A Quick Guide for Sponsor Licence Holders to Avoid Sanction.
The Home Office has significantly increased audits. Between April 2024 and March 2025, over 1,700 sponsor licences were suspended and more than 1,500 were revoked.
These audits are often unannounced, and inspectors expect prompt access to your records.
Now is the time to make sure your organisation is fully compliant with sponsor licence duties.
Why Compliance Matters
Failure to comply, even unintentionally, can result in:
- Fines of up to £60,000 per illegal worker
- Suspension of your sponsor licence (you cannot assign new Certificates of Sponsorship)
- Revocation of your licence, resulting in loss of sponsored workforce
- Criminal record and custodial sentences
- Operational disruption and reputational damage
What Happens During a UKVI Visit
An inspector may arrive without notice. During the visit, they may:
- Interview your Authorising Officer or Level 1 User
- Speak to at least one sponsored worker
- Review personnel files and SMS records
- Ask scripted questions and take handwritten notes
Your Sponsorship Responsibilities
To remain compliant, make sure you:
- Sponsor only genuine roles that meet the visa requirements (job title, duties, salary must match the CoS)
- Maintain full and accurate HR files, including ID documents, contracts, pay records, absences, and Right to Work documentation
- Use the SMS to report key changes within 10 working days (e.g. changes to duties, hours, work location)
Right to Work Checks – A Legal Requirement
Before any employee starts work, you must:
- Conduct a Right to Work check via the Home Office online checking service
- Check their documents in person
- Keep a signed and dated copy of the Right to Work check for your records
- Fresh Right to Work checks must also be carried out once a visa is renewed
Be Record Ready
UKVI will expect you to produce key documents without delay. These include:
- Visa expiry dates
- Contact details, contracts, pay slips, absence logs, visa and ID copies
- Proof of recruitment and Right to Work checks
Even a simple spreadsheet to track visa expiry dates is acceptable.
Working Hours and Salary Compliance
Sponsored workers must be performing the job and hours listed on their CoS.
- Overtime is allowed but cannot replace contracted hours
- Supplementary work must be in a skilled role, outside normal hours, and no more than 20 hours per week
- Changes to duties or hours must be reported via the SMS
Salaries must meet the minimum threshold. Only guaranteed gross basic pay counts (no bonuses, accommodation or allowances)
Clawback Agreements
Clawbacks from a sponsored worker are only allowed if:
- They are lawful, reasonable, and agreed in writing
- They are not deducted directly from the salary
- Separate payment arrangements (e.g. direct debit or standing order) are in place for things like accommodation or visa and immigration health surcharge repayment.
UKVI may investigate underpayment or deduction issues.
Legal Fees and Sponsorship Costs
Sponsors are required to cover:
- The Immigration Skills Charge
- The Certificate of Sponsorship (CoS) fee
These cannot be recovered from the worker.
Need Help? Migrate UK provides expert support with all areas of immigration compliance, including mock audits and ongoing sponsor licence management.