Appendix D: Sponsor Licence Record Keeping

Section A: What is Appendix D?

Appendix D is an appendix to the Home Office sponsor guidance that sets out the record-keeping requirements for sponsor licence holders under the wider sponsor licence duties. It specifies the documents that UK employers must retain for each individual they sponsor under various immigration routes, such as the Skilled Worker, Temporary Worker and Global Business Mobility routes. Sponsors of students must follow the Student Sponsor Guidance for record-keeping. The Appendix should be read in conjunction with the Home Office’s full sponsor guidance.

Appendix D was introduced to create a consistent framework for sponsorship compliance, ensuring that the Home Office can verify sponsors’ actions against the immigration rules. It is designed to remove ambiguity over what must be retained and for how long. Without this evidence trail, UKVI cannot confirm compliance, and sponsors risk enforcement even if the underlying activity was compliant.

The appendix covers:

• The types of documents that must be kept (e.g. passport copies, contracts, payslips, proof of qualifications)
• The format in which records must be stored (paper or digital)
• The length of time documents must be retained, including keeping records for the full sponsorship period and until the earlier of one year after sponsorship ends or examination and approval by a compliance officer
• Route-specific requirements (e.g. additional documents for GBM routes)

Appendix D duties are in addition to standard HR or payroll record-keeping and operate alongside other legal obligations such as right to work checks and data protection rules. Relying solely on ordinary HR files is unlikely to meet the Appendix D requirements, and gaps will be treated as non-compliance.

Failing to comply with Appendix D can result in enforcement action, including licence suspension or revocation, so sponsors must ensure documents are up to date, securely stored, and readily available for inspection by the Home Office. Inspections may be announced or unannounced, and an inability to produce documents when asked will usually be treated as a breach in itself.

The Home Office also updates the guidance periodically to reflect policy changes, such as the introduction of the eVisa system. Sponsors should regularly review the latest version and adjust their HR systems and processes to remain compliant.

Section B: Appendix D Documents

Importantly, all documents submitted as part of your sponsorship licence application must be retained and accessible for the duration of your licence validity. These records form the foundation of your compliance history and will be scrutinised in any Home Office review of your licence.

Appendix D then specifies the ongoing records sponsors must keep for each individual worker sponsored under the licence. The purpose is to provide a verifiable evidence base that the role is genuine, that the worker is appropriately qualified and paid, and that the sponsor has discharged its compliance duties in line with immigration rules. These documents are not optional: they must be kept in the format and for the period set out by the Home Office.

UKVI inspections often focus heavily on Appendix D compliance, and caseworkers will usually ask to see a sample of sponsored workers’ files. For this reason, it is advisable to maintain a dedicated file for each sponsored worker, clearly labelled and containing the documents required under Appendix D. Where records are stored electronically, they must be organised and accessible without delay in the event of an inspection.

1. Part 1: documents for sponsored workers

There are various documents that you must keep for each sponsored worker. These include:

• Proof of the individual’s right to work.
• Evidence of the worker’s date of entry to the UK where relevant. If the worker has an entry clearance vignette and an entry stamp, keep a copy of the passport page that shows the vignette and the entry stamp. For workers with an eVisa issued for entry clearance, keep a copy of the passport page showing the entry stamp where one is given. Note that some workers will not have an entry stamp, for example certain arrivals within the Common Travel Area or where no stamp is placed.
• A record of the worker’s national insurance number, unless the migrant is exempt from requiring one. This could include a copy of, for example, their NI card or NI number notification letter from HM Revenue & Customs or the Department for Work and Pensions, their wage slip or their P45/P60. In some cases, the NI number will be recorded on the BRP or in the result of an online right to work check.
• A history of the worker’s up-to-date contact details, ie; their UK residential address, personal email address and telephone number.
• If employing a child aged under 18, a copy of a letter from the worker’s parents or legal guardian, or just one parent if that parent has sole legal responsibility for the child, consenting to the arrangements that have been made with regard to the child’s application, travel, reception and care arrangements in the UK.
• A copy of the worker’s Disclosure and Barring Service (DBS) check where required for the role undertaken by the sponsored migrant.
• A record of the worker’s absences.
• Any other document set out in the relevant government guidance and codes of practice.
• If you are sponsoring under the GBM Service Supplier route, you will need to retain a copy of any contract you have awarded for the supply of service to you and either of the following:
  • the tender document for that contract
  • evidence of how the contract was awarded if it was not formally tendered
• If you are sponsoring under the GBM Secondment route, you will need to retain a copy of any relevant agreement or contract for goods or investment to which both you and the overseas business are parties. For each such agreement or contract, you must also keep one of the following:
  • evidence of how you were awarded the contract or investment, such as a tender application or investment application
  • a tender document for a contract for goods
  • evidence of how the contract for goods was awarded if it was not formally tendered

In most cases, you would keep a copy of each sponsored worker’s current passport pages showing all personal identity details, including biometric details, and relevant leave stamps, or immigration status document including their period of leave to remain in the UK, and a copy of their biometric residence permit (BRP) if they have one or eVisa if applicable. Records must be legible, attributable and readily retrievable on request. Sponsors should also review the list of required documents periodically, as Appendix D is updated in line with policy changes.

2. Sponsored worker record checklist

The table below provides a quick-reference checklist of the documents that sponsors are required to retain for each sponsored worker under Appendix D. Keeping a structured checklist for every sponsored worker file makes it easier to identify gaps before a compliance visit. Employers should review each file against the checklist at regular intervals to ensure continued compliance.

Maintaining files in line with this checklist not only demonstrates compliance but also streamlines the process of producing documents during an inspection. Employers who cannot produce records quickly are often treated as non-compliant, even if the documents exist elsewhere in the organisation.

3. Part 2: Documentary proof of the recruitment process

Sponsors must retain evidence of the recruitment process for all sponsored worker roles. This requirement continues even though the Resident Labour Market Test is no longer mandatory for most routes. UKVI expects to see evidence that the role is genuine and that the sponsored worker was recruited on merit rather than for the purpose of securing a visa.

The list of documents you may need to provide includes:

• All applications shortlisted for interview, for example CVs, application forms or emails
• The names and total number of applicants shortlisted for final interview
• Interview notes or other documentation for each settled worker who was not hired, explaining the reasons they were not employed
• Copies of adverts placed, or clear records of the content, dates and locations of any adverts used
• At least one piece of evidence demonstrating how the successful candidate was chosen, such as scored interview sheets or selection panel notes

If the role was not advertised, you must keep a clear record explaining how the individual was identified as suitable. UKVI may ask for evidence of internal processes, such as referrals, headhunting or redeployment decisions. These requirements apply across all sponsored roles and will be scrutinised at inspection to confirm that vacancies are genuine.

Employers should also be aware that recruitment evidence requirements may vary depending on the route. For example, there were temporary additional checks for care worker recruitment earlier in 2025. Appendix D is updated periodically, and sponsors must ensure they follow the version in force at the time of recruitment.

4. Part 3: Proof of rates of pay

When sponsoring workers, you can only assign a Certificate of Sponsorship (CoS) where the job is eligible for sponsorship. This includes meeting the minimum salary threshold for the relevant route and paying the worker at a rate consistent with the terms stated on the CoS. Appendix D requires sponsors to retain detailed evidence showing that pay requirements are met in practice, not just at the point of application.

As proof of compliance with the sponsored visa salary threshold, you must keep copies of the following:

• Copies of the worker’s payslips, clearly showing the name, NI number, tax code, any allowances paid and deductions made.
• Evidence of the amount and frequency of salary payments, for example bank transfer records showing the worker’s wages being deposited. Where alternative records are used, UKVI must be able to clearly identify the worker’s individual payments.
• A copy of any contract of employment or written statement of employment particulars between you and the worker. This should include both parties’ names and signatures, the start and end dates of the contract, details of the job, the working hours and the agreed rate of pay.
• Evidence of any allowances provided, where these are part of the package, unless they are clearly shown on payslips or in the contract.
• Any other documentation required under the immigration rules or the relevant code of practice at the time the CoS was assigned.

It is not sufficient to show that the salary was offered at the correct level on the CoS. UKVI will test compliance by looking at whether the worker was actually paid in line with those terms. Where records are incomplete or unclear, the Home Office may conclude that the sponsor has failed to comply with salary rules, even if the worker was paid correctly in practice.

Sponsors should therefore ensure their payroll processes are aligned with Appendix D requirements. Payroll and HR teams must work closely so that payslips, contracts and payment evidence are securely stored together and can be produced quickly. Inconsistent or missing evidence of payment is one of the most common reasons for adverse findings in sponsor compliance visits.

5. Part 4: Proof of skill level and qualifications

A further requirement is that you can only assign a Certificate of Sponsorship (CoS) to workers where the role is eligible for sponsorship in terms of skill level. Appendix D sets out the records you must keep to evidence that the job meets the correct threshold and that the individual has the necessary qualifications or experience.

You should retain a detailed and specific job description outlining the duties and responsibilities of the post, including the skills, qualifications and experience required. This document helps demonstrate to UKVI that the vacancy is genuine and meets the criteria for the relevant visa route.

In addition, you must keep evidence that the worker holds the required qualifications or has the experience needed to perform the role. The types of documents you may need to retain include:

• Copies of any qualifications the migrant holds that confirm skill level, such as a degree certificate or diploma.
• References from previous employers that demonstrate relevant work experience.
• Professional registration or accreditation documents, where the role requires formal registration with a UK body or regulator.
• Confirmation letters or certificates that evidence the worker is permitted to practise in a regulated profession in the UK.
• Any other evidence that shows the individual has the skills and experience to do the job as described on the CoS.

UKVI will expect to see a clear link between the requirements of the role and the worker’s qualifications or experience. For regulated roles, such as healthcare positions, it is not enough to keep generic qualifications; you must also retain proof of the required professional registration. Where records are missing or incomplete, the Home Office may conclude that the worker does not meet the skill level required for sponsorship, which can put your licence at risk.

As best practice, sponsors should keep copies of both the job description and supporting evidence in a single, easily identifiable file for each sponsored worker. This allows compliance officers to cross-check the worker’s qualifications against the role description quickly and reduces the risk of adverse findings during an audit.

Section C: Sponsor Record Keeping Rules

Appendix D does not just list the documents that must be retained, it also sets out the rules on how long those records must be kept and in what condition they should be available. Sponsors who misunderstand these rules often fall into compliance difficulties, not because they failed to collect the right documents, but because they disposed of them too soon or could not retrieve them when requested. UKVI caseworkers assess both the completeness and the accessibility of records during a compliance inspection.

1. How Long to Retain Appendix D Documents

In relation to sponsored workers, all relevant documents listed under Appendix D must be kept for the full period of sponsorship and until the earlier of the following:

• One year from the date you end your sponsorship of the migrant; or
• The date the documents have been examined and approved by a compliance officer, if this occurs within that one-year period after sponsorship ends.

If you sponsored the worker for less than one year, you must retain the documents for the duration of sponsorship or until they are examined and approved by a compliance officer within that one-year period. Sponsors must also be alert to other legal obligations that may require records to be held for longer, such as right to work checks under the Prevention of Illegal Working Regime, which requires retention for two years after employment ends.

In addition to immigration rules, organisations must comply with data protection law. This means ensuring personal data is not kept longer than necessary, while still meeting immigration retention periods. Balancing these obligations requires well-designed HR systems and clear internal policies on retention, deletion and audit.

2. Retention periods by obligation

The table below summarises the minimum retention periods that apply to core sponsorship and employment documents. Where multiple regimes apply, keep records for the longest relevant period.

Employers should ensure their HR teams understand these timelines clearly. It is common for payroll or HR staff to delete files in line with standard retention policies without realising that immigration rules require longer retention. Once deleted, the documents cannot be recreated, and this leaves the business exposed during an audit.

3. How to keep Appendix D Records

While Appendix D specifies which documents are to be retained, it does not prescribe a storage method. Records can be kept as paper or electronic copies, provided they are legible, complete and easily attributable to the individual worker concerned. UKVI expects sponsors to be able to produce records promptly, regardless of format, so systems must be organised and reliable.

Paper files should be clearly labelled, securely stored and accessible to compliance staff. Electronic files should be stored in a structured way, with file names that make the contents easy to identify. Employers should also test their systems periodically to confirm that documents can be retrieved quickly. A delay in producing documents during a compliance visit will usually be treated as a failure, even if the documents exist somewhere within the organisation.

Employers must also ensure that access to records complies with UK GDPR and data protection law. Sensitive data such as immigration status and personal addresses should be securely protected, with access limited to authorised staff. Encrypting digital files and applying clear access controls are considered best practice.

Section D: Appendix D & Compliance Risks

The Home Office has extensive powers to investigate sponsor licence holders for immigration breaches. These powers are exercised through both desk-based and onsite inspections, and they extend to every aspect of sponsor duties, with Appendix D record-keeping often forming the focus of review. Compliance is assessed not only by whether you have retained the right documents, but also whether they are complete, accurate and retrievable without delay.

Sponsors can be subject to an online compliance check or an onsite compliance visit, announced or unannounced, at any point during the validity of the licence. UKVI officers will typically request a sample of sponsored worker files and will expect these to be produced immediately. If the files are not available, or if they are incomplete, UKVI may record this as a breach of sponsor duties.

The consequences of poor record-keeping are severe. Failure to produce documents promptly during a compliance visit can be treated as evidence that sponsorship duties are not being met. The Home Office may then decide to take enforcement action, which could involve:

• Downgrading your licence rating, leading to increased Home Office oversight and additional costs for an action plan
• Suspending your licence, which prevents the assignment of new Certificates of Sponsorship and jeopardises recruitment plans
• Revoking your licence entirely, which will curtail the visas of your sponsored workers and force them to leave their jobs

These actions have direct operational, financial and reputational consequences. Losing sponsored staff at short notice can disrupt projects, damage client relationships and create workforce gaps that are difficult to fill. In heavily regulated sectors such as healthcare, the impact of sudden staff losses can also have serious compliance implications with sector regulators.

It is also important to note that compliance visits are not limited to high-risk sponsors. UKVI has the discretion to visit any licence holder at any time, regardless of size or sector, and unannounced visits are increasingly common. Employers should therefore assume that they could be inspected without warning and should maintain records in a constant state of readiness. A “tidy-up” only when a visit is expected will not be sufficient.

To manage these risks, sponsors should conduct regular internal audits of their Appendix D records, ensure HR systems are robust enough to produce documents quickly, and train all relevant staff on what records must be kept and why. Treating record-keeping as a live compliance function rather than a one-off administrative exercise is the most effective way to avoid enforcement action.

Section E: Summary

Appendix D sits at the heart of the sponsor licence regime. It is the evidence base that UKVI relies on to determine whether an organisation is meeting its sponsorship duties. While many of the required records overlap with standard HR and payroll documentation, the requirements are not identical. Sponsors who assume that their existing files will be sufficient risk finding gaps only when UKVI arrives for an inspection. At that point, it is too late to correct omissions, and the organisation is exposed to licence downgrades, suspension or revocation.

The consequences of non-compliance extend beyond immigration penalties. Losing a sponsor licence can result in the enforced departure of sponsored workers, project delays, business disruption and reputational harm. In highly regulated industries, such disruption can also create problems with sector regulators and clients who rely on continuity of service. The commercial impact of weak record-keeping therefore goes far beyond the immigration team or HR function.

Sponsors should approach Appendix D compliance as a daily operational responsibility, integrated into wider HR and workforce management systems. This means maintaining dedicated records for each sponsored worker, regularly auditing files against the Home Office requirements, and ensuring payroll and HR teams work together to keep evidence consistent and retrievable. Staff training and clear internal processes are vital to prevent documents being misfiled or deleted too soon.

With inspections increasingly carried out without notice, the only safe strategy is to keep records in a constant state of readiness. Well-organised, accessible records are the strongest protection against Home Office enforcement action.

Section F: Need Assistance?

Sponsor licence compliance is best approached as a daily concern. By integrating good record-keeping practices into the organisation’s standard HR and personnel processes, sponsors can ensure compliance and consistency, and avoid enforcement action.

Our business immigration specialists have extensive experience in supporting organisations through the lifecycle of their licence, from the initial application to ongoing compliance and licence management. For advice on any aspect of managing your sponsor licence, including record-keeping, contact us.

Section G: Appendix D FAQs

What is Appendix D?

Appendix D is an appendix to the UK sponsor guidance that sets out the documents licensed sponsors must retain to comply with their sponsor licence duties. It applies to sponsors of workers under the Skilled Worker, Global Business Mobility, and Temporary Worker routes. Sponsors of students should follow the Student Sponsor Guidance.

Why is Appendix D important?

Failure to retain the required records can result in enforcement action by the Home Office, including the suspension or revocation of your sponsor licence. UKVI may request to inspect these records at any time, often without notice.

How long do we need to keep records for sponsored workers?

You must retain Appendix D records for the full period of sponsorship and until the earlier of one year from the date you end sponsorship of the worker, or the date a UKVI compliance officer has reviewed and approved the documents if that occurs within that year. If the worker was sponsored for less than a year, the records must be kept for the full duration of sponsorship or until reviewed within that one-year period.

Can we store Appendix D documents electronically?

The guidance does not prescribe a format, so records can be stored electronically or in hard copy. However, they must be clearly organised, securely stored, and made available to UKVI promptly on request.

What types of documents must be kept for sponsored workers?

You must retain identity documents, proof of right to work, contracts of employment, salary records, job descriptions, evidence of recruitment where applicable, absence records, and any documentation relating to role-specific requirements, such as professional accreditations or contracts under Global Business Mobility routes.

Are there different record-keeping rules for students?

Licensed student sponsors must follow the Student Sponsor Guidance. Records include passports and visas, attendance and contact records and, where applicable, ATAS certificates and evidence of qualifications assessed at the admissions stage. Different rules apply for Child Students and for institutions endorsing Start up and Graduate route workers.

Do we need to keep records of the recruitment process?

If the route requires a genuine vacancy or salary threshold to be met, you should retain recruitment records such as CVs, interview notes, and evidence showing why any settled workers were not hired. Even though the Resident Labour Market Test has been abolished, sponsors still need to evidence how a worker was selected, including adverts where used and at least one item evidencing selection.

Do salary records need to show every payment?

Yes. You must keep payslips and proof of payment that clearly show the worker was paid the correct amount in line with the CoS and the rules for their visa route. If the salary includes allowances, you must keep records that confirm the value and purpose of those allowances.

What happens if we fail to provide documents during a compliance visit?

UKVI may treat this as a breach of your sponsor duties. This could result in your licence being downgraded, suspended, or revoked. All documents must be readily accessible and available upon request to avoid enforcement action.

How can we ensure we remain compliant with Appendix D?

Maintain well-organised digital or physical files for each sponsored worker and student. Conduct regular internal audits, train relevant staff, and ensure HR and compliance teams understand what documents must be retained and for how long.

Section H: Glossary

Section I: Additional Resources