Sponsor Licence Compliance: A Practical Guide for UK Employers
- Nisan Yesildaglar
- Jul 24
- 4 min read
Updated: Jul 25
Holding a sponsor licence gives your business access to global talent. But with that privilege comes strict legal duties. The Home Office expects sponsors to actively manage every aspect of a sponsored worker’s employment - from record keeping and visa tracking to reporting changes on time.
This guide walks you through your core compliance obligations, what UKVI expects during audits, common pitfalls, and how to stay fully compliant with help from imminova.
1️⃣ What Is Sponsor Compliance?
Sponsor compliance is the legal framework that employers must follow once they’re granted a sponsor licence. These duties are designed to prevent abuse of the UK’s immigration system and ensure only genuine employers can access overseas labour.
Your compliance obligations fall into three main areas:
Record Keeping: maintaining accurate and accessible documents
Monitoring: tracking visa status, start dates, and working conditions
Reporting: notifying UKVI of relevant changes through the Sponsor Management System (SMS)
⚠️ Failing to meet these duties can lead to licence suspension or revocation - with serious consequences for your business and workers.
2️⃣ Core Compliance Duties
Here’s what you must do once you become a sponsor.
A. Record Keeping
Sponsors must retain a specific set of documents for each sponsored worker and their organisation. These must be kept up to date and be accessible for UKVI audits.
Required documents include:
Copy of passport and current visa or BRP
Signed employment contract with job title, hours, and salary
Right to Work check evidence (copy of document + date stamp or digital check reference)
Payslips and proof of salary payments (e.g. bank statements)
Absence records, including holiday and sick leave logs
Job description and assigned SOC code
Copies of CoS and recruitment evidence (where relevant)
imminova Tip:📌 Many employers assume UK-born candidates don’t need Right to Work checks. They do. Always verify and record proof, regardless of nationality.
B. Monitoring
You must actively track each sponsored worker's status and working conditions. This includes:
Confirming their start date matches what was declared on the CoS
Monitoring changes to job title, salary, location, and duties
Tracking any unauthorised absences (10+ consecutive working days)
Ensuring the employee continues to meet visa conditions
imminova Tip:📌 Hybrid or remote working changes must be reported. If a worker’s normal work location changes - even partially - UKVI must be notified.
C. Reporting via the Sponsor Management System (SMS)
Sponsors are legally required to report specific changes to the Home Office through the SMS.
You must report within 10 working days if:
A sponsored worker fails to start, resigns, or is dismissed
Their role, salary, job location, or hours change
There is a change to your company name, ownership, or address
Your Key Personnel (Authorising Officer, Level 1 User) changes
imminova Tip:📌 UKVI doesn’t chase you for updates. If a change happens and you don’t report it on time, that alone can lead to a licence downgrade or even revocation.
3️⃣ How the Home Office Enforces Compliance
UKVI carries out both scheduled and unannounced audits - before or after granting a sponsor licence. They will assess your processes, records, systems, and whether sponsored workers are genuinely performing their roles.
Non-compliance outcomes include:
Action | What It Means |
Downgrade to B-rating | Your CoS allocation is frozen. You must follow a paid action plan and pass a follow-up audit. |
Suspension | No new CoS can be issued or assigned. You must respond to allegations before UKVI decides on revocation. |
Revocation | Licence is cancelled. Sponsored workers may lose their visa. You may be barred from reapplying for 12 months. |
imminova Tip:📌 Don’t wait for an audit to get your house in order. A mock audit now can prevent real trouble later.
4️⃣ Common Compliance Mistakes
UKVI audits often uncover similar issues. The most common include:
✅ Incomplete or missing Right to Work checks
✅ Salary payments inconsistent with the CoS or visa requirements
✅ Failure to report changes in job duties or working patterns
✅ No backup Level 1 user on SMS, locking the business out of reporting tools
✅ Overlooking follow-up checks for List B employees
✅ Not tracking visa, BRP, or CoS expiry dates
imminova Tip:📌 Employers often lose track of repeat checks for List B employees (e.g. limited leave holders). Our portal automatically tracks expiry dates and sends timely reminders for re-checks - reducing the risk of illegal working.
5️⃣ imminova’s Compliance Tools
imminova’s tech-enabled compliance solution helps you stay audit-ready, every day.
✅ Right to Work checks: Auto-classifies documents as List A or B and guides users through correct procedures
✅ Document vaults: Securely stores all sponsor and employee evidence in one place
✅ Automated reminders: Tracks visa, BRP, and List B expiry dates
✅ SMS workflows: Guided SMS update tools ensure you report changes on time
✅ Compliance dashboards: Real-time insight into risk areas and document gaps
✅ Mock audit support: Proactive reviews to catch issues before UKVI does
imminova Tip:📌 The most compliant sponsors are those with integrated systems, clear policies, and tech to catch human error. That’s where we come in.
6️⃣ Final Checklist for Compliance
To stay compliant, make sure you:
🔲 Verify and record Right to Work for all employees
🔲 Keep complete records for each sponsored worker
🔲 Track start dates, job changes, and visa status
🔲 Report changes promptly via the SMS
🔲 Train managers on reporting obligations
🔲 Assign at least two Level 1 Users on your licence
🔲 Conduct periodic internal audits
Need Help With Compliance?
Whether you’ve just secured a sponsor licence or you’re managing dozens of sponsored workers, imminova offers the tools and expertise to ensure total compliance - without the stress.
🔍 Want a health check on your current sponsorship systems?
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