Work & Sponsorship

Sponsor Licence Compliance Checklist 2026: 15 Duties Every Employer Must Meet

Sponsor Licence Compliance Checklist: 15 Things Every Employer Must Do – IAUK guide

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A sponsor licence comes with duties that last for as long as you hold it. If you miss them, the Home Office can downgrade, suspend or revoke your licence, and since March 2026 it can act on a reasonable suspicion of a breach. This sponsor licence compliance checklist sets out the 15 duties every UK sponsor must meet in 2026, including the new rules introduced in March and April 2026.

New in 2026

  • From 6 March 2026, you must tell sponsored workers about their UK employment rights in writing and keep proof that you did.
  • The “genuine vacancy” test has been replaced by the “eligible role” requirement.
  • For Certificates of Sponsorship assigned from 8 April 2026, the required salary must be paid in every pay period.
  • Key personnel must read the sponsor guidance and keep up with changes to it.

Sponsor licence compliance checklist: record-keeping duties

  1. Keep up-to-date contact details for every sponsored worker, including home address and phone number.
  2. Do a right-to-work check before employment starts and keep the record. Most sponsored workers now hold an eVisa, so this is usually an online check using a share code. Physical documents such as BRPs are no longer used.
  3. Keep the documents listed in Appendix D of the sponsor guidance, including contracts, payslips and the details of each Certificate of Sponsorship.
  4. Keep written evidence that you told each worker about their employment rights, such as the National Minimum Wage, working time, holiday pay, pension auto-enrolment and how to raise a grievance.

Reporting duties

Most changes must be reported through the Sponsor Management System (SMS) within 10 working days.

  1. Report a worker who does not start work when expected.
  2. Report unauthorised absence of more than 10 consecutive working days.
  3. Report when employment ends, for example through resignation or dismissal.
  4. Report significant changes to the job, such as a change of job title or occupation code, a cut in salary, a new work location or a change in hours.
  5. Report changes to your organisation, such as a change of ownership, a merger, new key personnel or a new address. Most must be reported within 20 working days.

Salary and role duties

  1. Pay at least the required salary in every pay period, and make sure the actual pay and hours match the Certificate of Sponsorship.
  2. Make sure every sponsored role is an eligible role: a real job, with duties that match the occupation code on the Certificate of Sponsorship.
  3. Never pass sponsorship costs to the worker. The Certificate of Sponsorship fee and the Immigration Skills Charge must be paid by you.

Want to know where you stand before UKVI visits?

An IAUK compliance audit checks your HR files, right-to-work records and SMS reporting against this list, then gives you a clear plan to fix any gaps.

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Key personnel and ongoing monitoring

  1. Make sure your key personnel know the rules. Your Authorising Officer, Key Contact and Level 1 Users must read the sponsor guidance and keep up with updates.
  2. Track visa expiry dates and do follow-up right-to-work checks, so no one keeps working after their permission ends.
  3. Cooperate with compliance visits, announced or not, and keep your SMS account active, including your annual Certificate of Sponsorship allocation.

What happens if you get it wrong

Depending on how serious the breach is, the Home Office can downgrade your licence to a B-rating with an action plan, suspend it, or revoke it. A revocation usually cuts your sponsored workers’ visas short to 60 days. Our guide on what to do if your sponsor licence is suspended or revoked explains the process.

Do you still need to renew a sponsor licence?

No. Since April 2024, sponsor licences no longer need to be renewed every four years. The duties above still apply for as long as you hold the licence.

Frequently asked questions

How long do I have to report changes to the Home Office?

Most changes about a sponsored worker must be reported within 10 working days. Many changes to your organisation must be reported within 20 working days.

What records does a sponsor need to keep?

The records listed in Appendix D of the sponsor guidance, including right-to-work checks, contracts, payslips and, since March 2026, proof that you told workers about their employment rights.

Can a sponsor licence be revoked for a mistake?

Yes. The guidance makes clear that a licence can be revoked even where a breach was not deliberate, which is why regular audits are worthwhile.

Who has to pay the Immigration Skills Charge?

The employer. It cannot be recovered from the sponsored worker.

Last reviewed: October 2026. Based on the Home Office sponsor guidance updated in March 2026. This article is general information, not advice on your individual case.

Sources: GOV.UK: sponsor guidance for employers.

About IAUK

IAUK Immigration Advisers is a Manchester-based firm regulated by the Immigration Advice Authority (IAA). Our guides are written by the IAUK advisory team, checked against GOV.UK and the Immigration Rules, and updated when the rules change. They are general information, not advice on your individual case.