The situation
The organisation employed several hundred people, including a substantial number of sponsored workers. It received a formal Home Office request for information concerning whether those workers were receiving the salaries recorded on their Certificates of Sponsorship.
The request covered several months of payroll activity across the entire sponsored workforce. It required employment contracts, payslips, payroll and tax information, business bank statements and evidence of individual payments.
The Home Office expressly raised the possibility of sponsor licence revocation. For a business providing care services, the investigation carried significant implications for staffing and continuity of service.
The challenge
The sponsor had a short deadline to assemble and explain a substantial volume of evidence held across HR, payroll and finance.
Each worker’s records needed to be reconciled across several sources. Contractual salary and hours, gross pay, deductions, net pay and payments from the employer’s bank account all needed to be traced to the correct individual and pay period.
Any apparent difference required investigation. We needed to establish its cause, the period affected and the evidence supporting an explanation, then assess the position against the requirements applicable to that worker.
Our approach
Our immediate priority was to assess the work required within the response period and consider whether an extension should be sought. Preparation continued on the basis that the original deadline might remain in place.
The core investigation involved worker-by-worker reconciliation. We examined the salary and hours recorded on the Certificate of Sponsorship, the employment contract, payroll information and evidence of payment.
Gross and net figures needed to be distinguished, deductions explained and bank payments matched to the relevant payroll period. Where payments were made in bulk, the reconciliation needed to show how the total related to individual workers.
We investigated matters capable of explaining differences between records, including changes in hours, absences and employment beginning or ending part-way through a pay period. Each explanation needed to be supported by documents and assessed against the applicable immigration requirements.
The review also considered whether changes had required action under the organisation’s sponsor reporting duties. We examined how salary and hours information passed between payroll, HR and those managing sponsorship, including responsibility for identifying changes requiring further assessment.
Evidence management was a substantial part of the work. The records needed to be organised so the Home Office could follow the relationship between contractual pay, payroll calculations and actual payments. Our approach used worker-level analysis to identify where an individual explanation or supporting document was required.
The wider representations also addressed the organisation’s care services and the operational consequences of an adverse decision. That context accompanied the detailed response to the salary concerns.
Value delivered
Our work brought employment, payroll, banking and sponsorship evidence into a coordinated analysis of the Home Office’s concerns.
The preparation gave the organisation a clearer basis for explaining individual pay records, identifying discrepancies requiring attention and supporting its account with documentary evidence.
It also examined the sponsor management processes connecting HR and payroll, including how changes were escalated to those responsible for immigration compliance.
Sponsor salary investigation support
DavidsonMorris advises employers responding to Home Office salary and payroll enquiries, requests for sponsorship evidence and related compliance investigations. Our support includes reviewing employment records, reconciling payment evidence and advising on discrepancies and reporting obligations.
Speak to our team about a Home Office salary investigation →
