The situation
The organisation wanted to assess how its immigration compliance arrangements were operating. Management sought an independent review of its sponsorship and right to work systems, including whether its records could demonstrate that the required processes were being followed.
The instruction was proactive. The employer had received neither a suspension notice nor a Home Office request for information, allowing the review to take place while the organisation had time to consider findings and plan any necessary improvements.
The challenge
The audit needed to establish how sponsorship responsibilities were carried out across the business. Written procedures formed part of the evidence, alongside worker records and explanations from the people responsible for recruitment, record keeping, payroll and sponsor reporting.
A central question was whether information reached the appropriate person when a worker’s circumstances changed. A manager might know about revised duties or working arrangements, while the Level 1 User depended on that information to assess whether sponsor action was required.
The review also needed to examine the causes of any gaps in the records. An omission could arise because a document had never been obtained, was stored elsewhere or fell between departments with different expectations about who was responsible. Each explanation called for a different response.
Our approach
Preparation began with access to our client portal and audit platform. We requested details of the sponsored workforce through a structured spreadsheet and provided a proposed agenda identifying the areas for examination and the personnel needed for the audit.
The substantive review took place live through Teams. We questioned the staff responsible for compliance and examined a sample of existing sponsored worker files to test how the organisation’s procedures were being applied.
File sampling allowed us to compare sponsorship information with employment and HR records. The review considered whether the required evidence was being obtained, retained and updated, and whether staff could retrieve it when needed. We examined the reasons behind any omissions to assess whether they reflected an individual error or a weakness affecting the wider process.
Our work also covered right to work procedures, including how checks were conducted before employment and how the organisation monitored time-limited permission. We followed the process beyond the recording of an expiry date to examine who received reminders, who contacted the worker and how follow-up action was completed and recorded.
Discussions with relevant personnel tested the allocation of responsibilities and how information passed between teams. We examined how changes involving sponsored workers reached those responsible for assessing reporting requirements, alongside the arrangements for maintaining compliance when a key individual was unavailable.
Following the audit, we discussed the findings and recommended follow-up action. Completed audit questionnaires, with our comments, were uploaded to the client portal to provide a documented record of the review.
Value delivered
The employer received an independent assessment of its current systems, supported by findings from sampled records and discussions with the people operating those systems.
The documented recommendations gave management a basis for prioritising improvements, allocating responsibility and reviewing progress. HR and those responsible for sponsorship could use the findings to address gaps in records, clarify responsibilities or strengthen processes where the audit identified a need for action.
Commissioning the review proactively gave the organisation time to consider the recommendations without the pressure of an active Home Office investigation or response deadline.
Sponsor licence audit support
DavidsonMorris provides digital and on-site sponsor licence compliance audits. Our reviews can cover sponsored worker records, right to work procedures, Sponsor Management System processes and the allocation of compliance responsibilities across the business.
Speak to our team about a sponsor licence compliance audit →
