What are the main compliance duties for sponsor licence holders?

Sponsor licence holders must keep records of sponsored workers (passports, visas, contact details), report changes to the Home Office via the Sponsor Management System (when workers leave, change roles, or are absent), conduct right-to-work checks, cooperate with Home Office compliance visits, and only assign Certificates of Sponsorship for genuine roles.

How often does the Home Office conduct compliance visits?

There is no fixed schedule. Compliance visits can happen at any time and may be announced or unannounced. New sponsors are more likely to receive a visit within the first year. The Home Office may also visit in response to specific concerns or tip-offs.

What happens if I fail a compliance visit?

If you fail a compliance visit, the Home Office may issue an action plan, downgrade your licence from A-rated to B-rated, suspend your licence, or revoke it entirely. The outcome depends on the severity and nature of the compliance failures identified.

What reports must I make on the Sponsor Management System?

You must report when a sponsored worker does not start their job, stops attending work for 10 or more consecutive days without permission, leaves the organisation, has a significant change in duties or salary, changes their work address, or if there is any suspicion that they are breaching their visa conditions.

Can I lose my sponsor licence for a single compliance failure?

A single minor failure is unlikely to result in revocation, but it may trigger an action plan or downgrade. However, serious failures — such as employing illegal workers, facilitating immigration fraud, or systematic non-compliance — can lead to immediate revocation.

Sponsor Licence Compliance: Duties and How to Stay Compliant

Updated 18 March 202612 min read

What you need to know

•Compliance is ongoing — not just at the point of licence application.
•You must report certain changes within specific timeframes via the SMS.
•Record-keeping failures are the most common compliance issue.
•Compliance visits can be announced or unannounced at any time.
•Systematic non-compliance can lead to licence revocation.

UK sponsor licence holders must meet ongoing compliance duties including record-keeping, reporting, right-to-work checks, and cooperation with Home Office visits. This guide covers every duty in detail and provides practical advice on staying compliant.

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Overview of Sponsor Duties

When the Home Office grants a sponsor licence, the employer takes on a set of duties that last for the entire duration of the licence. These duties are not optional — they are conditions of holding the licence, and failure to meet them can have serious consequences.

The duties fall into five main categories: record-keeping, reporting, right-to-work checks, cooperation with the Home Office, and general compliance with immigration law. The full guidance is published in the sponsor duties and compliance guidance on GOV.UK.

Record-Keeping Duties

You must maintain up-to-date records for every sponsored worker. The required records include:

A copy of the worker's passport (the pages showing identity details, leave stamps, and visa)
A copy of the worker's biometric residence permit or eVisa confirmation
The worker's contact details (current address and phone number)
A record of the worker's attendance and absences
A copy of the employment contract
Evidence of right-to-work checks conducted before employment started

These records must be kept for the duration of sponsorship and for one year after sponsorship ends. Missing or incomplete records are the single most common finding on compliance visits.

Reporting Duties

Sponsors must report certain events to the Home Office through the Sponsor Management System (SMS). Reports must be made within specific timeframes:

Within 10 Working Days

The sponsored worker does not start the job
The sponsored worker is absent from work for 10 or more consecutive working days without permission
The sponsored worker leaves the organisation
There is a significant change in the worker's duties, job title, or salary
The worker's employment is terminated or they are made redundant

Within 20 Working Days

Changes to the sponsor's own details (company name, address, key personnel, ownership)
The sponsor ceases trading or becomes insolvent

Late or missing reports are a serious compliance issue. Set up internal processes to ensure reports are submitted on time.

Right-to-Work Checks

Before any worker starts employment, you must conduct a right-to-work check. For sponsored workers, this means verifying their visa status and confirming they have permission to do the work you are sponsoring them for.

Follow-up checks should be conducted when a worker's leave is due to expire, to ensure they have applied for an extension or new visa. The right-to-work checking guidance on GOV.UK provides the full process.

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Compliance Visits

The Home Office can visit your premises at any time to check compliance. Visits may be:

Pre-licence: Before the licence is granted, to verify the business is genuine
Post-licence (announced): Scheduled in advance, giving you time to prepare
Post-licence (unannounced): No advance warning, to see your day-to-day compliance

During a visit, the compliance officer will typically check your sponsored workers' files, interview key personnel, verify that workers are performing the roles described on their Certificates of Sponsorship, and inspect your HR systems and processes.

You must cooperate fully. Obstructing or refusing to cooperate with a visit is itself a ground for licence action.

Key Personnel

Every sponsor must appoint key personnel who are responsible for managing the licence:

Authorising Officer: The most senior person responsible for the licence, typically a director or senior manager
Key Contact: The main point of contact with the Home Office
Level 1 User: The person who manages the SMS on a day-to-day basis

Changes to key personnel must be reported to the Home Office. If a key person leaves the organisation, you must update the SMS promptly and appoint a replacement. See the licence requirements guide for more on personnel.

Building a Compliance System

The best way to meet your duties is to build systematic processes rather than relying on individual memory:

Central filing: Maintain a dedicated file (physical or digital) for each sponsored worker containing all required documents
Compliance calendar: Track key dates including visa expiry dates, reporting deadlines, and licence renewal
Regular audits: Conduct internal audits of your sponsorship records at least quarterly
Staff training: Ensure HR staff and managers understand their obligations
Written policies: Document your compliance procedures so they survive staff changes

For small businesses, these systems can be simple. For larger organisations with many sponsored workers, dedicated immigration compliance software may be worthwhile.

Consequences of Non-Compliance

The Home Office has a range of responses to non-compliance:

Action plan: A warning with a deadline to fix specific issues. See our action plan guide.
Downgrade: From A-rated to B-rated. B-rated sponsors face restrictions and must complete an action plan to regain A-rating.
Suspension: The licence is temporarily paused while the Home Office investigates. See our suspension guide.
Revocation: The licence is permanently withdrawn. All sponsored workers' visas may be curtailed. See our revocation guide.

Next Steps

Review your current compliance processes against the duties outlined above. If you identify gaps, address them before the Home Office finds them. If you are applying for a new licence, build these systems from the start.

Related guides:

This guide is general immigration information, not immigration advice under s.82 Immigration and Asylum Act 1999. Immigration rules change frequently. For advice on your specific situation, consult an IAA-authorised adviser or an SRA-regulated immigration solicitor. Always check GOV.UK for the authoritative current rules.