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Sponsor Licence Compliance Checklist: 15 Things Every Employer Must Do

Holding a UK sponsor licence comes with significant ongoing compliance duties. Failure to meet these obligations can result in enforcement action, downgrading to a B-rating, or outright licence revocation — leaving your sponsored workers without valid immigration permission. Here are the 15 essential compliance duties every sponsor must fulfil.

Record-Keeping Duties

  1. Maintain up-to-date contact details for all sponsored workers, including home address, mobile number, and personal email
  2. Keep copies of right-to-work documents — passport biometric pages, BRP cards, and visa vignettes for every sponsored employee
  3. Record attendance and absence data — you must track working patterns and report any unauthorised absences exceeding 10 consecutive working days

Reporting Duties

  1. Report changes within 10 working days using the Sponsorship Management System (SMS) — including changes to job title, salary, work location, or working hours
  2. Report non-attendance if a sponsored worker fails to start their role or stops attending work without explanation
  3. Report any suspicion of immigration offences — if you believe a worker’s documents are fraudulent or they are breaching their visa conditions
  4. Notify UKVI of organisational changes — mergers, acquisitions, name changes, or changes to Key Personnel must be reported promptly

HR System Duties

  1. Appoint competent Key Personnel — your Authorising Officer, Key Contact, and Level 1 User must understand their compliance responsibilities
  2. Conduct right-to-work checks before employment starts — online checks via the Home Office checking service or manual document verification
  3. Perform follow-up right-to-work checks before a worker’s permission expires — set calendar reminders for visa expiry dates
  4. Ensure genuine vacancy — every sponsored role must be a real, substantive position that meets skill and salary thresholds

Ongoing Monitoring

  1. Monitor visa expiry dates and ensure workers apply for extensions before their leave expires
  2. Cooperate with UKVI compliance visits — have all records accessible and Key Personnel available if UKVI visits your premises (announced or unannounced)
  3. Keep your SMS account active — log in regularly, update your allocation of CoS certificates, and renew your licence before it expires
  4. Conduct regular internal audits — at least annually, review all sponsored workers’ files against the compliance checklist to identify gaps before UKVI does

What Happens If You Fail?

Non-compliance can trigger a UKVI audit, result in a downgrade from A-rating to B-rating (requiring a costly action plan), or lead to full licence revocation. If your licence is revoked, all sponsored workers must leave the UK within 60 days unless they find a new sponsor.

How IAUK Manchester Can Help

We offer comprehensive compliance audit services for Manchester businesses. Our team reviews your HR systems, SMS records, and documentation to ensure you meet every UKVI requirement. We also provide training for Key Personnel and ongoing compliance support. Learn about our compliance audit service or contact us for a free initial consultation.