The practical steps Bromley employers must take to prepare for a Home Office sponsor licence compliance audit

A sponsor licence compliance checklist covers eight practical areas: complete worker records, evidence of recruitment, correct salary payments, genuine sponsored roles, timely reports, secure Sponsorship Management System access, right to work checks and proof that workers receive information about their employment rights. The Home Office can examine your records, interview workers and visit premises, sometimes without warning. It can investigate where it reasonably suspects a breach, rather than waiting for a proven violation. Preparing now is safer than discovering problems during an inspection.

For Bromley employers, sponsored staff may work at your office, another branch or a client’s London premises. Compliance checks can extend to relevant work locations. Hedgley Immigration advises local businesses on work sponsorship, with experience that includes a former UKVI caseworker. This guide explains what officers may examine, which records you should retain, when changes must be reported and how to test your systems before a visit.

What is a sponsor licence compliance audit?

A compliance audit is a Home Office assessment of whether a licensed employer meets its sponsorship obligations. Officers may request documents, visit a workplace, interview staff or conduct a remote video inspection. Checks can take place before a licence is granted or while it is held, and visits may be announced or unannounced. The same responsibilities apply whether the organisation sponsors one worker or dozens.

The rules appear in Part 3 of the sponsor guidance. Checks can follow concerns about compliance, information supplied by other authorities or routine monitoring. The Home Office also compares sponsored workers’ pay with HMRC data. A mismatch between the salary stated on a Certificate of Sponsorship (CoS) and payroll records can therefore trigger questions even before a site visit.

Compliance officers should identify themselves. If you are uncertain whether a visitor is genuine, contact the Home Office’s business helpdesk on 0300 123 4699. Officers may inspect recruitment and payroll records and speak separately to managers or sponsored workers. Where staff work at a third-party location, sponsors should ensure appropriate access arrangements and cooperation without compromising confidentiality or creating misleading accounts of the work.

What the Home Office can check and what to have ready

Step 1: Build a complete file for every sponsored worker

Appendix D sets out the records sponsors must retain. You may store them electronically or on paper, but relevant information must be legible and available on request. Check each worker’s file against the latest requirements, remembering that some documents apply only to particular routes or circumstances.

• Evidence of appropriate right to work checks and the worker’s UK entry date where required.
• Their National Insurance number, where one has been issued and the requirement applies.
• Current UK address, personal email address and telephone number, with a history of changes.
• Payslips, employment contract or written particulars, and qualifying payment records.
• Job description, relevant qualifications and required professional registration.
• Absence records and documents supporting any exceptional working arrangements.

Generally, retain worker sponsorship records throughout sponsorship and until the earlier of one year after it ends or the date a compliance officer examines and approves them within that year. Keep documents supplied with your licence application for the required period while the licence remains in force. Right to work evidence can require longer retention, normally throughout employment and for two years afterwards, so do not delete everything when sponsorship ends.

Step 2: Be able to show how you recruited

The former resident labour market test no longer applies to Skilled Worker recruitment, but sponsors must still show that a genuine eligible role exists and explain how they recruited. If you advertised, retain the advert, its dates and location, applicant numbers, shortlist information and evidence of how you selected the successful candidate. If you did not advertise, keep a credible explanation and evidence of the person’s suitability, such as previous employment or a direct application. You do not normally have to retain unsuccessful candidates’ CVs or interview notes, provided the required recruitment records are available.

Step 3: Check pay in every pay period

Payroll deserves a separate compliance review. Skilled Worker rules updated on 8 April 2026 require pay in each pay period to meet the applicable occupation going rate for every hour worked. Where pay is monthly or less frequent, the worker must also receive at least a quarter of the required annual salary in any three-month period; for more frequent payroll, a corresponding 12-week test applies. A simple annual average is therefore insufficient to demonstrate compliance.

For instance, a reduction in one month’s pay may create an issue even if the annual total appears satisfactory, particularly where hourly going-rate requirements are not met. Compare each worker’s CoS, contractual hours, payslips, payroll reports and evidence of payment. Check bonuses, allowances, salary sacrifice, deductions and unpaid leave carefully. The Home Office can use HMRC information to test the figures, so unexplained differences may attract scrutiny.

Salary reductions from the CoS level and more than four weeks’ unpaid or reduced-pay absence in a calendar year usually require reporting, subject to the guidance’s exceptions. Sponsors must also comply with restrictions on passing sponsor licence costs, CoS fees and the Immigration Skills Charge to workers. Improper recovery of prohibited costs can result in serious compliance action, including revocation.

Step 4: Check the real job matches the sponsored job

An occupation code should reflect the worker’s actual duties, not simply an attractive title or a generic job description. Confirm that line managers understand the sponsored role and that responsibilities remain consistent with the CoS. A worker employed in a substantially different or ineligible role may put the licence at risk, especially where the change requires a fresh immigration application rather than an SMS update.

For example, a worker sponsored as a senior accountant might gradually move into a largely routine bookkeeping position. The employment documents may remain unchanged even though the actual duties have shifted. Ask managers to describe current responsibilities and compare these with the assigned occupation code. Our guide to how certificates of sponsorship work explains why the original assignment must accurately describe the work.

Changes of job title or core duties within the same occupation code generally require reporting within 10 working days, provided a new immigration application is not needed. A move to a different normal work location, including full-time remote working, is also reportable. Ordinary hybrid working does not normally need separate reporting, but you should retain accurate records of the arrangement and check the specific guidance.

Step 5: Report changes on time

Most reportable changes affecting workers must be submitted through the Sponsorship Management System (SMS) within 10 working days, while many organisational changes have a 20-working-day deadline. Keep a dated log showing the triggering event, the person responsible and confirmation that the report was submitted. Unauthorised absence lasting more than 10 consecutive working days must be reported within 10 working days after the tenth day.

Ordinary salary increases generally do not need reporting, although specific exceptions apply, including completion of professional registration by certain nurses or midwives. For organisational changes, follow the SMS instructions and submit supporting documents within any applicable deadline. Ownership changes may also require a new sponsor licence rather than an update alone. Where SMS generates a submission sheet, submit it with any required supporting documents within five working days of making the request.

Step 6: Tidy your Sponsorship Management System access

Changes introduced during 2026 make a user-access review particularly important.

• Mandatory multi-factor authentication began rolling out on 3 September 2026. Check each user’s relevant email address, telephone number and, for Level 1 Users, date of birth.
• New Level 2 Users cannot be appointed from 9 September 2026. Existing users must be upgraded to Level 1, if eligible, or deactivated by 8 March 2027.
• Accounts unused for 12 months are treated as inactive. After notification, affected Level 1 Users have three months to log in, check and update their details.
• If account deactivation leaves the licence without an active Level 1 User, the Home Office may suspend it and allow 28 days to appoint an eligible replacement before normally revoking it.

Keep an eligible Authorising Officer and at least one active Level 1 User in place. The Home Office recommends accessing SMS regularly, and Level 1 Users should review licence information and CoS activity at least monthly. SMS users generally cannot assign their own CoS or sponsor close relatives or partners through their own access. Directors considering self-sponsorship should examine the restrictions and authorisation arrangements. Relevant personnel requirements appear in Part 1 of the sponsor guidance.

Step 7: Get right to work checks and employment rights evidence in order

Carry out the prescribed right to work check before employment or relevant engagement begins, and retain evidence as described in the employer’s guide to right to work checks. From 1 October 2026, the statutory scheme also covers specified worker contracts, individual subcontractors and relevant online matching services. A civil penalty for illegal working can reach £60,000 per worker, and failures in right to work compliance can jeopardise sponsorship.

Sponsors must also provide workers with information about their UK employment rights and keep evidence of doing so. This can include written contract terms, handbook pages or records of training covering pay, working time, leave, pension obligations, health and safety and grievance procedures. Appendix D expressly requires evidence that this information has been given; a document that has never actually been shared is unlikely to demonstrate compliance.

A person’s immigration position may change during employment. A worker may obtain indefinite leave to remain, including in some cases through the long residence route. When sponsorship ends following settlement, report that event and update your records. Someone with the right of abode does not need sponsored permission, although appropriate checks must still establish their right to work.

What can happen if an audit finds problems

The Home Office’s response depends on the seriousness of the breach and whether it considers the problem remediable.

Suspension can delay sponsored workers’ pending immigration applications, including eligible settlement applications, until the licence position is resolved. A sponsor can normally receive no more than two B-ratings in any rolling four-year period; further non-compliance may result in revocation. Some revocation grounds have different consequences, so never assume a particular outcome is automatic.

Step 8: Run your own mock audit

Each quarter, select two or three sponsored workers and review their files as though officers were present. Compare their CoS, contract, job description, salary, actual duties and right to work evidence. Confirm reporting dates, bank payment evidence, current addresses and contact details. Decide who will manage a compliance visit and make sure reception staff and managers know how to check official identification and cooperate. Workers should be able to describe their real work and pay truthfully, without rehearsed answers.

Record any gaps, assign responsibility and document when you resolve them. If the issue affects pay, immigration status or a potentially reportable breach, seek advice promptly rather than attempting to conceal it or relying on retrospective paperwork.

Get a second pair of eyes before the Home Office looks

Many compliance weaknesses are easier to resolve before the Home Office raises concerns. If your business needs its sponsored worker files, payroll checks, SMS reporting and recruitment records reviewed, Hedgley Immigration can assess the arrangements and explain practical next steps. Speak to Hedgley Immigration about your work sponsorship responsibilities.