2026 Sponsor Licence Compliance Checklist for UK employers
UKVI now cross-checks your SMS reports against HMRC payroll data in near real time. One missed update can cost you the licence faster than you think. This is the working checklist we use to keep clients audit-ready.
What changed in 2026
The Home Office has shifted from periodic paper audits to continuous digital enforcement. These are the changes that catch most employers out.
Paper BRPs are gone
BRPs expired on 31 December 2024. Every right-to-work check now runs through the eVisa share-code service. Screenshots are not evidence.
B2 English from 8 January 2026
All new Skilled Worker applications need B2-level English. Old B1 results will be refused at the visa stage.
Higher salary floors
The general minimum sits at £41,700. Old 2024 occupation codes will trigger CoS rejection if you forget to refresh them.
Bigger civil penalties
Illegal working fines start at £45,000 per worker for a first breach, rising to £60,000 on repeat. Licence revocation often follows.
HMRC and UKVI talk to each other
Payroll data is cross-checked against your SMS reports automatically. Mismatches are flagged before a caseworker ever calls.
Strict 10-day reporting
No-shows, 10+ day unexplained absences, terminations and resignations must be reported within 10 working days. Batch reports at month-end will fail.
The three pillars of compliance
Compliance is a continuous lifecycle, not a once-a-year audit. Every system you build should serve one of these pillars.
Prevention
Right-to-work checks completed before day one create the statutory excuse that protects you from civil penalties. Skip a step and the protection disappears.
Monitoring
Track attendance, role and location for every sponsored worker. If you can't see drift, you can't report it within the required deadline.
Reporting
The SMS expects each event filed individually and on time. Late reports count as non-compliance even when the underlying facts are correct.
The six compliance phases
Work through these in order. Most licence problems start with a gap in one of the early phases that nobody noticed until audit day.
- 01
Governance & system setup
- Appoint an Authorising Officer who is genuinely employed in the UK with settled status — not a remote consultant or absent director.
- Make sure a Level 1 user logs into the SMS at least monthly. Dormant accounts are an immediate red flag in any audit.
- Build a recurring compliance calendar: monthly SMS check-ins, quarterly mock file audits, an annual refresher for everyone who handles sponsored hires.
- Replace any ‘ghost’ Key Personnel today. Auditors interview your AO directly — if they can't answer basic questions about the business, the licence is at risk.
- 02
Pre-employment right-to-work checks
- Ask the candidate for a 9-character share code generated from their UKVI account (valid for 90 days).
- Run the code through the GOV.UK online checking service using their date of birth.
- Download the official PDF profile page — never rely on a screenshot or printout of what's on screen.
- Save the PDF in the worker's personnel file with the date and the name of the person who completed the check. Keep it for two years after they leave.
- Finish the check before the worker starts. Even a few hours of work before a valid check counts as illegal employment.
- 03
Genuine vacancy & salary standards
- Confirm the role meets RQF Level 6 — graduate-level skill, complexity and autonomy. Padded job descriptions are spotted quickly.
- Pay the higher of the £41,700 general minimum or the going rate for the occupation code. Re-check Appendix Skilled Occupations before every CoS.
- Use guaranteed base pay only when calculating salary. Bonuses, expected overtime and future pay rises do not count.
- 04
Monitoring during employment
- Keep meaningful attendance records for every sponsored worker — building access, system logins, manager check-ins or output tracking depending on their pattern.
- If an office worker becomes fully remote (or moves to a different city long-term), report it as a change of work address within 20 working days.
- Watch for role drift. If actual duties no longer match the sponsored job description, either report the change or assign a fresh CoS that reflects the real role.
- 05
Reporting duties & SMS triggers
- 10 working days for worker-level events: failed start, 10+ days of unexplained absence, resignation or termination.
- 20 working days for organisation-level events: registered office change, mergers and acquisitions, change of Authorising Officer.
- Report each event individually as it happens — never wait until month-end to clear a backlog. The SMS timestamps everything.
- Assign a named owner to scan SMS triggers weekly and set automated reminders for upcoming visa expiries.
- 06
Record keeping under Appendix D
- Keep one digital folder per sponsored worker with: current contact details, full UK address history, all payslips, signed contract, right-to-work PDF, CoS reference and any change correspondence.
- Refresh each folder monthly as new payslips arrive — don't leave it to audit week.
- Pass the ‘20-minute test’: an auditor picks three workers at random and expects complete files within 20 minutes. Run this drill yourself every quarter.
What a compliance visit really looks like
Worker interviews
Auditors speak to sponsored staff directly — typical day, who they report to, current projects, where they work, how the role has changed. Answers are matched against the CoS job description.
Consistency cross-checks
Three months of payslips, bank statements, HMRC payroll, attendance records and SMS history are compared side by side. Inconsistencies are treated as fraud, not error.
Quarterly self-audit
Can you produce complete files for five random workers in 20 minutes? Are all resignations from the past six months reported? Has Level 1 logged in within 30 days? Fix any ‘no’ immediately.
If something goes wrong
UKVI has four enforcement tools, listed from least to most severe. Self-reporting a gap almost always lands you on the gentler end of this list.
Action plan
A formal notice listing failures with a fix-by date (usually 28 days). Closes the matter if completed properly.
Downgrade to B-rating
You lose fast-track CoS assignment. Every CoS needs caseworker approval, slowing recruitment significantly.
Suspension
No new CoS can be assigned while UKVI investigates. Existing workers stay legal but your hiring pipeline freezes overnight.
Revocation
Permanent loss of sponsorship. Sponsored workers have 60 days to find a new sponsor or leave the UK.
Day-zero checklist for new sponsored hires
Tick every item before the worker starts. Skipping one is how statutory excuses get lost.
- Right-to-work check completed using an eVisa share code
- PDF profile page saved with worker's name and check date
- Signed contract showing correct salary and SOC code
- Current UK address and mobile number recorded
- Passport bio page copied to the personnel file
- CoS reference number logged
- Start date confirmed and matched in the SMS
- Line manager briefed on reporting duties for this hire
- Digital personnel folder created with every required document
Frequently asked questions
What does sponsor licence compliance actually cover?
It's the ongoing duty to prevent illegal working, monitor sponsored workers, report changes through the SMS and keep the records listed in Appendix D for the full sponsorship period.
What records must we keep under Appendix D?
Right-to-work evidence, NI numbers, current contact details, signed contracts, full pay records and proof of recruitment. Hold them for the duration of sponsorship and at least two years after the worker leaves.
What happens if a sponsored worker doesn't start?
Report the no-show on the SMS within 10 working days of the agreed start date and explain why they didn't arrive.
Can UKVI turn up unannounced?
Yes. Compliance officers can arrive in person — or run a remote inspection — at any time to review your HR systems and interview sponsored workers.
What evidence prevents a civil penalty?
The dated PDF response from the online right-to-work check (or, where a manual check is permitted, a clear copy of the documents) completed before the worker started.
Important: support service only — no immigration or legal advice
PriorityCOS is an administrative support service. We pursue Home Office Priority Service slots for Certificate of Sponsorship requests and help collate Sponsor Licence application paperwork. We do not provide immigration or legal advice.
We are not a law firm and we are not registered with the OISC (now the Immigration Advice Authority) or the SRA. We do not represent you before the Home Office, do not log in to your SMS account, and do not issue the CoS.
If your matter requires regulated immigration advice — for example eligibility opinions, refusals, appeals, judicial review, contested compliance action, or personal immigration applications — we will refer you to a qualified OISC/IAA-registered immigration adviser or SRA-regulated immigration solicitor. Any reliance on regulated advice should come from those advisers, not from PriorityCOS.
For any regulated advisory work, PriorityCOS acts purely as a lead-generation agency for SRA-regulated immigration consultants and OISC/IAA-registered advisers. The advice, client relationship, and professional responsibility sit with that regulated firm — not with PriorityCOS.
Don't wait for the audit letter.
Book a sponsor licence mock audit. We'll find the gaps before UKVI does and hand you a clear fix list.