Sponsor Licence Compliance Guide 2026

Key points about Sponsor Licence Compliance

• Sponsor licence compliance means meeting all Home Office sponsor duties from the date your licence is granted until it ends.
• Sponsors must comply with five core duties: reporting duties, record-keeping duties, complying with immigration law, complying with wider UK law, and avoiding behaviour not conducive to the public good.
• Failure to comply can result in your licence being downgraded, suspended, or revoked.
• The Home Office can carry out announced or unannounced compliance checks, including site visits, digital interviews, document inspections, and interviews with sponsored workers and key personnel.

What is sponsor licence compliance?

Sponsor licence compliance means meeting all of the duties and responsibilities required by the Home Office as a licenced sponsor of workers from overseas. If you hold a sponsor licence, you are responsible for those duties from the day your licence is granted until it is surrendered, made dormant, or revoked.

The Home Office monitors sponsors on an ongoing basis. It also carries out formal compliance checks to verify whether you are meeting your duties. If you breach your duties, or if the Home Office reasonably suspects you are failing to comply, it can take enforcement action. This includes downgrading your licence, suspending it, or revoking it entirely. In more serious cases, civil penalties may be issued if illegal working is found.

In March 2026, the Home Office tightened the rules and reflected these changes in the updated Sponsor Licence Compliance Guidance, including:

• Sponsors now have an explicit duty to read all parts of the guidance and stay aware of any changes made to it
• The Home Office can now take action if it reasonably suspects that you are failing to comply with your duties, even without proof of an actual breach
• The guidance reinforces that sponsorship is a privilege, not a right
• Sponsors must ensure that the job role a worker actually performs matches the Certificate of Sponsorship (CoS) exactly
• Sponsors must carry out right-to-work checks on any worker you wish to sponsor (including a worker who is not your direct employee), or any worker you otherwise wish to employ (whether sponsored or not).
• From 8 April 2026, sponsors must ensure Skilled Workers are paid the required salary in each pay period, and the pay must meet the required rate for the hours worked during that pay period

Sponsor licence compliance duties and requirements

Employers with a sponsor licence must continuously comply with their sponsor duties. There are five core duties:

1. Reporting duties
2. Record-keeping duties
3. Complying with immigration law
4. Complying with wider UK law
5. Not engaging in behaviour that is not conducive to the public good

Reporting Duties

You must report certain changes to the Home Office using the Sponsorship Management System (SMS). Reports must be made within strict deadlines.

1. Report worker-related changes within 10 working days, including:

• A sponsored worker does not start the role within 28 days of the expected start date
• A sponsored worker is absent from work without your permission for more than 10 consecutive working days
• A sponsored worker is absent from work without pay, or on reduced pay, for more than 4 weeks in total in any calendar year
• A sponsored worker’s salary or pay is reduced from the level stated on their CoS (you do not need to report increases)
• There are significant changes to the details of a worker’s employment, such as a change of job role, job title, or core duties (where the change is within the same occupation code)
• A sponsored worker’s normal work location changes
• You stop sponsoring a worker for any reason

If you report that a worker’s absence is unauthorised or that you are stopping sponsorship, you must also provide the worker’s last known home address, telephone number, and any personal email addresses you hold.

2. Report organisation-related changes within 20 working days, including:

• A change in your organisation’s legal structure, such as a merger, takeover, or change of ownership
• A change in your organisation’s size or charitable status
• Insolvency proceedings, such as administration, liquidation, or a company voluntary arrangement
• Any other changes set out in section C2 of the sponsor guidance

3. Report suspected breaches or criminal activity immediately, including:

• If you know or suspect that a sponsored worker has breached their conditions of stay
• If you have information suggesting that a sponsored worker may be engaged in terrorism or criminal activity. This must be reported to the police as soon as reasonably practicable

4. Additional reporting duties for specific routes:

• If you are sponsoring a Scale-up Worker, you must report the date they actually start working for you
• If you are sponsoring an overseas qualified nurse or midwife on the Skilled Worker route, you must report when they complete NMC registration, or if they fail to achieve it within the 8-month timeframe
• If you are sponsoring an offshore worker, you must report the dates they arrive in and leave UK waters, no later than 10 working days after each event

Record-keeping duties

As a licensed sponsor, you must keep specific documents for every worker you sponsor. The full list of required documents, and how long you must keep them, is set out in Appendix D of the sponsor guidance.

Your record-keeping duties include the following:

• Document retention: You must keep all documents listed in Appendix D for each sponsored worker. These include evidence of right to work checks, qualifications, recruitment, salary, and work location.
• Format of records: Documents can be kept in paper or electronic form. If kept electronically, all relevant parts of the document must remain clearly visible.
• Compliance with requests: You must provide the Home Office with any documents it requests, relating to your sponsored workers or the running of your organisation. If you fail to provide them within the timeframe specified, the Home Office will take action against you.
• Sponsoring children under 18: You must keep a copy of a consent letter from the child’s parents or legal guardian. This must cover consent to the child’s application, travel, and care arrangements in the UK.
• Wider legal requirements: Some documents may need to be kept for longer periods to comply with legislation on preventing illegal working or requirements set by other government departments.
• Data protection: You must comply with the Data Protection Act 2018 and the UK GDPR. The Information Commissioner’s Office publishes guidance on both.

Complying with immigration law

Complying with immigration law is a legal responsibility. You must comply with all parts of the Workers and Temporary Workers sponsor guidance, not just the immigration rules themselves.

The key actions you must take include:

• Only sponsor workers who are appropriately qualified, registered, or experienced for the specific job. For example, if you are sponsoring a doctor, you must ensure they hold the correct GMC registration before they begin work.
• Do not sponsor workers who lack the necessary experience or qualifications. If a worker is no longer entitled to do the job for any reason, you must stop employing or engaging them immediately.
• Carry out right-to-work checks for every worker you sponsor or employ in a sponsored role. This applies even if the worker is not a direct employee of your organisation.
• Only assign a CoS for a role that meets the definition of an eligible role under the route you are sponsoring on. Assigning a CoS for an ineligible role gives the Home Office grounds to suspend or revoke your licence.
• Ensure the actual duties performed by your sponsored worker accurately match the role and job description for which the CoS was assigned. This is an area the Home Office checks closely.
• Only allow sponsored workers to carry out the roles permitted by the conditions of their leave.
• Do not allow a Sponsorship Management System (SMS) user to assign their own CoS, or to assign one to a close relative or partner.
• Do not attempt to recover sponsorship fees or associated administrative costs from a sponsored worker where this is expressly prohibited in the guidance.

Complying with wider UK law

All sponsors have a legal duty to comply with UK law beyond just immigration regulations. The Home Office expects you to maintain compliance with a wide range of legislation.

This includes:

• Employment law, including the National Minimum Wage, Working Time Regulations, and workers’ rights
• Health and safety legislation
• Planning and licensing requirements for your business premises
• Safeguarding obligations, where relevant to the nature of your work
• Tax, VAT, and customs obligations
• Data protection law

A failure to comply with wider UK law can be grounds for the Home Office to take action against your sponsor licence, separate from any action taken by other enforcement agencies.

Not engaging in behaviour that is not conducive to the public good

The rules say that sponsors must not behave in a way that is harmful to the wider public good. This applies to your organisation as a whole, as well as to the individuals named on your licence, such as your Authorising Officer and key personnel.

The Home Office can take action against your licence if your organisation or any key personnel are found to have engaged in behaviour that is not conducive to the public good. This includes, but is not limited to, involvement in serious criminal activity, terrorism, hate crimes, discrimination, or other conduct that poses a risk to the public interest.

How the Home Office conducts sponsor licence compliance checks

The Home Office monitors all sponsors on an ongoing basis. It may carry out compliance checks at any time, either announced or unannounced. There are several ways a compliance check can be triggered:

• Routine monitoring of the SMS and the information you have submitted
• Intelligence or concerns raised by third parties, such as workers, local authorities, or other government agencies
• Information identified during a visa application processed by the Home Office
• An employer’s own history of compliance or previous enforcement action

When carrying out a formal check, the Home Office may use one or more of the following methods:

• Requesting documents or information from you in writing
• Verifying documents and information you have already submitted
• Visiting your premises in person (a site visit)
• Conducting a digital compliance check by video interview
• Making checks with other government departments, agencies, or local authorities

You are expected to cooperate fully. Failing to cooperate, or failing to provide requested documents within the timeframe given, is itself a breach of your sponsor duties.

What happens during a sponsor licence compliance check?

During a compliance check, a Home Office compliance officer will assess whether you are meeting your sponsor duties. They may:

• Interview you, your key personnel, and your sponsored workers
• Inspect your records and documents, including right to work evidence, payroll records, qualifications, and recruitment documentation
• Verify the details held on your licence against what they find at your premises
• Check whether the roles being performed by your sponsored workers match the CoS details
• Examine your organisation’s wider systems and processes for managing sponsored workers
• Check other workers at your premises for illegal working, even those who are not sponsored

If the officer identifies a discrepancy or a potential compliance problem during the check, they will note it, and it will be considered when deciding what action, if any, to take. The Home Office will notify you of its decision in writing.

How to stay compliant and prepare for compliance visits

Staying compliant with your sponsor duties requires constant attention, not just a one-off review. The following steps will help you maintain compliance and prepare for any compliance visit:

• Make sure key personnel understand sponsor duties. Your Authorising Officer and Level 1 users must be familiar with the full sponsor guidance, including any updates. The Home Office notifies sponsors of changes via the SMS message board.
• Make sure sponsored workers understand their role. Each worker should clearly know their job duties, work location, salary, and conditions of stay. Any changes to these must be reported to your Level 1 user promptly.
• Report worker and organisation changes on time. Train your HR team and line managers to flag salary changes, role changes, absences, and location changes to the licence holder immediately. Maintain a log of all reports submitted via the SMS, including the dates they were made.
• Keep required records ready. Maintain a complete file for each sponsored worker, including right-to-work evidence, qualifications, recruitment records, payroll records, and work location history. Make sure payroll processes are compliant and that each worker is paid the required salary in every pay period.
• Ensure the role matches the CoS. Before assigning a CoS, check the role, duties, salary, occupation code, and worker eligibility carefully. Keep evidence showing why the role is eligible. Regularly review whether the worker’s actual duties still match what is stated on the CoS, and report any changes where required.
• Keep professional registration and licensing evidence. Where a sponsored worker is required to hold a professional registration or licence to work in their role, keep a copy and monitor renewal dates.

Common sponsor licence compliance breaches and consequences

Breaching your sponsor licence compliance duties can result in your licence being downgraded, suspended, or revoked. The action the Home Office takes depends on the severity of the breach, how often it has occurred, and the overall risk to immigration control.

If you are found to have employed illegal workers, you may also face a civil penalty of up to £60,000 per illegal worker under the Immigration, Asylum and Nationality Act 2006. In cases of deliberate or knowing employment of illegal workers, criminal prosecution is also possible. The Home Office does not publish a fixed list of breaches that lead to specific outcomes. However, the sponsor guidance sets out the circumstances in which the Home Office will revoke a licence (Annex C1), normally revoke a licence (Annex C2), and may revoke a licence (Annex C3). The examples below are drawn from those annexes.

Compliance breaches that may lead to licence downgrade

Downgrading is used for less serious or fixable compliance failures. When a licence is downgraded, it moves to a B-rating. The sponsor must follow a time-limited action plan to address the failures. During this period, the sponsor cannot assign new CoS or sponsor new workers. If the action plan is not completed satisfactorily, the licence may be revoked.

Examples of breaches that may lead to a downgrade include:

• Having no adequate processes in place to comply with your sponsor duties
• Failing to provide documents the Home Office requested, such as right to work evidence or specified records you were required to keep
• Failing to carry out right to work checks before a sponsored worker began employment
• Not keeping records in the format or for the period required by Appendix D
• Failure to report worker or organisational changes within the required timeframes

Compliance breaches that may lead to licence suspension

The Home Office may suspend your licence where it believes you may be breaching your duties, or where a breach is suspected but further investigation is needed before a final decision is made. During suspension, you cannot assign new CoS or sponsor new workers, but your existing sponsored workers can continue to work.

Examples of situations that may lead to suspension include:

• A compliance check raises serious concerns that require further investigation
• There is a reasonable suspicion that the sponsor is failing to comply with immigration law or wider UK law
• The sponsor’s key personnel have links to criminal activity or other conduct not conducive to the public good
• Information provided to the Home Office appears to be false or misleading
• A sponsored worker has breached their conditions of stay, and the sponsor has failed to report it

Compliance breaches that may lead to licence revocation

Revocation is the most serious outcome. If your licence is revoked, the permission of your sponsored workers will typically be curtailed or cancelled. You may be barred from re-applying for a licence for a period of time, and where dishonesty or deliberate misconduct was involved, the Home Office will require compelling evidence of suitability before any future application is considered.

Examples of breaches that will or normally will lead to revocation include:

• Providing false information or using deception in your licence application or in any CoS you have assigned
• Employing workers who do not have the right to work in the UK, or assigning a CoS for a role that does not exist
• Assigning a CoS to a worker whom you had no intention of employing in a genuine role
• Failing to pay sponsored workers the salary stated on their CoS, or consistently failing to meet the minimum required salary in each pay period
• Being convicted of a criminal offence, or having key personnel convicted of an offence relevant to the running of the organisation
• Failing to maintain or renew required regulatory licences or registrations (for example, CQC registration for health and social care sponsors)
• Behaving in a way that is not conducive to the public good, including involvement in serious criminal or extremist activity
• Failing to cooperate with a Home Office compliance check

Reference:

Workers and Temporary Workers sponsor guidance

GOV.UK: Workers and Temporary Workers: guidance for sponsors part 2: sponsor a worker