Home Office Sponsor Compliance Checks: What to Expect

Home Office Sponsor Compliance Checks: At a Glance

A Home Office sponsor compliance check is UKVI scrutiny of whether an organisation continues to meet its sponsor duties and remains suitable to hold a sponsor licence.

Compliance checks can take several forms. UKVI may request documents or information, verify records against data held elsewhere in government, interview Key Personnel or sponsored workers, carry out an onsite visit or conduct a digital compliance check remotely. Onsite visits may be announced or unannounced.

UKVI can examine far more than retained documents. A compliance check may test the organisation’s HR systems, Sponsor Management System (SMS) records, payroll and salary data, right to work controls and whether the role described on a worker’s Certificate of Sponsorship (CoS) reflects the employment in practice.

Sponsored workers may also be interviewed about their duties, pay, working arrangements and place of work. UKVI can compare those answers with the sponsor’s records and information already held by the Home Office.

Where compliance concerns are identified, action can affect the organisation’s ability to sponsor workers and may include a reduction in CoS allocation, downgrade to a B-rating with an action plan where appropriate, suspension or revocation.

This guide explains how Home Office sponsor compliance checks work, what UKVI may examine, when checks can take place and how employers should prepare for scrutiny.

 

Section A: What Is a Home Office Sponsor Compliance Check?

 

A Home Office sponsor compliance check is the wider process UKVI uses to assess whether an organisation is complying with the sponsorship system. For an existing sponsor, the central question is whether the organisation continues to meet its sponsor duties and remains suitable to hold a sponsor licence.

A compliance check does not necessarily involve a physical visit. UKVI can use one or several forms of scrutiny depending on the circumstances.

These can include:

 

• requesting documents or other information from the sponsor;
• checking information previously provided to the Home Office;
• examining the sponsor’s HR records and systems;
• interviewing Key Personnel and other employees;
• interviewing current or previously sponsored workers;
• carrying out an onsite compliance visit;
• conducting a digital compliance check using remote video conferencing;
• checking information held by other government departments, agencies or public bodies; and
• verifying information relating to sponsored workers, including employment and salary information.

 

A compliance check is therefore the wider Home Office scrutiny process. A physical compliance visit is one method UKVI may use within that process.

 

1. What Does UKVI Assess During a Sponsor Compliance Check?

 

UKVI uses compliance checks to test whether sponsorship is being managed correctly across the organisation.

The Home Office may assess whether the sponsor:

 

• continues to meet the requirements for holding a sponsor licence;
• is complying with its sponsor duties;
• has appropriate HR systems and processes in place;
• is maintaining the records required under the sponsor guidance;
• is monitoring its sponsored workers appropriately;
• is reporting relevant changes to UKVI;
• is complying with its wider obligations relating to immigration and right to work;
• is sponsoring workers in genuine and eligible roles;
• is paying sponsored workers in accordance with the requirements applying to their sponsorship; and
• has provided accurate information to the Home Office.

 

The assessment can move beyond whether individual documents exist. UKVI may test whether the organisation’s procedures operate as described and whether its records correspond with actual employment practices.

For example, an absence monitoring policy carries limited weight if absences are not recorded or relevant cases are not escalated for sponsor reporting review. Likewise, an employment contract will not resolve a compliance concern where the worker’s actual duties, salary or place of work differ materially from the sponsorship information.

The central compliance question is whether the sponsor’s records, systems and actual employment practices are consistent with its sponsorship obligations.

 

2. When Can the Home Office Carry Out a Compliance Check?

 

UKVI can carry out compliance checks before or after a sponsor licence is granted.

For organisations applying for their first licence, the relevant issues are addressed separately in our guide to Sponsor Licence Pre-Licence Compliance Visits.

Existing licence holders remain subject to compliance scrutiny throughout the life of the licence. A successful sponsor licence application does not prevent UKVI from examining the organisation’s systems and sponsored workforce later.

A sponsor may therefore be checked at any stage while it remains licensed, including after many years of sponsorship activity.

 

3. Does a Compliance Check Mean UKVI Suspects Non-Compliance?

 

No. A compliance check does not, by itself, mean that UKVI has concluded the sponsor has breached its duties.

Compliance activity forms part of the Home Office’s ongoing oversight of the sponsorship system. In some cases, however, scrutiny may be prompted by information suggesting that a particular aspect of the sponsor’s arrangements requires closer examination.

Relevant information can arise from immigration applications, government records, previous compliance activity, allegations or other evidence available to UKVI.

The scope and intensity of a check can therefore vary. Employers should nevertheless treat every compliance check seriously because concerns identified during the exercise can lead to wider Home Office action even where they were unrelated to the original reason for scrutiny.

 

4. Can UKVI Check a Sponsor Without Visiting Its Premises?

 

Yes. A physical visit is only one form of sponsor compliance checking.

UKVI can request documents and information, undertake verification activity, use information held elsewhere in government and conduct digital compliance checks using remote video conferencing.

For organisations operating through hybrid, remote or geographically dispersed working arrangements, compliance therefore depends on the sponsor retaining effective oversight wherever sponsored workers are based.

Where a physical inspection is considered appropriate, Home Office guidance allows compliance activity at addresses where sponsored workers carry out their duties. Depending on the circumstances, this can include another branch or operational site, a client or third-party location and, where a sponsored worker normally works from home, their home address.

Home-based working does not place sponsored employment outside the scope of Home Office scrutiny. Sponsors should maintain compliance readiness as an ongoing organisational requirement, with records, systems and responsible personnel capable of responding whenever UKVI carries out a check.

 

 

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Section B: Why Does the Home Office Carry Out Sponsor Compliance Checks?

 

The Home Office carries out sponsor compliance checks to protect the integrity of the sponsorship system and to determine whether licensed sponsors continue to meet the requirements attached to their licences.

Holding a sponsor licence gives an organisation significant responsibilities. A sponsor can facilitate a worker’s access to a sponsored immigration route and is expected to provide accurate information to UKVI, maintain appropriate records, monitor sponsored workers and report relevant changes.

UKVI therefore maintains oversight of licensed sponsors throughout the life of the licence.

A compliance check may form part of routine Home Office monitoring, or it may be prompted by information that causes UKVI to examine a particular sponsor, worker or aspect of the organisation’s sponsorship arrangements.

 

1. Can UKVI carry out a check because it suspects a sponsor has breached its duties?

 

Yes.

Home Office sponsor guidance provides that compliance activity may be undertaken where UKVI has reasonable grounds to suspect that a sponsor has breached its duties or may no longer be suitable to hold a sponsor licence.

Previous compliance history can also be relevant, including poor compliance with the Home Office or other government departments.

However, the existence of a compliance check should not automatically be interpreted as an allegation of wrongdoing.

UKVI has broad compliance responsibilities and can examine licensed sponsors as part of its ongoing oversight of the sponsorship system.

 

2. What can trigger a sponsor compliance check?

 

There is no exhaustive list of circumstances that will result in a compliance check.

Information capable of attracting UKVI scrutiny can potentially arise from numerous sources.

Depending on the circumstances, this can include:

 

• concerns identified during previous Home Office compliance activity;
• information contained in a sponsored worker’s immigration application;
• discrepancies between information supplied by the sponsor and information held elsewhere by government;
• questions about whether a sponsored role is genuine or corresponds with the Certificate of Sponsorship;
• salary or payroll discrepancies;
• information suggesting sponsor duties have not been met;
• allegations made to the Home Office;
• intelligence or other information available to UKVI;
• possible illegal working or right to work concerns;
• information obtained from another government department or public body;
• previous sponsor licence problems or compliance failures; or
• other immigration or enforcement activity involving the organisation.

 

The Home Office can also use information gathered through one compliance issue to examine other aspects of the sponsor’s arrangements.

A check that begins with a concern relating to one worker can therefore expose wider weaknesses affecting the sponsor’s systems or other sponsored employees.

 

3. Can a sponsored worker’s visa application trigger scrutiny of the employer?

 

Potentially, yes.

Home Office compliance activity can take account of information contained in applications made by sponsored workers.

For example, UKVI may identify information that appears inconsistent with the details recorded on the worker’s Certificate of Sponsorship or with information previously provided by the employer.

This does not necessarily mean that the sponsor has breached its duties. There may be a legitimate explanation for a discrepancy.

However, UKVI can investigate further and may seek evidence from the sponsor to establish the correct position.

This illustrates why sponsors should ensure that information used for sponsorship accurately reflects the employment being offered and that subsequent changes are considered under the relevant reporting requirements.

 

4. Can payroll information lead to a compliance check?

 

Yes.

Salary is a significant area of sponsor compliance because many sponsored work routes impose specific salary requirements.

The Home Office conducts regular checks with HM Revenue & Customs (HMRC) to assess whether sponsored workers are being paid appropriately and in accordance with the Immigration Rules and sponsor guidance.

UKVI can therefore compare sponsorship information with payroll information available through HMRC.

A discrepancy does not automatically establish a breach. Differences may arise because of timing, permitted changes or other legitimate circumstances.

However, sponsors should be capable of reconciling the salary stated for sponsorship purposes with:

 

• the worker’s employment contract;
• payroll records;
• actual payments made;
• working hours;
• any periods of reduced or unpaid pay; and
• any relevant reports made to the Home Office.

 

Employers should not assume that UKVI’s understanding of sponsored salary is limited to the information entered on the CoS.

 

5. Can allegations or intelligence result in a compliance check?

 

Yes.

Home Office guidance allows UKVI to consider evidence and intelligence from a range of sources, including public allegations.

Information provided to the Home Office may therefore lead UKVI to investigate whether a sponsor is complying with its duties.

The existence of an allegation does not establish that it is true. A compliance check allows UKVI to test the information against the organisation’s records, systems and actual employment practices.

Employers should respond to the resulting compliance activity on the evidence rather than becoming focused solely on where they believe the allegation originated.

 

6. Can information from other government bodies be used?

 

Yes.

UKVI can make checks with other government departments, agencies and local authorities as part of its compliance activity.

This enables the Home Office to compare information supplied through the sponsorship system with information available elsewhere within government.

The practical consequence is that employers should assume that material information provided to UKVI may be capable of independent verification.

For example, payroll information may be considered alongside HMRC data, while other aspects of an organisation’s activities may be capable of verification through relevant public records or government sources.

 

7. Can previous compliance problems increase the likelihood of scrutiny?

 

Yes.

A sponsor’s previous compliance history can be relevant to future Home Office scrutiny.

Where an organisation has previously experienced compliance problems, UKVI may want to establish whether the underlying weaknesses have been corrected and whether improvements are operating effectively.

This makes remediation particularly important following any earlier compliance issue.

The organisation should not simply correct the individual record that exposed the problem. It should consider why the failure occurred and whether the same weakness could affect other sponsored workers.

Where appropriate, employers should be able to evidence the changes made following previous Home Office concerns, such as:

 

• revised compliance procedures;
• additional staff training;
• changes to responsibility and oversight;
• improved reporting processes;
• stronger HR and payroll communication; or
• additional internal sponsor compliance auditing.

 

8. What is UKVI ultimately trying to establish?

 

Although the immediate reason for a compliance check can vary, UKVI is ultimately assessing whether the organisation continues to meet the requirements of the sponsorship system.

This can include whether:

 

• information supplied to the Home Office is accurate and complete;
• the organisation continues to operate genuinely and lawfully;
• sponsored roles are genuine and meet the applicable requirements;
• the sponsor is complying with its record-keeping duties;
• required changes are being reported;
• appropriate systems exist to monitor sponsored workers;
• the organisation continues to meet the suitability requirements for holding a sponsor licence; and
• the reality of sponsored employment corresponds with the information on which sponsorship was based.

 

For employers, the recurring compliance principle is therefore consistency.

What the sponsor has told the Home Office, what its records show and what is happening in the workplace should align.

 

 

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Section C: Can a Sponsor Compliance Check Be Unannounced?

 

Yes. Home Office sponsor compliance visits can be announced or unannounced.

An employer should therefore not assume that UKVI will provide advance warning before attending its premises.

The ability to conduct an unannounced visit allows compliance officers to examine how the organisation operates during an ordinary working day rather than assessing systems that have only been prepared because a visit is expected.

This makes ongoing compliance readiness particularly important for sponsor licence holders.

 

1. How much notice does UKVI have to give?

 

There is no standard notice period that licensed sponsors can rely upon.

UKVI may contact the organisation to arrange compliance activity in advance, but the Home Office can also attend without prior notice.

Employers should therefore maintain their sponsor records and systems on the assumption that they may need to demonstrate compliance at short notice.

This includes ensuring that appropriate personnel know how to respond if compliance officers arrive when the organisation’s usual immigration or HR contact is unavailable.

 

2. What should happen if Home Office officers arrive unexpectedly?

 

The organisation should respond calmly and follow an established internal escalation procedure.

Relevant front-of-house or reception personnel should know that a legitimate Home Office compliance visit should be escalated promptly to the people responsible for the sponsor licence.

The initial response should include:

 

• asking the attending officers for official identification;
• verifying their identity where necessary;
• notifying the Authorising Officer, relevant Level 1 User, HR or other responsible personnel;
• cooperating with legitimate Home Office compliance activity; and
• avoiding speculative answers where the employee does not know the information requested.

 

Home Office guidance states that visiting compliance officers, including third parties carrying out visits on behalf of the Home Office, will have official Home Office identification.

If there is genuine doubt about whether an individual is acting for the Home Office, the sponsor can verify the position using the Home Office Business Helpdesk on 0300 123 4699.

Verification should be handled promptly and should not be used to obstruct or unnecessarily delay legitimate compliance activity.

 

3. Does the Authorising Officer have to be present?

 

An unannounced visit cannot safely be managed on the assumption that UKVI will attend only when the Authorising Officer is available.

The organisation should have sufficient resilience within its sponsor management arrangements to respond appropriately if a particular individual is absent.

Relevant personnel should know:

 

• who is responsible for the sponsor licence;
• where sponsored worker records are held;
• how relevant HR systems operate;
• who can access the Sponsor Management System;
• who can answer questions relating to payroll, recruitment or individual workers; and
• how the matter should be escalated internally.

 

The absence of one member of staff should not result in the organisation being unable to explain how sponsorship is managed.

 

4. Does the sponsor have to allow UKVI access?

 

Licensed sponsors are required to cooperate with Home Office compliance activity.

Current Home Office sponsor guidance requires sponsors to allow Home Office staff full access to premises or sites under the sponsor’s control on demand.

Depending on the scope of the compliance check, officers may want to inspect the workplace, examine relevant records and systems, establish where sponsored workers perform their duties and speak to relevant personnel.

A sponsor should not obstruct legitimate compliance activity or attempt to prevent officers from examining matters relevant to the organisation’s sponsor duties.

 

5. Can UKVI inspect locations other than the sponsor’s main office?

 

Yes.

Compliance checking is not necessarily confined to the address used as the organisation’s principal office.

Depending on the circumstances, UKVI may need to examine other premises or sites where the sponsor operates or where sponsored workers perform their duties.

This is particularly relevant for organisations with:

 

• multiple branches;
• regional offices;
• operational sites;
• remote workers;
• home-based sponsored workers; or
• sponsored workers based at client or third-party premises.

 

Where a sponsored worker normally works from home, Home Office guidance allows compliance checking at the physical address where the worker carries out their duties, which can include the worker’s home address where relevant.

Again, this should not be interpreted as meaning that UKVI routinely visits sponsored workers at home. It demonstrates that home working does not remove the employment arrangement from the scope of sponsor compliance checking.

 

6. What if sponsored workers are based at client or third-party sites?

 

The sponsor remains responsible for its sponsorship duties where sponsored workers carry out their work at a third-party or client location.

Home Office guidance requires the sponsor to ensure that the third party is aware that an unannounced compliance visit may take place and that the third party cooperates fully with Home Office compliance activity.

This is an important contractual and operational issue for sponsors using client-site working arrangements.

The employer should consider in advance how Home Office access would be managed and whether the relevant third party understands the sponsor’s immigration compliance obligations.

The current sponsor guidance is explicit that where the third party is uncooperative with a Home Office compliance check, the Home Office will take action against the sponsor.

Employers should therefore not leave UKVI access and cooperation arrangements to be negotiated for the first time when compliance officers arrive at the client site.

 

7. Does remote or hybrid working prevent an unannounced compliance check?

 

No.

Remote and hybrid working change how an employer may need to demonstrate compliance, but they do not remove the Home Office’s ability to scrutinise the sponsorship arrangement.

The sponsor should still know:

 

• where sponsored workers are working;
• what duties they are performing;
• who manages them;
• how attendance and absence are monitored;
• how relevant employment changes are communicated internally; and
• whether changes require action under the sponsor reporting requirements.

 

UKVI may also use digital compliance checking where appropriate.

For organisations with substantial remote working, this makes effective electronic record keeping, management oversight and communication between HR, managers and sponsor licence personnel particularly important.

 

8. Why are unannounced visits significant?

 

An unannounced compliance visit provides UKVI with an opportunity to assess the organisation’s normal operating position.

It can expose weaknesses that may be less obvious during a pre-arranged exercise, such as:

 

• staff not knowing who is responsible for sponsorship;
• records that cannot be retrieved;
• inconsistent explanations of a sponsored worker’s role;
• poor communication between HR and operational managers;
• unreported changes;
• weak attendance monitoring; or
• third-party working arrangements that the sponsor is not effectively overseeing.

 

The practical compliance standard is therefore not whether the organisation can prepare for UKVI given sufficient warning.

It is whether the sponsor is capable of demonstrating compliance on an ordinary working day.

 

 

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Section D: What Happens During a Home Office Compliance Check?

 

What happens during a Home Office sponsor compliance check will depend on the form of the check, the organisation being inspected and the issues UKVI wants to examine.

An onsite compliance visit can involve inspection of the workplace, examination of documents and HR systems, interviews with relevant employees and sponsored workers and comparison of the organisation’s records with information already held by the Home Office.

UKVI can also conduct elements of its compliance activity remotely, including through digital compliance checks.

The scope of a check should not be assumed to be limited to the particular worker or issue that appears to have triggered Home Office interest. If officers identify other potential compliance problems during the exercise, these can also become relevant.

As part of the formal compliance assessment, Home Office officers can assess relevant compliance criteria as Met or Not Met. A post-licence assessment recorded as Not Met can contribute to further sponsor licence action, including downgrading, suspension or revocation depending on the circumstances and the applicable sponsor guidance.

 

1. What happens when the compliance officers arrive?

 

During an onsite visit, the attending officers should identify themselves using official Home Office identification.

The organisation should verify their identity and notify the appropriate internal personnel.

Depending on the structure of the employer, this could include:

 

• the Authorising Officer;
• relevant Level 1 Users;
• HR personnel;
• the organisation’s compliance team;
• in-house legal personnel;
• senior management;
• relevant line managers;
• recruitment personnel; and
• payroll or finance personnel.

 

The sponsor should have a clear process for coordinating the visit rather than allowing requests to be handled independently by employees who may not understand the organisation’s sponsorship arrangements.

This does not mean that UKVI enquiries should be obstructed or controlled. The purpose is to ensure that requests are directed to the appropriate people and that accurate information is provided.

 

2. Will UKVI explain why it is carrying out the check?

 

The compliance officers may explain the nature or scope of the compliance activity, but employers should not assume that the check will remain confined to a single issue.

UKVI has broad compliance responsibilities and may examine matters relevant to whether the organisation continues to meet its sponsor duties and remains suitable to hold a sponsor licence.

If evidence obtained during the check indicates another potential compliance problem, the Home Office can investigate that issue as well.

Employers should therefore respond to the compliance exercise as a review of their sponsorship arrangements rather than preparing only for the issue they believe prompted the check.

 

3. What information can UKVI examine?

 

Home Office compliance activity can involve a wide range of information.

Officers may examine matters including:

 

• information supplied when the sponsor licence was obtained;
• information subsequently reported through the Sponsor Management System;
• Certificates of Sponsorship;
• sponsored worker records;
• employment contracts;
• job descriptions;
• salary and payroll information;
• working hours;
• work locations;
• attendance and absence records;
• right to work records;
• recruitment records;
• contact information;
• HR policies and procedures;
• the systems used to monitor sponsored workers; and
• other records required under the sponsor guidance.

 

UKVI can also verify information using other government departments, agencies, local authorities and other available evidence or intelligence.

 

4. Will the Home Office inspect the sponsor’s HR systems?

 

Potentially, yes.

Home Office sponsor guidance allows compliance officers to inspect records and systems relevant to the sponsor’s compliance obligations.

The officers may want to understand how the organisation manages matters such as:

 

• right to work;
• immigration permission;
• worker contact details;
• attendance and absence;
• changes to sponsored employment;
• salary and payroll;
• record keeping;
• reporting to UKVI; and
• internal escalation of sponsorship issues.

 

The fact that an organisation has a written compliance policy will not necessarily demonstrate that the system works.

UKVI may examine whether employees understand the procedures and whether the records show that those procedures are actually followed.

 

5. Can UKVI compare the CoS with the worker’s actual job?

 

Yes.

A central part of sponsor compliance is whether the worker is genuinely performing the role for which they have been sponsored.

UKVI may compare the information on the Certificate of Sponsorship with:

 

• the worker’s employment contract;
• the job description;
• information provided by the line manager;
• the worker’s own account;
• payroll information;
• working hours;
• the worker’s place of work; and
• what the worker is actually doing on a day-to-day basis.

 

Differences in terminology do not necessarily establish non-compliance. Job titles and internal descriptions can vary.

The important issue is whether the substance of the role remains consistent with the basis on which the worker was sponsored and continues to meet the applicable requirements.

 

6. Will UKVI check salaries and payroll?

 

It can.

UKVI may examine whether sponsored workers are being paid in accordance with the requirements applying to their sponsorship.

Compliance officers can consider:

 

• the salary recorded on the CoS;
• the worker’s contractual salary;
• actual payroll payments;
• working hours;
• salary changes;
• periods of reduced or unpaid pay;
• relevant deductions; and
• whether relevant changes were reported where required.

 

The Home Office also conducts regular checks with HMRC in relation to the pay of sponsored workers.

Employers should therefore be able to reconcile sponsorship information with their payroll records and explain legitimate differences where they exist.

 

7. Will UKVI check right to work compliance?

 

Yes. Right to work compliance can form part of Home Office scrutiny.

A sponsor is required to carry out an appropriate right to work check on any worker it sponsors, irrespective of the precise employment relationship, and retain the required evidence.

In addition, the statutory right to work checking regime applies more widely across the workforce. From 1 October 2026, the statutory checking responsibility was extended to specified additional working arrangements, including certain individuals engaged under a worker’s contract, individual subcontractors and certain arrangements facilitated through online matching services.

Employers should therefore ensure that their right to work procedures reflect the current regime and are not limited simply to conventional sponsored employees.

During sponsor compliance activity, UKVI may also identify potential illegal working concerns involving individuals outside the sponsored workforce.

Failure to comply with right to work requirements can expose an organisation to consequences beyond the sponsor licensing regime, including potential civil penalty and other enforcement action where applicable.

 

8. Can UKVI inspect the workplace?

 

Yes.

During an onsite compliance visit, officers may inspect the premises to understand how the organisation operates and where sponsored workers carry out their duties.

This can help UKVI assess whether the reality of the business corresponds with information previously supplied to the Home Office.

For example, the physical operation of the organisation may be relevant when considering:

 

• whether the business is genuinely operating;
• whether sponsored roles appear genuine;
• where sponsored workers are based;
• how workers are supervised;
• whether the organisation has the operational structure described to UKVI; and
• whether employment arrangements correspond with sponsorship information.

 

Sponsors are required to cooperate with compliance activity and allow Home Office staff full access to premises or sites under their control on demand.

 

9. Can UKVI interview employees during the check?

 

Yes.

Compliance officers may speak to individuals involved in the organisation’s sponsorship arrangements and can interview sponsored workers.

Depending on the issues being examined, relevant personnel could include:

 

• the Authorising Officer;
• Level 1 Users;
• HR personnel;
• recruitment employees;
• line managers;
• payroll or finance staff;
• directors or senior managers;
• other employees with relevant knowledge; and
• sponsored workers.

 

UKVI may compare the information obtained during interviews with documentary evidence and information already held by the Home Office.

Employers should not coach employees to provide predetermined answers. Personnel should answer questions truthfully and should avoid guessing where they do not know the answer.

 

10. Can the check continue after the officers leave?

 

Yes.

The physical visit may only be one stage of the compliance process.

UKVI may subsequently:

 

• review documents collected during the visit;
• compare different sources of information;
• carry out further government checks;
• request additional documents;
• seek clarification of information supplied;
• conduct further interviews; or
• investigate issues identified during the original check.

 

The organisation should therefore retain a clear record of the visit, including what was requested, what was supplied, who was interviewed and any matters that require follow-up.

 

11. Will the compliance officer tell the sponsor whether it has passed?

 

No immediate assessment should be expected.

Current Home Office sponsor guidance states that the compliance officer will not indicate their assessment during the compliance check.

Employers should therefore avoid drawing conclusions from:

 

• comments made by individual officers;
• the length of the visit;
• the number of documents requested;
• whether particular workers were interviewed; or
• the manner in which the officers leave the premises.

 

Once the Home Office has completed its checks and considered what action, if any, should follow, the sponsor will be notified of the Home Office’s decision in writing.

Further enquiries or requests for evidence may take place before that decision is reached.

Throughout the process, the recurring question is whether the sponsor’s records, systems, information reported to UKVI and the reality of sponsored employment tell the same story.

 

 

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Section E: What Documents Can the Home Office Ask to See?

 

Home Office compliance officers can ask to see documents and information relevant to assessing whether an organisation is meeting its sponsor duties and remains suitable to hold a sponsor licence.

The precise documents requested will depend on the organisation, the sponsored workers involved and the scope of the compliance check.

UKVI is not limited to examining documents originally submitted with the sponsor licence application. It can consider records created throughout the sponsorship relationship and compare those records with information held by the Home Office, other government bodies and the organisation’s actual employment practices.

Sponsors should also be familiar with the record-keeping requirements contained in Appendix D of the sponsor guidance, which sets out documents and information sponsors are required to retain.

 

1. Can UKVI ask to see sponsor licence records?

 

Yes.

UKVI may examine records relating to the administration of the sponsor licence itself.

Depending on the circumstances, this can include information concerning:

 

• the organisation’s current sponsor licence details;
• business and trading addresses;
• Key Personnel;
• SMS users;
• Certificates of Sponsorship assigned by the organisation;
• changes reported through the Sponsor Management System;
• the organisation’s sponsored worker population; and
• other information previously supplied to the Home Office.

 

The sponsor should be able to explain how responsibility for the licence is allocated and how information requiring Home Office action is identified and escalated internally.

 

2. Can the Home Office ask to see sponsored worker files?

 

Yes.

Sponsored worker files are likely to be important evidence during a compliance check.

Depending on the worker and immigration route, relevant records can include:

 

• identity and immigration documentation;
• evidence of the right to work check;
• contact information;
• employment contracts;
• job descriptions;
• recruitment records where these are required to be retained;
• evidence of relevant qualifications or professional registration where required;
• salary and payroll records;
• attendance and absence information;
• records relating to changes in employment; and
• other documentation required under Appendix D.

 

The precise record-keeping requirement depends on the circumstances, and employers should avoid applying a generic checklist without considering the current sponsor guidance and the particular sponsored route.

 

3. What right to work records should be available?

 

The sponsor should be able to produce evidence demonstrating that appropriate right to work checks have been carried out and retained.

For sponsored workers, the sponsor has a specific sponsor duty to conduct an appropriate right to work check on any worker it sponsors, whether or not the individual is employed by the sponsor under a conventional employment relationship.

Appendix D also requires sponsors to retain evidence of right to work checks on workers they employ, whether sponsored or not, as well as workers they sponsor whether or not they employ them.

Employers should therefore ensure that their records reflect the scope of the current requirements rather than treating right to work compliance as relevant only to conventional sponsored employees.

Evidence should demonstrate that the appropriate check was conducted at the required time and that the required record of the check has been retained.

Where an individual’s permission is time-limited and a further check is required, the organisation should also be able to demonstrate how this is identified and managed.

 

4. Can UKVI ask to see recruitment records?

 

Yes.

Home Office compliance officers can examine recruitment information relevant to sponsored workers, including records that the sponsor is required to retain under Appendix D.

The Home Office may want to understand how a sponsored worker was recruited and whether the recruitment process is consistent with the organisation’s explanation of the role.

Depending on the circumstances and applicable record-keeping requirements, relevant evidence can include:

 

• job advertisements;
• details of where a role was advertised;
• applications;
• shortlisting information;
• interview records;
• recruitment notes; and
• other evidence explaining the recruitment process.

 

Sponsors should retain the recruitment evidence required by the applicable sponsor guidance and should be able to explain how the successful worker came to be appointed.

 

5. Can the Home Office ask to see employment contracts and job descriptions?

 

Yes.

Employment documentation can be used to assess whether the sponsored employment corresponds with the basis on which the worker was sponsored.

UKVI may compare:

 

• the Certificate of Sponsorship;
• the employment contract;
• the written job description;
• information supplied by the worker;
• information supplied by the line manager; and
• the duties actually being performed.

 

The existence of a job description is not conclusive evidence that the sponsored role is compliant.

UKVI can examine the substance of the worker’s day-to-day employment to establish whether the role is genuine and whether it corresponds with the sponsored position.

 

6. Can UKVI request salary and payroll documents?

 

Yes.

Salary is an important area of sponsor compliance, and employers should be able to evidence what sponsored workers are actually being paid.

Relevant records can include:

 

• employment contracts;
• payslips;
• payroll records;
• records of salary changes;
• evidence relating to working hours;
• records concerning periods of reduced or unpaid pay; and
• other evidence relevant to the worker’s remuneration.

 

UKVI can compare these records with the salary stated on the Certificate of Sponsorship and information available from HMRC.

If there is a difference, the employer should be able to establish the chronology and explain the reason accurately.

 

7. Can UKVI ask for attendance and absence records?

 

Yes.

Sponsors are expected to monitor sponsored workers appropriately, and UKVI may examine how the organisation records and responds to attendance and absence.

The evidence available will depend on the employer’s working arrangements and could include:

 

• electronic attendance records;
• timesheets;
• rota information;
• absence records;
• holiday records;
• sickness records;
• manager records; and
• other evidence showing how attendance is monitored.

 

For remote and hybrid workers, the absence of a traditional clocking-in system does not remove the need for appropriate oversight.

The sponsor should be able to explain how it knows whether the worker is attending work and how unexplained absence or other relevant events are escalated.

 

8. Can the Home Office ask to see workers’ contact details?

 

Yes.

Sponsors have record-keeping obligations relating to sponsored workers’ contact information.

The organisation should have appropriate processes for maintaining the required details and updating them where necessary.

During a compliance check, UKVI may examine whether:

 

• required contact information is held;
• the information is current;
• the sponsor has a process for obtaining changes; and
• relevant records can be retrieved when required.

 

A policy requiring workers to notify HR of changes is more useful where the organisation can also demonstrate that the procedure operates in practice.

 

9. Can UKVI examine records of SMS reports?

 

Yes.

Reporting duties are a central part of sponsor compliance.

UKVI may examine whether relevant events were identified and whether required reports were made through the Sponsor Management System within the applicable requirements.

The Home Office may compare:

 

• HR records;
• payroll records;
• employment changes;
• attendance information;
• organisational records; and
• the sponsor’s SMS history.

 

This can expose situations where the underlying business knew about a change but the information was not escalated to the person responsible for the sponsor licence.

Employers should therefore ensure that sponsor reporting is integrated with their wider HR and management processes.

 

10. Can UKVI ask to see corporate or business records?

 

Potentially.

Where relevant to the compliance assessment, the Home Office may consider information about the organisation itself.

This can be particularly important where UKVI is examining whether the sponsor continues to operate genuinely and lawfully or whether information previously provided about the business remains accurate.

Depending on the circumstances, relevant evidence may concern matters such as:

 

• the organisation’s trading activities;
• corporate structure;
• business premises;
• operational arrangements;
• ownership or control; and
• other matters relevant to sponsor eligibility or suitability.

 

The precise documents required will depend on the issue being examined.

 

11. Do sponsor records have to be held on paper?

 

No. Sponsor records can generally be maintained electronically where this is consistent with the applicable record-keeping requirements.

What matters during a compliance check is that the organisation can produce the required records and demonstrate that they are reliable.

Employers using multiple electronic systems should consider whether relevant information can be retrieved efficiently.

A sponsored worker’s information may, for example, be spread across:

 

• an HR platform;
• a payroll system;
• an applicant tracking system;
• an absence management system;
• the SMS;
• electronic personnel files; and
• records held by operational managers.

 

The sponsor should understand how these sources fit together.

 

12. What if a required document is missing?

 

A missing document should be investigated rather than concealed.

The organisation should establish:

 

• whether the document was required to be retained;
• whether it exists elsewhere;
• why it is unavailable;
• whether equivalent contemporaneous evidence exists;
• whether other worker files have the same problem; and
• what corrective action is appropriate.

 

A missing record can be more significant where it reveals a wider failure in the sponsor’s record-keeping system.

Employers should not create or alter historic records in a way that misleadingly suggests that documentation existed at an earlier date when it did not.

If information has subsequently been reconstructed or a process corrected, the chronology should remain clear.

The objective is not simply to produce a complete-looking file for UKVI. It is to demonstrate that the organisation has maintained reliable records and can explain what happened, when it happened and how its sponsorship obligations were managed.

 

 

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Section F: What HR Systems Will the Home Office Check?

 

Home Office sponsor guidance requires organisations to have appropriate systems in place to meet their sponsor duties. During a compliance check, UKVI can examine whether those systems operate effectively in practice.

There is no requirement for every sponsor to use a particular HR software package or compliance platform. The appropriate system will depend on matters such as the organisation’s size, structure, sponsored worker population and working arrangements.

The central question is whether the organisation has reliable processes that allow it to meet its sponsorship obligations.

 

1. Will UKVI check how the sponsor monitors immigration permission?

 

Potentially, yes.

The organisation should have processes appropriate to its workforce for identifying and managing immigration and right to work requirements.

During a compliance check, UKVI may want to understand:

 

• how right to work checks are conducted;
• where evidence is retained;
• how time-limited permission is identified where follow-up is required;
• who is responsible for completing checks;
• how problems are escalated; and
• how the organisation ensures checks are completed at the appropriate time.

 

From 1 October 2026, employers should also ensure that their procedures reflect the expanded statutory right to work checking requirements applying to specified additional working arrangements, as well as the separate sponsor duty to check the right to work of any worker the organisation sponsors.

 

2. Will UKVI check attendance and absence monitoring?

 

Yes, this can form an important part of sponsor compliance scrutiny.

The sponsor should have an appropriate mechanism for monitoring sponsored workers and identifying relevant absences or changes.

The precise method will depend on the organisation.

For example, attendance may be monitored through:

 

• electronic access systems;
• timesheets;
• rotas;
• HR attendance systems;
• line management records;
• remote working systems; or
• a combination of different controls.

 

UKVI may be interested not only in whether attendance is recorded but also in what happens when a problem is identified.

An effective system should enable relevant information to reach the people responsible for considering whether Home Office reporting action is required.

 

3. Will the Home Office check how worker contact details are maintained?

 

It can.

Sponsors are required to retain specified contact information for sponsored workers.

The organisation should therefore have a process for obtaining and maintaining required information and for recording relevant changes.

UKVI may examine whether this system works in practice rather than merely asking whether a policy exists.

If worker details are consistently out of date, this may suggest that the underlying process is ineffective.

 

4. Will UKVI check how reportable events are identified?

 

Yes.

A sponsor can only meet its reporting duties if relevant information reaches the people responsible for the licence.

This means the Home Office may examine the internal communication processes connecting:

 

• line managers;
• HR;
• recruitment;
• payroll;
• finance;
• senior management;
• the Authorising Officer; and
• relevant Level 1 Users.

 

For example, payroll may know that a sponsored worker’s salary has changed, while the employee responsible for the SMS remains unaware.

Similarly, a line manager may know that a worker has changed duties or location without recognising that the change needs to be escalated for immigration consideration.

A functioning sponsor compliance system should bridge these gaps.

 

5. Will UKVI examine use of the Sponsor Management System?

 

Potentially, yes.

The SMS is central to the administration of a sponsor licence, and UKVI may consider whether it is being used appropriately.

This can include whether:

 

• appropriate users have access;
• former users have been removed or otherwise dealt with appropriately;
• Key Personnel information is current;
• required reports have been made;
• Certificates of Sponsorship are being assigned appropriately; and
• the organisation has effective controls around access and responsibility.

 

Employers should also account for the current transition away from the Level 2 User role.

Since 9 September 2026, sponsors can no longer appoint new Level 2 Users. Existing Level 2 Users can remain temporarily during the transitional period, but they must be converted to Level 1 Users, where eligible, or deactivated by 8 March 2027. Sponsors should therefore review any remaining Level 2 accounts and manage the transition appropriately.

The Home Office is also rolling out mandatory multi-factor authentication (MFA) across Sponsor Management System accounts. Rollout began on 3 September 2026 and is being introduced to existing sponsors on a phased basis, with completion expected by November 2026. MFA applies immediately to organisations granted a sponsor licence on or after 9 September 2026. Sponsors should ensure that Level 1 User date of birth, mobile number and email details are accurate for authentication purposes, that any remaining Level 2 Users have a current email address and that credentials and one-time passcodes are not shared.

Sponsors should also review inactive SMS User accounts. Current Home Office guidance treats an SMS User account as inactive where it has not been accessed for 12 months. Inactive accounts may be deactivated by the Home Office following the applicable review process. If this leaves the sponsor with no active Level 1 User, the Home Office can suspend the licence and allow 28 days for an eligible Level 1 User to be nominated, 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. Does UKVI expect sponsors to have written policies?

 

Written procedures can be valuable evidence of how the organisation intends to manage sponsor compliance, but policies alone are not sufficient.

UKVI can test whether the organisation’s actual practices correspond with its written procedures.

For example, an employer may have a policy requiring managers to report changes affecting sponsored workers to HR.

If managers are unaware of that obligation or there is no evidence that the process operates, the existence of the policy may provide limited reassurance.

Employers should therefore focus on both:

 

• documented compliance procedures; and
• evidence that those procedures operate in practice.

 

7. Who should be responsible for sponsor compliance?

 

Responsibility will vary between organisations, but sponsorship should have appropriate oversight and should not depend entirely on the knowledge of one junior employee.

The Authorising Officer has an important role in the governance of the sponsor licence, while Level 1 Users carry out relevant SMS functions.

Operational compliance may also involve HR, payroll, recruitment, managers, legal and other functions.

The organisation should be able to explain:

 

• who has overall responsibility;
• who performs particular compliance tasks;
• how information is escalated;
• who can access relevant records;
• who makes SMS reports; and
• what happens when the usual responsible person is unavailable.

 

A resilient system should continue to function despite ordinary staff absence or turnover.

 

8. What if sponsor compliance is outsourced?

 

External advisers can support an organisation with sponsor licence administration and immigration compliance, but outsourcing does not transfer the sponsor’s responsibility to the adviser.

The licensed organisation remains responsible for meeting its sponsor duties.

UKVI may therefore examine whether the sponsor itself has sufficient oversight of its sponsored workforce and whether relevant information reaches its advisers where external support is used.

An organisation cannot safely rely on an external adviser to make a required report if nobody within the business tells the adviser that the underlying event has occurred.

Effective outsourcing therefore requires clear communication and defined responsibilities between the organisation and its adviser.

 

9. How should HR systems deal with remote and hybrid workers?

 

Remote and hybrid working arrangements should be incorporated into the organisation’s sponsor compliance systems.

The sponsor should still be capable of establishing matters such as:

 

• where the worker normally works;
• their working pattern;
• who manages them;
• how attendance is monitored;
• how absence is identified;
• what duties they are performing;
• how changes are communicated; and
• whether any relevant change requires Home Office action.

 

The compliance system does not have to replicate traditional office attendance controls, but it must provide appropriate oversight for the organisation’s actual working model.

 

10. How can an employer test whether its HR systems are working?

 

A useful practical exercise is to select a sponsored worker and trace their employment through the organisation’s systems from recruitment to their current position.

The employer can ask:

 

• How was the worker recruited?
• What information appears on the CoS?
• Was the appropriate right to work check completed?
• What does the employment contract say?
• What does the worker actually do?
• What is the worker currently paid?
• Do payroll records support that figure?
• Where does the worker work?
• How is attendance monitored?
• Have there been changes since sponsorship began?
• Were relevant changes identified and reported?
• Are required records available?

 

If the organisation cannot reconcile these elements for an individual sponsored worker, this can indicate a weakness requiring further investigation.

A wider Sponsor Licence Compliance Audit can then be used to test the organisation’s systems and sponsored worker population in greater depth.

The key Home Office concern is not whether an employer owns sophisticated HR software. It is whether the organisation has effective systems capable of identifying, recording and responding to the events that matter for sponsor compliance.

 

 

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Section G: What Will UKVI Check About Sponsored Workers?

 

Sponsored workers are likely to be a central focus of a Home Office sponsor compliance check.

UKVI can examine whether workers are genuinely employed in accordance with the basis on which they were sponsored and whether the organisation is meeting its continuing sponsor duties in relation to those workers.

The Home Office can compare information from multiple sources, including the Certificate of Sponsorship, the worker’s immigration application, HR and payroll records, information reported through the Sponsor Management System, interviews with managers and the worker’s own account of their employment.

The important issue is whether these different sources present a consistent picture of the sponsored employment.

 

1. Will UKVI check whether the worker genuinely works for the sponsor?

 

Yes.

UKVI can examine whether the sponsored worker is genuinely working in the employment for which they were sponsored.

Depending on the circumstances, officers may consider:

 

• the identity of the employer;
• the worker’s employment contract;
• the Certificate of Sponsorship;
• the worker’s actual duties;
• who manages and supervises the worker;
• where the worker performs their duties;
• attendance and absence records;
• salary and payroll information; and
• the worker’s own description of their employment.

 

This can be particularly important where workers operate remotely, across several locations or at client or third-party premises.

The sponsor should retain sufficient oversight to demonstrate that the sponsored employment continues to correspond with the arrangement on which sponsorship is based.

 

2. Will the Home Office check the worker’s actual job duties?

 

Yes.

UKVI can investigate what a sponsored worker actually does rather than relying solely on the written job title or job description.

Compliance officers may compare:

 

• the duties described on the CoS;
• the formal job description;
• the employment contract;
• information supplied during the worker’s immigration application;
• the line manager’s description of the role;
• the worker’s description of their duties; and
• the work being carried out in practice.

 

Employers should therefore ensure that job descriptions remain meaningful representations of sponsored roles.

It is not sufficient for the paperwork to describe an eligible sponsored position if the worker is actually performing materially different duties.

 

3. Will UKVI consider whether the sponsored role is genuine?

 

Yes.

The Home Office can examine whether the sponsored role is genuine and whether the organisation genuinely requires the worker to perform that role.

This assessment is not necessarily confined to the wording used on the CoS.

UKVI can consider the wider circumstances of the employment and the organisation, including what the worker does in practice.

Where the evidence suggests that a role has been created primarily to facilitate immigration permission rather than to meet a genuine business requirement, this can create serious sponsor compliance concerns.

Similarly, concerns can arise where the role described for sponsorship purposes bears little resemblance to the worker’s actual employment.

 

4. Will UKVI check the worker’s salary?

 

Yes.

UKVI can examine whether a sponsored worker is receiving the salary required by the applicable immigration route and whether actual payments correspond with the information used for sponsorship.

Relevant evidence can include:

 

• the salary stated on the Certificate of Sponsorship;
• the employment contract;
• payslips;
• payroll records;
• HMRC information;
• working hours;
• salary changes;
• periods of reduced or unpaid pay; and
• relevant deductions.

 

The Home Office conducts regular checks with HMRC in relation to sponsored worker pay.

Sponsors should therefore investigate differences between sponsored salary information and payroll records rather than assuming they will not be identified.

 

5. Will the Home Office check working hours?

 

Potentially.

Working hours can be relevant to whether salary requirements are met and whether the sponsored employment corresponds with the information provided to UKVI.

The Home Office may therefore consider:

 

• contractual hours;
• actual working patterns;
• timesheets or rota information;
• payroll information;
• information provided by managers; and
• the worker’s own account.

 

Where hours or working patterns have changed, the sponsor should understand the immigration implications and whether any reporting or other action was required.

 

6. Will UKVI check where sponsored workers are working?

 

Yes.

Work location can be relevant to sponsor compliance.

The sponsor should know where sponsored workers normally carry out their duties and maintain appropriate oversight of their working arrangements.

This includes workers who:

 

• work at the sponsor’s main premises;
• work across several sponsor locations;
• work from home;
• operate under hybrid arrangements;
• work at client premises; or
• perform duties at another third-party location.

 

Where working arrangements change, the organisation should consider whether the change has sponsor reporting implications.

Home Office compliance activity can also take place at physical locations where sponsored workers carry out their duties, including a worker’s home address where they normally work from home and this is relevant to the check.

 

7. Will UKVI check attendance and absences?

 

Yes.

The Home Office can examine whether the sponsor is appropriately monitoring its sponsored workers and responding to relevant absences.

The method used will depend on the organisation’s working model, but the sponsor should be able to demonstrate how it knows whether a sponsored worker is attending work and how unexplained absence or other relevant events are escalated.

Evidence may include:

 

• attendance systems;
• timesheets;
• rotas;
• absence records;
• holiday records;
• sickness records;
• manager records; and
• remote-working monitoring arrangements.

 

UKVI may also consider whether relevant events were reported where the sponsor guidance required a report.

 

8. Will UKVI check whether changes affecting the worker were reported?

 

Yes.

The Home Office may compare the worker’s employment history with the sponsor’s SMS reporting history.

Where there has been a change affecting the sponsored worker, the organisation should be able to establish:

 

• what changed;
• when the change occurred;
• when the organisation became aware of it;
• whether the change was reportable;
• whether a report was made where required; and
• whether any additional immigration action was necessary.

 

This can expose weaknesses where information is known within one part of the organisation but does not reach the employees responsible for the sponsor licence.

 

9. Will UKVI check the worker’s right to work?

 

Yes.

A sponsor must carry out an appropriate right to work check on any worker it sponsors and retain the required evidence.

UKVI may examine:

 

• what type of right to work check was carried out;
• when the check was completed;
• whether the required evidence was retained;
• whether any follow-up check was required; and
• whether the worker’s current immigration position is understood.

 

Appendix D also requires sponsors to retain evidence of right to work checks for workers they employ, whether sponsored or not, and workers they sponsor whether or not they employ them.

In addition, from 1 October 2026, the statutory right to work checking regime extends to specified additional working arrangements. Employers should ensure their wider right to work procedures reflect the current requirements.

 

10. What happens if the worker’s account differs from the employer’s records?

 

A difference does not automatically establish sponsor non-compliance.

Workers and employers may use different terminology, remember dates differently or describe working arrangements in different ways.

UKVI can, however, investigate material inconsistencies.

For example, further scrutiny may be required if:

 

• the CoS describes one role but the worker describes substantially different duties;
• the sponsor says the worker is based at one location but the worker says they normally work elsewhere;
• payroll records show a different salary from the amount relied upon for sponsorship;
• the manager and worker provide materially different descriptions of the role; or
• the employer’s attendance records conflict with the worker’s account.

 

The sponsor should investigate the factual position and provide evidence capable of explaining any legitimate discrepancy.

 

11. Can a problem involving one worker lead UKVI to check others?

 

Yes.

A compliance concern involving one sponsored worker may indicate a wider weakness in the organisation’s systems.

For example, if UKVI identifies that a salary change for one worker was not reported because payroll did not notify the sponsor licence team, the Home Office may examine whether other sponsored workers have experienced similar changes.

Likewise, one incomplete right to work record or sponsored worker file may lead to questions about the organisation’s wider record-keeping process.

Employers should adopt the same approach internally.

Where a problem is identified, the sponsor should ask both:

 

1. What happened in this individual case?
2. Could the same problem affect other sponsored workers?

 

For UKVI, the central issue is whether each sponsored worker’s Certificate of Sponsorship, employer records, government information and actual experience of employment are materially consistent.

 

 

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Section H: Can the Home Office Interview Sponsored Workers?

 

Yes. Home Office compliance officers can interview sponsored workers as part of sponsor compliance activity.

Interviews can take place during an onsite compliance visit or through digital compliance activity.

A worker interview allows UKVI to obtain a direct account of the sponsored employment and compare that account with information provided by the sponsor and other evidence available to the Home Office.

Employers should therefore assume that sponsored workers may be asked to explain their own employment rather than relying solely on documents prepared by the organisation.

 

1. Why does UKVI interview sponsored workers?

 

A worker can provide first-hand evidence about how the sponsored role operates in practice.

The interview may help UKVI establish matters such as:

 

• what job the worker actually performs;
• their day-to-day duties;
• where they work;
• their working hours;
• what they are paid;
• who manages them;
• how they were recruited;
• how their employment operates; and
• whether their experience corresponds with the information provided for sponsorship purposes.

 

This provides UKVI with an additional source of evidence against which the sponsor’s records can be tested.

 

2. What questions can a sponsored worker be asked?

 

There is no single prescribed questionnaire that every sponsored worker will receive.

The questions will depend on the circumstances and what UKVI is examining.

Areas that may be explored include:

 

• the worker’s job title;
• their duties;
• their normal working day;
• working hours;
• salary;
• work location;
• remote or hybrid working;
• their line manager;
• how work is allocated;
• their recruitment;
• relevant qualifications or experience;
• changes to the role;
• attendance and absence; and
• other matters relevant to the sponsored employment.

 

The precise questions can vary according to the worker, the route and the compliance issues under consideration.

 

3. Will UKVI ask what the worker actually does day to day?

 

Potentially, yes.

This can be particularly important when UKVI is assessing whether the sponsored role is genuine and corresponds with the information on the CoS.

The worker may be asked to explain their duties in their own words.

UKVI can then compare the answer with:

 

• the CoS;
• the job description;
• the employment contract;
• the manager’s account; and
• other available evidence.

 

The worker does not need to recite the wording of a formal job description.

Indeed, an artificially rehearsed answer may be less useful than a straightforward and accurate explanation of what the employee actually does.

 

4. Can workers be asked about salary and hours?

 

Yes.

The worker may be asked what they are paid, how often they are paid and what hours they normally work.

UKVI can compare these answers with payroll information, the employment contract, the CoS and information available from HMRC.

Minor differences in recollection do not necessarily demonstrate a breach, but significant discrepancies may require further investigation.

 

5. Can workers be asked where they work?

 

Yes.

Work location can be particularly relevant where the worker:

 

• works remotely;
• has a hybrid working arrangement;
• works across several sponsor sites;
• is deployed to a client location; or
• works at another third-party premises.

 

The worker’s explanation should reflect the actual working arrangement.

If that arrangement differs from the sponsor’s understanding or relevant information held by UKVI, the Home Office may investigate whether the difference has sponsor compliance implications.

 

6. Can UKVI ask workers how they were recruited?

 

Yes.

Recruitment can be relevant when UKVI is assessing the genuineness of the role and the circumstances in which the worker came to be sponsored.

The worker may be asked how they became aware of the vacancy, how they applied, whether they were interviewed and how the role was offered.

The Home Office can compare this account with recruitment evidence retained by the employer where relevant.

 

7. Can UKVI obtain the worker’s account directly?

 

Yes.

Home Office sponsor guidance expressly allows compliance officers to speak to sponsored workers as part of compliance activity.

The employer should not assume that it will be able to control the information provided by the worker or answer questions on the worker’s behalf.

The purpose of speaking to the worker is to allow UKVI to obtain evidence directly from someone experiencing the sponsored employment.

 

8. Should employers prepare workers for an interview?

 

Employers can explain that Home Office compliance activity may involve interviews and can ensure that their own records accurately reflect the worker’s employment.

They should not coach workers to provide scripted or misleading answers.

Appropriate preparation involves checking the factual position rather than rehearsing a particular account.

For example, the employer can verify that:

 

• the worker’s job description reflects their actual duties;
• salary records are accurate;
• working hours are understood;
• work locations are correctly recorded;
• employment changes have been dealt with appropriately; and
• the sponsor’s records correspond with the reality of the role.

 

If that exercise reveals a discrepancy, the employer should investigate the underlying compliance issue rather than attempt to train the worker to reproduce the employer’s paperwork.

 

9. What if a worker gives an incorrect answer?

 

An incorrect or inconsistent answer does not automatically prove that the sponsor has breached its duties.

People can misunderstand questions, use different terminology or make mistakes when recalling details.

The significance of an answer will depend on the circumstances and the other available evidence.

Where UKVI raises a concern based on an interview, the sponsor should establish:

 

• what the worker was asked;
• what answer was given;
• whether the answer was factually accurate;
• whether the issue can be clarified by contemporaneous evidence; and
• whether the discrepancy reveals a genuine compliance problem.

 

The employer should not simply dismiss an inconvenient worker answer, but nor should it assume that every difference in wording establishes non-compliance.

 

10. Can a worker interview expose wider sponsor compliance problems?

 

Yes.

A worker’s account can reveal matters that lead UKVI to examine other parts of the organisation’s sponsorship arrangements.

For example, an interview could indicate that:

 

• job duties have changed;
• salary differs from sponsorship records;
• the worker normally works at an unrecorded location;
• the sponsor has limited oversight of client-site workers;
• relevant changes have not been escalated internally; or
• the organisation’s records do not reflect actual working practices.

 

UKVI may then examine whether the issue is confined to that worker or represents a broader systems failure.

The safest preparation is therefore not to teach workers what to say. It is to ensure that the sponsored employment itself is compliant and that the organisation’s records accurately describe it.

A sponsored worker should be able to give a truthful account of their employment that is materially consistent with a genuinely compliant sponsored role.

 

 

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Section I: Who Else Can the Home Office Interview?

 

Sponsored workers are not the only people UKVI may speak to during a sponsor compliance check.

Home Office compliance officers can interview people within the organisation whose knowledge is relevant to the sponsor licence, the recruitment and management of sponsored workers or the operation of the employer’s HR systems.

The individuals involved will depend on the structure of the organisation and the issues being examined.

UKVI may want to establish not only whether senior personnel understand the organisation’s sponsor duties, but also whether the processes described by management are understood and followed by the employees responsible for operating them.

 

1. Can UKVI interview the Authorising Officer?

 

Yes.

The Authorising Officer has overall responsibility for the sponsor licence and should have appropriate oversight of the organisation’s sponsorship arrangements.

UKVI may therefore ask the Authorising Officer about matters such as:

 

• how the sponsor licence is governed;
• who is responsible for day-to-day sponsorship administration;
• how sponsor duties are managed;
• how relevant information reaches the sponsor licence team;
• how compliance problems are escalated;
• how sponsored workers are monitored; and
• what oversight exists across the organisation.

 

The Authorising Officer does not necessarily need to perform every operational sponsorship task personally.

However, an inability to explain how the organisation manages its licence may raise questions about whether appropriate oversight exists.

 

2. Can UKVI interview Level 1 Users?

 

Yes.

Level 1 Users may be particularly relevant because of their access to and use of the Sponsor Management System.

Questions could concern:

 

• how SMS reports are made;
• how reportable events are identified;
• how Certificates of Sponsorship are assigned;
• how changes affecting sponsored workers are handled;
• who provides information to the Level 1 User;
• how SMS access is controlled; and
• how the organisation checks the accuracy of information submitted to UKVI.

 

Employers should ensure that individuals given Level 1 access understand the functions they perform and the significance of information submitted through the SMS.

 

3. What about existing Level 2 Users?

 

UKVI may also encounter existing Level 2 Users during the current transitional period, although the Level 2 User role is being withdrawn.

Since 9 September 2026, sponsors have not been able to appoint new Level 2 Users. Existing Level 2 Users can remain temporarily, but sponsors must convert them to Level 1 Users, where eligible, or deactivate them by 8 March 2027.

Where an organisation still has existing Level 2 Users, it should ensure their access remains appropriate during the transitional period and that the required migration or deactivation is being managed.

 

4. Can UKVI interview HR personnel?

 

Yes.

HR employees may be able to explain how many of the organisation’s sponsor compliance systems operate in practice.

UKVI may ask about matters such as:

 

• right to work checks;
• worker onboarding;
• record keeping;
• contact details;
• attendance and absence;
• changes to employment;
• salary changes;
• internal escalation procedures; and
• communication with employees responsible for the sponsor licence.

 

The Home Office can compare HR’s explanation with the organisation’s written procedures and the records maintained for individual sponsored workers.

 

5. Can UKVI interview line managers?

 

Yes.

Line managers can be particularly important where UKVI wants to understand what a sponsored worker actually does.

A manager may be asked about:

 

• the worker’s duties;
• working hours;
• work location;
• reporting lines;
• attendance;
• performance of the role;
• changes in responsibilities; and
• how relevant changes are communicated to HR.

 

This can help UKVI test whether the role described in sponsorship documentation corresponds with the worker’s actual day-to-day employment.

Line managers should therefore understand that changes affecting sponsored workers may have immigration consequences and should be escalated through the organisation’s compliance process.

 

6. Can recruitment personnel be interviewed?

 

Yes.

Home Office sponsor guidance allows compliance officers to speak to employees and colleagues involved in recruitment.

Recruitment personnel may be asked to explain matters such as:

 

• how the vacancy arose;
• how the role was advertised where relevant;
• how candidates were identified;
• how the sponsored worker applied;
• how the selection process operated;
• who interviewed the worker; and
• why the individual was appointed.

 

This information can be compared with recruitment records and the sponsored worker’s own account.

 

7. Can payroll or finance personnel be interviewed?

 

Potentially, yes.

Where salary or payroll is relevant to the compliance check, UKVI may need information from employees who understand how the worker is paid.

This may include questions about:

 

• the worker’s current salary;
• salary history;
• working hours;
• payroll records;
• salary changes;
• periods of reduced or unpaid pay;
• relevant deductions; and
• how payroll changes involving sponsored workers are communicated to HR or the sponsor licence team.

 

A common compliance risk arises where payroll makes a legitimate operational change but nobody considers whether the change has sponsorship implications.

Effective sponsor compliance therefore requires communication between payroll and the people responsible for immigration compliance.

 

8. Can directors or senior managers be interviewed?

 

Yes, where their knowledge is relevant to the compliance check.

Senior personnel may be able to provide information about the organisation’s operations, structure, recruitment requirements, sponsored roles or overall approach to sponsor licence governance.

This can be particularly relevant where UKVI is examining whether:

 

• the organisation is genuinely operating;
• the business has a genuine requirement for sponsored roles;
• appropriate management oversight exists;
• significant organisational changes have occurred; or
• the sponsor remains suitable to hold its licence.

 

9. Do employees need to give identical answers?

 

No.

Different employees will naturally understand different parts of the organisation and may describe the same process using different terminology.

UKVI should not be expected to receive a rehearsed, word-for-word account from everybody it interviews.

What can create concern is a material inconsistency about an important compliance issue.

For example, concerns may arise if:

 

• HR says line managers monitor sponsored worker absences but managers say they have no such responsibility;
• the sponsor says a worker performs one role while the line manager describes materially different duties;
• the Authorising Officer says salary changes are escalated but payroll says no such process exists; or
• management describes a compliance procedure that operational employees do not recognise.

 

Such differences can indicate that the organisation’s documented compliance framework is not operating effectively in practice.

 

10. Should employers prepare personnel before a compliance check?

 

Where advance notice has been given, relevant employees can be reminded about the compliance process and their responsibilities.

Preparation should focus on establishing the factual position rather than agreeing a common script.

Relevant personnel should understand:

 

• their own responsibilities;
• the processes they operate;
• where relevant records are held;
• how issues are escalated;
• who is responsible for other areas of compliance; and
• that they should not guess where they do not know an answer.

 

If preparation reveals that employees do not understand the procedures they are supposed to operate, the organisation should treat this as a potential compliance weakness rather than simply teaching them what to say to UKVI.

A Home Office compliance check can therefore test whether sponsor compliance is embedded across the organisation rather than existing solely within the knowledge of one immigration or HR specialist.

 

 

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Section J: Can UKVI Conduct a Digital Compliance Check?

 

Yes. Home Office sponsor guidance expressly allows UKVI to conduct digital compliance checks using remote video conferencing facilities.

A digital compliance check enables the Home Office to examine sponsor compliance without necessarily carrying out an initial physical visit to the organisation’s premises.

Employers should not treat a remote check as less significant than an onsite inspection. UKVI can still examine documents and systems, interview relevant personnel and sponsored workers and investigate whether the organisation is meeting its sponsor duties.

 

1. What happens during a digital compliance check?

 

The precise format will depend on the circumstances.

UKVI may use remote technology to:

 

• speak to the sponsor’s Key Personnel;
• interview sponsored workers;
• interview other relevant employees;
• request documents;
• review information supplied by the organisation;
• ask questions about HR and compliance systems; and
• investigate specific sponsorship issues.

 

Digital compliance activity can also be combined with other forms of Home Office checking.

 

2. Can UKVI request documents electronically?

 

Yes.

The Home Office can request documents and information as part of its compliance activity, and electronic records may be supplied where appropriate.

Employers should ensure that documents provided to UKVI are:

 

• the correct records;
• complete where required;
• legible;
• capable of being understood in context; and
• consistent with the organisation’s factual position.

 

Where information is stored across different HR or payroll systems, the organisation should understand what is being supplied and how the different records relate to one another.

 

3. Can UKVI interview sponsored workers remotely?

 

Yes.

Current sponsor guidance expressly allows compliance officers to interview sponsored workers onsite or digitally.

A remote interview can therefore be used to obtain the worker’s direct account of matters such as:

 

• their job;
• duties;
• salary;
• working hours;
• work location;
• line management;
• recruitment; and
• other aspects of the sponsored employment.

 

The same principles apply as during an onsite interview. The worker should provide a truthful account of their employment and should not be coached to reproduce scripted answers.

 

4. Can UKVI test HR systems remotely?

 

Potentially.

UKVI may ask the organisation to explain or demonstrate how relevant compliance systems operate and may request records produced by those systems.

The employer should be able to demonstrate how it manages matters including:

 

• right to work;
• worker records;
• contact information;
• attendance and absence;
• salary information;
• changes affecting sponsored workers;
• reporting; and
• SMS administration.

 

The Home Office’s ability to inspect records and systems relevant to sponsor compliance should not be interpreted as an unrestricted entitlement to browse unrelated confidential information. Employers should cooperate fully with legitimate compliance requests while managing access to relevant systems and data appropriately.

 

5. Is a digital compliance check less serious than an onsite visit?

 

No.

A digital check is another method through which the Home Office can exercise its sponsor compliance functions.

The fact that officers are not physically present does not reduce the importance of:

 

• providing accurate information;
• producing required records;
• answering questions truthfully;
• ensuring relevant personnel are available; and
• investigating discrepancies identified during the process.

 

Information obtained during a digital compliance check can contribute to Home Office action against the sponsor licence in the same way as evidence gathered through other compliance activity.

 

6. Can a digital check lead to a physical compliance visit?

 

Potentially, yes.

UKVI is not necessarily restricted to one method of compliance checking.

If information obtained remotely raises further questions, the Home Office may seek additional evidence or undertake further compliance activity.

Likewise, a physical visit may be supplemented by subsequent digital interviews or requests for documents.

Employers should therefore think of the different methods as components of the wider compliance process rather than entirely separate procedures.

 

7. How should employers prepare for a digital compliance check?

 

The organisation should prepare with the same level of care as it would for an onsite compliance visit.

This includes:

 

• identifying who will coordinate the response;
• reviewing the sponsor licence and SMS information;
• checking sponsored worker files;
• reconciling Certificates of Sponsorship with actual employment;
• reviewing salary and payroll information;
• checking right to work records;
• ensuring relevant personnel understand their responsibilities;
• ensuring requested records can be retrieved; and
• investigating discrepancies before information is supplied.

 

Documents should not be altered or reconstructed in a misleading way simply because they are being provided electronically.

Where an historic record is missing or a compliance weakness exists, the employer should establish the true position and determine the appropriate response.

 

8. Are digital checks particularly relevant to remote-working organisations?

 

They can be.

Remote and hybrid organisations may have fewer traditional workplace records and may rely heavily on electronic systems for management, attendance, communication and document retention.

This can make digital compliance activity particularly effective in testing whether the sponsor retains meaningful oversight of its sponsored workers.

UKVI may want to understand:

 

• where workers are based;
• how they are managed;
• how attendance is monitored;
• how work is allocated;
• how changes are identified;
• how records are maintained; and
• how relevant information reaches the sponsor licence team.

 

A decentralised workforce should not result in decentralised compliance to the point that nobody within the sponsor has a reliable overall picture of the sponsored employment.

Whether the compliance check takes place in a meeting room or through a video call, the fundamental Home Office enquiry remains the same: can the sponsor demonstrate that its systems, records and actual employment arrangements comply with the sponsorship requirements?

 

 

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Section K: What Happens if Sponsored Workers Work Remotely or at Client Sites?

 

Remote, hybrid and client-site working arrangements do not remove an employer’s sponsor duties.

A sponsor remains responsible for maintaining appropriate oversight of sponsored workers and should be able to demonstrate where those workers are working, what duties they are performing and whether their actual employment remains consistent with the basis on which they were sponsored.

These arrangements can create additional compliance risks because information about the worker may be spread between HR, operational managers, clients and the employees responsible for the sponsor licence.

Employers should therefore ensure that their sponsor compliance systems reflect the way their workforce actually operates.

 

1. Can sponsored workers work from home?

 

Potentially, yes.

Home working is not, in itself, incompatible with sponsorship. The arrangement must, however, remain consistent with the requirements applying to the worker’s immigration route and employment.

The sponsor should maintain sufficient oversight to understand:

 

• where the worker normally works;
• how frequently they work remotely;
• their normal working pattern;
• who manages and supervises them;
• how their attendance is monitored;
• how absences are identified;
• what duties they perform;
• how the sponsor remains in contact with them; and
• whether changes to the arrangement have any reporting implications.

 

The fact that an employee is not physically present at the sponsor’s premises does not remove the organisation’s responsibility for monitoring the sponsored employment.

 

2. Can the Home Office carry out a compliance check at a home-working location?

 

Potentially, yes.

Current Home Office sponsor guidance provides for compliance checks at physical addresses where sponsored workers carry out their duties. Where a sponsored worker normally works from home, this can include the worker’s home address where relevant to the compliance activity.

This should not be interpreted as meaning that UKVI routinely visits sponsored workers at home.

It does, however, demonstrate that home-based working does not place the sponsored employment outside the scope of Home Office scrutiny.

Sponsors should therefore ensure that the working arrangement recorded within their systems accurately reflects how and where the worker performs their role.

 

3. What can UKVI check about remote and hybrid workers?

 

Where a sponsored worker works remotely or under a hybrid arrangement, UKVI may examine how the sponsor maintains effective oversight.

Depending on the circumstances, this can include:

 

• the worker’s normal work location;
• the contractual working arrangement;
• the actual pattern of home and workplace attendance;
• the worker’s duties;
• working hours;
• salary;
• line management arrangements;
• methods of communication;
• attendance and absence monitoring;
• changes to working arrangements; and
• whether relevant changes were reported where required.

 

UKVI can compare the employer’s records with information provided by the sponsored worker and their manager.

The sponsor should therefore be able to explain how remote working operates in practice rather than relying solely on a contractual home-working clause or general hybrid-working policy.

 

4. What if a sponsored worker works across several company locations?

 

Employers with multiple sites should maintain appropriate oversight of where sponsored workers are based and how their roles operate across those locations.

The sponsor should know whether the worker:

 

• has a principal work location;
• regularly works at other branches or sites;
• has moved permanently to another location;
• works according to a rotational pattern; or
• has experienced another material change to their working arrangements.

 

Where the working arrangement changes, the sponsor should consider whether the change has implications under the sponsor reporting requirements.

Operational managers should understand that moving a sponsored employee between locations can have immigration compliance implications and should not be treated solely as an internal management decision.

 

5. Can sponsored workers work at client premises?

 

Potentially, yes, provided the arrangement is compatible with the applicable immigration and sponsorship requirements.

However, placing a sponsored worker at a client or other third-party site does not transfer sponsor responsibility to the client.

The licensed sponsor remains responsible for the worker and must maintain sufficient oversight of the sponsored employment.

Depending on the circumstances, UKVI may examine:

 

• why the worker is based at the client site;
• what duties they perform there;
• whether those duties correspond with the sponsored role;
• who manages and supervises the worker;
• how attendance is monitored;
• how the sponsor remains informed about the worker;
• how changes are communicated to the sponsor; and
• whether the arrangement remains consistent with the information provided for sponsorship purposes.

 

The sponsor should therefore retain meaningful control and oversight rather than assuming that responsibility for the worker has passed to the client.

 

6. Can the Home Office visit a client or third-party site?

 

Yes, where relevant to the sponsor compliance check.

Current Home Office guidance specifically addresses sponsored workers who perform their duties at a third party’s office.

The sponsor is expected to ensure that the third party is aware that an unannounced Home Office compliance visit may take place and that the third party will cooperate fully with the compliance activity.

This means sponsors should consider Home Office access before placing sponsored workers at client premises.

Appropriate arrangements may need to be reflected in contracts, service agreements, operational procedures or other arrangements between the sponsor and the client.

 

7. What happens if the client refuses to cooperate with UKVI?

 

This can create a serious problem for the sponsor.

The current Home Office sponsor guidance is explicit that where a relevant third party is uncooperative with a compliance check, the Home Office will take action against the sponsor.

The precise sponsor licence consequence will depend on the circumstances and the applicable guidance. Employers should not, however, assume that they can avoid responsibility by explaining that the premises belong to a client and access is controlled by that client.

Where sponsored workers are deployed to third-party sites, the sponsor should establish in advance:

 

• whether the client understands the possibility of Home Office compliance activity;
• who within the client organisation should respond;
• how access would be managed;
• how the sponsor would be notified;
• how relevant records would be made available; and
• how full cooperation with legitimate UKVI compliance activity will be secured.

 

These arrangements should be resolved before a compliance visit occurs rather than negotiated after Home Office officers arrive.

 

8. What if the sponsored worker is managed day to day by the client?

 

Client involvement in the worker’s day-to-day activities can require particularly careful compliance management.

UKVI may want to understand the substance of the arrangement, including:

 

• who directs the worker’s activities;
• who determines their duties;
• who supervises their work;
• who monitors attendance and absence;
• who manages performance;
• who approves changes to the role;
• how the sponsor receives information about the worker; and
• whether the sponsor retains sufficient oversight of the sponsored employment.

 

The fact that a client has operational involvement does not remove the sponsor’s immigration responsibilities.

The sponsor should be able to demonstrate that it knows what the worker is doing and that the arrangement continues to comply with the basis on which the worker was sponsored.

 

9. What if a client assignment changes?

 

Changes to client assignments should be considered from a sponsor compliance perspective rather than treated purely as commercial or operational matters.

Depending on the circumstances, the sponsor may need to consider changes to:

 

• the worker’s duties;
• work location;
• line management;
• salary;
• working hours;
• the nature of the assignment;
• the underlying sponsored role; and
• information previously provided to UKVI.

 

The organisation should then determine whether the change remains compatible with the worker’s existing sponsorship and whether any reporting or other immigration action is required.

This is why operational teams managing client assignments should have a mechanism for escalating changes involving sponsored workers to HR or the sponsor licence team.

 

10. How should sponsors monitor workers at third-party locations?

 

The precise system will depend on the nature of the organisation and the assignment, but the sponsor should retain sufficient information to exercise meaningful oversight.

This may involve processes for monitoring:

 

• the worker’s current location;
• their duties;
• attendance;
• absences;
• working hours;
• salary;
• changes to the assignment;
• information supplied by the client; and
• events that may require escalation for sponsor reporting purposes.

 

The organisation should also know who within the client business can provide relevant information where required.

A sponsor should not discover during a Home Office compliance check that it has little current knowledge of what a sponsored worker has been doing at a client site.

 

11. Does hybrid working reduce the need to monitor attendance?

 

No.

Hybrid working may require a different form of attendance monitoring, but it does not remove the sponsor’s obligation to maintain appropriate oversight.

The sponsor should have a system appropriate to the working arrangement that enables relevant absence and attendance issues to be identified.

For example, oversight may involve a combination of:

 

• office attendance records;
• manager supervision;
• electronic systems;
• timesheets;
• work scheduling;
• remote-working records; and
• other appropriate controls.

 

UKVI is likely to be interested in whether the system actually enables the sponsor to know whether the worker is performing their sponsored employment, rather than whether a traditional office attendance register exists.

 

12. How should employers prepare remote and client-site arrangements for a compliance check?

 

Employers should be able to establish the factual position for each relevant sponsored worker.

Before or during a compliance review, the sponsor should be able to answer:

 

• Where does the worker actually work?
• How often are they at each location?
• What duties are they performing?
• Who supervises them?
• How is attendance monitored?
• How are absences recorded?
• How does the sponsor receive information about changes?
• Have there been changes since the worker was sponsored?
• Were any required reports made?
• Does the current arrangement remain consistent with the CoS?
• Can relevant records be retrieved promptly?
• If the worker is at a client site, will the client cooperate fully with UKVI?

 

Remote and third-party working are not inherently incompatible with sponsor compliance.

The principal risk arises where the working model causes the sponsor to lose visibility or effective oversight of the sponsored worker.

The core compliance question remains: does the sponsor know where the worker is, what the worker is doing and whether the reality of the employment continues to correspond with the sponsorship arrangement?

 

 

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Section L: How Should Employers Prepare for a Sponsor Compliance Check?

 

Employers should prepare for a Home Office sponsor compliance check by establishing the organisation’s actual compliance position rather than simply assembling documents for inspection.

The strongest preparation is ongoing compliance. Sponsor records, HR systems, payroll information, SMS records and actual employment arrangements should be maintained accurately throughout the life of the licence.

Where advance notice of a check is given, the employer should use the available time to reconcile these different sources and identify any discrepancies requiring investigation.

The objective should not be to make the organisation appear compliant for the visit. It should be to establish whether it is compliant and, where weaknesses exist, understand their nature, extent and appropriate remediation.

 

1. Who should coordinate the employer’s response?

 

The organisation should identify an appropriate person or team to coordinate the compliance response.

Depending on the organisation, this could involve:

 

• the Authorising Officer;
• relevant Level 1 Users;
• HR;
• the compliance function;
• in-house legal;
• senior management; and
• external immigration advisers.

 

The response should be coordinated so that requests are tracked, accurate information is provided and issues identified during preparation are investigated consistently.

 

2. Should the sponsor review its SMS before the check?

 

Yes.

The sponsor should review information held within the Sponsor Management System and consider whether it accurately reflects the organisation’s current position.

Areas to review can include:

 

• organisation details;
• addresses and work locations;
• Key Personnel;
• current Level 1 Users;
• any remaining transitional Level 2 Users;
• sponsored workers;
• Certificates of Sponsorship;
• reports relating to sponsored workers;
• reported organisational changes; and
• other relevant licence information.

 

Since new Level 2 Users can no longer be appointed from 9 September 2026, sponsors with existing Level 2 Users should also ensure they are managing the transition to Level 1 status, where eligible, or deactivation by 8 March 2027.

Employers should not make unnecessary or inaccurate SMS changes merely because a compliance visit is approaching. Where an issue is identified, the correct position and appropriate action should first be established.

 

3. Should every sponsored worker file be reviewed?

 

The scope of the review will depend on the size of the sponsored workforce and the time available, but employers should consider whether a broader review is required rather than looking only at workers specifically identified by UKVI.

For each worker reviewed, the sponsor should consider:

 

• identity and immigration status;
• right to work evidence;
• documents required under Appendix D;
• contact information;
• Certificate of Sponsorship information;
• employment contract;
• job description;
• recruitment evidence where required;
• qualifications or professional registration where relevant;
• salary;
• working hours;
• payroll records;
• work location;
• attendance and absence;
• employment changes; and
• SMS reports.

 

The organisation should be looking for inconsistencies between these sources rather than simply confirming that documents exist.

 

4. Should the employer compare the CoS with the worker’s actual job?

 

Yes.

This is one of the most important preparation exercises.

The employer should compare the Certificate of Sponsorship with the worker’s current employment and establish whether the sponsored role continues to operate as described.

This should include considering:

 

• job title;
• actual duties;
• occupation classification where relevant;
• salary;
• working hours;
• work location;
• reporting lines; and
• any material changes since sponsorship began.

 

Where the worker’s role has evolved, the sponsor should establish what changed, when it changed and whether any sponsor reporting or other immigration action was required.

 

5. Should payroll be reconciled with sponsorship records?

 

Yes.

The organisation should establish what each sponsored worker is actually being paid and compare this with the salary information relevant to their sponsorship.

The review should consider:

 

• contractual salary;
• actual gross pay;
• working hours;
• salary changes;
• periods of reduced or unpaid pay;
• relevant deductions;
• payroll records; and
• any reporting action taken.

 

This is particularly important because the Home Office conducts regular checks with HMRC in relation to sponsored worker pay.

 

6. Should right to work records be reviewed?

 

Yes.

The employer should check that appropriate right to work checks have been carried out and that the required evidence has been retained.

For sponsor compliance purposes, the organisation should remember that it is required to conduct an appropriate right to work check on any worker it sponsors, irrespective of whether the individual is employed under a conventional employment relationship.

Appendix D also requires sponsors to retain evidence of right to work checks for workers they employ, whether sponsored or not, and workers they sponsor whether or not they employ them.

From 1 October 2026, employers should additionally ensure that their procedures reflect the expanded statutory right to work checking responsibilities applying to specified additional working arrangements.

 

7. Should attendance and absence records be reviewed?

 

Yes.

The employer should check that its attendance monitoring process works for the organisation’s actual working model.

This is particularly important where sponsored workers:

 

• work remotely;
• work under hybrid arrangements;
• move between sites;
• work shifts;
• work at client locations; or
• are managed partly by third parties.

 

The sponsor should be able to explain how absences are identified, recorded and escalated where they may have sponsor reporting implications.

 

8. Should previous SMS reports be checked?

 

Yes.

The employer should compare relevant employment events with its SMS reporting history.

The purpose is to establish whether reportable changes were identified and dealt with appropriately.

If a report appears to have been missed or made incorrectly, the sponsor should investigate:

 

• what happened;
• when the event occurred;
• when the organisation became aware of it;
• why the reporting issue arose;
• whether the problem affects other workers; and
• what corrective action is now appropriate.

 

9. How should Key Personnel prepare?

 

Key Personnel should understand the organisation’s actual sponsorship arrangements and their own responsibilities.

Preparation should involve reviewing factual information and relevant procedures, not memorising scripted answers.

They should be capable of explaining matters relevant to their role, including:

 

• how the licence is governed;
• who manages day-to-day compliance;
• how SMS reporting operates;
• how sponsored workers are monitored;
• how information reaches the sponsor licence team;
• where relevant records are held; and
• how compliance problems are escalated.

 

10. Should sponsored workers be told about the check?

 

Where appropriate, sponsored workers can be informed that Home Office compliance activity is taking place and that UKVI may wish to speak to them.

They should not be coached to provide a predetermined account.

The employer should instead ensure that its own records accurately reflect the worker’s actual employment.

If a worker is likely to describe their role differently from the CoS because the role has genuinely changed, the employer should investigate the underlying sponsorship issue rather than attempting to change the worker’s description.

 

11. What should the employer do if preparation identifies a compliance problem?

 

The issue should be investigated promptly and accurately.

The organisation should establish:

 

• what happened;
• when it happened;
• who knew about it;
• whether the problem is ongoing;
• which sponsor requirement is potentially affected;
• whether Home Office reporting or other action is required;
• whether the problem affects other sponsored workers; and
• what remediation is appropriate.

 

The employer should preserve the true chronology.

Records should not be fabricated, backdated or altered to create a misleading impression that a compliance step was completed when it was not.

Where a process has subsequently been corrected, the organisation should be able to explain what went wrong and what remedial measures have been implemented.

 

12. Should the employer carry out a mock compliance audit?

 

A structured internal review can be valuable, particularly where the sponsor has a significant sponsored workforce or complex operating model.

A practical approach is to select sponsored workers and trace their complete employment journey through:

 

• recruitment;
• right to work;
• Certificate of Sponsorship;
• contract;
• job duties;
• payroll;
• attendance;
• work location;
• employment changes;
• SMS reporting; and
• current working arrangements.

 

A more comprehensive Sponsor Licence Compliance Audit can be used to test the sponsor’s governance, systems, records and sponsored worker population in greater depth.

 

13. What should employers check for workers at client sites?

 

Where sponsored workers are based at third-party premises, the sponsor should establish:

 

• the worker’s current location;
• the reason for the client assignment;
• the duties being performed;
• who manages the worker;
• how attendance and absence are monitored;
• how the sponsor maintains oversight;
• how changes are communicated;
• whether relevant changes have been reported; and
• whether the client will cooperate fully with Home Office compliance activity.

 

The sponsor should remember that current Home Office guidance states that where a relevant third party is uncooperative with a compliance check, the Home Office will take action against the sponsor.

 

14. Should the employer create a compliance response file?

 

For an announced check, it can be useful to organise the relevant information so that requests can be handled efficiently.

The file or electronic workspace might include:

 

• the Home Office correspondence concerning the check;
• a list of relevant sponsored workers;
• requested documents;
• key sponsor licence information;
• records of internal compliance reviews;
• identified discrepancies and explanations;
• remedial action already undertaken;
• responsibility for outstanding actions; and
• a record of information ultimately supplied to UKVI.

 

This should be a genuine response record rather than a replacement for the organisation’s underlying HR and sponsorship records.

 

15. What should employers avoid doing before a compliance check?

 

Employers should avoid actions that create further compliance or credibility problems.

In particular, they should not:

 

• fabricate missing records;
• backdate documents misleadingly;
• alter records to conceal a discrepancy;
• coach workers or employees to provide false or scripted accounts;
• conceal relevant information;
• provide information to UKVI without checking its accuracy; or
• make unnecessary SMS changes without first establishing the correct compliance position.

 

Where a genuine problem exists, a factually accurate investigation and properly documented remediation will generally place the organisation in a stronger position than attempting to make the historic record appear different from reality.

The central preparation exercise is therefore reconciliation: the sponsor licence, SMS, worker files, HR systems, payroll records and actual working arrangements should be tested against one another before UKVI does the same exercise itself.

 

 

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Section M: What Should Employers Do During an Unannounced Home Office Visit?

 

An unannounced Home Office compliance visit can place immediate pressure on an organisation because there may be little or no time to prepare before compliance officers begin their enquiries.

The employer’s response should be controlled, cooperative and accurate.

Front-of-house staff should know how to escalate the arrival of Home Office officers, while those responsible for the sponsor licence should understand how the organisation will coordinate the visit.

The objective should not be to obstruct or delay UKVI. It should be to ensure that legitimate compliance requests are dealt with efficiently and that information provided on behalf of the organisation is accurate.

 

1. What should reception or front-of-house staff do?

 

Reception, security and other front-of-house employees should have a simple escalation procedure for an unannounced Home Office visit.

They should know:

 

• who should be contacted internally;
• how to contact an alternative person if the usual contact is unavailable;
• that Home Office identification should be checked;
• that legitimate compliance activity should not be obstructed; and
• that they should not attempt to answer detailed sponsorship questions outside their knowledge.

 

This is particularly important for organisations with several offices or sites, where compliance officers may attend a location at which the central HR or immigration team is not based.

 

2. Should the employer verify the officers’ identity?

 

Yes.

Home Office sponsor guidance states that a visiting compliance officer, or a third party conducting a visit on behalf of the Home Office, will have official Home Office identification.

The organisation should check this identification as part of its normal security procedures.

If there is genuine doubt about whether an individual is acting on behalf of the Home Office, the sponsor can verify the position using the Home Office Business Helpdesk on 0300 123 4699.

Identity verification should be dealt with promptly. It should not be used as a means of obstructing or unnecessarily delaying legitimate compliance activity.

 

3. Who should be notified internally?

 

The appropriate internal escalation will depend on the organisation, but relevant personnel may include:

 

• the Authorising Officer;
• relevant Level 1 Users;
• HR;
• the compliance team;
• in-house legal;
• senior management;
• relevant line managers;
• payroll or finance; and
• external immigration advisers.

 

The organisation should avoid unnecessary internal circulation of the visit while ensuring that the people needed to respond are informed promptly.

 

4. What if the Authorising Officer is unavailable?

 

The absence of the Authorising Officer does not mean that the compliance visit cannot proceed.

Sponsors should therefore avoid creating a compliance system that depends entirely on the availability of one individual.

Other appropriate personnel should be able to:

 

• identify who manages the sponsor licence;
• locate relevant records;
• explain basic compliance processes;
• identify the employees who can answer specialist questions; and
• escalate the visit appropriately.

 

Where the Home Office wants to speak specifically to the Authorising Officer and that person is genuinely unavailable, the sponsor should explain the position accurately rather than attempting to substitute another employee’s knowledge for theirs.

 

5. Does the employer have to allow access to its premises?

 

Sponsors are required to cooperate with Home Office compliance activity.

Current Home Office sponsor guidance requires a sponsor to allow Home Office staff full access to premises or sites under the sponsor’s control on demand.

The employer should therefore ensure that relevant employees, security personnel and site managers understand that legitimate UKVI compliance activity must be accommodated.

Where sponsored workers perform duties at third-party premises, the sponsor should also have made appropriate arrangements for the third party to cooperate with Home Office compliance activity.

The Home Office guidance states that where the relevant third party is uncooperative with a compliance check, the Home Office will take action against the sponsor.

 

6. Should one person coordinate the visit?

 

Where practicable, it can be helpful for an appropriate representative to coordinate the organisation’s response.

The coordinator can:

 

• act as a central point of contact;
• identify the appropriate person to answer particular questions;
• coordinate document requests;
• keep track of information supplied;
• record follow-up requests;
• ensure relevant internal personnel are notified; and
• help prevent contradictory information being supplied simply because employees are working from different records.

 

This should not be used to interfere with legitimate Home Office enquiries or prevent UKVI from speaking directly to relevant personnel or sponsored workers.

 

7. Should the employer keep a record of the compliance visit?

 

Yes.

A contemporaneous internal record can be valuable, particularly if UKVI subsequently raises compliance concerns.

The organisation should consider recording:

 

• the date and time of the visit;
• the names or identifying details of the attending officers;
• which premises were visited;
• which employees were involved;
• which sponsored workers were interviewed;
• which documents were requested;
• which documents were provided;
• which systems were examined;
• questions or issues raised by UKVI;
• additional information requested; and
• any deadlines given for follow-up information.

 

The record should be factual rather than speculative.

 

8. What should employees do if they do not know an answer?

 

They should not guess.

Providing speculative information can create discrepancies that subsequently need to be explained.

Where an employee does not know the answer to a question, it is generally more appropriate to say so and identify who within the organisation is likely to have the relevant information.

Likewise, if a question requires checking a record before an accurate answer can be given, the employee should explain this.

Accuracy is more important than attempting to provide an immediate answer to every question.

 

9. How should document requests be handled?

 

Documents requested by UKVI should be located and supplied in an organised manner where possible.

The employer should understand what is being provided and should maintain a record of material supplied during or after the visit.

If a requested document cannot immediately be found, the organisation should establish:

 

• whether the record exists;
• where it should be held;
• whether another relevant record is available;
• whether the document was required to be retained; and
• whether UKVI will allow it to be provided subsequently.

 

The absence of a document should not be concealed by creating a misleading replacement or altering the historical record.

 

10. What should the employer do if UKVI identifies a discrepancy during the visit?

 

The employer should establish the facts before giving an explanation.

A discrepancy may have a legitimate explanation, but an improvised answer can create additional problems if it later proves inaccurate.

The organisation should consider:

 

• what UKVI believes the discrepancy to be;
• what the underlying records show;
• whether the issue can be explained immediately and accurately;
• whether further investigation is needed; and
• whether supporting evidence should be provided after the visit.

 

Where a genuine compliance failure is identified, the employer should preserve the correct chronology and consider the appropriate remedial and reporting response.

 

11. What should happen if UKVI wants to interview sponsored workers?

 

The employer should cooperate with legitimate Home Office compliance activity.

Current sponsor guidance allows compliance officers to speak directly to sponsored workers as part of their checks.

The organisation should not coach workers, provide them with scripted answers or attempt to control their account of their employment.

If the worker’s description differs from the sponsor’s records, the employer should investigate the factual reason for the difference.

 

12. What if UKVI wants to inspect electronic HR records?

 

The sponsor should cooperate with legitimate requests to inspect records and systems relevant to the compliance check.

Where information is held electronically, an appropriate employee may be needed to retrieve or demonstrate relevant records.

The Home Office’s compliance powers should not be interpreted as requiring the employer to provide uncontrolled access to unrelated confidential information across its entire HR, payroll or business systems.

The organisation should facilitate access to information relevant to the compliance check while continuing to manage unrelated confidential and personal data appropriately.

 

13. Should external immigration advisers be contacted?

 

Where the organisation uses external immigration advisers, it may be appropriate to notify them promptly, particularly where the visit raises significant compliance issues.

External advisers may be able to assist with:

 

• understanding the scope of the compliance activity;
• reviewing requests for information;
• investigating discrepancies;
• assessing sponsor reporting obligations;
• reviewing potential compliance breaches;
• preparing follow-up submissions; and
• responding to subsequent Home Office action.

 

The involvement of an adviser does not remove the sponsor’s obligation to cooperate with UKVI.

 

14. What should happen immediately after the officers leave?

 

The organisation should conduct an internal debrief while events are still fresh.

The debrief should identify:

 

• what UKVI examined;
• who was interviewed;
• what information was provided;
• which documents were supplied;
• what questions caused difficulty;
• which discrepancies were identified;
• what further information UKVI requested;
• what deadlines apply; and
• whether immediate compliance action is required.

 

Relevant records should be preserved, and responsibility for follow-up actions should be allocated.

If the visit exposed a possible sponsor compliance failure, the organisation should investigate the issue promptly rather than waiting to see whether the Home Office raises it formally.

The most effective response to an unannounced visit is therefore preparedness, cooperation, accurate information and disciplined follow-up.

 

 

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Section N: What Happens After a Sponsor Compliance Check?

 

A Home Office sponsor compliance check does not necessarily end when compliance officers leave the premises or a digital meeting concludes.

UKVI may continue reviewing the evidence, compare information obtained from different sources, conduct further verification and request additional documents or clarification.

The Home Office will then determine whether any sponsor licence action is appropriate.

 

1. Does UKVI make a decision immediately?

 

No immediate decision should be expected.

Home Office sponsor guidance states that a compliance officer will not indicate their assessment during the compliance check.

After the checks have been completed, the Home Office will consider what action, if any, is appropriate.

Current guidance confirms that the sponsor will then be notified of the Home Office’s decision in writing.

The organisation should therefore avoid attempting to infer the outcome from the officers’ behaviour or comments during the visit.

 

2. Can UKVI ask for more information after the check?

 

Yes.

The Home Office may need further documents or explanations before reaching its decision.

The sponsor should treat follow-up requests as part of the compliance process and ensure that responses are:

 

• accurate;
• complete;
• consistent with the underlying evidence;
• provided within any applicable deadline; and
• reviewed appropriately where significant compliance issues are involved.

 

The employer should keep a clear record of information supplied after the visit.

 

3. What should the sponsor do while waiting for the outcome?

 

The organisation should not remain passive if the compliance check has exposed potential weaknesses.

It should conduct its own review of the issues raised during the check.

This can include:

 

• reviewing interview notes;
• checking documents supplied to UKVI;
• investigating discrepancies;
• reviewing affected sponsored worker files;
• checking whether the same issue affects other workers;
• considering whether any sponsor reporting action is required;
• correcting defective processes; and
• preserving evidence of remedial action.

 

Remediation should be genuine and properly documented. Records should not be retrospectively altered to create a misleading impression of historic compliance.

 

4. What happens if UKVI identifies no material compliance concerns?

 

Where the Home Office is satisfied with the sponsor’s compliance position, the check may conclude without substantive enforcement action against the sponsor licence.

The organisation should nevertheless use the exercise as an opportunity to identify any internal improvements revealed by the process.

For example, even where UKVI takes no action, the visit may show that:

 

• documents were difficult to retrieve;
• responsibilities were unclear;
• line managers required additional training;
• client-site arrangements required stronger controls; or
• internal communication could be improved.

 

Addressing these issues can improve readiness for future compliance activity.

 

5. What action can the Home Office take following a compliance check?

 

The action available to UKVI depends on the findings and the applicable sponsor guidance.

Potential consequences can include:

 

• requesting further information or evidence;
• reducing the sponsor’s Certificate of Sponsorship allocation;
• downgrading the sponsor licence to a B-rating and requiring a sponsor action plan where appropriate;
• suspending the sponsor licence;
• revoking the sponsor licence;
• taking action affecting sponsored workers’ immigration permission; and
• referring matters for other enforcement action where appropriate.

 

Not every compliance breach results in the same outcome. The Home Office will consider the nature of the issue and the relevant provisions of the sponsor guidance.

 

6. When can a sponsor be downgraded to a B-rating?

 

Current Home Office guidance provides that where a sponsor has breached its duties but the breach is relatively minor and the sponsor is willing and able to correct it, UKVI will in most cases downgrade the licence to a B-rating and issue a time-limited sponsor action plan.

The sponsor will then be expected to address the matters specified in the action plan within the applicable period.

A B-rating should not be treated as a routine or insignificant administrative warning. It represents formal Home Office compliance action and can restrict the sponsor while remedial requirements are outstanding.

 

7. When can more serious sponsor licence action follow?

 

More serious breaches can result in more serious action.

Current Home Office guidance provides that where the breach is more serious, UKVI may suspend the sponsor licence with a view to revocation or, in appropriate circumstances, revoke the licence without first suspending it.

This can include cases involving significant or systematic failures, circumstances in which the organisation no longer meets relevant eligibility or suitability requirements, serious risks to immigration control or other conduct falling within the applicable sponsor guidance.

The outcome will depend on the particular breach and the relevant sponsor rules. Employers should therefore avoid assuming that sponsor enforcement always follows a fixed sequence from warning, to B-rating, to suspension and then revocation.

 

8. Can UKVI reduce the sponsor’s CoS allocation?

 

Yes.

Reducing a sponsor’s Certificate of Sponsorship allocation is one of the forms of action available to the Home Office following compliance concerns.

This can have an immediate operational impact on an employer that expects to sponsor additional workers.

Organisations facing compliance action should therefore consider both the regulatory implications and the practical effect on planned recruitment.

 

9. Can a compliance check result in sponsor licence suspension?

 

Yes.

Where the Home Office identifies sufficiently serious compliance concerns, the sponsor licence can be suspended in accordance with the sponsor guidance.

Suspension can have significant consequences for the organisation’s ability to use its sponsor licence while the matter is being considered. While the licence remains suspended, the sponsor cannot assign any Certificates of Sponsorship.

A sponsor receiving a suspension notice should review the allegations, underlying evidence and applicable response process urgently.

 

10. Can a compliance check lead to sponsor licence revocation?

 

Yes.

Serious sponsor non-compliance can result in revocation of the sponsor licence.

Depending on the applicable provisions and circumstances, revocation may follow suspension or may occur without prior suspension.

Revocation can affect the organisation’s ability to sponsor workers and can have significant consequences for workers whose immigration permission depends on that sponsorship.

The employer should therefore obtain appropriate advice promptly where compliance findings create a material risk of revocation.

 

11. Can sponsored workers be affected by the outcome?

 

Potentially, yes.

Home Office action against a sponsor can have consequences for workers sponsored by that organisation.

UKVI can also take action in relation to individual immigration permission where the applicable rules and circumstances justify it.

The precise consequences depend on the sponsor action taken, the worker’s immigration position and the relevant Immigration Rules. Where a sponsor licence is revoked and the worker was not actively and knowingly complicit in the reasons for revocation, the Home Office will ordinarily consider shortening the worker’s permission so that 60 calendar days remain, unless the worker already has 60 days or less remaining. Where the worker was actively and knowingly complicit, more immediate cancellation action may be taken. Current Home Office cancellation guidance also contains a temporary concession for specified adult social care workers where sponsor licence revocation is the sole reason cancellation would otherwise arise.

Employers should therefore consider workforce implications alongside the immediate sponsor licence response.

 

12. Can matters be referred for other enforcement action?

 

Yes.

Information identified during sponsor compliance activity can potentially reveal issues falling outside the immediate sponsor licensing regime.

Depending on the circumstances, matters may be relevant to:

 

• illegal working enforcement;
• civil penalty action;
• criminal investigation;
• other Home Office functions; or
• another government department or enforcement body.

 

The existence of a sponsor compliance check therefore does not prevent UKVI from taking or referring separate action where the evidence indicates another potential breach.

 

13. Does every compliance error lead to enforcement action?

 

No.

The significance of a compliance problem depends on the nature of the requirement, the facts and the applicable sponsor guidance.

There is an important difference between a relatively minor breach that the sponsor is willing and able to correct and a more serious compliance failure capable of leading to suspension or revocation.

However, employers should not assume that administrative failures are automatically inconsequential.

Record keeping, reporting and monitoring are themselves sponsor duties, and weaknesses in these areas can expose the organisation to Home Office action.

 

14. Should the sponsor correct problems before receiving the written outcome?

 

Where a genuine compliance weakness has been identified, the organisation should normally consider appropriate remediation without waiting unnecessarily for the Home Office’s final decision.

Depending on the issue, remediation might include:

 

• correcting an HR process;
• improving internal escalation;
• training managers;
• reviewing sponsored worker files;
• strengthening payroll controls;
• correcting client-site monitoring arrangements;
• reviewing SMS administration; or
• taking required reporting action after establishing the correct position.

 

Remediation does not erase an historic breach, but it can demonstrate that the organisation has identified the underlying weakness and taken steps to prevent recurrence.

 

15. Should the sponsor review other worker files after a problem is identified?

 

Yes, where there is a reasonable possibility that the same weakness could affect other workers.

A compliance issue involving one employee can be evidence of a wider systems problem.

For example, if one sponsored worker’s salary change was not escalated because payroll does not communicate changes to the sponsor licence team, the employer should consider whether other sponsored workers may have been affected by the same process failure.

Likewise, an incomplete worker file may justify checking whether the organisation’s wider record-keeping procedure is operating effectively.

The employer should distinguish between an isolated individual error and evidence of a systemic compliance weakness.

 

16. What should employers learn from a compliance check?

 

A Home Office compliance check should be treated as a significant governance event even where it does not result in formal sponsor action.

After the process concludes, the organisation should consider:

 

• which records UKVI found difficult to verify;
• which questions employees struggled to answer;
• whether sponsored roles were accurately documented;
• whether payroll and sponsorship records aligned;
• whether reporting processes operated effectively;
• whether remote and client-site workers were adequately monitored;
• whether Key Personnel had sufficient oversight; and
• whether changes to compliance governance are required.

 

The aim should be to strengthen the organisation’s ongoing sponsor compliance framework rather than simply preparing for the possibility of another visit.

Once UKVI has completed its checks, the formal outcome will be communicated to the sponsor in writing. Until then, employers should focus on preserving the evidence, meeting any Home Office deadlines, investigating identified concerns and addressing genuine compliance weaknesses.

 

 

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Section O: What Happens if the Home Office Finds Sponsor Non-Compliance?

 

If a Home Office compliance check identifies sponsor non-compliance, the potential consequences will depend on the nature of the issue, the relevant sponsor requirement and the seriousness of the breach.

There is no single outcome that applies to every compliance failure.

UKVI can consider the findings against the organisation’s sponsor duties and the wider requirements for holding a sponsor licence. This can result in action ranging from measures designed to correct relatively minor breaches through to suspension or revocation where the circumstances are more serious.

Employers should not assume that enforcement necessarily follows a fixed sequence. Depending on the applicable sponsor guidance and the findings, serious non-compliance can result in significant sponsor licence action without the organisation first receiving a B-rating.

 

1. What types of non-compliance can UKVI identify?

 

A compliance check can expose problems across different areas of sponsor licence management.

Depending on the circumstances, these can include failures relating to:

 

• sponsor record keeping;
• reporting duties;
• monitoring sponsored workers;
• maintaining worker contact information;
• right to work compliance;
• the genuineness or eligibility of sponsored roles;
• salary and payroll;
• working hours;
• work locations;
• remote or client-site working arrangements;
• SMS administration;
• Key Personnel;
• Certificates of Sponsorship;
• cooperation with Home Office compliance activity; or
• the organisation’s continuing eligibility or suitability to hold a sponsor licence.

 

The Home Office may also identify concerns relating to illegal working or other matters that fall outside the immediate sponsor licence regime.

 

2. Does UKVI distinguish between relatively minor and more serious breaches?

 

Yes, although employers should not attempt to create their own rigid classification system for predicting Home Office action.

Current Home Office guidance provides that where a sponsor has breached its duties but the breach is relatively minor and the sponsor is willing and able to correct it, UKVI will in most cases downgrade the sponsor’s licence to a B-rating and issue a time-limited sponsor action plan.

More serious breaches can lead to more serious action.

Depending on the applicable guidance and circumstances, this can include significant or systematic failures, circumstances in which the sponsor no longer meets relevant eligibility or suitability requirements, serious risks to immigration control or other conduct falling within the Home Office’s sponsor enforcement provisions.

In these circumstances, UKVI may suspend the licence with a view to revocation or, where the relevant provisions permit, revoke the sponsor licence without first suspending it.

 

3. Can administrative errors still matter?

 

Yes.

Employers should not assume that a failure is irrelevant simply because it appears administrative.

Record keeping, reporting and monitoring are substantive sponsor duties.

An apparently minor administrative error can also reveal a wider weakness. For example:

 

• a missing document may indicate defective record-keeping procedures;
• a late SMS report may indicate that managers do not escalate changes;
• an incorrect work address may indicate that remote workers are not being monitored effectively;
• a salary discrepancy may expose weak communication between payroll and the sponsor licence team; or
• an outdated Key Personnel record may indicate inadequate licence governance.

 

The employer should therefore investigate both the individual error and the system that allowed it to occur.

 

4. Can one worker’s compliance problem affect the wider sponsor licence?

 

Yes.

A problem involving one sponsored worker can cause UKVI to examine whether the same issue affects other workers.

For example, if the Home Office identifies that one worker’s salary change was not considered for reporting purposes, it may investigate whether the organisation has an effective process for identifying salary changes across the sponsored workforce.

Similarly, one defective right to work record can lead to wider questions about the organisation’s checking procedures.

The significance of the issue will depend on the facts. An isolated error and a systemic compliance failure are not necessarily equivalent, but the sponsor should be able to establish which situation it is dealing with.

 

5. Can UKVI reduce the sponsor’s Certificate of Sponsorship allocation?

 

Yes.

The Home Office can reduce a sponsor’s Certificate of Sponsorship allocation following compliance concerns.

This can affect the organisation’s ability to sponsor additional workers and can have immediate consequences for recruitment planning.

Employers should therefore consider the operational impact of compliance action as well as the regulatory implications.

 

6. Can the sponsor licence be downgraded to a B-rating?

 

Yes.

Where the sponsor has breached its duties but the breach is relatively minor and the organisation is willing and able to correct it, current Home Office guidance states that UKVI will, in most cases, downgrade the licence to a B-rating and issue a time-limited sponsor action plan.

The action plan will identify the improvements the sponsor is required to make.

The organisation will then need to address the specified compliance issues within the applicable period.

A B-rating should be treated seriously. It is formal Home Office action indicating that the sponsor is not currently meeting the required compliance standard.

 

7. What is a sponsor action plan?

 

A sponsor action plan sets out compliance improvements the Home Office requires the sponsor to make following a downgrade to a B-rating.

The sponsor will need to complete the required actions within the time allowed and demonstrate that the relevant weaknesses have been addressed.

Current guidance provides that the action plan fee must normally be paid within 10 working days of notification. The action plan runs for 3 months. A sponsor can ordinarily be B-rated and subject to an action plan only twice within a rolling four-year period. Failure to comply with the applicable action plan requirements can result in further sponsor licence action, including revocation where the relevant grounds are met.

The precise requirements will depend on the compliance problems identified.

Employers subject to an action plan should ensure that remediation addresses the underlying cause of the problem rather than simply correcting the individual records identified by UKVI.

 

8. Can the sponsor licence be suspended?

 

Yes.

Where the Home Office identifies more serious sponsor compliance concerns, UKVI may suspend the sponsor licence in accordance with the applicable sponsor guidance.

Suspension is a significant enforcement step and can materially affect the organisation’s ability to use its sponsor licence while the Home Office considers further action. While the licence remains suspended, the sponsor cannot assign any Certificates of Sponsorship.

The sponsor should examine the suspension notice carefully, establish the factual basis of each concern and respond within the applicable process and timeframe.

Where a licence has been suspended with a view to revocation, the organisation should treat the matter as urgent.

 

9. Can the sponsor licence be revoked?

 

Yes.

Serious sponsor non-compliance can result in revocation.

Depending on the applicable sponsor guidance and the nature of the breach, revocation can follow a period of suspension or can occur without prior suspension.

Revocation can have significant consequences for:

 

• the organisation’s ability to sponsor workers;
• existing sponsored workers;
• planned international recruitment;
• business operations dependent on sponsored personnel; and
• the organisation’s future ability to participate in the sponsorship system.

 

Employers facing a material risk of revocation should obtain advice promptly and preserve the evidence relevant to the Home Office’s findings.

 

10. Can sponsored workers be affected by sponsor non-compliance?

 

Yes.

Home Office action against the sponsor licence can have consequences for workers whose immigration permission depends on sponsorship by the organisation.

UKVI can also take action affecting individual immigration permission where the relevant Immigration Rules and circumstances provide for this.

The precise impact will depend on the enforcement action taken and the worker’s immigration position. Where a sponsor licence is revoked and the worker was not actively and knowingly complicit in the reasons for revocation, the Home Office will ordinarily consider shortening the worker’s permission so that 60 calendar days remain, unless the worker already has 60 days or less remaining. Where the worker was actively and knowingly complicit, more immediate cancellation action may be taken. Current Home Office cancellation guidance also contains a temporary concession for specified adult social care workers where sponsor licence revocation is the sole reason cancellation would otherwise arise.

Employers responding to serious sponsor licence action should therefore consider the position of their sponsored workforce alongside the organisation’s regulatory response.

 

11. What if the compliance check identifies illegal working?

 

Illegal working concerns can expose the organisation to separate enforcement consequences in addition to sponsor licence action.

Depending on the circumstances, this can include:

 

• civil penalty action;
• criminal investigation where applicable;
• additional Home Office enforcement activity; and
• consequences for the sponsor licence.

 

Right to work compliance should therefore be treated as both a workforce compliance issue and an important element of sponsor licence risk management.

 

12. Can UKVI refer information to another government body?

 

Potentially, yes.

Information obtained during sponsor compliance activity may be relevant to other Home Office functions, government departments, agencies or enforcement bodies.

The sponsor licensing process does not prevent information from being used or referred where another potential regulatory, civil or criminal issue has been identified and the relevant legal framework permits this.

 

13. Does correcting a problem remove the original breach?

 

No.

Remedial action can be important, but it does not retrospectively change what occurred.

If a sponsor failed to meet a duty, correcting the process afterwards does not mean that the historical failure never happened.

However, effective remediation can demonstrate that the organisation has:

 

• identified the problem;
• understood its cause;
• assessed whether other workers are affected;
• corrected the underlying process;
• allocated responsibility appropriately; and
• taken steps to reduce the risk of recurrence.

 

Employers should therefore preserve an accurate chronology showing both the original issue and the subsequent remedial action.

 

14. How should the sponsor investigate non-compliance?

 

The investigation should be systematic and evidence-based.

For each issue, the organisation should establish:

 

1. What happened?
2. When did it happen?
3. Which sponsor requirement is relevant?
4. Who knew about the issue and when?
5. Is the problem still ongoing?
6. Does it affect any other sponsored workers?
7. Was any required Home Office report made?
8. What evidence exists?
9. What remediation has been undertaken?
10. What further action is required?

 

This creates a more reliable basis for responding to UKVI than attempting to explain concerns before the facts have been established.

 

15. Why is the distinction between an isolated and systemic problem important?

 

A compliance failure affecting one worker may have arisen from an unusual individual error, or it may expose a weakness affecting the organisation’s wider sponsorship system.

Employers should investigate which is the case.

For example, one late SMS report might result from an isolated administrative oversight. Alternatively, it might demonstrate that there is no effective process for managers to notify the sponsor licence team about employment changes.

The same distinction can apply to:

 

• right to work checks;
• salary monitoring;
• record keeping;
• absence monitoring;
• client-site oversight;
• work location reporting; and
• Key Personnel administration.

 

The sponsor should not describe an issue as isolated unless the evidence supports that conclusion.

 

16. What should employers do when UKVI alleges non-compliance?

 

The organisation should establish the factual and legal position before deciding how to respond.

This involves identifying:

 

• the specific Home Office concern;
• the sponsor requirement said to have been breached;
• the evidence relied upon;
• the organisation’s contemporaneous records;
• whether the alleged facts are correct;
• whether there is a legitimate explanation;
• whether a breach has occurred;
• whether the issue extends beyond the individual case; and
• what remediation has taken place.

 

The response should then address the actual concern rather than relying on general statements that the organisation takes sponsor compliance seriously.

Where significant sponsor licence action is possible, the employer should consider obtaining legal advice at an early stage.

The essential response to identified non-compliance is to determine what went wrong, how far the problem extends, what the sponsor guidance requires and what evidence demonstrates the organisation’s current position and remediation.

 

 

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Section P: Can a Sponsor Challenge the Findings of a Compliance Check?

 

A sponsor may have opportunities to respond to Home Office compliance concerns, but the available process will depend on the action UKVI proposes or has taken.

There is no single general appeal procedure applying to every sponsor compliance finding.

Employers should therefore identify precisely what Home Office decision, allegation or proposed action they are dealing with and follow the process applicable to that particular situation.

 

1. What if the Home Office has misunderstood the facts?

 

Where a compliance concern is based on a factual error or misunderstanding, the sponsor should identify the issue clearly and support its position with appropriate evidence.

For example, a concern may arise because:

 

• a document has been misunderstood;
• two records cover different periods;
• an interview answer requires clarification;
• a salary figure has been interpreted without relevant context;
• a worker’s location has changed legitimately; or
• UKVI does not have a relevant piece of evidence.

 

The sponsor should explain the factual chronology and provide contemporaneous evidence where available.

A specific evidence-based explanation will generally be more useful than a broad assertion that the Home Office is wrong.

 

2. What if UKVI requests further information?

 

The sponsor should treat a request for further information as an important opportunity to clarify the compliance position before the Home Office reaches or finalises its decision.

The organisation should:

 

• identify exactly what UKVI is asking;
• check the underlying records;
• investigate discrepancies;
• provide relevant evidence;
• explain the chronology where necessary;
• ensure the response is internally consistent; and
• meet the applicable deadline.

 

Information should not be supplied without understanding how it relates to the Home Office concern.

 

3. Can interview evidence be clarified?

 

Where UKVI relies on an interview answer that appears inaccurate or has been misunderstood, the sponsor may need to establish the surrounding facts and identify evidence capable of clarifying the position.

This could involve considering:

 

• what question was asked;
• what the interviewee understood the question to mean;
• what answer was given;
• whether the answer was factually accurate;
• whether terminology caused confusion; and
• what contemporaneous records demonstrate.

 

The sponsor should not attempt to rewrite an inconvenient interview after the event. Any clarification should be grounded in evidence and the genuine factual position.

 

4. What if the sponsor licence is suspended?

 

A suspension notice should be reviewed urgently.

The sponsor should analyse each Home Office allegation separately and establish:

 

• what UKVI alleges occurred;
• which sponsor requirement is relied upon;
• what evidence the Home Office appears to be using;
• whether the alleged facts are correct;
• what evidence the sponsor holds;
• whether a breach occurred;
• whether the issue is isolated or systemic;
• what remediation has already taken place; and
• what response is required within the applicable timeframe.

 

The response should address the specific compliance concerns rather than relying on generic descriptions of the organisation’s HR systems.

 

5. Can remedial action form part of the sponsor’s response?

 

Yes, where relevant.

If the sponsor accepts that a weakness existed, evidence of genuine remediation may form an important part of explaining the organisation’s current position.

Depending on the issue, this could include:

 

• revised procedures;
• additional compliance training;
• changes to internal responsibilities;
• improved payroll escalation;
• additional sponsored worker audits;
• stronger client-site controls;
• changes to record-keeping systems; or
• improved senior management oversight.

 

Remediation should not be presented as if it retrospectively removes an historic breach. The response should distinguish clearly between what happened and what has subsequently been done to correct the problem.

 

6. Should a sponsor automatically admit or deny every alleged breach?

 

No.

The factual position should first be established.

An immediate admission without checking the underlying evidence may be inaccurate, while an unsupported denial can damage the credibility of the response where the records demonstrate that a failure occurred.

The organisation should investigate each allegation and determine the appropriate position based on the sponsor guidance and the available evidence.

 

7. Is there a general statutory appeal against sponsor licence decisions?

 

Sponsor licence decisions do not generally operate under the same statutory appeal framework that applies to certain individual immigration decisions.

The available route for responding to or challenging Home Office action will depend on the particular decision and the applicable sponsor guidance and public law principles.

This makes it important to identify the precise decision rather than assuming that a conventional immigration appeal will be available.

 

8. Can sponsor licence revocation potentially be challenged?

 

Depending on the circumstances, legal challenge may potentially be available against a sponsor licence revocation decision.

The appropriate course will depend on matters including:

 

• the legal basis of the decision;
• the reasons given by the Home Office;
• the underlying evidence;
• whether the relevant sponsor guidance was applied correctly;
• whether material evidence was overlooked or misunderstood;
• whether the decision-making process was lawful; and
• the procedural options available in the particular case.

 

Employers facing revocation should obtain advice promptly because the consequences can be substantial and any available legal challenge may be subject to strict procedural requirements.

 

9. Can judicial review be relevant?

 

Potentially, depending on the circumstances.

Judicial review is a public law procedure concerned with the lawfulness of decision-making. It is not simply a fresh merits appeal against a sponsor licence decision.

Whether judicial review is appropriate will depend on the facts, the decision, any available alternative remedies and the potential grounds of challenge.

Strict procedural and time requirements can apply, so organisations considering a legal challenge should obtain advice without delay.

 

10. What evidence should the sponsor preserve?

 

Where compliance action may be disputed, the organisation should preserve relevant evidence from the outset.

This can include:

 

• the original Home Office correspondence;
• records of the compliance visit;
• documents supplied to UKVI;
• relevant worker files;
• SMS records;
• payroll information;
• HR system records;
• employment contracts;
• job descriptions;
• attendance records;
• internal emails or communications relevant to the issue;
• evidence of reporting;
• contemporaneous notes made during or immediately after the visit; and
• evidence of subsequent remedial action.

 

Records should be preserved in their genuine form. Historic documents should not be altered in an attempt to strengthen the sponsor’s position.

 

11. What makes an effective response to Home Office compliance findings?

 

An effective response should engage directly with the concerns raised by UKVI.

For each issue, the sponsor should aim to establish:

 

1. What does the Home Office allege?
2. Which sponsor requirement is relevant?
3. What are the correct facts?
4. What contemporaneous evidence supports those facts?
5. Has a breach actually occurred?
6. If so, how extensive is it?
7. What remedial action has been taken?
8. What evidence demonstrates that remediation?

 

A generic statement that the organisation has strong compliance systems is unlikely to resolve a specific allegation if the Home Office has evidence suggesting otherwise.

The response should be structured around the actual findings and supported by evidence.

 

12. When should legal advice be considered?

 

Legal advice should be considered where the compliance check exposes significant sponsor licence risk, particularly where:

 

• UKVI alleges serious or systemic non-compliance;
• a B-rating and sponsor action plan may materially affect the organisation;
• the licence has been suspended;
• revocation is being considered or has occurred;
• illegal working concerns have arisen;
• civil or criminal enforcement exposure exists;
• the Home Office appears to have misunderstood material evidence; or
• the organisation is considering a legal challenge.

 

Early advice can also help the organisation preserve evidence, establish the correct factual chronology and avoid making inaccurate statements before the compliance position has been fully investigated.

The central principle when challenging Home Office findings is to respond to the specific concern, applicable sponsor requirement, underlying facts and supporting evidence rather than relying on unsupported assertions about the organisation’s general compliance record.

 

 

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Section Q: Sponsor Compliance Check Checklist

 

A sponsor compliance check can examine multiple aspects of an organisation’s sponsorship arrangements at the same time. Employers should therefore assess compliance across the sponsor licence, individual sponsored workers, HR systems, payroll, right to work procedures and actual working arrangements.

The following checklist can be used as a practical framework for preparing for Home Office compliance activity and for testing ongoing sponsor licence readiness.

 

1. Sponsor licence and Key Personnel

 

Check that the organisation’s sponsor licence information remains accurate and that responsibility for the licence is clearly allocated.

 

• Are the organisation’s sponsor licence details current?
• Are relevant trading and operating addresses correctly recorded?
• Is the Authorising Officer information current?
• Is the Key Contact information current?
• Are Level 1 Users appropriate and current?
• Have former or inappropriate SMS users been removed or otherwise dealt with correctly?
• Does the organisation understand who is responsible for each area of sponsor compliance?
• Can appropriate personnel access relevant records if the usual sponsor licence contact is absent?
• Have significant organisational changes been considered for sponsor reporting purposes?

 

Sponsors should also review any remaining Level 2 Users. 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, after which the Level 2 User role will no longer continue.

Sponsors should also ensure that current SMS security and access requirements are being managed, including the phased rollout of mandatory multi-factor authentication, accurate user contact and personal details and the review of inactive SMS accounts. An SMS User account that has not been accessed for 12 months may be treated as inactive, and sponsors should maintain appropriate active Level 1 User access throughout the life of the licence.

 

2. Sponsor Management System

 

Review the SMS against the organisation’s actual position.

 

• Does the SMS accurately reflect the organisation’s current details?
• Are Key Personnel details current?
• Are appropriate users maintaining SMS access?
• Are sponsored workers correctly recorded?
• Can Certificates of Sponsorship be reconciled with individual worker files?
• Have relevant worker changes been reported where required?
• Have relevant organisational changes been reported?
• Are previous reports capable of being reconciled with HR records?
• Are there outstanding SMS issues requiring investigation?
• Are SMS User personal and contact details accurate for current multi-factor authentication requirements?
• Are inactive or unnecessary SMS User accounts being reviewed and addressed?
• Is appropriate active Level 1 User access being maintained, with regular SMS access in line with Home Office recommendations?

 

Do not make unnecessary changes simply because a compliance check is expected. Where a discrepancy is identified, establish the correct factual position and determine the appropriate action.

 

3. Sponsored worker files

 

For each sponsored worker being reviewed, consider whether the organisation holds the required records and whether those records accurately reflect the employment.

 

• Identity and immigration records available?
• Required right to work evidence retained?
• Relevant Appendix D records available?
• Current contact information retained?
• Certificate of Sponsorship information available?
• Employment contract available?
• Current job description available?
• Recruitment evidence retained where required?
• Relevant qualification or professional registration evidence retained where required?
• Salary information available?
• Payroll records available?
• Working hours understood?
• Work location recorded accurately?
• Attendance and absence records available?
• Employment changes documented?
• Relevant SMS reports identifiable?

 

The review should establish more than whether a document exists. It should test whether the documents collectively provide an accurate account of the worker’s sponsored employment.

 

4. Right to work compliance

 

Review whether the organisation is meeting both its sponsor-specific duties and its wider statutory right to work responsibilities.

 

• Has an appropriate right to work check been carried out on every worker sponsored by the organisation?
• Has the required evidence of each check been retained?
• Where follow-up checks are required, are they identified and completed at the appropriate time?
• Can the organisation demonstrate when and how checks were carried out?
• Are right to work responsibilities clearly allocated internally?
• Are problems escalated appropriately?
• Do procedures reflect the current statutory right to work regime?

 

For sponsor record-keeping purposes, Appendix D requires sponsors to retain evidence of right to work checks on any worker they employ, whether sponsored or not, and any worker they sponsor, whether or not they employ that individual.

Employers should also ensure their procedures reflect the statutory changes effective from 1 October 2026, extending right to work checking responsibilities to specified additional working arrangements, including certain individuals engaged under a worker’s contract, individual subcontractors and certain arrangements involving online matching services.

 

5. Sponsored role and Certificate of Sponsorship

 

Compare the information used for sponsorship with the worker’s current employment.

 

• Does the worker still perform the sponsored role?
• Do their actual duties correspond with the role described for sponsorship purposes?
• Is the role genuine?
• Does the relevant occupation classification remain appropriate?
• Does the employment contract correspond with the actual role?
• Does the line manager’s understanding of the role correspond with the sponsor’s records?
• Would the worker describe their duties in materially the same way?
• Have duties changed since sponsorship began?
• If the role changed, were the immigration implications considered?
• Was any required reporting or other immigration action taken?

 

The sponsor should be able to reconcile the CoS, employment contract, job description, management evidence and the worker’s actual day-to-day duties.

 

6. Salary and payroll

 

Reconcile sponsorship information with actual payroll records.

 

• What salary is stated for sponsorship purposes?
• What salary is stated in the employment contract?
• What is the worker actually being paid?
• Do payroll records support this figure?
• Are the worker’s hours accurately recorded?
• Have there been salary changes?
• Have there been periods of reduced or unpaid pay?
• Are relevant deductions understood?
• Were relevant changes considered under the sponsor reporting requirements?
• Can discrepancies be explained by contemporaneous evidence?

 

Remember that the Home Office conducts regular checks with HMRC in relation to sponsored worker pay.

 

7. Attendance and absence monitoring

 

Test whether the organisation can demonstrate appropriate monitoring of sponsored workers.

 

• How is attendance monitored?
• How are absences recorded?
• How are unexplained absences identified?
• Who is responsible for escalation?
• Do line managers understand their responsibilities?
• Does information reach HR or the sponsor licence team where required?
• Are remote and hybrid workers covered by the monitoring process?
• Are workers at client sites adequately monitored?
• Can relevant records be retrieved?
• Have reportable events been identified and dealt with appropriately?

 

The method of monitoring can vary according to the organisation’s working model, but the sponsor should be able to demonstrate that the system works in practice.

 

8. HR systems and internal responsibilities

 

Assess whether the organisation’s compliance processes connect the different business functions involved in sponsorship.

 

• Who has overall responsibility for sponsor compliance?
• Who carries out right to work checks?
• Who monitors immigration permission?
• Who maintains sponsored worker records?
• Who monitors attendance and absence?
• Who identifies employment changes?
• Who makes SMS reports?
• How does payroll communicate relevant changes?
• How do line managers escalate changes?
• How does recruitment communicate with HR and the sponsor licence team?
• What happens when the usual responsible employee is absent?
• Are relevant employees trained?

 

The organisation should avoid a situation where sponsor compliance depends entirely on one individual with no effective cover, oversight or internal communication process.

 

9. Reporting duties

 

Review relevant employment and organisational events against the sponsor’s SMS history.

 

• Have relevant changes involving sponsored workers been identified?
• Were required reports made?
• Were reports made within the applicable requirements?
• Can the organisation evidence when it became aware of relevant events?
• Have changes to work location been considered?
• Have changes to salary or working arrangements been considered?
• Have relevant absences or cessation of employment been considered?
• Have relevant organisational changes been reported?
• Do HR records correspond with the SMS reporting history?

 

Where a potential missed report is identified, investigate the chronology and determine whether the issue is isolated or reflects a wider weakness in the reporting process.

 

10. Remote and hybrid workers

 

For sponsored workers operating remotely or under hybrid arrangements, check whether the sponsor retains meaningful oversight.

 

• Where does the worker normally work?
• What is their normal working pattern?
• Is the arrangement accurately reflected in the organisation’s records?
• Who manages the worker?
• How is attendance monitored?
• How are absences identified?
• How does the sponsor maintain contact?
• Are the worker’s duties understood?
• Have working arrangements changed?
• Were any relevant changes considered for reporting purposes?

 

Where a sponsored worker normally works from home, remember that Home Office compliance activity can, where relevant, take place at the physical address where the worker carries out their duties, including their home address.

 

11. Client and third-party sites

 

Where sponsored workers perform duties at client or third-party locations, review the sponsor’s oversight and the third party’s compliance arrangements.

 

• Where is the worker currently based?
• Why are they working at the third-party location?
• What duties do they perform?
• Do those duties remain consistent with the sponsored role?
• Who directs and supervises the worker?
• How is attendance monitored?
• How does the sponsor receive information about absences or changes?
• Does the sponsor retain sufficient control and oversight?
• Has the client been informed that an unannounced Home Office compliance visit may occur?
• Will the client cooperate fully with UKVI?
• Are appropriate access arrangements in place?
• Can relevant records be produced promptly?

 

Current Home Office guidance states that where a relevant third party is uncooperative with a compliance check, the Home Office will take action against the sponsor.

 

12. Preparing Key Personnel and other employees

 

Relevant personnel should understand their actual responsibilities and the processes they operate.

 

• Does the Authorising Officer understand how sponsorship is governed?
• Do Level 1 Users understand their SMS responsibilities?
• Are any remaining transitional Level 2 Users being converted or deactivated within the required timeframe?
• Does HR understand sponsor compliance procedures?
• Do line managers know when changes should be escalated?
• Does payroll understand that salary changes can have immigration implications?
• Do recruitment personnel understand the records they need to maintain?
• Can relevant employees locate required records?
• Do employees know not to guess when they do not know an answer?

 

Preparation should establish factual understanding. Employees and sponsored workers should not be coached to provide scripted or misleading answers.

 

13. During the Home Office compliance check

 

During an onsite or digital compliance check:

 

• verify the identity of visiting officers;
• notify appropriate internal personnel;
• cooperate with legitimate Home Office compliance activity;
• allow Home Office staff full access to premises or sites under the sponsor’s control on demand where applicable;
• identify an appropriate person to coordinate the organisation’s response;
• maintain a contemporaneous record of the compliance activity;
• record documents requested and supplied;
• facilitate access to relevant records and systems;
• cooperate with legitimate interviews;
• provide accurate information;
• do not guess where the answer is unknown;
• do not coach sponsored workers or other employees;
• investigate discrepancies rather than improvising explanations;
• record requests for follow-up information; and
• record any deadlines imposed by UKVI.

 

Where there is genuine doubt about the identity of a visiting officer or third party acting for the Home Office, the sponsor can verify the position using the Home Office Business Helpdesk on 0300 123 4699.

 

14. Immediately after the compliance check

 

Once the onsite visit or digital meeting has concluded:

 

• conduct an internal debrief;
• record what UKVI examined;
• record who was interviewed;
• preserve contemporaneous notes;
• confirm which documents were supplied;
• identify outstanding Home Office requests;
• record applicable deadlines;
• investigate discrepancies;
• review potential compliance failures;
• consider whether the same issues affect other sponsored workers;
• identify remedial action;
• consider whether any SMS reporting action is required;
• preserve evidence of remediation; and
• obtain legal advice where significant sponsor licence exposure exists.

 

Do not wait for the Home Office’s written decision before addressing a genuine weakness that has already been identified.

 

15. Final sponsor compliance readiness questions

 

For each sponsored worker, the organisation should be capable of answering the following questions:

 

1. Who is this worker?
2. What immigration permission do they hold?
3. Was the appropriate right to work check completed and retained?
4. What role were they sponsored to perform?
5. What do they actually do?
6. What are they paid?
7. Do payroll records confirm this?
8. What hours do they work?
9. Where do they work?
10. Who manages them?
11. How is their attendance monitored?
12. Have their circumstances changed?
13. Were relevant changes reported where required?
14. Are the required records available?
15. Would the worker’s own account materially correspond with the sponsor’s records?

 

At organisational level, the sponsor should also be capable of answering:

 

1. Who is responsible for the sponsor licence?
2. How are sponsor duties embedded into HR processes?
3. How do managers, payroll, recruitment and HR communicate relevant changes?
4. Can the organisation retrieve required records promptly?
5. Does the SMS reflect the organisation’s actual position?
6. Can the sponsor demonstrate effective oversight of remote and client-site workers?
7. Could the organisation respond effectively to an unannounced Home Office visit today?

 

The central compliance test is alignment. The sponsor licence, SMS, HR systems, payroll records, sponsored worker documents and reality of the employment should tell the same story.

 

 

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Section R: FAQs: Home Office Sponsor Compliance Checks

 

What is a Home Office sponsor compliance check?

A Home Office sponsor compliance check is an assessment carried out by UKVI to establish whether an organisation is meeting its sponsor duties and remains suitable to hold a sponsor licence.

The check can involve requests for documents and information, verification against information held by other government bodies, interviews, an onsite compliance visit or a digital compliance check.

UKVI may examine the organisation’s HR systems, Sponsor Management System records, sponsored worker files, right to work evidence, payroll information, recruitment records, attendance monitoring, work locations and reporting processes.

The central issue is whether the organisation is complying with its sponsor duties in practice and whether the information provided to the Home Office accurately reflects the sponsored employment.

 

Why would UKVI carry out a sponsor compliance check?

UKVI can carry out compliance checks as part of its ongoing oversight of licensed sponsors.

A check does not necessarily mean that the Home Office has already concluded that the sponsor is non-compliant.

Compliance activity can also arise where information creates concerns about the sponsor’s compliance or continuing suitability. Relevant information can come from a range of sources, including worker immigration applications, HMRC information, other government bodies, previous compliance history, allegations or other intelligence available to the Home Office.

UKVI can use the check to determine whether information previously supplied by the sponsor remains accurate and whether sponsor duties are being met.

 

Can the Home Office visit a sponsor without warning?

Yes.

Home Office compliance visits can be announced or unannounced.

A sponsor should therefore maintain its compliance systems continuously rather than relying on advance notice of a visit to bring records up to date.

Where officers arrive without warning, the organisation should verify their identification, notify the appropriate internal personnel and cooperate with legitimate compliance activity.

Current sponsor guidance requires sponsors to allow Home Office staff full access to premises or sites under the sponsor’s control on demand.

 

How much notice does the Home Office give before a compliance visit?

There is no single notice period that applies to every sponsor compliance check because Home Office visits can be announced or unannounced.

Where notice is provided, the Home Office may give the sponsor information about the proposed compliance activity or request documents in advance.

However, employers should not structure their compliance systems on the assumption that advance notice will always be given.

The organisation should be capable of responding appropriately if UKVI attends without prior warning.

 

What documents can UKVI ask to see during a sponsor compliance check?

The documents requested will depend on the scope of the check, but UKVI can examine records relevant to the organisation’s sponsor duties and sponsored workers.

These can include:

 

• Certificates of Sponsorship;
• employment contracts;
• job descriptions;
• right to work evidence;
• documents required under Appendix D;
• recruitment records;
• salary and payroll records;
• attendance and absence records;
• worker contact information;
• evidence of relevant qualifications or professional registration;
• SMS reporting records; and
• relevant organisational records.

 

UKVI can also inspect relevant HR systems and assess whether the organisation’s processes are capable of supporting effective sponsor compliance.

 

Can Home Office officers interview sponsored workers?

Yes.

Home Office sponsor guidance allows compliance officers to interview sponsored workers as part of compliance activity, including through onsite or digital interviews.

A worker may be asked about matters such as:

 

• their job;
• day-to-day duties;
• salary;
• working hours;
• work location;
• line manager;
• recruitment; and
• other aspects of their sponsored employment.

 

UKVI can compare the worker’s account with the Certificate of Sponsorship, employer records, payroll information, information provided by managers and other available evidence.

Employers should not coach sponsored workers to provide scripted answers. The objective should be to ensure that the sponsored employment itself is compliant and that the organisation’s records accurately reflect it.

 

Can UKVI interview employees separately from management?

UKVI can speak directly to sponsored workers and to other employees or colleagues relevant to the compliance check, including people involved in recruitment or the management of sponsored workers.

The sponsor should not assume that all information will be obtained through senior management or that management will answer questions on behalf of other employees.

UKVI may want a direct account from the person with first-hand knowledge of the matter being examined.

Employers should therefore ensure that relevant personnel understand their own responsibilities and can provide accurate factual information. They should not attempt to coordinate scripted answers between employees.

 

Can the Home Office inspect an employer’s HR systems?

Yes.

UKVI can inspect records and systems relevant to sponsor compliance and assess whether the organisation has effective processes for meeting its sponsor duties.

This may include examining how the organisation manages:

 

• right to work checks;
• immigration permission;
• sponsored worker records;
• attendance and absence;
• contact information;
• salary changes;
• changes to sponsored employment;
• SMS reporting; and
• internal compliance escalation.

 

This should not be interpreted as an unrestricted entitlement to browse unrelated confidential information throughout the employer’s systems. The sponsor should cooperate fully with legitimate compliance requests while facilitating access to records and systems relevant to the check.

 

Does UKVI check sponsored worker payroll information with HMRC?

Yes.

Current Home Office sponsor guidance confirms that UKVI conducts regular checks with HMRC to verify information relating to sponsored worker pay.

Employers should therefore ensure that salary information used for sponsorship can be reconciled with actual payroll records.

UKVI may consider the salary stated on the CoS alongside the employment contract, payslips, payroll records, working hours, salary changes and relevant HMRC information.

Where a discrepancy exists, the sponsor should investigate and establish the factual position rather than assuming that differences between sponsorship and payroll information will not be identified.

 

Can the Home Office visit a client site where sponsored workers are based?

Yes, where relevant to sponsor compliance activity.

Where sponsored workers perform their duties at a third party’s office, current Home Office guidance requires the sponsor to ensure that the third party is aware that an unannounced compliance visit may take place and that the third party will cooperate fully.

The sponsor should therefore have appropriate arrangements in place before deploying sponsored workers to client premises.

The Home Office guidance states that where a relevant third party is uncooperative with a compliance check, the Home Office will take action against the sponsor.

The sponsor cannot avoid its compliance responsibilities simply because the worker performs duties at premises controlled by a client.

 

Can a sponsor compliance check be carried out remotely?

Yes.

UKVI can conduct digital compliance checks using remote video conferencing facilities.

During a digital check, compliance officers may interview Key Personnel, sponsored workers or other relevant employees, request documents and examine how the organisation operates its sponsor compliance systems.

A digital check should be treated with the same seriousness as an onsite compliance visit.

UKVI can also combine different forms of compliance activity. A digital check may therefore be followed by further requests for information or other compliance activity where required.

 

How long does a Home Office sponsor compliance check take?

There is no single duration that applies to every compliance check.

The time required will depend on factors such as:

 

• the size and complexity of the organisation;
• the number of sponsored workers being examined;
• the scope of the Home Office’s enquiries;
• the records and systems being reviewed;
• the number of interviews required;
• whether discrepancies are identified; and
• whether further information is required after the initial visit or digital meeting.

 

The compliance process may also continue after officers leave the premises. UKVI can review the evidence, carry out further verification and request additional information before deciding whether sponsor licence action is required.

 

What happens after a Home Office sponsor compliance visit?

After completing its checks, the Home Office will consider the evidence and determine what action, if any, is appropriate.

The compliance officer should not be expected to provide a pass or fail assessment during the visit itself.

Current sponsor guidance confirms that, once the Home Office has completed its consideration, the sponsor will be notified of the decision in writing.

Before that decision is made, UKVI may request additional documents, clarification or other evidence.

The sponsor should use the period following the check to investigate any discrepancies identified during the process and address genuine compliance weaknesses rather than simply waiting for the written outcome.

 

Can a Home Office compliance check lead to sponsor licence suspension?

Yes.

Where UKVI identifies sufficiently serious sponsor compliance concerns, the Home Office can suspend the sponsor licence in accordance with the applicable sponsor guidance.

Current guidance distinguishes between relatively minor breaches that a sponsor is willing and able to correct and more serious compliance failures.

Where a breach is relatively minor and the sponsor is willing and able to correct it, UKVI will, in most cases, downgrade the licence to a B-rating and issue a time-limited sponsor action plan.

More serious breaches may result in suspension with a view to revocation or other action permitted by the sponsor guidance.

 

Can the Home Office revoke a sponsor licence after a compliance check?

Yes.

Serious sponsor non-compliance can result in revocation of the sponsor licence.

Depending on the applicable provisions and circumstances, UKVI may suspend the licence with a view to revocation or may revoke the licence without first suspending it.

More serious cases can include significant or systematic failures, circumstances in which the organisation no longer meets relevant eligibility or suitability requirements, serious risks to immigration control or other conduct falling within the applicable sponsor guidance.

Revocation can have significant consequences for the employer’s ability to sponsor workers and for existing workers whose immigration permission depends on the organisation’s sponsorship.

 

How should an employer prepare for a Home Office sponsor compliance check?

The employer should prepare by establishing its actual compliance position and reconciling the different records that UKVI may examine.

This should include reviewing:

 

• the sponsor licence and SMS;
• Key Personnel;
• Certificates of Sponsorship;
• sponsored worker files;
• right to work evidence;
• Appendix D records;
• employment contracts;
• job descriptions and actual duties;
• salary and payroll information;
• working hours;
• attendance and absence;
• work locations;
• remote and hybrid arrangements;
• client-site workers;
• SMS reporting history; and
• the effectiveness of HR compliance systems.

 

Key Personnel and other relevant employees should understand their responsibilities, but workers and staff should not be coached to provide scripted answers.

If preparation identifies a genuine compliance problem, the employer should establish what happened, assess whether other workers are affected, determine what action is required and document appropriate remediation.

The purpose of preparation is not to make the organisation appear compliant for the duration of a visit. It is to ensure that the organisation can demonstrate that sponsor compliance works in practice.

 

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Section S: Conclusion

 

A sponsor licence places an organisation under continuing Home Office scrutiny. UKVI can carry out compliance checks to determine whether the organisation continues to meet its sponsor duties and remains suitable to participate in the sponsorship system.

A Home Office sponsor compliance check can extend well beyond a review of immigration documents.

Depending on the circumstances, UKVI may examine:

 

• the sponsor licence and Sponsor Management System;
• Certificates of Sponsorship;
• sponsored worker files;
• right to work records;
• Appendix D documentation;
• recruitment records;
• employment contracts and job descriptions;
• actual job duties;
• salary and payroll information;
• working hours;
• attendance and absence monitoring;
• work locations;
• remote and hybrid working arrangements;
• client and third-party working arrangements;
• HR systems;
• reporting processes;
• Key Personnel and SMS administration; and
• the organisation’s wider sponsor compliance governance.

 

Compliance officers can also speak directly to Key Personnel, managers, HR employees, recruitment personnel, sponsored workers and other individuals with relevant knowledge of the organisation’s sponsorship arrangements.

Checks can take place onsite or digitally and can be announced or unannounced.

The central issue is whether the organisation is complying with its sponsor duties in practice.

UKVI can compare what the sponsor has told the Home Office with what is recorded on the CoS, what appears within the SMS, what HR and payroll records show, what managers say, what sponsored workers say and what is actually happening within the workplace.

Employers should therefore avoid treating sponsor compliance as an administrative exercise confined to the immigration or HR team.

Effective compliance depends on information moving between the people responsible for recruitment, HR, payroll, line management, workforce operations and the sponsor licence.

This becomes particularly important where sponsored workers:

 

• work remotely;
• operate under hybrid arrangements;
• move between business locations;
• work at client sites; or
• are managed through decentralised business structures.

 

The sponsor must retain sufficient oversight to know where its sponsored workers are, what they are doing and whether their employment continues to correspond with the basis on which they were sponsored.

Where a compliance check identifies problems, employers should investigate both the individual issue and the possibility of a wider systems failure.

Current Home Office guidance provides that where a sponsor has breached its duties but the breach is relatively minor and the sponsor is willing and able to correct it, UKVI will, in most cases, downgrade the licence to a B-rating and issue a time-limited sponsor action plan.

More serious compliance failures can lead to suspension with a view to revocation or, where the applicable provisions provide for this, revocation without prior suspension. Other consequences can include a reduction in the sponsor’s CoS allocation, action affecting sponsored workers and referrals for other enforcement action.

Employers should therefore maintain sponsor compliance continuously rather than attempting to prepare only when a Home Office visit is announced.

The most effective approach is regular reconciliation between the sponsor licence, SMS, sponsored worker files, HR systems, payroll records and the reality of each sponsored worker’s employment.

UKVI is not merely checking whether paperwork exists. It is testing whether sponsor compliance works in practice.

 

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Section T: Glossary

 

 

Term	Meaning
Authorising Officer	The senior person responsible for the sponsor licence and for ensuring that the organisation meets its sponsorship responsibilities. The Authorising Officer has overall responsibility for the sponsor’s use of the sponsorship system, although day-to-day administration may be carried out by other authorised personnel.
B-Rating	A sponsor licence rating that can be imposed where a sponsor has breached its duties but, in the circumstances covered by the sponsor guidance, the organisation is considered willing and able to correct the relevant compliance failures. Current guidance provides that relatively minor breaches will, in most cases, result in a downgrade to a B-rating and a time-limited sponsor action plan.
Certificate of Sponsorship	An electronic sponsorship record assigned by a licensed sponsor to an eligible worker. The CoS contains information about the sponsored role and employment and forms part of the worker’s immigration application.
Compliance Check	Home Office activity used to assess whether a sponsor or prospective sponsor meets the requirements of the sponsorship system. A compliance check can involve document requests, verification with other bodies, interviews, onsite visits, digital checks and other relevant evidence.
Compliance Officer	A Home Office official carrying out compliance activity relating to a sponsor or prospective sponsor. Compliance officers may inspect relevant records and systems, conduct interviews and investigate whether sponsorship requirements are being met.
Compliance Visit	An onsite Home Office compliance check at premises relevant to the sponsor or sponsored employment. Visits can be announced or unannounced and may involve document inspection, interviews and examination of relevant HR systems and working arrangements.
Digital Compliance Check	A Home Office compliance check conducted using remote technology such as video conferencing. Digital checks can involve interviews, requests for records and examination of the organisation’s sponsor compliance arrangements without an initial physical visit.
Home Office	The UK government department responsible for immigration, borders and related functions. Sponsor licensing and sponsor compliance functions are administered through the Home Office, including UK Visas and Immigration.
Key Personnel	Individuals appointed in connection with the administration and oversight of a sponsor licence, including the Authorising Officer, Key Contact and Level 1 Users and, during the transitional period, any remaining Level 2 Users. The historic Level 2 User role is being withdrawn. 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, after which the Level 2 User role will no longer continue.
Level 1 User	An authorised user with access to the Sponsor Management System and permissions to carry out sponsorship administration within the scope permitted by the Home Office system and sponsor guidance.
Sponsor Action Plan	A time-limited plan imposed by the Home Office following relevant sponsor compliance failures and a downgrade to a B-rating. It specifies actions the sponsor must take to address the identified compliance weaknesses.
Sponsor Duties	The continuing responsibilities imposed on licensed sponsors. These include duties relating to record keeping, reporting, monitoring sponsored workers, maintaining relevant information, complying with immigration requirements and cooperating with Home Office compliance activity.
Sponsor Licence	Home Office authorisation allowing an eligible organisation to sponsor qualifying workers under relevant UK immigration routes, subject to the organisation continuing to meet the applicable sponsorship requirements.
Sponsor Management System	The Home Office online system used by licensed sponsors to administer their sponsor licence, manage relevant sponsorship activity and report specified changes to UKVI.
Sponsored Worker	An individual sponsored by a licensed organisation under an eligible immigration route. The sponsor has continuing responsibilities relating to the worker for the duration of the relevant sponsorship.
Sponsor Licence Suspension	Home Office action that temporarily suspends the sponsor licence while compliance concerns are considered. Suspension can significantly restrict the organisation’s ability to use its sponsor licence and may be imposed with a view to potential revocation.
Sponsor Licence Revocation	Home Office action withdrawing an organisation’s sponsor licence. Revocation can prevent the organisation from continuing to sponsor workers and can have immigration consequences for workers sponsored by the organisation.
UK Visas and Immigration	UK Visas and Immigration, commonly referred to as UKVI, is part of the Home Office and administers immigration functions including sponsor licensing and sponsor compliance activity.

 

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Section U: Useful Links

 

Resource	URL
Home Office: Workers and Temporary Workers – Sponsor Duties and Compliance	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
Home Office: Appendix D – Keeping Documents for Sponsorship	https://www.gov.uk/government/publications/keep-records-for-sponsorship-appendix-d
Home Office: Employer’s Guide to Right to Work Checks	https://www.gov.uk/government/publications/right-to-work-checks-employers-guide
GOV.UK: Check a Job Applicant’s Right to Work	https://www.gov.uk/check-job-applicant-right-to-work
Home Office: Workers and Temporary Workers – Apply for a Sponsor Licence	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-1-apply-for-a-licence
Home Office: Workers and Temporary Workers – Sponsor a Worker	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-2-sponsor-a-worker

 

 

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