Home Office Sponsor Licence Audit: How to Prepare

What This Is Called, and Where the Rules Live

The Home Office does not use the word audit. Its term is a compliance check, and it may involve a visit, an interview, or a request for documents. The rules are in Part 3 of the sponsor guidance: sponsor duties and compliance, with the record-keeping requirements in its Appendix D and the fee rules in Part 1: apply for a licence.

Part 3 says the Home Office may check sponsors at any time, before or after a licence is granted, and that a check involving a visit or an interview can be announced or unannounced. A sponsor must co-operate and allow full access to any premises or sites under its control on demand. Where sponsored workers work at a third party's premises, it is the sponsor's responsibility to make sure that third party knows an unannounced visit may happen and co-operates; if the third party does not, the Home Office says it will act against the sponsor.

Renewal Was Abolished

Part 3 is explicit: “The requirement to renew your sponsor licence every 4 years was removed on 6 April 2024. Once granted, your licence will remain valid for an indefinite period (or for a maximum of 4 years in the case of the UK Expansion Worker and Scale-up routes), unless you either surrender it or we revoke it.”

Anything that describes a renewal cycle, a renewal fee or a renewal audit is out of date. A licence ends by surrender or revocation, or not at all. The Home Office has said it will publish further guidance on how it manages inactive licences.

The Fee Rules That Now Cost a Licence

This is the change most likely to catch a sponsor whose processes were set up before it. Part 3 lists, among the circumstances in which the Home Office will normally revoke a licence:

• Asking a sponsored worker to pay, or recouping or attempting to recoup by any means, some or all of the sponsor licence fee — including the fee for adding a route to an existing licence — or an associated administrative cost. This applies where the recovery is attempted on or after 31 December 2024 for Skilled Worker, and on or after 9 April 2025 for all other Worker and Temporary Worker routes.
• Asking a worker to pay, or recouping or attempting to recoup, some or all of the certificate of sponsorship fee or any associated administrative costs. This applies where the certificate was assigned on or after 31 December 2024 on Skilled Worker, and on or after 9 April 2025 on the Global Business Mobility routes, Minister of Religion, International Sportsperson, Scale-up and Seasonal Worker.
• Asking a worker to pay, or recouping or attempting to recoup, some or all of the Immigration Skills Charge. This one is listed without a date qualifier.

“By any means” is doing work in those sentences. A clawback clause in a contract, a deduction from salary, and a repayment agreement triggered by early resignation are all ways of recouping. Part 3 also lists paying a sponsored worker in cash as a ground on which the Home Office will normally revoke.

What a Compliance Check Looks At

• Record-keeping. Part 3 requires certain documents to be kept for each sponsored worker, with the list in Appendix D to the sponsor guidance. Appendix D, not a checklist from elsewhere, is what the officer is working from.
• Reporting. Whether reports have been made through the sponsorship management system within the deadlines — generally 10 working days for events concerning a sponsored worker, and 20 working days for changes to the sponsor organisation itself.
• The role against the occupation code. Part 3 says the scheme rests on sponsors ensuring the sponsored role accurately reflects the details on the certificate of sponsorship, including the occupation code and job description.
• Salary. Whether the worker is paid what the certificate says and at least the going rate for the code, alongside the general threshold. Since 26 March 2026 the Rules also require the salary to be paid in each pay period.
• Systems and people. Whether the sponsor is genuine, trading or operating lawfully, and actually complying with its duties. Compliance officers may interview the sponsor and any of its sponsored workers.

Our guide to sponsor duties and employer responsibilities guide cover the duties themselves.

Right to Work Checks and eVisas

Biometric residence permits stopped being issued at the end of 2024. Immigration status is now held as an eVisa in a UKVI account and proved to an employer with a share code, which lasts 90 days. A right to work check on a sponsored worker is an online check against that share code, and it is the online check that gives a statutory excuse. Any process still built around collecting a copy of a physical permit needs updating.

Right to rent, by contrast, is an England-only scheme and is not part of a sponsor's duties.

Outcomes

• No action. The licence stays at A-rating.
• Action plan. The Home Office sets steps to be taken. Part 3 says a sponsor must adhere to any action plan set for it, and that an action plan for a B-rated sponsor may add extra duties.
• Downgrade to a B-rating. Part 3 says this is generally for relatively minor breaches that an action plan can resolve. A B-rated sponsor must comply with a time-limited action plan, must pay a fee for it, and cannot sponsor any new workers until the A-rating is regained. Some automatic permissions on the licence are removed. Before downgrading, the Home Office writes setting out what it proposes and why, giving 20 working days to respond in writing.
• Suspension. Used where concerns are more serious while the Home Office investigates.
• Revocation. Part 3 says a revoked licence is revoked across every route the sponsor holds, no further workers can be sponsored, and the Home Office “will normally cancel the permission of any workers you are sponsoring”. The organisation comes off the public register of sponsors. There is no right of appeal, and a further licence application cannot be made until at least 12 months have passed. See our guide to what happens to sponsored workers when a sponsor stops sponsoring.

Care Sector Sponsors

The care routes have changed substantially, and a compliance check on a care provider now runs against a different set of rules from two years ago. Sponsorship of new applicants below degree level closed on 22 July 2025 unless the occupation code is on the Immigration Salary List or the Temporary Shortage List. GOV.UK now lists care worker (occupation code 6135) and senior care worker (6136) only for someone extending, updating or switching a Health and Care Worker visa, not for a first application from outside the UK.

Sponsors holding certificates or workers under the older arrangements remain subject to the full duties, and the fee-recovery rules above apply to them as to anyone else. See our health and care sponsorship guide.

Preparing

1. Work from Appendix D rather than an internal checklist, and check each sponsored worker's file against it.
2. Review what has been reported through the sponsorship management system against what has actually happened, and against the deadlines in Part 3.
3. Compare each worker's actual pay, in each pay period, with the certificate of sponsorship and the current going rate for the code.
4. Read every contract, clawback clause and repayment agreement against the fee-recovery grounds above.
5. Make sure the Authorising Officer and Key Contact details are current and that those people can speak to what the organisation does.
6. Where workers are based at a third party's site, make sure that site knows an unannounced visit may happen.

The starting point on GOV.UK is UK visa sponsorship for employers. Our Home Office contact guide covers the reporting channels, and our Skilled Worker guide the route itself.

This site sets out the published guidance. It does not assess a particular organisation's compliance, and it cannot say what the outcome of a check would be.

Questions and answers