Sponsor licence compliance

Sponsor compliance

Holding a sponsor licence allows UK employers to recruit international workers, but it also comes with ongoing legal responsibilities. These duties apply for the full duration of your licence.

Although sponsor licences no longer need to be renewed, it is important to remember that a licence will only remain valid if the sponsor continues to meet their compliance duties. If you do not meet these requirements, the UK Home Office could take action including licence suspension or revocation, which may lead to losing the ability to sponsor new workers and, in some circumstances even sponsored workers losing their permission to stay.

What is sponsor compliance?

Sponsor compliance refers to the duties your organisation must meet to retain its licence. These are set out in the official sponsor guidance on GOV.UK.

Sponsor duties and responsibilities

Sponsors are responsible for keeping accurate records, reporting relevant changes, monitoring sponsored workers, and ensuring roles meet immigration requirements.

Reporting and oversight

Sponsors must report specific changes to both their organisation and sponsored workers within strict timeframes using the Sponsor Management System.

Reportable changes include, among others, a change of office address, a change to a sponsored worker’s work location, and when a sponsored worker leaves their role. Reporting timeframes vary depending on the change, with some requiring notification within 10 working days. 

Continuing compliance with relevant visa conditions 

It is important that following the grant of the workers visa, that they continue to meet the conditions for which they were granted. The Home Office can check if sponsors are paying the salary stated on the Certificate of Sponsorship. Sponsors must ensure that any pay variations are correctly reported or can be shown not to require reporting.

It is good practice for sponsors to review any changes to ensure they have complied with their reporting duties. If in doubt seek legal advice for clarification.

Record keeping for sponsors

Sponsors must maintain certain records. 

As the Sponsor Management System is used to report changes to the Home Office, it is essential that all sponsor and worker details are kept accurate and up to date.

Sponsors must keep the required documents on file, including contracts, payslips, and evidence of job duties and work location. Evidence of right to work checks must also be retained for the required period.Sponsors must also keep evidence that sponsored workers have been informed of their employment rights in the UK.

Key Personnel

It is essential for sponsors to maintain accurate and up to date records of their Key Personnel, particularly when individuals leave the organisation or roles change.

Kep Personnel are identified when applying for a sponsor licence. They are the Authorising Officer, Key Contact and Level 1 user. 

If roles change or one of the Key Personnel leaves the organisation it is important to not only report the change but also ensure the role is covered. 

Compliance checks and Audits

The Home Office may carry out compliance checks at any time, including unannounced audits, to assess whether these duties are being met. These checks typically review HR systems, records, and internal processes.

Failure to comply can result in enforcement action, including licence downgrading, suspension, or revocation.

Legal advice

How legal advice can help:

• Conduct pre-audit preparation and compliance reviews to identify and fix gaps before an inspection
• Advise on corrective steps and manage remedial action plans where issues are identified
• Provide ongoing guidance to strengthen policies, training, and internal checks to reduce future risk
• Attend audits and represent the organisation during meetings or interviews with the Home Office

Seraphus provides comprehensive services to sponsors beyond licence applications. It is far easier to identify and address issues in advance than to respond to a Home Office audit. Sponsors are therefore encouraged to carry out internal audits and seek advice at an early stage, even where no audit has been announced.