proportionate timeframe.

 

4. Low-Risk Findings

 

A Low internal grading can be used for administrative or process improvements that do not appear to create material sponsor compliance exposure.

Examples could include:

 

• minor inconsistencies in filing conventions;
• opportunities to improve document organisation;
• non-material procedural inconsistencies;
• minor improvements to internal guidance; or
• additional controls that would improve auditability without correcting an existing material failure.

 

Low-risk findings should still be recorded where they justify action.

A large number of apparently minor findings can also indicate a wider weakness in compliance culture or administration, so the audit should consider the cumulative picture rather than reviewing each issue entirely in isolation.

 

5. Assess the Cause as Well as the Finding

 

Risk grading should not end with describing what went wrong.

The auditor should establish why the problem occurred.

For each material finding, ask:

 

• What happened?
• When did it happen?
• Why did it happen?
• Is the problem isolated?
• Could the same issue affect other sponsored workers?
• Is the issue continuing?
• Which control should have prevented or identified it?
• Why did that control fail?
• What action is required now?
• What change will prevent recurrence?

 

This distinction is important because the immediate finding and its root cause may be different.

For example, a missed SMS report may be the finding, but the underlying cause could be that line managers do not know they need to tell HR when a sponsored worker changes their normal work location.

Correcting the SMS position without correcting the escalation process leaves the underlying risk in place.

 

 

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Section M: What Should a Mock Sponsor Licence Audit Report Contain?

 

The audit report should provide the organisation with a practical record of what was tested, what was found and what needs to happen next.

A report that merely concludes that the sponsor is “compliant”, “mostly compliant” or “requires improvement” provides limited value.

Findings should be specific enough for the organisation to understand the evidence, the relevant sponsor obligation, the potential risk and the action required.

A useful structure is:

Finding → Evidence → Relevant Sponsor Obligation → Risk → Root Cause → Required Action → Owner → Deadline → Re-Test.

 

1. Finding

 

The report should describe precisely what the audit identified.

For example, rather than recording “poor reporting controls”, the report could identify that a sampled change to a sponsored worker’s normal work location was not escalated from the line manager to HR and therefore was not considered by the sponsorship team at the relevant time.

The finding should be factual and avoid conclusions that are not supported by the evidence.

 

2. Evidence

 

The report should identify the evidence supporting the finding.

This can include:

 

• Certificate of Sponsorship information;
• SMS records;
• HR records;
• employment contracts;
• job descriptions;
• payroll records;
• salary payment evidence;
• attendance information;
• emails or internal records;
• management interviews; and
• sponsored worker interviews.

 

Recording the evidence helps distinguish established facts from assumptions and provides a basis for subsequent remediation.

 

3. Relevant Sponsor Obligation

 

The report should identify the sponsor requirement potentially engaged by the finding.

This may relate to reporting, record keeping, right to work, SMS administration, sponsor key personnel, monitoring sponsored workers or another relevant sponsor duty.

Where the position depends on the worker’s immigration route or particular circumstances, the report should avoid presenting a generic rule as universally applicable.

The current sponsor guidance and applicable Immigration Rules should be checked where necessary.

 

4. Risk

 

The report should explain why the finding matters.

The risk may concern:

 

• the sponsor’s compliance with its duties;
• the immigration position of an individual sponsored worker;
• the accuracy of information held by the Home Office;
• the organisation’s ability to evidence compliance;
• a weakness affecting multiple workers;
• the reliability of an internal compliance process; or
• potential Home Office scrutiny or enforcement.

 

The report should avoid presenting a particular enforcement outcome as automatic unless the applicable rules expressly require that outcome.

 

5. Root Cause

 

The root cause explains why the finding arose.

Possible causes can include:

 

• lack of training;
• unclear responsibility;
• poor communication between departments;
• inadequate HR-system controls;
• overreliance on one individual;
• insufficient Authorising Officer oversight;
• failure to update procedures following changes in sponsor requirements;
• local working practices diverging from central policy; or
• a process that was never designed to identify sponsorship implications.

 

Identifying the root cause allows remediation to address the system rather than simply correcting the individual file.

 

6. Required Action

 

The report should specify what the organisation needs to do.

Actions should be sufficiently clear to be implemented and monitored.

Depending on the finding, this could involve:

 

• investigating an individual worker’s position;
• assessing whether SMS action is required;
• obtaining legitimate missing evidence;
• correcting current internal records;
• reviewing payroll arrangements;
• changing an HR process;
• improving manager escalation;
• providing targeted training;
• reviewing SMS-user access;
• dealing with inactive accounts;
• addressing existing Level 2 User accounts during the transitional period;
• strengthening Authorising Officer oversight; or
• obtaining specialist advice.

 

The required action should address both the immediate finding and, where relevant, its underlying cause.

 

7. Owner and Deadline

 

Every material remediation action should have an identified owner.

Without ownership, audit recommendations can remain unresolved even where the organisation accepts that action is required.

The owner may be HR, payroll, a Level 1 User, the Authorising Officer, a line manager, senior management or another relevant function.

The report should also set a proportionate deadline based on the significance and urgency of the finding.

Potentially serious issues may require immediate investigation, while lower-risk process improvements may reasonably be implemented over a longer period.

 

8. Re-Test

 

Where the finding concerns a material control weakness, the report should specify how remediation will be re-tested.

This is particularly important where the corrective action involves changing a process.

For example, if managers were failing to notify HR about changes involving sponsored workers, issuing new guidance to managers does not establish that the revised process works.

A later sample of actual employment changes should be tested to determine whether the relevant information now reaches HR and the sponsorship team correctly.

 

9. Suggested Mock Audit Report Structure

 

Report Field	Purpose
Finding	States clearly what the audit identified.
Evidence	Records the material supporting the finding.
Sponsor obligation	Identifies the relevant compliance requirement.
Risk	Explains why the issue matters.
Root cause	Identifies why the problem arose.
Required action	Specifies the corrective or preventive action required.
Owner	Allocates responsibility for completing the action.
Deadline	Sets the required timeframe for completion.
Re-test	Defines how the organisation will verify that remediation works.

 

 

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Section N: What If a Mock Audit Finds Sponsor Licence Breaches?

 

A mock audit may identify errors, control weaknesses or circumstances suggesting that a sponsor duty has not been met.

The appropriate response is neither to dismiss the issue nor to assume automatically that the sponsor licence will be subject to enforcement action.

The organisation should establish the facts, determine the applicable requirement, assess the significance of the issue and decide what corrective action is appropriate.

 

1. Establish the Facts and Chronology

 

The first step should be to understand exactly what happened.

The organisation should establish:

 

• the event or conduct in question;
• when it occurred;
• which sponsored workers were affected;
• which records or systems are relevant;
• when the organisation became aware of the issue;
• what action was taken at the time;
• whether the issue is continuing; and
• what evidence exists.

 

Reliable factual analysis should come before remediation decisions.

 

2. Determine Whether the Problem Is Isolated or Systemic

 

If the problem is identified through a sample, the organisation should consider whether the same issue could affect other sponsored workers.

For example, one missing contact history may indicate an individual administrative error.

Alternatively, it may reveal that the HR system overwrites previous contact information for every employee, creating a wider record-keeping problem.

Similarly, one missed salary change may be isolated, or it may demonstrate that payroll can alter sponsored workers’ remuneration without notifying HR or the sponsorship team.

Where there is a realistic possibility of wider impact, the audit sample should be expanded.

 

3. Preserve the Historical Record

 

Historic compliance problems should not be concealed by altering the record to make it appear that an action occurred when it did not.

The organisation should not backdate documents, manufacture evidence or create a misleading account of past events.

Where legitimate evidence exists but has not previously been organised appropriately, it can be gathered and retained.

Where a current record is inaccurate, it can be corrected in an appropriate and transparent manner.

The distinction is between legitimate remediation and creating a false historical record.

 

4. Assess Whether Current Sponsor Action Is Required

 

Once the facts are established, the employer should determine whether action is required under the current sponsor rules.

Depending on the issue, this can involve:

 

• taking appropriate SMS action;
• reviewing the worker’s current sponsorship position;
• correcting current internal information;
• obtaining legitimate missing records;
• reviewing right to work evidence;
• considering whether a change of employment application is required;
• addressing salary or working arrangements;
• changing an internal process; or
• obtaining specialist legal advice.

 

Where the position is material or uncertain, the organisation should avoid making assumptions about retrospective corrective action and should assess the issue against the requirements applicable to the worker and sponsor.

 

5. Fix the System as Well as the Individual Case

 

Remediation should address the underlying cause of the breach.

For example, suppose the audit identifies a salary reduction that was not considered by the sponsorship team.

The immediate response may require an assessment of the affected worker’s position and whether any sponsor action is required.

However, if the salary reduction occurred because payroll could make changes without notifying HR, the organisation should also change that process.

A stronger control could require relevant salary changes affecting sponsored workers to be reviewed for sponsorship implications before implementation.

The same principle applies across the audit:

Individual correction + root-cause remediation + re-testing.

 

6. Consider Potential Home Office Consequences in Context

 

Where sponsor non-compliance is established, the potential Home Office response depends on the nature and seriousness of the issue and the applicable sponsor guidance.

Home Office action can include measures such as restrictions affecting sponsorship activity, downgrading, suspension or revocation of the sponsor licence, depending on the circumstances and the relevant provisions. While a licence is suspended, the sponsor cannot assign Certificates of Sponsorship.

Not every administrative error produces the same consequence, and a mock audit should not present a particular enforcement outcome as automatic where the applicable rules do not require it.

The internal Critical, High, Moderate and Low audit gradings used in this methodology should therefore remain separate from Home Office enforcement classifications and decisions.

 

7. Create a Sponsor Compliance Remediation Plan

 

Material findings should be transferred into a structured remediation plan so that corrective actions can be tracked through to completion.

 

Finding	Risk	Required Action	Owner	Deadline	Status	Re-Test
Describe the identified issue	Critical / High / Moderate / Low internal grading	Specify corrective and preventive action	Named responsible person or function	Proportionate completion date	Open / In progress / Complete	Method and date for verification

 

The remediation plan can cover findings involving:

 

• sponsored worker records;
• SMS information;
• right to work controls;
• salary and payroll;
• absence monitoring;
• sponsor reporting;
• key personnel;
• SMS-user access, MFA and inactive accounts;
• legacy Level 2 User arrangements;
• HR systems;
• manager training;
• record keeping; and
• governance and oversight.

 

8. Re-Test After Remediation

 

Remediation should not be treated as complete merely because an action has been marked as finished.

Where the audit identified a control failure, the revised control should be tested.

For example:

 

• if a new absence escalation process has been introduced, test subsequent absence cases;
• if payroll controls have changed, sample subsequent salary changes;
• if managers have received training, test whether later employment changes were escalated correctly;
• if SMS-user arrangements have been revised, verify that access and oversight operate as intended;
• if record-keeping procedures have changed, sample new worker files; and
• if reporting controls have been strengthened, trace later events from occurrence through to any required SMS action.

 

The remediation cycle should therefore be:

Identify → Investigate → Remediate → Implement → Re-Test → Monitor.

This turns the mock sponsor licence audit from a one-off inspection exercise into a mechanism for improving the organisation’s ongoing sponsor compliance framework.

 

 

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Section O: How Long Does a Mock Sponsor Licence Audit Take?

 

There is no standard duration for a mock sponsor licence audit.

The time required depends on the size and complexity of the organisation, the number of sponsored workers, the scope of the review and what the audit discovers.

A relatively straightforward sponsor with a small sponsored workforce, centralised HR systems and limited organisational change may require a more focused exercise. A large employer operating across multiple sites, sponsoring workers under different routes or using complex HR and payroll systems may require considerably more extensive testing.

The effectiveness of the audit should therefore not be judged by how quickly it can be completed.

 

1. Factors Affecting the Duration of a Mock Audit

 

Factors that can affect the scope and duration include:

 

• the number of sponsored workers;
• the number of sponsorship routes used;
• the number of sites or operating locations;
• the size of the worker-file sample;
• the complexity of the organisation’s corporate structure;
• the number of sponsor key personnel and SMS users;
• the quality and accessibility of existing records;
• the number of HR, payroll and other systems involved;
• remote, hybrid and client-site working arrangements;
• the extent of interview testing;
• recent organisational or personnel changes;
• previous sponsor compliance concerns; and
• any known potential breaches requiring investigation.

 

The audit should be scoped around the employer’s actual risk profile rather than an arbitrary number of hours or files.

 

2. The Audit May Need to Expand

 

An initial audit scope should not prevent further investigation where the evidence indicates a wider problem.

For example, if one sampled worker has a salary discrepancy, the auditor may need to test other sponsored workers affected by the same payroll process.

If one site is failing to escalate changes in work location, other locations may need to be sampled.

If several sponsored workers have missing historic contact information, the issue may arise from the design of the HR system rather than individual file administration.

The initial sample therefore provides a starting point rather than an absolute limit.

Where findings indicate a potentially systemic issue, the audit should expand sufficiently to establish its nature and extent.

 

3. Allow Time for Investigation and Remediation

 

The document-review stage is only one part of a meaningful mock audit.

Time may also be required to:

 

• investigate discrepancies;
• interview relevant personnel;
• reconcile information across different systems;
• assess sponsor reporting history;
• review payroll evidence;
• determine whether issues are isolated or systemic;
• prepare findings;
• develop a remediation plan; and
• re-test significant corrective actions.

 

An employer preparing for possible Home Office scrutiny should therefore avoid treating a mock audit as a last-minute document exercise where possible.

The greater value comes from allowing sufficient time to identify weaknesses, understand their cause and implement legitimate corrective action.

 

 

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Section P: How Often Should Sponsors Conduct Mock Audits?

 

There is no universal Home Office rule requiring every sponsor to conduct a mock sponsor licence audit at a fixed interval.

The frequency should instead reflect the organisation’s sponsorship activity, operating model and compliance risk.

A sponsor with a large and rapidly changing sponsored workforce may require more frequent assurance than an organisation with a small, stable sponsored population and mature compliance controls.

Employers should therefore avoid assuming that completing an annual audit automatically demonstrates effective sponsor governance.

 

1. Use a Risk-Based Audit Cycle

 

Factors relevant to audit frequency can include:

 

• the number of sponsored workers;
• the volume of Certificate of Sponsorship activity;
• the number of sites;
• the complexity of the organisation;
• the frequency of sponsored worker recruitment;
• changes to sponsor key personnel;
• turnover within HR or payroll teams;
• previous audit findings;
• previous Home Office compliance activity;
• corporate restructuring or acquisition activity;
• material changes to sponsor requirements;
• changes to HR or payroll systems; and
• known or suspected compliance concerns.

 

The organisation can then determine the level and frequency of assurance appropriate to its circumstances.

 

2. Combine Periodic and Event-Triggered Audits

 

A strong compliance framework does not have to rely on a single recurring audit date.

A more responsive model combines periodic assurance with reviews triggered by events that materially alter the organisation’s sponsorship risk.

For example, an additional review may be appropriate following:

 

• a substantial increase in sponsored worker numbers;
• a change of Authorising Officer;
• significant changes among Level 1 Users;
• the departure of experienced sponsorship personnel;
• a merger or acquisition;
• significant restructuring;
• implementation of a new HR or payroll system;
• opening or closing significant business locations;
• identification of a potentially material compliance failure;
• material changes to sponsor guidance; or
• notification of Home Office compliance activity.

 

This produces a more useful governance model:

Periodic assurance + Event-triggered review + Targeted re-testing.

 

3. Re-Test High-Risk Areas More Frequently

 

Not every part of the sponsorship system needs to be tested at the same frequency.

If a previous audit identified repeated problems with payroll escalation, for example, salary changes may justify targeted testing before the next full mock audit.

If the organisation has recently changed its absence-monitoring process, subsequent absence cases can be sampled to determine whether the new process works.

If manager training was introduced because employment changes were not reaching HR, the organisation can test later events to establish whether the escalation process has improved.

This allows audit activity to concentrate on areas where evidence shows the greatest need for assurance.

 

4. Respond to Changes in Sponsor Requirements

 

The audit cycle should also respond to material changes in Home Office requirements and systems.

For example, sponsors conducting reviews during 2026 should account for changes affecting SMS-user governance, including multi-factor authentication, inactive accounts and the transition away from Level 2 Users.

Where requirements change, the organisation should not merely update its written policy.

It should test whether the new requirement has been translated into working procedures and whether relevant personnel understand what has changed.

 

 

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Section Q: Common Mock Sponsor Licence Audit Mistakes

 

A mock audit can provide false reassurance if it is designed to demonstrate compliance rather than expose weaknesses.

The strongest exercises deliberately test areas where systems could fail and follow discrepancies until their cause is understood.

Common mistakes include the following.

 

1. Auditing Documents Instead of Employment Reality

 

Reviewing policies, contracts and job descriptions is not enough.

The audit should establish whether those documents correspond with what is actually happening.

A worker can have a perfectly drafted job description while performing materially different duties. A contract can state one salary while payroll evidence shows another. An HR system can record one location while the worker routinely works somewhere else.

Documentary compliance should therefore be tested against operational reality.

 

2. Reviewing Only the Best Worker Files

 

Selecting files that HR already knows are complete can undermine the value of the exercise.

The sample should reflect risk and include sufficient independent or random selection to test ordinary record keeping.

The purpose is to identify what could be found if external scrutiny selected different workers, not to demonstrate that the organisation can produce several exemplary files.

 

3. Checking the SMS Without Testing Underlying Events

 

An orderly SMS history does not prove that every relevant event reached the sponsorship team.

The mock audit should work backwards from actual HR, payroll, management and corporate events and determine whether sponsorship implications were considered.

This can expose events that never reached the SMS process at all.

 

4. Treating Every Error as an Isolated Error

 

Correcting one file can conceal a wider control problem.

If one sponsored worker’s change of address was not captured correctly, the auditor should consider whether the same HR process affects other workers.

If one salary change was missed, the payroll-to-sponsorship escalation process should be tested.

The audit should repeatedly ask:

Could the same failure have happened elsewhere?

 

5. Focusing Only on HR

 

Sponsor compliance frequently depends on information held outside the HR function.

Payroll may control salary changes. Line managers may know about changes in duties and location. Corporate teams may manage acquisitions or restructuring. Local sites may maintain attendance information.

A mock audit that tests only the central HR team can therefore miss important weaknesses in the organisation’s information flow.

 

6. Ignoring Authorising Officer and Key Personnel Knowledge

 

Correctly named key personnel do not automatically demonstrate effective sponsor governance.

The audit should establish whether relevant personnel understand their responsibilities and whether the Authorising Officer exercises meaningful oversight.

It should also test whether the sponsor has a system for checking SMS-user activity and whether appropriate cover exists when key personnel are unavailable.

 

7. Ignoring Current SMS User Controls

 

A mock audit conducted in the current sponsor environment should not overlook SMS-user governance.

The review should account for:

 

• multi-factor authentication arrangements;
• accuracy of relevant user contact information;
• inactive SMS accounts;
• appropriate Level 1 User coverage;
• former personnel retaining unnecessary access; and
• the transition of existing Level 2 Users before the end of the transitional period.

 

SMS access should be treated as an active governance issue rather than a static list of named users.

 

8. Coaching People to Give Identical Answers

 

Mock interviews should not become rehearsals in which workers and managers are taught predetermined responses.

The objective is to discover whether people genuinely understand their roles and whether their answers correspond with the evidence.

An unexpected or incorrect answer can be one of the most useful findings in the exercise because it can expose a weakness that would otherwise remain hidden.

 

9. Treating Policies as Proof of Compliance

 

A written policy establishes what the organisation intends to happen.

It does not establish what actually happens.

The audit should therefore distinguish between:

Policy → Process → Evidence → Reality.

A weakness can occur at any point in that chain.

 

10. Correcting Records Without Preserving the Historical Position

 

Where inaccurate or incomplete records are identified, remediation should not create a misleading account of past events.

Documents should not be backdated and evidence should not be manufactured to suggest that an action occurred when it did not.

The organisation should preserve the factual historical position while taking legitimate corrective action.

 

11. Failing to Test Different Sites

 

Central policies may operate differently across business locations.

Where the sponsor operates from multiple sites, the audit should consider whether local managers follow the same escalation, absence-monitoring and record-keeping arrangements.

Sampling across sites can reveal whether a central compliance framework actually operates consistently throughout the organisation.

 

12. Ignoring Remote, Hybrid and Client-Site Working

 

Modern working arrangements can make work-location testing more complex.

The audit should establish where sponsored workers actually perform their duties and distinguish between ordinary day-to-day variations, hybrid arrangements, changes to normal work location and relevant client-site arrangements.

The sponsor should also test whether appropriate records are retained and whether changes that engage reporting requirements are identified.

 

13. Ignoring the Sponsored Worker’s Perspective

 

The sponsored worker is an important source of evidence about employment reality.

A worker may identify changes in duties, management, hours or location that are not apparent from the HR file.

Interview testing therefore provides an opportunity to compare the formal record with the individual’s actual experience of the role.

 

14. Producing a Report Without a Remediation Plan

 

An audit report has limited value if identified weaknesses are not converted into action.

Material findings should have an owner, required action, deadline and, where appropriate, a re-test.

The audit should remain open until significant corrective actions have been implemented rather than ending when the written report is issued.

 

15. Failing to Re-Test

 

A revised policy or completed training session does not establish that the underlying problem has been resolved.

Where the audit identifies a control failure, the organisation should test subsequent real-world events to establish whether the revised control works.

Without re-testing, the sponsor may discover at the next audit or Home Office compliance check that the same weakness remains.

 

16. Treating a Clean Audit Report as the Objective

 

The purpose of a mock sponsor licence audit is not to produce a report containing as few findings as possible.

An audit that identifies weaknesses can be more valuable than one that produces a superficially clean result.

The strongest mock audits are designed to expose problems while the organisation still has an opportunity to understand and address them.

The relevant measure of success is therefore not the number of findings.

It is whether the organisation has obtained a realistic understanding of its sponsor compliance position and strengthened its controls as a result.

 

 

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Section R: Mock Sponsor Licence Audit Checklist

 

A practical mock sponsor licence audit checklist should test the sponsor’s licence information, sponsored workers, HR systems, reporting controls, record keeping, key personnel and operational practices.

The checklist below can be used to structure the review, but it should not be treated as a substitute for considering the organisation’s particular circumstances or the current Home Office sponsor guidance.

Where a checklist item identifies a discrepancy, the auditor should investigate the cause and consider whether the same weakness could affect other sponsored workers or parts of the organisation.

The objective is not simply to mark each item as complete. It is to determine whether the sponsor can demonstrate effective compliance in practice.

 

1. Sponsor Licence Details

 

• Confirm the correct legal entity holds the sponsor licence.
• Check that relevant organisation details remain accurate.
• Review registered, trading and operating addresses.
• Identify any new, closed or relocated premises.
• Review significant changes to ownership or control.
• Identify mergers, acquisitions, disposals or restructuring.
• Check whether relevant branches or organisational changes have been considered for sponsorship purposes.
• Identify any significant business changes that may not have reached the sponsorship team.
• Check whether required organisational changes were reported within the applicable timeframe.
• Confirm that the sponsor licence continues to correspond with the organisation’s current structure and activities.

 

2. Authorising Officer and Sponsor Key Personnel

 

• Confirm that the Authorising Officer remains in post and their details are current.
• Confirm that the Key Contact information remains accurate.
• Review current Level 1 Users.
• Identify former personnel who may still have inappropriate access or responsibilities.
• Confirm that responsibilities for sponsorship administration are clearly allocated.
• Check whether sufficient cover exists during absence or departure of key personnel.
• Test whether the Authorising Officer has meaningful oversight of sponsor compliance.
• Confirm that the sponsor has a system for checking SMS-user activity.
• Establish how significant sponsor compliance concerns are escalated to the Authorising Officer.
• Review how Certificate of Sponsorship activity is overseen.
• Consider whether the Authorising Officer follows the Home Office recommendation to check Certificates of Sponsorship assigned to workers at least monthly.

 

3. SMS Users, MFA and Inactive Accounts

 

• Identify every current SMS user.
• Confirm that each user still requires access.
• Check whether each user’s role and access remain appropriate.
• Confirm that Level 1 User date of birth, mobile number and email details are current.
• Confirm that any remaining Level 2 User email details are current.
• Check that users can operate the required multi-factor authentication arrangements.
• Confirm that passwords, user IDs and one-time passcodes are not shared.
• Identify SMS accounts that have not been accessed for a significant period.
• Check for accounts that may become or have become inactive following 12 months without access.
• Check whether any Home Office inactive-user notice or 3-month remediation period applies.
• Confirm that the sponsor retains sufficient active Level 1 User coverage.
• Confirm that Level 1 Users access the SMS regularly, in line with the Home Office recommendation of at least monthly access.
• Where no active Level 1 User remains, check the 28-day post-suspension requirement to nominate an eligible replacement.
• Check whether former employees or employees who have changed roles retain unnecessary access.
• Review internal controls over SMS access and use.
• Confirm that responsibility for monitoring SMS-user continuity is allocated.

 

4. Existing Level 2 Users

 

• Identify whether the sponsor still has any existing Level 2 Users.
• Record the functions currently performed by each Level 2 User.
• Confirm that no new Level 2 User has been appointed from 9 September 2026.
• Determine whether each existing Level 2 User is eligible to become a Level 1 User.
• Decide whether conversion to Level 1 User or deactivation is appropriate.
• Plan for existing Level 2 Users to be converted or deactivated by 8 March 2027.
• Reallocate responsibilities where necessary.
• Check that the organisation will retain sufficient Level 1 User capacity following the transition.
• Document responsibility for completing the transition.

 

5. Sponsored Worker Population

 

• Generate an accurate list of current sponsored workers.
• Compare the list with HR records and relevant SMS information.
• Identify sponsored workers who have left the organisation.
• Identify workers who have moved between departments, roles or sites.
• Identify workers whose salary or working hours have changed.
• Identify workers with significant absence history.
• Identify remote, hybrid and client-site workers.
• Identify workers whose circumstances have changed materially since sponsorship began.
• Check for inconsistencies between sponsorship records and the current workforce.

 

6. Right to Work

 

• Check right to work evidence for sampled sponsored workers.
• Confirm that the appropriate checking method was used.
• Check when the right to work check was completed.
• Confirm that evidence of the check has been retained appropriately.
• Identify workers with time-limited permission.
• Test follow-up controls for time-limited permission.
• Check that relevant expiry and follow-up dates are recorded accurately.
• Confirm that responsibility for follow-up checks is allocated.
• Investigate missing, incomplete or inconsistent evidence.
• Where relevant to the wider compliance review, sample non-sponsored workers to test whether the organisation’s right to work controls operate consistently.
• Ensure the organisation’s right to work procedures reflect the regime applicable from 1 October 2026, including relevant wider working arrangements where applicable.

 

7. Date-of-Entry Evidence

 

• Identify sponsored workers whose current permission derives from employer-sponsored entry clearance where Appendix D requires date-of-entry evidence.
• Check whether the required evidence of entry to the UK has been retained.
• Confirm that the evidence satisfies the current Appendix D requirements applicable to the worker.
• Do not assume that the right to work record automatically satisfies the separate record-keeping requirement.
• Investigate gaps and establish whether legitimate contemporaneous evidence is available.

 

8. Sponsored Worker Contact Details

 

• Check the worker’s current UK residential address.
• Check the worker’s personal email address.
• Check the worker’s telephone number.
• Confirm that required contact information is kept up to date.
• Check whether the required history of changes is retained.
• Test whether the HR system overwrites historic contact information.
• Confirm that workers know how to notify the organisation of changes.
• Test whether changes submitted by workers reach the correct HR records.
• Compare contact information across relevant systems where necessary.

 

9. Recruitment Records

 

• Establish how each sampled sponsored worker was recruited.
• Identify the recruitment evidence required under the applicable Appendix D provisions.
• Check whether relevant recruitment records have been retained.
• Review application, selection or interview evidence where applicable.
• Check evidence relating to recruitment agencies or other recruitment channels where relevant.
• Confirm that the recruitment record corresponds with the sponsored position.
• Do not assume that recruitment evidence is irrelevant merely because no formal resident labour market test applied.

 

10. Certificate of Sponsorship and Job Role

 

• Review the Certificate of Sponsorship for each sampled worker.
• Compare the sponsored job title with the worker’s current position.
• Compare the occupation classification with the worker’s substantive duties.
• Compare the original role description with the current job description.
• Interview the relevant manager where appropriate.
• Interview the sponsored worker where appropriate.
• Identify material changes to duties or responsibilities.
• Determine when any role changes occurred.
• Check whether the sponsorship implications of those changes were assessed.
• Distinguish between changes capable of being dealt with through sponsor reporting and changes that may require a new Certificate of Sponsorship and change of employment application.
• Investigate any material difference between the sponsored role and employment reality.

 

11. Salary and Payroll

 

• Check the salary stated on the Certificate of Sponsorship.
• Compare this with the employment contract.
• Compare contractual salary with payroll records.
• Review payslips.
• Review evidence of actual salary payments.
• Check relevant working hours.
• Identify salary changes during sponsorship.
• Identify periods of reduced pay.
• Identify relevant periods of unpaid absence.
• Review relevant allowances or other remuneration components where applicable.
• Investigate discrepancies between CoS, contract, payroll, payslips and actual payment evidence.
• Check whether non-absence-related salary reductions were reported through the SMS and whether the revised salary remained permissible.
• Do not assume that every ordinary salary increase requires reporting; note the specific reporting requirement for a relevant increase following registration of a sponsored pre-registration nurse or midwife.
• Test whether payroll can identify sponsored workers.
• Test whether payroll changes are escalated to HR or the sponsorship team where required.

 

12. Working Hours

 

• Compare sponsored working hours with contractual hours.
• Compare contractual hours with current working arrangements.
• Identify workers whose hours have materially changed.
• Identify workers who have moved between full-time and part-time arrangements.
• Check whether changes were considered from a sponsorship perspective.
• Consider whether salary and working hours remain consistent with applicable sponsorship requirements.
• Investigate unexplained discrepancies.

 

13. Work Location, Remote and Hybrid Working

 

• Identify each sampled worker’s normal work location.
• Compare actual working arrangements with sponsor and HR records.
• Identify changes to the worker’s main office location.
• Identify new or changed client-site arrangements.
• Identify workers operating under hybrid arrangements.
• Identify workers who are contractually based wholly or essentially at home.
• Distinguish normal day-to-day location variations from substantive changes to normal working arrangements.
• Check whether reportable changes of normal work location were identified and acted upon.
• Do not assume that moving to a hybrid pattern itself automatically requires an SMS report.
• Check whether suitable records of relevant working arrangements are retained.
• Test whether managers understand when location changes should be escalated.

 

14. Absence and Attendance Monitoring

 

• Identify the system used to record absence and attendance.
• Confirm who is responsible for monitoring sponsored workers.
• Test whether authorised and unauthorised absence can be distinguished.
• Sample actual absence cases.
• Check whether managers escalate relevant absences.
• Check whether HR receives the information promptly.
• Test cases involving more than 10 consecutive working days of unauthorised absence where applicable.
• Check whether the relevant sponsor reporting deadline was identified and met.
• Separately identify cumulative periods of unpaid or reduced-pay absence.
• Consider the four-week calendar-year rule, the Scale-up distinction, the worker’s normal working pattern and applicable exceptions.
• Check whether required SMS reporting was completed and whether sponsorship should have stopped.
• Check whether absence records correspond with payroll information where relevant.
• Investigate gaps or inconsistent records.

 

15. Sponsor Reporting

 

• Select actual employment events and trace them through the reporting process.
• Check changes to roles and duties.
• Check relevant salary changes.
• Check relevant working-hours changes.
• Check changes to normal work location.
• Check relevant absence events.
• Check cessation of employment.
• Check relevant organisational changes.
• Check changes affecting sponsor key personnel.
• Establish whether each event was identified internally.
• Establish when it was escalated to the sponsorship team.
• Determine whether a reporting requirement applied.
• Check whether the applicable reporting deadline was met.
• Remember that many worker-related reports operate on a 10-working-day timeframe and many organisational reports on a 20-working-day timeframe, subject to the specific rules and exceptions.
• Review significant decisions that an event did not require reporting where appropriate.
• Investigate late or missed reports and identify the root cause.

 

16. Record Keeping and Document Retention

 

• Check sampled files against the current Appendix D requirements.
• Confirm that required evidence exists.
• Confirm that evidence can be retrieved efficiently.
• Identify records stored in personal emails or uncontrolled locations.
• Check whether documents are distributed across systems without clear ownership.
• Review naming and filing conventions.
• Check access to historic records following system changes.
• Confirm that relevant sponsored worker records are retained for the applicable period.
• Unless a specific requirement provides otherwise, test retention throughout sponsorship and until the earlier of one year after sponsorship ends or the relevant records have been examined and approved by a Home Office compliance officer.
• Check sponsor licence application records against the applicable retention requirements.
• Consider whether other legal or regulatory requirements require longer retention.

 

17. HR Systems and Internal Escalation

 

• Confirm that sponsored workers can be identified within relevant HR systems.
• Test how changes in role reach the sponsorship team.
• Test how salary changes reach the sponsorship team.
• Test how working-hours changes are escalated.
• Test how work-location changes are escalated.
• Test how absence information is escalated.
• Test how worker departures are communicated.
• Check whether payroll can make relevant changes without sponsorship review.
• Check whether managers understand their escalation responsibilities.
• Identify processes dependent on one individual.
• Check business-continuity arrangements during absence or staff turnover.
• Test whether HR, payroll, management and sponsorship teams describe the same process.

 

18. Management and Key Personnel Interviews

 

• Interview the Authorising Officer.
• Interview relevant Level 1 Users.
• Interview existing Level 2 Users where applicable during the transitional period.
• Interview relevant HR personnel.
• Interview payroll personnel where appropriate.
• Interview line managers responsible for sampled sponsored workers.
• Test knowledge of escalation procedures.
• Test understanding of responsibilities during absence or staff changes.
• Compare interview answers with written procedures.
• Compare answers between different departments.
• Investigate inconsistent descriptions of how sponsor compliance processes operate.
• Avoid coaching personnel to give predetermined answers.

 

19. Sponsored Worker Interviews

 

• Ask the worker to describe their job title.
• Ask them to describe their normal duties.
• Confirm their line manager.
• Ask where they normally work.
• Ask about remote, hybrid or client-site working where relevant.
• Confirm normal working hours.
• Confirm their understanding of salary and payment arrangements.
• Ask whether their role or duties have changed.
• Ask whether their normal work location has changed.
• Ask how they report absence.
• Ask how they update their address and contact information.
• Compare answers with the Certificate of Sponsorship.
• Compare answers with the employment contract and job description.
• Compare answers with payroll and location evidence.
• Compare answers with the manager’s account.
• Investigate material differences rather than expecting identical terminology.
• Do not coach workers to provide rehearsed answers.

 

20. Findings, Remediation and Re-Testing

 

• Record each material finding clearly.
• Identify the evidence supporting the finding.
• Identify the relevant sponsor obligation.
• Assess the potential risk.
• Determine whether the issue is isolated or systemic.
• Identify the root cause.
• Allocate an internal risk grading where useful.
• Make clear that internal risk categories are not Home Office classifications.
• Specify the required corrective action.
• Allocate an owner.
• Set a proportionate deadline.
• Record progress against remediation.
• Expand the audit sample where findings indicate wider risk.
• Preserve an accurate historical record.
• Do not manufacture, backdate or alter evidence to create a misleading impression of historic compliance.
• Obtain specialist advice where potentially material sponsor or worker issues require legal assessment.
• Re-test significant control changes.
• Confirm that corrective action operates in practice rather than merely existing on paper.

 

A completed checklist should therefore lead to more than a list of documents reviewed.

The employer should be able to answer four fundamental questions:

1. Are our sponsorship records accurate?

2. Do our systems identify events that affect sponsor compliance?

3. Do our people understand and operate those systems?

4. Can we evidence what actually happens in practice?

If the answer to any of these questions is uncertain, the mock audit should identify what needs to be investigated, remediated and re-tested before the organisation can rely on the control.

 

 

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Section S: Preparing for an Actual Home Office Compliance Check

 

A mock sponsor licence audit can be particularly valuable where an employer is preparing for actual Home Office scrutiny.

The Home Office can conduct sponsor compliance checks in different ways. Compliance activity is not limited to a physical inspection of the employer’s premises. It can involve requests for information or documents, verification activity, digital checks, interviews, onsite visits and other evidence-gathering.

Compliance visits and interviews can also be announced or unannounced.

Employers should therefore think in terms of being able to demonstrate compliance whenever required, rather than preparing only for a scheduled physical visit.

 

1. Do Not Treat Inspection Preparation as a Document-Tidying Exercise

 

Preparing for Home Office scrutiny should involve more than checking that personnel files look complete.

The organisation should be able to demonstrate that:

 

• its sponsor licence information is accurate;
• its SMS-user arrangements are properly controlled;
• its sponsored worker population is understood;
• required records can be produced;
• right to work controls operate effectively;
• salary and payroll information corresponds with sponsorship records;
• workers are performing the roles for which they are sponsored;
• relevant work-location arrangements are understood;
• absence can be monitored;
• reportable events can be identified and escalated;
• key personnel understand their responsibilities; and
• employment reality corresponds with the evidence held by the sponsor.

 

The mock audit should therefore test the organisation in broadly the same condition in which it normally operates.

 

2. Test Document Retrieval

 

The employer should test whether relevant evidence can be retrieved efficiently if requested.

This can include selecting sponsored workers without advance warning to the HR team and asking for relevant records such as:

 

• right to work evidence;
• relevant Appendix D records;
• recruitment evidence;
• employment contracts;
• job descriptions;
• payroll and salary-payment evidence;
• contact information;
• absence records;
• work-location information; and
• records relating to changes during sponsorship.

 

Difficulty retrieving records can itself expose a compliance weakness even where the underlying documents eventually exist.

 

3. Check Who Would Deal With the Home Office

 

The organisation should understand who will take responsibility if Home Office officials make contact or attend a business location.

This is particularly important for organisations operating across multiple sites.

Relevant personnel should know:

 

• who should be informed internally;
• how the Authorising Officer or sponsorship team can be contacted;
• where relevant records are held;
• who has access to the SMS;
• who can explain HR and sponsorship processes;
• how legal or specialist support can be obtained where required; and
• how requests for information should be managed internally.

 

Reception, security or local management personnel do not need detailed knowledge of sponsor compliance, but organisations should avoid a situation where an unexpected visit creates confusion about who is responsible for responding.

 

4. Prepare Key Personnel Without Coaching Them

 

The Authorising Officer, Level 1 Users and other relevant personnel should understand their own responsibilities and the organisation’s sponsorship processes.

Preparation should focus on genuine understanding.

Personnel should not be given scripts designed to produce predetermined answers.

If a mock interview identifies uncertainty, the organisation should correct the underlying knowledge or process gap.

The objective is for personnel to be able to explain accurately how sponsorship works within the organisation because they understand and operate the system, not because they have memorised responses.

 

5. Prepare Sponsored Workers Appropriately

 

Sponsored workers should not be coached to provide rehearsed answers.

They should, however, understand normal employment procedures that genuinely apply to them, including how to report absence and how to update relevant personal information.

If a mock interview reveals that a worker’s understanding of their job, location, hours or reporting arrangements differs materially from the employer’s records, the discrepancy should be investigated.

The appropriate response is to establish the true position rather than teach the worker to repeat the documentary version.

 

6. Review the Physical and Operational Workplace

 

Where onsite scrutiny is possible, the mock audit should consider what the Home Office would observe at the workplace.

Depending on the organisation, this can include:

 

• whether the business operates from the locations recorded for sponsorship purposes;
• whether sponsored workers are present where expected;
• whether managers understand the roles performed by sponsored workers;
• whether organisational charts correspond with actual reporting lines;
• whether HR and attendance systems operate as described;
• whether remote, hybrid and client-site arrangements are understood; and
• whether the organisation can explain how sponsored workers are monitored across different locations.

 

This is another reason why a mock audit should test reality rather than documents alone.

 

7. Address Known Problems Before Scrutiny

 

Where the mock audit identifies a potential compliance issue, the employer should investigate it promptly.

Depending on the circumstances, appropriate action may include correcting current records, obtaining legitimate missing evidence, taking required sponsor action, reviewing an individual’s sponsorship position, strengthening procedures or obtaining legal advice.

Historic evidence should not be manufactured, altered or backdated to create the appearance that an action occurred when it did not.

Effective preparation means understanding the true compliance position and taking legitimate corrective action.

 

8. Can Home Office Sponsor Compliance Visits Be Unannounced?

 

Yes. Home Office sponsor compliance activity can include unannounced visits and interviews.

An employer should therefore not rely on receiving advance notice before checking whether its sponsorship records and systems are in order.

A mock sponsor licence audit can help establish whether the organisation would be able to demonstrate compliance if scrutiny occurred without a lengthy preparation period.

For detailed guidance on what happens during an actual visit, employers should refer to the dedicated Sponsor Licence Compliance Visit guide.

 

 

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Section T: How DavidsonMorris Can Help With Mock Sponsor Licence Audits

 

DavidsonMorris advises UK sponsor licence holders on sponsor compliance, Home Office scrutiny and the management of immigration compliance risk.

We can conduct mock sponsor licence audits designed around the organisation’s sponsorship arrangements, workforce, operating model and areas of potential exposure.

The objective is to test how the sponsor’s compliance framework operates in practice, identify weaknesses before they become more serious and provide a structured plan for remediation.

 

1. Independent Sponsor Compliance Review

 

An independent mock audit can provide a different perspective from an internal HR review.

Organisations that operate their sponsorship processes every day can become accustomed to existing practices and may not identify assumptions, workarounds or control gaps that have developed over time.

Our review can examine areas including:

 

• sponsor licence and SMS information;
• Authorising Officer and key personnel arrangements;
• SMS-user governance;
• MFA and inactive-user issues;
• the transition from existing Level 2 User arrangements;
• sponsored worker files;
• right to work processes;
• Appendix D record keeping;
• recruitment records;
• salary and payroll evidence;
• job roles and duties;
• work-location arrangements;
• absence monitoring;
• sponsor reporting;
• HR and management escalation processes;
• key personnel interviews; and
• sponsored worker interview testing.

 

2. Risk-Based Worker File Sampling

 

For organisations with larger sponsored workforces, we can use risk-based sampling rather than limiting the exercise to files selected because they are known to be complete.

The sample can take account of factors such as different sponsorship routes, sites, departments, managers, salary changes, role changes, absence history and remote or hybrid working arrangements.

Where a sampled finding suggests a wider problem, the review can be expanded to determine whether the issue is isolated or systemic.

 

3. Mock Interviews

 

Mock interviews can be used to test whether key personnel, HR, managers and sponsored workers understand the processes and employment arrangements relevant to them.

The purpose is not to provide scripted answers.

Interview testing can identify differences between policy, process, documentary evidence and operational reality, allowing the organisation to address the underlying issue.

 

4. Audit Findings and Remediation

 

Where issues are identified, the findings can be structured around the evidence, relevant sponsor obligation, potential risk, root cause and required action.

Remediation can then be prioritised according to the significance of the issue.

Depending on the findings, this may involve:

 

• reviewing individual sponsored worker positions;
• assessing whether sponsor reporting or other SMS action is required;
• improving record keeping;
• strengthening HR and payroll controls;
• changing internal escalation processes;
• reviewing SMS-user arrangements;
• training key personnel and managers;
• improving Authorising Officer oversight; and
• re-testing controls after changes have been implemented.

 

5. Preparing for Home Office Scrutiny

 

Where an organisation has been notified of a Home Office compliance check or has reason to expect increased scrutiny, the review can focus on inspection readiness.

This can include testing document retrieval, sponsored worker records, key personnel knowledge, management processes, worker interviews and the consistency between SMS information and actual employment arrangements.

Where potentially material compliance concerns are identified, early assessment can help the organisation understand the issue and determine the appropriate response before further action is taken.

For advice on mock sponsor licence audits and Home Office inspection preparation, contact DavidsonMorris.

 

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Section U: Mock Sponsor Licence Audit FAQs

 

What is a mock sponsor licence audit?

A mock sponsor licence audit is a structured review of an employer’s sponsorship records, systems, personnel and working practices designed to simulate the type of scrutiny that can arise during Home Office sponsor compliance activity.

It can test the sponsor licence, SMS information, worker files, right to work evidence, record keeping, reporting, salary and payroll, absence monitoring, work locations, key personnel knowledge and employment reality.

 

Is a mock sponsor licence audit required by the Home Office?

No. There is no separate Home Office requirement for every sponsor to conduct a mock sponsor licence audit.

Sponsors are, however, required to comply with their underlying sponsor duties. A mock audit is an assurance method employers can use to test whether those duties are being met in practice and identify weaknesses before they are exposed through Home Office scrutiny.

 

What does a mock sponsor licence audit check?

A comprehensive audit can check the sponsor licence and SMS, key personnel, sponsored worker records, right to work evidence, Appendix D records, recruitment, job roles, salary and payroll, working hours, work locations, absence monitoring, sponsor reporting, HR systems, management processes and governance.

It should also test whether the organisation’s records correspond with actual employment arrangements.

 

Is a mock sponsor licence audit the same as a Home Office compliance visit?

No. A mock audit is an internal or independently commissioned assurance exercise. A Home Office compliance check is official compliance activity undertaken by the Home Office.

The mock audit can use realistic testing methods to help an employer identify weaknesses, but it does not replicate the Home Office’s powers or guarantee how a future compliance check would be conducted.

 

Is a mock audit the same as a sponsor compliance audit?

They can overlap, but the focus is different.

A broader sponsor compliance audit assesses whether the organisation is meeting its sponsor duties. A mock sponsor licence audit deliberately tests those arrangements from the perspective of potential external Home Office scrutiny, including document sampling, evidence reconciliation and interview testing.

Employers looking for a broader review of their sponsorship framework can refer to our Sponsor Licence Compliance Audit guide.

 

Can the Home Office make an unannounced sponsor compliance visit?

Yes. Home Office compliance activity can include unannounced visits and interviews.

Sponsors should therefore maintain ongoing compliance rather than relying on receiving advance notice before reviewing their records and systems.

 

Who should be interviewed during a mock sponsor licence audit?

Depending on the organisation, interviewees can include the Authorising Officer, Level 1 Users, relevant HR and payroll personnel, line managers and sponsored workers.

Existing Level 2 Users can also be included during the current transitional period where they continue to perform sponsorship functions.

The questions should reflect each person’s actual responsibilities.

 

Should sponsored workers be prepared for Home Office interviews?

Employers can ensure sponsored workers understand genuine employment procedures and can use mock interviews to identify discrepancies between records and reality.

Workers should not be coached to give predetermined or misleading answers.

If a worker’s account differs materially from the sponsor’s records, the employer should investigate the underlying discrepancy.

 

How many sponsored worker files should a mock audit review?

There is no universal number suitable for every sponsor.

The sample should reflect the size, complexity and risk profile of the sponsored workforce.

A combination of risk-based and random sampling can be useful. If the initial sample identifies a recurring weakness, the review should be expanded where necessary to establish whether the issue is systemic.

 

Should a mock audit include non-sponsored workers?

It can be appropriate to include non-sponsored workers where the audit is testing wider controls such as right to work compliance.

This can help determine whether a weakness is specific to sponsorship administration or forms part of a broader workforce compliance problem.

 

How often should an employer conduct a mock sponsor licence audit?

There is no universal Home Office timetable.

The frequency should reflect factors such as the number of sponsored workers, volume of sponsorship activity, organisational complexity, previous findings, changes in personnel, corporate changes and developments in sponsor requirements.

Periodic assurance can be combined with event-triggered reviews and targeted re-testing.

 

What happens if a mock audit identifies a sponsor breach?

The employer should establish the facts, determine the applicable sponsor requirement, assess whether the issue is isolated or systemic and identify the appropriate corrective action.

Potentially material issues may require specialist legal advice.

Historic records should not be manufactured or backdated in an attempt to create the appearance of earlier compliance.

 

Can a mock audit prevent sponsor licence suspension or revocation?

A mock audit cannot guarantee that the Home Office will not take enforcement action.

Its purpose is to identify weaknesses and provide an opportunity for legitimate investigation and remediation before those weaknesses are identified through external scrutiny.

The potential consequences of non-compliance depend on the nature of the issue and the applicable sponsor guidance.

 

What records should be available for a mock sponsor audit?

The records required depend on the worker, sponsorship route and applicable Appendix D requirements.

They can include right to work evidence, date-of-entry evidence where required, contact details and relevant history, recruitment records, Certificates of Sponsorship, contracts, job descriptions, payroll and salary-payment evidence, absence information, work-location records and evidence relating to relevant changes during sponsorship.

 

Should a mock audit check the Sponsor Management System?

Yes. The SMS should be reviewed against actual organisational and employment information.

The audit should also consider SMS-user governance, multi-factor authentication, inactive accounts, Level 1 User coverage and the current transition arrangements affecting existing Level 2 Users.

 

What is the biggest mistake employers make when conducting a mock audit?

One of the most significant weaknesses is treating the exercise as a document check rather than testing whether policy, process, evidence and employment reality correspond.

A strong mock audit follows discrepancies through to their cause and determines whether the same weakness could affect other workers or parts of the organisation.

 

Can a sponsor conduct its own mock audit?

Yes. An employer can conduct internal compliance testing using personnel who understand the sponsor requirements and can review the organisation objectively.

Independent review can also be useful where the organisation wants external scrutiny, where existing processes have not previously been tested, where potentially significant issues have been identified or where Home Office compliance activity is anticipated.

 

What should happen after a mock sponsor licence audit?

Material findings should be converted into a remediation plan with clear actions, owners, deadlines and re-testing where appropriate.

The organisation should then verify that revised controls operate in practice.

The objective is not simply to complete the audit but to strengthen the sponsor compliance framework that operates after the audit has finished.

 

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Section V: Mock Sponsor Licence Audit: Key Takeaways

 

A mock sponsor licence audit should test whether an employer can demonstrate sponsor compliance in practice, not simply whether it has the right policies and documents.

The most effective approach tests the relationship between:

Policy → Process → Evidence → Employment Reality.

For employers preparing for Home Office scrutiny, the key points are:

 

• A mock sponsor licence audit is an internal assurance exercise designed to identify compliance weaknesses before they are exposed through Home Office scrutiny.
• There is no separate Home Office requirement requiring every sponsor to conduct a mock audit, but sponsors remain responsible for complying with their underlying sponsorship duties.
• The audit should test the sponsor licence, SMS information, sponsored worker files, right to work evidence, Appendix D records, reporting, salary and payroll, absence monitoring, work locations and organisational controls.
• Records should be compared with actual employment arrangements rather than reviewed in isolation.
• Sponsored worker sampling should be risk-based and can be supplemented with random selection.
• The audit should test whether employment and organisational changes reach the people responsible for sponsor compliance.
• Key personnel, HR, payroll, managers and sponsored workers can all form part of interview testing.
• Interview preparation should test genuine knowledge and consistency rather than coach predetermined answers.
• Current SMS governance should include MFA, inactive-user controls, appropriate Level 1 User coverage and the transition from existing Level 2 User accounts.
• Worker files should include date-of-entry evidence where required under Appendix D and the required history of relevant worker contact details.
• Salary should be tested through the full evidence chain from Certificate of Sponsorship to contract, payroll, payslip and actual payment evidence.
• Changes in duties, salary, hours and work location should be assessed according to their specific sponsorship implications rather than assuming every change requires the same action.
• Home Office compliance activity can include document requests, verification, digital checks, interviews and onsite activity and can be announced or unannounced.
• Historic weaknesses should be investigated and legitimately remediated. Evidence should never be manufactured or backdated to create a misleading impression of compliance.
• Audit findings should identify the evidence, relevant obligation, risk, root cause, required action, owner, deadline and method of re-testing.
• Internal risk categories such as Critical, High, Moderate and Low are audit-management tools and are not Home Office compliance classifications.
• The audit should expand where an individual discrepancy indicates a potentially systemic problem.
• Significant corrective actions should be re-tested to establish whether the revised controls actually work.

 

The central question for a sponsor is not simply:

“Do we have the required documents?”

It is:

“If the Home Office scrutinised our sponsorship arrangements today, could our people, systems, records and employment practices demonstrate that we are meeting our sponsor duties?”

 

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Section W: Mock Sponsor Licence Audit Glossary

 

Term	Meaning
Authorising Officer	The senior person responsible for the sponsor licence and for overseeing the organisation’s sponsorship arrangements. The Authorising Officer is responsible for the activities of SMS users and the sponsor should have a system for checking those activities. Current Home Office guidance also recommends that the Authorising Officer checks Certificates of Sponsorship assigned to workers at least monthly.
Certificate of Sponsorship (CoS)	An electronic sponsorship record assigned through the Sponsor Management System to an eligible worker. It contains information relevant to the sponsored role and immigration application, including information about the employment.
Compliance Check	Home Office activity used to assess whether a sponsor is meeting its sponsorship obligations and remains suitable to hold a sponsor licence. A compliance check can involve documents and information, verification activity, digital checks, interviews, onsite visits and other evidence. Visits and interviews can be announced or unannounced.
Compliance Visit	An onsite form of Home Office sponsor compliance activity. A compliance visit can involve examination of records, systems and working practices and interviews with relevant personnel or workers. It should be understood within the Home Office’s broader compliance-check framework.
Home Office Inspection	A commonly used description for Home Office scrutiny of a sponsor. In the sponsor guidance, the broader concept is a compliance check, which can extend beyond a physical inspection or visit.
Key Contact	The person who acts as a main point of contact between the sponsoring organisation and UK Visas and Immigration in relation to the sponsor licence.
Level 1 User	An SMS user with responsibility for carrying out permitted sponsor-management activities through the Sponsor Management System. Sponsors should maintain appropriate Level 1 User coverage and ensure access remains properly controlled.
Level 2 User	A legacy SMS-user role being phased out under the current transitional arrangements. Sponsors cannot appoint new Level 2 Users from 9 September 2026. Existing Level 2 Users can temporarily remain but should be converted to Level 1 Users, where eligible, or deactivated by 8 March 2027.
Mock Sponsor Licence Audit	A structured internal or independently commissioned exercise that tests a sponsor’s records, systems, people and employment practices from the perspective of potential Home Office scrutiny.
Multi-Factor Authentication (MFA)	An additional authentication control for access to the Sponsor Management System. Mandatory MFA rollout began on 3 September 2026 and applies immediately to organisations granted a sponsor licence on or after 9 September 2026.
Appendix D	The Home Office sponsor guidance dealing with documents that sponsors are required to keep in relation to their sponsorship activities and sponsored workers.
Right to Work Check	The process used by an employer or other person within the applicable statutory framework to establish an individual’s right to undertake the relevant work in the UK and, where the prescribed requirements are met, obtain the applicable statutory protection against liability for illegal working.
Sponsor Duties	The responsibilities imposed on licensed sponsors, including relevant duties concerning record keeping, reporting, monitoring sponsored workers, compliance with immigration requirements and cooperation with the Home Office.
Sponsor Licence Compliance Audit	A structured review of whether an organisation is meeting its sponsor duties. It overlaps with a mock sponsor licence audit, but a mock audit places particular emphasis on simulating external Home Office scrutiny and testing inspection readiness.
Sponsor Management System (SMS)	The online Home Office system used by licensed sponsors to manage relevant sponsorship functions, including authorised user administration, Certificates of Sponsorship and specified sponsor reporting activity.
Sponsored Worker	A worker whose relevant immigration permission is supported by sponsorship from a licensed sponsor under an applicable sponsored work route.
Internal Risk Grading	A methodology used by the employer or auditor to prioritise findings according to their potential significance. Categories such as Critical, High, Moderate and Low are not Home Office classifications unless expressly identified as such in applicable official guidance.
Re-Testing	The process of reviewing a control again after remediation to establish whether corrective action has resolved the identified weakness and operates effectively in practice.

 

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Section X: Useful Links

 

The following official Home Office and GOV.UK resources should be checked when conducting a mock sponsor licence audit because sponsor requirements and operational procedures can change.

 

Resource	URL
Workers and Temporary Workers: Sponsor Guidance	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Workers and Temporary Workers: Sponsor Guidance Part 3 — Sponsor Duties and Compliance	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
Appendix D: Keeping Documents for Sponsorship	https://www.gov.uk/government/publications/keep-records-for-sponsorship-appendix-d
Employer’s Guide to Right to Work Checks	https://www.gov.uk/government/publications/right-to-work-checks-employers-guide
Sponsor Management System Guidance	https://www.gov.uk/government/publications/use-the-sponsorship-management-system-sms
UK Immigration Rules	https://www.gov.uk/guidance/immigration-rules

 

Because sponsor guidance is updated periodically, employers should ensure that any audit is conducted against the version of the relevant guidance in force at the time of the review.

 

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Section Y: Mock Sponsor Licence Audit: Final Considerations

 

A mock sponsor licence audit gives an employer an opportunity to examine its sponsorship arrangements before weaknesses are exposed through Home Office scrutiny.

Its value comes from testing the organisation as it actually operates.

A sponsor may have detailed policies, experienced HR personnel and apparently complete worker files while still carrying significant compliance risk if relevant information does not move through the organisation effectively.

A manager may change a sponsored worker’s duties without understanding that HR needs to know. Payroll may implement a salary change without knowing that the employee is sponsored. An HR system may overwrite historic contact information. A sponsored worker may move to a different normal work location without the sponsorship team being told. An SMS user may become inactive. The Authorising Officer may be named correctly on the licence while having limited visibility of how sponsorship is being managed.

These are the types of weaknesses a meaningful mock audit should expose.

The exercise should therefore connect the complete compliance chain:

Sponsor Licence → SMS → Sponsored Worker → HR Records → Payroll → Managers → Working Practices → Evidence → Sponsor Action.

Where those elements correspond, the organisation is better placed to evidence how its sponsor duties are being managed.

Where they diverge, the employer should understand why, determine the applicable sponsor requirement and take appropriate corrective action.

A mock audit should not attempt to create the appearance of perfect historic compliance. It should establish the true position, identify weaknesses, preserve an accurate historical record and improve the systems responsible for future compliance.

The most effective approach is therefore continuous:

Test → Identify → Investigate → Remediate → Re-Test → Monitor.

For employers facing an anticipated Home Office compliance check, concerned about possible sponsor breaches or seeking independent assurance over their sponsorship arrangements, early review provides the opportunity to understand the compliance position and address identified weaknesses on an informed basis.

DavidsonMorris supports sponsor licence holders with mock audits, sponsor compliance reviews, Home Office compliance checks and remediation of identified sponsorship issues.

 

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