Holding a UK sponsor licence is an ongoing responsibility. The Home Office may check your organisation’s systems, records, payroll, recruitment practices and sponsored workers at any point. A compliance check can be announced or unannounced and may take place on-site, remotely, by telephone or through a document request.

The best preparation is not a folder of policies that nobody uses. It is a practical system that produces consistent evidence when tested.

This checklist is designed for employers sponsoring Skilled Workers and other Worker or Temporary Worker routes. It focuses specifically on a pre-audit review: what to test, what evidence to collect and how to identify gaps before a Home Office compliance visit.

It is different from a general sponsor licence guide or a standalone explanation of the 2026 per-pay-period salary rule. The purpose here is to test how your entire compliance system operates together.

Important: Sponsor guidance and the Immigration Rules can change. Employers should check the latest Home Office guidance and obtain tailored advice before relying on this checklist.

1. Confirm your licence details and sponsor responsibilities

Begin with a current “licence snapshot”. Check that the following are accurate:

• Your organisation’s legal name and trading name
• Registered, head-office and trading addresses
• Branches and other work locations
• Licensed immigration routes
• Authorising Officer and Key Contact details
• Active Level 1 and Level 2 Users
• Current licence rating
• Certificate of Sponsorship (CoS) allocation

Compare the information in the Sponsor Management System (SMS) with your company records, Companies House information, HR systems and actual working arrangements.

Your organisation remains responsible for sponsor duties even if day-to-day immigration administration is delegated to an external HR provider, payroll company or immigration adviser.

2. Review SMS users and permissions

Check every person with access to the SMS. Confirm that:

• Each user is still employed or properly engaged by the organisation
• Their role and contact details are current
• Former employees have been removed promptly
• At least one eligible Level 1 User is available to conduct day-to-day sponsorship activity
• Users understand what they are authorised to do
• Passwords are not shared
• There is a cover arrangement for holidays, sickness and unexpected departures

Review access at least quarterly and whenever there is a change in the HR or immigration team.

Your audit file should contain a dated access review, a list of current users, evidence of training and a record of any users removed or added.

SMS access is not simply an administrative issue. A lack of an active Level 1 User or poor control of SMS permissions can create a serious compliance concern.

3. Test right-to-work and digital check records

For every sponsored worker, confirm that a compliant right-to-work check was completed before employment began.

Where an online check was required, retain the relevant evidence, including:

• The worker’s share-code check result or downloadable profile
• The date the check was completed
• The date on which permission expires, where applicable
• The name of the person who carried out the check
• Any follow-up check required before the original permission expires

For workers with time-limited permission, diarise follow-up checks. Do not rely on the worker to remind you that their status is approaching expiry.

Check that records are clear, readable, securely stored and linked to the correct employee. A sponsored worker must have the right to work for your organisation and to perform the work in question. The Home Office sponsor guidance also requires sponsors to carry out appropriate checks on sponsored workers even where a statutory excuse would not otherwise apply.

4. Reconcile worker files and contact details

Select a sample of sponsored worker files and compare each file against HR, payroll and SMS records.

A practical file should normally allow you to locate:

• The CoS reference and relevant CoS details
• Right-to-work evidence
• Passport and immigration status information, where applicable
• Employment contract or written terms
• Job description and occupation code analysis
• Salary and working-hours information
• Professional registration evidence, where relevant
• National Insurance number
• Payslips or payroll evidence
• Recruitment and shortlisting records, where required
• Absence and attendance records
• Records of changes to the worker’s employment

Pay particular attention to contact details. Sponsors must maintain a history of each sponsored worker’s UK residential address, telephone number, mobile number and email address, together with a process for keeping that information current.

A worker moving home may not automatically trigger an SMS report, but the change should be captured promptly in your internal records. Do not confuse the duty to maintain accurate contact history with the separate duty to report changes in employment or sponsorship.

5. Audit your reporting calendar

Create a reportable-events log showing:

• What happened
• When it happened
• Who identified it
• Who decided whether a report was required
• The reporting deadline
• The date and reference of the SMS report
• Any supporting evidence

Under the current sponsor guidance, changes to a sponsored worker’s circumstances generally need to be reported within 10 working days. Examples include:

• The worker does not start the sponsored role within the relevant period
• Unauthorised absence exceeds the reportable threshold
• Salary or pay is reduced
• There is a significant change to the job role, title or core duties
• The normal work location changes
• Sponsorship ends
• The worker resigns, is dismissed or is made redundant
• The employment ends earlier than stated on the CoS

Changes to the organisation generally need to be reported within 20 working days, unless a different deadline applies. These may include changes to the organisation’s address, structure, branches, Key Personnel, ownership or trading status.

Do not wait until the end of the month to review events. Build reporting triggers into HR, payroll, absence and offboarding processes.

6. Check absences and unauthorised leave

Reconcile HR absence records with rota, timesheet and payroll data for every sponsored worker.

Your process should distinguish between:

• Annual leave
• Sickness absence
• Statutory family leave
• Approved unpaid leave
• Industrial action
• Unauthorised absence
• Absence connected with the end of employment

The Home Office expects sponsors to monitor attendance and report unauthorised absence exceeding 10 consecutive working days. The report must be made no later than 10 working days after the tenth day of absence.

Also check whether unpaid or reduced-pay absence exceeds four weeks in a calendar year. There are exceptions for certain types of statutory leave and other circumstances, so obtain advice before deciding that a report is unnecessary.

Your audit should test a real historical absence, not merely confirm that a policy exists.

7. Recalculate salary and occupation-code compliance

This is one of the most important parts of the 2026 audit.

For each sponsored worker, compare:

• The actual duties with the occupation code
• The actual job with the CoS job description
• The contractual salary with the CoS salary
• Payroll records with the required salary threshold
• Working hours with the hours stated on the CoS
• The normal work location with the recorded location

Under the 2026 changes associated with HC 1691 and paragraph SW 14.3B, employers must assess Skilled Worker salary compliance over the relevant pay-period framework rather than relying only on an annualised salary figure.

Your payroll test should therefore consider:

• The applicable general salary threshold
• The going rate for the occupation code
• The worker’s actual hours and pay
• Pay frequency
• Any relevant averaging window
• Salary sacrifice or permitted deductions
• Unpaid leave, reduced pay and irregular payments
• Whether payroll and CoS information remain aligned

Keep a calculation showing how each sponsored worker passes the applicable test. Do not assume that a worker earning the correct annual amount will automatically be compliant if payments fluctuate during the year.

8. Review CoS allocation and usage

Reconcile the SMS with your recruitment and HR records.

Check:

• CoS requested against genuine business need
• CoS allocated against CoS assigned
• Assigned CoS against successful visa applications
• Unused or withdrawn CoS
• Defined and Undefined CoS usage
• Job, salary, hours and work location entered on each CoS
• Dates of sponsorship and actual start dates
• Reasons for any cancelled or unused CoS

Look for patterns such as repeated unused certificates, unexplained changes to job details or applications for allocations that do not reflect the organisation’s current workforce plan.

A CoS must describe a genuine role and accurately reflect the employment that will be undertaken.

9. Check organisation changes and work locations

Ask whether the organisation has changed since the last SMS update.

Review:

• Office moves
• New branches
• Closure of sites
• Remote-working arrangements
• New client locations
• Mergers, takeovers and restructures
• TUPE transfers
• Changes to ownership or control
• Changes to regulatory registrations

A sponsored worker working permanently from home or regularly from a new client site may require a review of the recorded work location. Hybrid working does not necessarily require a report for every day-to-day location change, but regular changes and entirely remote arrangements must be assessed carefully.

10. Test document retention and retrieval

The Home Office permits sponsorship records to be held electronically or on paper, but they must be accessible and legible.

Test whether you can retrieve a complete sample file within one working day. Check that:

• Documents are named consistently
• Access is restricted appropriately
• Files are backed up
• More than one trained person can retrieve them
• Records are not stored only in an individual employee’s inbox
• Data protection requirements are followed
• Retention periods are recorded

Appendix D sets out the sponsorship records that must be retained and the relevant retention requirements. Some records may also need to be retained for longer under employment, tax, professional regulation or right-to-work rules.

11. Prepare sponsored workers and relevant staff for interviews

A Home Office officer may interview the Authorising Officer, Level 1 User, HR staff, payroll staff, recruiting managers and sponsored workers.

You should not script answers. Instead, confirm that relevant people understand:

• The worker’s actual job and duties
• Their salary and working hours
• Their normal work location
• Who manages them
• How absence is recorded
• How right-to-work checks are completed
• How reportable changes reach the SMS user
• What to do if a worker leaves or stops attending

Sponsored workers should be able to describe their role accurately and consistently with the CoS and job description. Differences do not automatically prove a breach, but unexplained inconsistencies should be investigated.

12. Conduct an internal mock audit and remediate gaps

Finish with a realistic simulation.

Choose several sponsored workers at random and ask an independent person to:

1. Retrieve each file without advance preparation.
2. Compare the CoS, contract, payroll and job description.
3. Verify right-to-work evidence.
4. Review salary over the relevant pay periods.
5. Check absence and contact-detail records.
6. Confirm whether any reportable event was missed.
7. Interview the HR or line manager responsible.
8. Produce a written findings report.

Classify each issue as critical, urgent or routine. Assign an owner and deadline, then repeat the test after remediation.

Keep the mock-audit report. It demonstrates that the organisation does not merely possess policies; it actively monitors whether those policies work.

Final thoughts

A sponsor licence compliance visit is an assessment of your organisation’s real systems. The strongest preparation is a regular, evidence-based review across HR, payroll, recruitment, management and immigration administration.

For official guidance, review the Home Office sponsor duties and compliance guidance and the Home Office compliance visits guidance.

If you need help reviewing your sponsor licence systems, salary records or CoS processes, speak to Tyndel Solicitors’ Immigration team. Our immigration solicitors UK advise employers on sponsor licence applications, compliance audits, reporting duties and Skilled Worker sponsorship, including support from Skilled Workers COS Solicitors.

This article provides general information and is not a substitute for legal advice on your organisation’s circumstances or the latest Immigration Rules.