Sponsor Licence Compliance and Ongoing Services
Holding a Sponsor Licence is the beginning of a set of ongoing legal obligations that apply for the lifetime of your licence. A failure to meet them, even an administrative one, can result in your licence being downgraded, suspended or revoked. At JV LEGAL we advise licensed sponsors on every aspect of their compliance duties from day-to-day record-keeping and reporting, to urgent representation when the Home Office initiates compliance visit.
Our Sponsor Compliance Services
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Compliance audit and gap analysis
Immigration Compliance Service and Premise Audit (1 day) → £1,500
A thorough review of your HR systems, record-keeping, reporting procedures, and SMS usage against current UKVI guidance. We identify gaps, assess risk, and provide a clear action plan.
02
Ongoing compliance: legal assistance and guidance
Monthly service package → from £210
Continued ongoing expert legal support for licensed sponsors: ongoing advice on compliance queries, regular reviews of your sponsored workforce and reporting obligations, and proactive alerts to changes in sponsor guidance.
03
Sponsor Management System and CoS support
CoS assignment advice → £750 per CoS
Training on using the SMS correctly: assigning Certificates of Sponsorship, managing sponsored worker records, submitting required reports. We advise on each CoS assignment including SOC code selection and salary compliance.
What are Sponsor Compliance Duties?
When the Home Office grants your Sponsor Licence, you accept a legally binding set of obligations that apply continuously, not just at the point of hiring. These duties fall into four core areas: record-keeping, reporting, monitoring and right-to-work compliance.
The Home Office can audit your compliance at any time, announced or unannounced, in person or remotely. Enforcement has intensified and licence revocations reached their highest levels in 2025 and scrutiny has continued to increase in 2026. A passive approach to compliance is no longer viable, so you must ensure your business remains compliant at all times.
The exact requirements you will need to satisfy will vary depending on your circumstances. You may wish to speak to an immigration lawyer for an individual expert advice.
T / +44 (0) 207 112 8035
E / info@jvlegal.co.uk
Your Four Core Sponsor Licence Compliance Duties
Holding a UK Sponsor Licence comes with ongoing compliance obligations. The Home Office expects sponsors to maintain robust HR and immigration compliance systems throughout the duration of the licence. Failure to comply with sponsor duties can lead to Sponsor Licence suspension, Sponsor Licence revocation, civil penalties for illegal working, downgrading of your licence rating and disruption to your sponsored workforce. The four core Sponsor Licence compliance duties are record-keeping, reporting, monitoring and right-to-work compliance.
01 Record-Keeping Duties
UK sponsor licence holders must maintain accurate, up-to-date and readily accessible records for each sponsored worker.
Required records typically include:
Copies of passports, visas, BRPs/eVisas, and immigration status documents;
Evidence of right-to-work checks carried out before employment commenced and, where applicable, during employment;
Employment contracts and records demonstrating that the worker continues to perform the role stated on their Certificate of Sponsorship (CoS);
Salary and payroll records showing ongoing compliance with applicable salary thresholds and sponsorship requirements;
Current contact details, including residential address, telephone number, and email address;
National Insurance number where available;
Absence and attendance records, including periods of unpaid leave where relevant.
In most cases, sponsor records must be retained for whichever is the shorter of the duration of sponsorship plus one year; or until a compliance officer has examined and approved them, with certain documents required to be kept for a minimum period under sponsor guidance and employment legislation.
02 Right-to-Work Compliance Duties
All UK employers have a legal obligation to conduct compliant right-to-work checks before employment begins. Sponsor Licence holders are subject to enhanced scrutiny in this area.
Sponsors must:
Conduct compliant right-to-work checks before employment commences;
Carry out follow-up checks where a worker has time-limited immigration permission;
Retain clear records of all checks carried out, including copies of documents and the date of the check;
Ensure checks are conducted in accordance with current Home Office guidance, including online checks where applicable.
Failure to carry out compliant right-to-work checks may result in substantial civil penalties and enforcement action.
The maximum civil penalty for illegal working is currently up to £45,000 per illegal worker for a first breach; and up to £60,000 per illegal worker for repeat breaches.
A civil penalty will also frequently trigger a Home Office Sponsor Licence compliance audit and may place the licence at risk.
03 Reporting Duties
Sponsor Licence holders must report certain events to the UKVI/Home Office through the Sponsor Management System (SMS) within prescribed timeframes.
Reportable events include:
A sponsored worker failing to start work on the expected start date;
Unauthorised absence from work for a significant period;
Early termination of employment or resignation;
Significant changes to a worker’s role, duties, salary, work location, or working pattern;
Changes to the sponsoring organisation, including mergers, acquisitions, change of ownership, or insolvency-related events.
Most worker-related changes must be reported within 10 working days, while certain organisational changes must generally be reported within 20 working days.
04 Monitoring Duties
Sponsors are expected to actively monitor their sponsored workforce and maintain effective internal compliance systems.
This includes:
Tracking visa expiry dates and immigration permission;
Monitoring attendance and identifying unexplained absences promptly;
Ensuring sponsored workers continue to undertake the role described on their Certificate of Sponsorship;
Monitoring salary and working conditions to ensure continued compliance with sponsorship requirements;
Maintaining updated contact details and employment records.
The Home Office may conduct announced or unannounced compliance audits to assess whether these systems are operating effectively in practice.
UKVI Sponsor Licence Enforcement: What Happens If You Do Not Comply?
The Home Office take Sponsor Licence compliance extremely seriously. UKVI operates a risk-based compliance system and has broad powers to investigate sponsors at any stage: before a licence is granted, during the validity of the licence or following a compliance concern. Sponsor compliance is monitored through a combination of announced and unannounced compliance visits, digital monitoring systems, data matching with HMRC and other government departments, and information received from third parties, including employees and former employees. UKVI does not rely solely on sponsors self-reporting compliance issues.
Where concerns are identified, UKVI may take enforcement action against the sponsor. The consequences can be severe and may affect the business’s ability to recruit overseas workers, retain existing sponsored staff and continue operating normally.
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If UKVI identifies compliance failings but considers them capable of being remedied, a Sponsor Licence may be downgraded from an A-rating to a B-rating. This means the Home Office has identified deficiencies in the sponsor’s HR systems, record-keeping procedures, reporting practices, or wider compliance framework.
A sponsor subject to a B-rating will usually be required to follow a mandatory Home Office action plan designed to address the identified concerns within a specified period. During this time, the business will not normally be permitted to assign new Certificates of Sponsorship to recruit additional sponsored workers. The sponsor will also be subject to increased scrutiny and monitoring by UKVI.
If the compliance issues are not resolved, or if further breaches occur, the Sponsor Licence may ultimately be revoked. Repeated compliance failures within the relevant monitoring period are treated particularly seriously by the Home Office.
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UKVI may suspend a Sponsor Licence where serious compliance concerns arise and further investigation is required. Suspension can occur with little or no advance warning and often has immediate operational consequences for the business.
During the suspension period, the organisation is generally prohibited from assigning new Certificates of Sponsorship. Existing sponsored workers can usually continue working while the investigation is ongoing, however visa extensions, new recruitment, and ongoing immigration applications may be disrupted. The sponsor will normally be given an opportunity to respond to the allegations raised by UKVI and provide supporting evidence within a specified timeframe.
A Sponsor Licence suspension can significantly affect recruitment plans, workforce continuity, and commercial operations, particularly for businesses heavily reliant on overseas workers.
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Sponsor Licence revocation is the most serious enforcement action available to UKVI. Revocation means the sponsor loses its permission to employ sponsored workers entirely. This action is generally reserved for serious or repeated breaches of sponsor duties, illegal working, false representations, or failures considered sufficiently severe by the Home Office.
Where a licence is revoked, all Certificates of Sponsorship assigned by the business become invalid. Sponsored workers may have their visas curtailed, typically to 60 calendar days, requiring them to secure a new sponsor, switch immigration category, or leave the UK.
The consequences of revocation can be substantial. In addition to losing the ability to sponsor overseas workers, businesses may face operational disruption, reputational damage, loss of key personnel, and wider commercial consequences. In most cases, there is no full right of appeal against revocation, although limited legal remedies such as judicial review may be available depending on the circumstances. A cooling-off period before a fresh Sponsor Licence application can be submitted may also apply.
How JV LEGAL Can Help
At JV LEGAL we provide full support throughout all stages of the Sponsor Licence Application process.
We start with a detailed consultation and assessment of your specific circumstances, guide you through every step of the process to a successful decision and provide full-scope ongoing compliance support post-approval.
Frequently Asked Questions
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UKVI does not follow a fixed audit schedule. Any licensed sponsor can be audited at any time. Data suggests approximately 20% of all sponsor licence holders face some form of compliance review during their licence tenure. No business is too small to be audited.
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Contact JV LEGAL or other immigration advisor immediately. It is advised to seek legal advice prior to sending any information to the Home Office. The response you give and how quickly can determine whether a concern results in no action, a B-rating, a suspension, or revocation.
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In many cases, yes and proactive remediation is viewed far more favourably than issues discovered during an audit. JV LEGAL advises on the best approach, which may include voluntary disclosure to UKVI or prompt internal remediation. Do not ignore identified compliance failures at any time.