Holding a UK sponsor licence is a key privilege that allows companies to employ skilled international talent under the points-based immigration system. But with that privilege comes responsibility, and the Home Office expects strict adherence to compliance rules. Ignoring these obligations can result in suspension, revocation of the licence, or future bans on sponsorship.

Many organisations unintentionally breach the rules, often due to unclear processes or a lack of awareness. This guide outlines essential compliance areas to help sponsor licence holders avoid costly mistakes.

1. Know Your Responsibilities as a Sponsor

All licensed sponsors must follow the guidelines set by the Home Office, including:

  • Maintaining complete and current records for all sponsored employees.
  • Updating any changes to the business or employee status through the Sponsor Management System (SMS).
  • Following UK immigration and employment laws, including visa conditions.
  • Preventing illegal employment by conducting valid right-to-work checks.

It’s important to understand that compliance isn’t just about initial checks — it’s ongoing. One critical issue is salary compliance. Sponsors must pay either the national minimum wage or the minimum salary threshold tied to the job’s SOC code — whichever is higher.

For example, if a Certificate of Sponsorship (CoS) was issued when the hourly rate was £10.10 but the legal minimum has since risen to £11.44, the worker must now be paid £11.44. Paying the old rate breaches immigration rules.

2. Keep Detailed and Updated Records

You must retain records for each sponsored employee throughout their employment and for at least 12 months after sponsorship ends. This includes:

  • Copies of passports, BRPs, and visas.
  • Contact information (address, phone, email).
  • Job descriptions, employment contracts, and salary details.
  • Proof of right-to-work checks and, if applicable, recruitment process documentation.

Incomplete records are a common reason for compliance failures. Ensure records are regularly updated and securely stored.

3. Meet Reporting Requirements Promptly

Timely updates to the SMS are a crucial sponsor obligation. Employers must report:

  • Employee changes include resignations, role modifications, prolonged absences, or pay adjustments.
  • Business changes such as address updates, mergers, acquisitions, or structural reorganisation.
  • Location changes when an employee transfers to another branch or office.

Timelines matter:

  • Report employment changes within 10 working days.
  • Report business changes within 20 working days.

If a promotion results in a change of job role, check whether the new role falls under the same Standard Occupational Classification (SOC) code. If not, a new visa application may be needed — and the employee must not start the new role until it’s approved.

4. Monitor Working Hours – Sponsored and Non-Sponsored Workers

For Sponsored Workers:

Skilled Worker visa holders can work:

  • In their primary role listed on the CoS.
  • Up to 20 extra hours weekly in a role with an eligible SOC code.

If they exceed 20 additional hours, they must be sponsored for the second job, too. Even working 23 extra hours without sponsorship constitutes illegal work, risking visa cancellation for the employee and fines of up to £60,000 for the employer.

For Non-Sponsored Workers:

Students: Generally limited to 20 hours/week during term time.

Dependants: Usually allowed to work full-time, though some restrictions may apply.

Visitors or other visa holders: Many are not allowed to work at all.

Always check visa terms and monitor working hours to avoid non-compliance.

5. Conduct Internal Compliance Checks

Be prepared for Home Office audits, which can be announced or unannounced. To stay ready:

  • Perform regular in-house audits of your sponsorship procedures.
  • Train HR staff on current immigration rules and record-keeping requirements.
  • Ensure all documents are easily accessible in case of inspection.

6. Avoid Common Compliance Mistakes

Many sponsor licences are lost due to preventable errors, such as:

  • Not reporting significant employee or business changes.
  • Failing to conduct or document right-to-work checks.
  • Allowing sponsored staff to work hours beyond their visa conditions.

A proactive approach — supported by robust HR systems and training — can help you remain compliant and protect your ability to sponsor overseas workers.

Final Thoughts

Holding a sponsor licence is not just about hiring talent; it’s about maintaining trust with the UK Home Office. Ongoing compliance requires vigilance, transparency, and a well-informed team.

By managing records properly, reporting on time, tracking working hours, and staying up-to-date with changing regulations, your business can continue to benefit from global talent, without risking penalties or losing your licence.

Remember: When in doubt, ask yourself — how will this impact our sponsor licence?

Need Assistance?

If you’re managing a UK Sponsor Licence and want to ensure full compliance, it’s advisable to seek expert support. Ash Norton Solicitors specialises in UK immigration and sponsorship services — offering tailored guidance on maintaining your sponsor duties, avoiding penalties, and preparing for Home Office audits.

Let our experts help you protect your licence and continue hiring international talent with confidence.