SponsorGuard
Menu
Sign inRequest access
All blog articles

· 10 min read

UK sponsor licence duties: a practical compliance checklist for 2026

A sponsor licence lets you recruit overseas workers. It also comes with duties that the Home Office expects you to meet every day, not just when you apply.

This guide turns the current guidance into a working checklist. It's written for HR teams and Authorising Officers at sponsor employers, and for the immigration solicitors and advisers who support them. It isn't legal advice.

Why sponsor compliance matters more in 2026

The Home Office's own transparency data shows how far enforcement has grown. Adding up the quarterly figures in its sponsorship transparency data (table SC_01), 3,100 Skilled Worker sponsor licences were revoked in calendar year 2025, compared with 1,494 in 2024. In the 12 months to June 2026 the figure was 4,403. (Migration transparency data, GOV.UK)

The guidance has also tightened. Since 8 April 2026, Sponsor a Skilled Worker sets out pay-period tests for salary compliance. On 1 October 2026 a new code of practice on preventing illegal working came into force, extending the Right to Work Scheme to a wider range of working arrangements.

The five headline duties

Part 3 of the sponsor guidance (para C1.11) groups sponsor duties into five areas:

  1. reporting duties
  2. record-keeping duties
  3. complying with immigration law and all parts of the sponsor guidance
  4. complying with wider UK law
  5. not behaving in ways that are not conducive to the public good

If the Home Office reasonably suspects you're not meeting these duties, C1.12 lists what it can do: reduce your CoS allocation, downgrade your rating, suspend your licence, revoke it, or report you to the police or other authorities. (Part 3: sponsor duties and compliance)

The checklist below follows those areas.

Checklist 1: reporting duties

Worker changes: 10 working days

Unless the guidance says otherwise, you must report changes to a sponsored worker's circumstances on the Sponsorship Management System (SMS) within 10 working days (C1.13, C1.15). These include:

  • the worker doesn't start within 28 days of the expected start date
  • the worker is absent without permission for more than 10 consecutive working days. You must report no later than 10 working days after the 10th day of absence (C1.19)
  • the worker is absent without pay, or on reduced pay, for more than 4 weeks in total in a calendar year
  • the worker's salary is reduced from the level on their CoS
  • significant changes to their employment, such as a change of job title or core duties within the same occupation code
  • a change to their normal work location, including a move to working entirely from home (C1.21, C1.24)
  • you stop sponsoring them, for any reason

Organisation changes: 20 working days

Most changes to your organisation must be reported within 20 working days of you becoming aware of them (C2.3). Examples include changes of address, new branches, mergers or takeovers, a change in organisation size or charitable status, and changes to key personnel.

Report as soon as reasonably practicable

C1.14 also requires you to report suspected breaches of a worker's conditions of stay, and to pass relevant information to the police, as soon as reasonably practicable.

Practical tip: late reports usually happen because a line manager or payroll knows about the event, but the person with SMS access doesn't. Map how each event reaches your SMS users.

Checklist 2: record-keeping (Appendix D)

Appendix D lists the documents you must keep for each sponsored worker. The current version is valid from 3 August 2026. (Appendix D: record-keeping duties)

  • Right to work evidence: the check, how it was done, and the date (section 1)
  • Recruitment evidence, where a labour market test or similar step applied to the role (section 2)
  • Salary evidence: payslips showing name, NI number, tax code, allowances and deductions, plus evidence of each payment into the named worker's account (section 3). Appendix D says the Home Office won't accept accounts that show only "wages for personnel" without identifying the worker.
  • Contract or written statement of employment particulars, showing the parties, start and end dates, the job, hours and pay
  • Skill level evidence: a detailed job description, relevant qualifications, and any professional registration the role needs (section 4)
  • NI number and a history of contact details (address, personal email, phone), kept up to date (section 5)

How long to keep them: while you sponsor the worker, then until one year after sponsorship ends, or until a compliance officer has examined and approved them if that's sooner. You must also keep the documents from your licence application for as long as you hold the licence.

Checklist 3: right to work checks

  • Check every worker before employment starts. As a sponsor, you must check sponsored workers even where you wouldn't need a statutory excuse (Part 3, C7.28).
  • Do follow-up checks for anyone with time-limited permission (C7.29).
  • For eVisa holders, use the Home Office online service with the worker's share code.
  • Don't rely on a recruitment agency or adviser to do the check for you. The code of practice in force from 1 October 2026 says that, apart from prescribed checks done by a right to work digital verification service provider (which must now be a registered provider), the employer won't have a statutory excuse if a third party carries out the check. (Code of practice on preventing illegal working)
  • Review contractor and sub-contractor arrangements. Under the 2025 Act, the scheme now covers workers' contracts, individual sub-contractors and some online matching services.

What's at stake: the civil penalty starts at £45,000 per illegal worker for a first breach and £60,000 for a repeat breach within 3 years (code of practice, as above). Part 3 (C7.30) adds that if you're issued with a civil penalty, your licence is likely to be revoked.

Checklist 4: salary and role compliance

  • Pay at least the salary on the CoS, and the higher of the general threshold and the going rate for the occupation code, after any discount that applies. For CoS assigned on or after 22 July 2025, the general threshold can be any of £41,700, £37,500, £33,400, £31,300, £28,200 or £25,000, depending on the points option. (Sponsor a Skilled Worker, SK5.10)
  • Check pay by pay period as well as annually. Pay must be at least monthly, unless the contract says otherwise. Depending on pay frequency and working pattern, totals over any 3-month, 12-week or 17-week period must reach the matching share of the annual salary (SK7.20 to SK7.24).
  • Don't include allowances in the CoS salary figure unless an exception applies (SK7.3).
  • Keep the actual role matched to the CoS occupation code and job description. A role that doesn't match, and isn't a permitted change, is a mandatory ground for revocation (Part 3, C1.45).

The Home Office says it will check pay "through either compliance checks or HMRC checks, or both" (SK7.19), and Part 3 (C7.7) refers to regular HMRC checks.

Checklist 5: people and SMS access

  • At least one Level 1 User at all times (C2.16). If your only Level 1 User leaves, you can't use the SMS and must use the change of circumstances form (C2.15).
  • An Authorising Officer who is senior and genuinely engaged.
  • Level 2 Users are being phased out, and Part 3 only allowed adding them before 9 September 2026 (C2.4). Plan for Level 1 cover instead.
  • Nobody assigns a CoS to themselves or to a close relative or partner (C1.42).

Checklist 6: being ready for a compliance check

Checks can happen at any time, announced or unannounced, on site or by video (C7.9, C7.14). For a step-by-step plan, see How to prepare for a Home Office sponsor compliance visit.

A note for immigration solicitors and advisers

If you manage sponsor compliance for several clients, this checklist multiplies by every client you have. What usually breaks isn't knowledge of the rules. It's visibility: which client has a deadline next week, or an evidence gap an officer would find. A short monthly status report per client, built around these six areas, gives clients something concrete and supports your retainer.

How SponsorGuard fits

SponsorGuard is compliance software for UK sponsor licence holders and the solicitors and advisers who support them. Based on what's live on the product today, it helps you:

  • import your workforce data and CoS PDFs to build a permanent, searchable record
  • automate the GOV.UK right-to-work share-code check, while your team still confirms the photo and the result, and anything unclear is flagged for review
  • track RTW re-checks, with alerts at 90, 60, 30, 14 and 7 days and when overdue
  • track eVisa expiry and the 10 and 20 working day SMS reporting windows
  • flag absences, and check recorded salaries against the SOC going rate and general threshold
  • assemble an Appendix D evidence pack for each worker, plus a pre-visit self-assessment
  • give firms one multi-client dashboard across all their sponsor clients

SponsorGuard is a tracking and evidence tool. It doesn't give legal advice, it doesn't submit anything to the Home Office, and it can't guarantee any Home Office outcome. AI-assisted outputs always need review by an authorised person.

FAQ

What are the main duties of a UK sponsor licence holder?

Part 3 of the Home Office sponsor guidance groups them into five areas: reporting, record-keeping, complying with immigration law and the sponsor guidance, complying with wider UK law, and not acting against the public good (para C1.11).

How long do I have to report changes on the SMS?

Usually 10 working days for changes to a sponsored worker's circumstances, and 20 working days for most changes to your organisation. Some events have their own rules, such as unauthorised absence of more than 10 consecutive working days (Part 3, C1.13 to C1.19 and C2.3).

How long must sponsors keep Appendix D records?

While you sponsor the worker, then until one year after sponsorship ends, or until a compliance officer has examined and approved the documents if that's sooner. Documents from your licence application must be kept for as long as you hold the licence.

What is the fine for employing an illegal worker in 2026?

Under the code of practice in force from 1 October 2026, the starting point is £45,000 per worker for a first breach and £60,000 for a repeat breach within 3 years, before any reductions.

Can a recruitment agency do our right to work checks?

Not in a way that gives you a statutory excuse. The exception is prescribed checks done by a registered right to work digital verification service provider. As a sponsor you must also make sure every sponsored worker is checked.

Sources

Want to see how this works in practice? SponsorGuard is opening an invite-only pilot for up to 8 sponsor employers and immigration firms. It lasts 30 days, opening in October 2026. You can also run the free sponsor health-check without logging in. Find both at sponsorguard.com.