Sponsor Licence Compliance Checklist 2026
The Home Office can visit your organisation with little notice to check whether you’re meeting your sponsor licence duties. They assess your compliance across five specific areas — and failure in any of them can lead to licence suspension, downgrade, or revocation.
In 2024, the Home Office revoked or suspended 3,187 sponsor licences — a 252% increase from the previous year. This checklist covers everything you need to have in place.
The 5 Home Office Inspection Areas
The UK Visas and Immigration (UKVI) compliance team assesses sponsors against these five core areas during an audit:
- Monitoring immigration status — Are you tracking visa expiry dates and work permissions?
- Maintaining migrant contact details — Do you have up-to-date addresses and phone numbers?
- Reporting duties (the 10-day rule) — Are you reporting changes to UKVI within 10 working days?
- Record keeping — Do you hold the required documents for each sponsored worker?
- General sponsor duties — Are you meeting the wider obligations of holding a licence?
Area 1: Monitoring Immigration Status
You must actively track the immigration status of every sponsored worker. This includes:
- [ ] Record the visa start and end dates for each worker
- [ ] Set up alerts for visas expiring in the next 90, 60, and 30 days
- [ ] Check that each worker’s visa permits the type of work they’re doing
- [ ] Verify that workers aren’t exceeding any hour restrictions on their visa
- [ ] Keep evidence of Right to Work checks conducted before employment started
- [ ] Schedule follow-up Right to Work checks before visa expiry dates
Common mistake: Relying on a single spreadsheet that nobody updates. If a worker’s visa expires and you haven’t noticed, you’re employing an illegal worker — which is a criminal offence carrying unlimited fines.
Area 2: Maintaining Migrant Contact Details
UKVI expects you to know where your sponsored workers live and how to contact them. You must:
- [ ] Hold current UK residential addresses for all sponsored workers
- [ ] Update addresses within 10 working days of being notified of a change
- [ ] Keep a direct phone number and email for each sponsored worker
- [ ] Store next-of-kin or emergency contact information
- [ ] Verify contact details are still accurate at least once per year
Why it matters: If UKVI contacts you about a sponsored worker and you can’t confirm their current address, they may conclude you’ve lost track of them — a significant compliance failure.
Area 3: Reporting Duties (The 10-Day Rule)
As a sponsor, you must report certain changes to UKVI via the Sponsorship Management System (SMS) within 10 working days. Reportable events include:
- [ ] Worker stops turning up for work (absent for 10+ consecutive working days without permission)
- [ ] Worker’s employment ends (for any reason — resignation, dismissal, redundancy)
- [ ] Worker’s role, job title, or salary changes significantly
- [ ] Worker moves to a different work location
- [ ] Worker’s contract is not renewed or is shortened
- [ ] Any suspicion that the worker is breaching their visa conditions
- [ ] Changes to the sponsor organisation (address, ownership, director changes)
Critical: Late or missing reports are one of the most common reasons for compliance action. The Home Office expects you to have systems that flag these events automatically — not rely on managers remembering to report them.
Area 4: Record Keeping
You must retain specific documents for every sponsored worker for the duration of their employment and for at least one year after they leave. Required records include:
For each sponsored worker:
- [ ] Copy of passport (photo page and visa/vignette page)
- [ ] Copy of Biometric Residence Permit (BRP) — both sides
- [ ] Right to Work check evidence (date checked, document seen, who checked)
- [ ] Employment contract or terms of engagement
- [ ] National Insurance number
- [ ] History of absences (dates, reasons, whether authorised)
- [ ] Contact details and residential address history
- [ ] Certificate of Sponsorship (CoS) reference number and assignment details
Organisation-wide records:
- [ ] Up-to-date list of all sponsored workers with CoS numbers
- [ ] Copies of all SMS reports submitted to UKVI
- [ ] Records of who in the organisation has access to SMS
- [ ] Evidence of Right to Work training for HR staff
- [ ] Documentation of your compliance processes and procedures
Retention period: Keep documents for at least 1 year after the worker leaves or the sponsorship ends, whichever is later.
Area 5: General Sponsor Duties
These are broader obligations that underpin the whole system:
- [ ] Appoint a named Authorising Officer, Key Contact, and Level 1 User for SMS
- [ ] Ensure the Authorising Officer is based in the UK and is senior enough to be accountable
- [ ] Only assign CoS to genuine vacancies that meet the skill and salary requirements
- [ ] Don’t charge workers for sponsorship costs (it’s illegal under the Immigration Skills Charge rules)
- [ ] Cooperate fully with any UKVI compliance visit (provide documents, make staff available)
- [ ] Notify UKVI of changes to your organisation within 20 working days (mergers, takeovers, branch closures)
- [ ] Keep your sponsor licence details up to date on SMS (address, key personnel, organisation details)
- [ ] Have HR systems capable of monitoring and reporting — the Home Office expects digital record-keeping for organisations with more than a handful of sponsored workers
What Happens If You Fail a Compliance Visit?
The consequences depend on severity:
| Outcome | When it applies |
|---|---|
| Action plan | Minor issues — UKVI gives you time to fix problems |
| B-rating downgrade | Significant failings — you can’t sponsor new workers until issues are resolved |
| Licence suspension | Serious concerns — a 20-day investigation period |
| Licence revocation | Major or repeated failures — you lose your licence entirely |
If your licence is revoked, all currently sponsored workers have their visas curtailed to 60 days — they must either find a new sponsor or leave the UK.
Your Monthly Compliance Routine
Build these checks into your monthly calendar:
- Weekly: Review upcoming visa expiry dates (next 90 days)
- Weekly: Check for unreported absences or leavers
- Monthly: Verify contact details are current for all sponsored workers
- Monthly: Confirm all required documents are on file
- Quarterly: Review and update your compliance procedures
- Annually: Audit your entire sponsored worker population against this checklist
How SponsorPro Helps
SponsorPro automates the compliance checks in this checklist. The platform:
- Scores your compliance in real time across all 5 Home Office inspection areas
- Sends automated alerts for visa expiries, reporting deadlines, and missing documents
- Tracks every sponsored worker’s status, contact details, and documents in one place
- Generates professional audit packs that are ready for a Home Office visit
- Flags issues before they become problems — so you’re always audit-ready
Start your 7-day free trial — no credit card required.
This checklist is based on the UK Visas and Immigration Sponsor Guidance published by the Home Office and is current as of February 2026. Immigration rules change frequently — always verify against the latest official guidance.
Check your compliance score
See how your organisation measures up across all 5 Home Office inspection areas.
Start Free Trial