Holding a sponsor licence is an ongoing responsibility. Your organisation must be able to show that its sponsorship systems work in practice: not simply that policies exist on paper.

The Home Office may conduct an announced or unannounced compliance visit. Its current guidance explains that compliance officers can assess your HR systems, sponsored-worker records, reporting processes, right-to-work checks, genuine vacancies and the organisation’s continuing trading presence.

This checklist is designed as a practical pre-audit review for UK employers. It is not a substitute for the current Home Office sponsor guidance on duties and compliance or the separate compliance visits guidance. Always check the rules applicable to your route and the date on which each worker’s permission or Certificate of Sponsorship (CoS) was issued.

How this checklist differs from a general compliance or salary guide

A general sponsor licence compliance article explains the duties broadly. A salary-focused article, including one dealing with HC 1691 or other Statement of Changes, concentrates on immigration salary rules.

This checklist has a different purpose: it asks whether your records, people and systems would produce consistent answers if reviewed by a Home Office compliance officer today.

1. Check Sponsor Management System access

Review every user with access to the Sponsor Management System (SMS).

Confirm that:

• former employees and inactive users have been removed;
• access levels reflect each person’s current responsibilities;
• passwords are not shared;
• your Level 1 User can manage day-to-day sponsorship activity;
• SMS activity is overseen and properly recorded; and
• there is a contingency plan if a key user is absent.

The Authorising Officer, Key Contact, Level 1 Users and Level 2 Users should understand their responsibilities. Keep a record of relevant training and internal instructions.

2. Check right-to-work records

Right-to-work checks must be completed using the correct process before employment begins. Depending on the worker’s status, this may involve an online check, a share code, original documents or an approved identity service provider.

For each sponsored worker, check that you have retained:

• the right-to-work evidence or online check;
• the date on which the check was completed;
• any relevant restrictions on the type or hours of work;
• evidence of follow-up checks where permission is time-limited; and
• records showing what action was taken when permission expired or could not be verified.

The GOV.UK right-to-work guidance should be used alongside the sponsor guidance. Do not assume that a worker’s visa or eVisa status automatically confirms that the role, hours and employer are permitted.

3. Check business and worker contact details

Confirm that the organisation’s details are accurate on the SMS and in internal records.

Review:

• registered and trading addresses;
• branch and work locations;
• telephone numbers and email addresses;
• changes to ownership or corporate structure; and
• the organisation’s continuing trading presence.

For each sponsored worker, maintain current contact information and a history of changes, including residential address, telephone number and email address. Your process should make it clear who updates the records, when this happens and how changes are escalated.

4. Check reporting duties

Create a reportable-events log and reconcile it against HR, payroll and management records.

Consider whether you have reported, where required:

• a worker who did not start the sponsored role;
• a worker who has left or stopped being sponsored;
• dismissal, resignation or redundancy;
• significant changes to salary, duties, hours or work location;
• prolonged unpaid leave or unauthorised absence;
• changes affecting the organisation, branches or corporate structure; and
• changes to key personnel.

The current Home Office guidance includes specific reporting deadlines. Many worker-related reports must be made within 10 working days, but not every type of report has the same timescale. Check the relevant guidance before acting and avoid relying on an informal email or internal note as a substitute for an SMS report.

5. Check salary and occupation-code compliance

For every sponsored worker, compare the following documents side by side:

• the CoS;
• employment contract or written terms;
• job description;
• payroll records;
• payslips; and
• actual duties performed.

Check the occupation code against the role’s real duties, not merely its job title. Confirm that the salary, hours and permitted salary components remain compliant with the applicable version of the Immigration Rules and Appendix Skilled Occupations.

Do not rely on an annual salary calculation alone. Review pay dates, gross payments, deductions, unpaid leave and any changes made since the CoS was assigned. If the salary or duties have changed, determine whether an SMS report or a new immigration application is required.

This is where specialist advice from Skilled Workers COS Solicitors can help, particularly where an occupation code, salary reduction, promotion or change of duties is being considered.

6. Check attendance and absence records

Your HR system should allow you to identify whether a sponsored worker:

• started work on the recorded start date;
• stopped attending work;
• has had unauthorised absences;
• has taken unpaid leave;
• is working the hours recorded on the CoS; or
• has left the organisation.

The Home Office compliance visits guidance refers to specific reporting triggers, including a worker who does not start within the relevant period, 10 consecutive days of unauthorised absence, and certain periods of unpaid leave. Exceptions may apply, including some statutory leave, sickness, jury service and other circumstances set out in the guidance.

Do not create attendance records retrospectively. If your organisation uses a rota, time-recording system, absence form or manager sign-off process, ensure it is used consistently.

7. Check CoS records

Review both current and historic CoS records for accuracy.

For each certificate, check:

• worker identity;
• route;
• job title and occupation code;
• duties;
• salary and hours;
• start and end dates;
• work location;
• whether the correct type of CoS was used; and
• whether the information matches the worker’s actual employment.

Keep evidence explaining why the vacancy existed and why the role is genuine. Depending on the circumstances, this may include recruitment records, organisational charts, business plans, interview records and correspondence with the candidate.

8. Check that HR systems work in practice

A written policy is not enough if staff do not follow it.

Test the process from recruitment to exit:

1. Who identifies that a candidate needs sponsorship?
2. Who completes the right-to-work check?
3. Who approves the role and salary?
4. Who assigns the CoS?
5. Who monitors attendance and immigration expiry dates?
6. Who reports changes to the Home Office?
7. Who closes the file when the worker leaves?

Ask HR, payroll and line managers the same practical questions. Inconsistencies between departments can expose weaknesses even where individual documents appear complete.

9. Check key personnel

Confirm that your Authorising Officer, Key Contact, Level 1 Users and Level 2 Users:

• remain suitable for their roles;
• are still employed or engaged in a permitted capacity;
• are based in the UK where required;
• have sufficient authority and knowledge;
• have current contact details; and
• understand how to access and use the SMS.

If someone leaves or changes role, do not wait for an audit before reviewing the licence. Consider whether the change must be reported and whether a replacement needs to be appointed.

10. Check document retention and retrieval

Documents should be stored securely, in English or Welsh or with a certified translation where required, and be readily retrievable.

Review your retention schedule for:

• right-to-work evidence;
• CoS records;
• contracts and job descriptions;
• payslips and payroll records;
• absence and attendance records;
• recruitment and shortlisting evidence;
• worker contact details;
• professional registration or accreditation evidence; and
• SMS reports and correspondence.

The applicable retention period can differ depending on the type of document and the duty concerned. Check Appendix D and the current sponsor guidance before deleting records. Test whether a manager could retrieve a complete worker file quickly without relying on one individual’s inbox.

11. Prepare for sponsored-worker interviews

The Home Office may interview sponsored workers to assess whether they are carrying out the sponsored role and being paid as recorded.

Workers should be able to explain, in their own words:

• their job title and main duties;
• their usual work location;
• their working hours;
• who they report to;
• how they are paid; and
• what changed, if anything, since they started.

Do not coach workers to give predetermined answers. Instead, ensure that job descriptions, contracts, payroll, rotas and actual working practices are consistent. Interviews should also be conducted with appropriate regard to privacy, data protection and the worker’s welfare.

12. Record and remedy problems

If you identify a gap, record:

• what is wrong;
• which workers or records are affected;
• when the issue began;
• the relevant sponsor duty;
• the immediate risk;
• who owns the corrective action; and
• the deadline for completion.

Correct errors promptly, but do not backdate documents or create records that did not exist. If a report was missed, take advice on the appropriate disclosure or corrective action. Preserve the audit trail, including explanations for decisions and copies of any reports submitted.

Where there may have been a material breach involving salary, duties, right to work, illegal working, a non-genuine vacancy or a missed report, obtain advice before making further changes.

Final preparation before a compliance visit

Nominate a small response team comprising the Authorising Officer, HR lead, payroll contact and legal adviser. Keep a controlled index of key records and ensure staff know who should meet Home Office officers and how documents will be produced.

The Home Office’s current compliance-visit guidance should remain your primary reference. It explains the areas officers may assess, including HR systems, worker files, right-to-work records, contact details, attendance monitoring, reporting systems and worker interviews.

If your organisation needs a confidential sponsor licence review, reporting advice or support with a Skilled Worker application, contact Tyndel Solicitors’ Immigration team. Our immigration solicitors in the UK advise employers on sponsor licence applications, compliance systems, CoS assignments and responding to Home Office concerns.

This article provides general information as at 17 August 2026. Sponsor duties and Immigration Rules can change. Employers should check the current Home Office guidance and obtain advice on their specific circumstances.