Sponsor Compliance Reviews

Sponsor Compliance Reviews for UK Employers

Holding a sponsor licence places continuing legal and administrative responsibilities on an employer. These responsibilities begin when the licence is granted and continue until the licence is surrendered, made dormant or revoked.

James Immigration Solutions Ltd provides structured sponsor compliance reviews to help employers assess whether their HR systems, sponsored-worker files, Sponsor Management System records and internal procedures are aligned with current Home Office requirements.

A compliance review can identify weaknesses before they become serious licence issues and help the organisation prepare for a possible UK Visas and Immigration compliance check.

What is a sponsor compliance review?

A sponsor compliance review is an independent assessment of how an organisation is managing its sponsor licence and sponsored workers.

The review may examine:

  • Sponsor licence information and authorised users.
  • Sponsored-worker files.
  • Certificate of Sponsorship records.
  • Right-to-work evidence.
  • Recruitment and role-selection records.
  • Salary, payroll and working-hours evidence.
  • Attendance and absence monitoring.
  • Worker contact information.
  • Sponsor Management System reports.
  • Organisational change reporting.
  • Internal HR procedures and staff responsibilities.
  • Compliance with route-specific sponsor guidance.

A JISL review is not a Home Office inspection and does not constitute Home Office approval or certification. It is a preparatory and risk-identification service designed to help the organisation understand and improve its systems.

Why are sponsor compliance reviews important?

The Home Office places substantial trust in licensed sponsors. Employers are expected to monitor sponsored workers, retain prescribed documents, report specified events and ensure that the information submitted in support of sponsorship remains accurate.

According to the current Home Office sponsor duties and compliance guidance, UKVI continually monitors sponsor compliance and may take action where an organisation:

  • Breaches its sponsor duties.
  • Presents a risk to immigration control.
  • Fails to comply with immigration or wider UK law.
  • Employs workers illegally.
  • Passes prohibited sponsorship costs to workers.
  • Provides inaccurate or misleading information.
  • Engages in conduct considered contrary to the public good.

Small administrative weaknesses can become more serious when they occur repeatedly or across several sponsored-worker files. A compliance review helps the employer understand whether its procedures work in practice rather than merely existing on paper.

When should an employer arrange a compliance review?

A review may be particularly useful:

  • After receiving a sponsor licence.
  • Before assigning the organisation’s first Certificate of Sponsorship.
  • Before requesting a substantial increase in CoS allocation.
  • Before sponsoring several new workers.
  • After changes to key personnel or SMS users.
  • Following staff turnover in the HR or recruitment team.
  • After opening a new branch or work location.
  • Before or after a merger, takeover or restructuring.
  • Where sponsored workers operate at client sites.
  • After discovering a missed SMS report.
  • Where a worker’s role, salary, hours or location has changed.
  • When the Home Office announces a compliance visit.
  • After receiving a request for information from UKVI.
  • Before responding to proposed licence action.
  • As part of a regular annual compliance programme.

A sponsor should not wait for a Home Office visit before checking whether its systems are effective.

How can UKVI check sponsor compliance?

The Home Office may conduct compliance checks before or after granting a sponsor licence.

Under the current sponsor compliance guidance, a compliance check can involve:

Type of check What it may involve
Documentary check A request for additional records, documents or explanations
Onsite visit Officers attending an office, branch, work location or relevant client site
Digital compliance check Remote interviews through video-conferencing facilities
Information verification Checking information provided with the sponsor licence or worker applications
Government data checks Comparing information with HMRC or other government departments
Interviews Speaking with key personnel, HR staff, managers, colleagues or sponsored workers
System inspection Examining HR, payroll, attendance, right-to-work and SMS procedures

A visit or interview may be announced or unannounced. UKVI may inspect premises under the sponsor’s control and relevant third-party locations where sponsored workers perform their duties.

If workers are based at a client site, the sponsor should ensure that the client understands that UKVI may conduct checks there and that appropriate cooperation may be required.

What does UKVI examine during a compliance visit?

The Home Office’s published sponsor compliance visit caseworker guidance explains the areas officers may examine before and after a licence is granted.

These can include whether:

  • The organisation is genuinely trading or operating lawfully.
  • The sponsor continues to have an operating presence.
  • Sponsored roles are genuine vacancies.
  • The role satisfies the relevant skill and salary requirements.
  • The worker is performing the job recorded on the CoS.
  • Salary, hours, duties and work locations match the sponsored role.
  • The number of Certificates of Sponsorship requested is justified.
  • Right-to-work checks have been completed properly.
  • Immigration-expiry dates are monitored.
  • Worker attendance and absences are tracked.
  • Worker contact details and their history are retained.
  • Reportable events have been notified through the SMS.
  • Required documents are available.
  • Key personnel remain eligible and active.
  • SMS users keep their login details secure.
  • Recruitment and CoS decisions are properly supported.
  • Sponsored workers comply with the conditions of their permission.
  • The sponsor complies with employment law and other relevant UK laws.
  • The organisation has cooperated fully with UKVI.

Officers may also compare information obtained from managers, HR staff, workers, the SMS, payroll records and HMRC data.

Areas covered by a JISL sponsor compliance review

The precise review will depend on the organisation’s licence, sponsored routes, number of workers and identified risks.

1. Sponsor licence and SMS review

We can examine whether:

  • The sponsor’s name, addresses and contact details are current.
  • Licensed routes remain appropriate.
  • Branches and work locations are correctly recorded.
  • The Authorising Officer and Key Contact details are accurate.
  • Level 1 and Level 2 users remain eligible and require access.
  • Former employees or representatives have been removed.
  • SMS users have individual accounts.
  • Home Office messages are monitored.
  • Organisational changes have been reported.
  • Appropriate records of SMS actions are retained.

Read more about our Sponsor Management System support.

2. Sponsored-worker file review

We can review all sponsored-worker files or an agreed sample.

A file review may consider whether the organisation holds the relevant:

  • Passport and identity information.
  • Evidence of the worker’s immigration status.
  • Online right-to-work check evidence.
  • Date-of-entry evidence where required.
  • Certificate of Sponsorship details.
  • Contact details and history of changes.
  • National Insurance number.
  • Employment contract or written terms.
  • Job description.
  • Salary and working-hours information.
  • Payslips and payment evidence.
  • Attendance, leave and absence records.
  • Qualification and skills evidence.
  • Professional registration or accreditation.
  • Recruitment records where applicable.
  • SMS reporting confirmations.
  • Evidence supporting changes to employment.

The exact documents required depend on the sponsored route and individual circumstances.

The current requirements are set out in Appendix D of the sponsor guidance.

3. Certificate of Sponsorship review

We can compare the information recorded on each CoS with the worker’s actual employment.

This may include:

  • Sponsorship route.
  • CoS type.
  • Occupation code.
  • Job title.
  • Detailed duties.
  • Salary.
  • Weekly hours.
  • Employment dates.
  • Main and additional work locations.
  • Professional-registration requirements.
  • Sponsor notes.
  • Changes occurring after assignment.
  • Evidence demonstrating that the vacancy is genuine.

Discrepancies between the CoS, contract, payroll records and the worker’s actual duties can present a serious compliance risk.

Related services include Certificate of Sponsorship support and occupation and salary reviews.

4. Salary and payroll review

The Home Office can make checks with HMRC to establish whether sponsored workers are being paid in accordance with the Immigration Rules and sponsor guidance.

Our review may compare:

  • Salary stated on the CoS.
  • Contractual salary.
  • Actual gross pay.
  • Payslips.
  • PAYE information.
  • Bank-payment evidence.
  • Working hours.
  • Overtime arrangements.
  • Deductions.
  • Periods of unpaid or reduced-pay absence.
  • Salary changes reported through the SMS.

A worker receiving less than the salary stated on the CoS does not automatically establish a breach in every situation. However, the sponsor must understand whether an exception applies, whether a report is required and whether the worker needs a new immigration application.

5. Right-to-work procedures

We can assess whether the organisation:

  • Uses the correct right-to-work checking method.
  • Completes checks before employment begins.
  • Retains the required evidence.
  • Records the date of each check.
  • Uses the correct online Home Office service.
  • Schedules follow-up checks where permission is time-limited.
  • Responds appropriately to outstanding applications or appeals.
  • Applies its procedure consistently.
  • Protects personal information appropriately.

Further information is available on our Right-to-Work Procedures page and in the official employer’s guide to right-to-work checks.

6. Attendance and absence monitoring

The sponsor must have an effective system for monitoring sponsored workers’ attendance.

Our review may examine:

  • How attendance is recorded.
  • Who reviews absences.
  • How unauthorised absence is identified.
  • How annual leave and sickness absence are recorded.
  • Whether managers notify the sponsor-compliance team.
  • Whether extended unpaid or reduced-pay absence is identified.
  • How missed start dates are escalated.
  • Whether relevant reports were made through the SMS.

The Home Office does not prescribe one particular attendance system. The organisation must nevertheless be able to demonstrate that its chosen system is effective.

7. Worker contact details

A sponsor must retain current contact details for sponsored workers and, where applicable, a history of changes.

This may include:

  • UK residential address.
  • Personal telephone or mobile number.
  • Email address.
  • Previous contact information.
  • The date on which a change was notified.

Our review can assess whether the organisation has a clear process for workers to report changes and whether HR records are updated promptly.

8. Reporting duties

We can review whether reportable events were identified and notified within the applicable deadlines.

This can include changes relating to:

  • Delayed employment start.
  • Unauthorised absence.
  • Resignation, dismissal or redundancy.
  • Early termination of sponsorship.
  • Unpaid or reduced-pay absence.
  • Salary.
  • Job title or core duties.
  • Work location.
  • Key personnel.
  • Organisation name or address.
  • Branches, sites or PAYE references.
  • Ownership, merger or takeover.
  • Insolvency or cessation of trading.

Sponsored-worker changes are normally reportable within 10 working days, while relevant organisational changes are generally reportable within 20 working days, unless the guidance provides a different period.

9. Genuine vacancy and recruitment review

UKVI may examine whether the sponsored job is genuine and whether the worker is actually performing that job.

Our review may compare:

  • The organisation’s business activities.
  • The operational need for the role.
  • Organisational structure.
  • Job description.
  • Occupation code.
  • Worker qualifications and experience.
  • Recruitment documents.
  • Interview notes.
  • Reporting lines.
  • Daily duties.
  • Work outputs.
  • Client contracts where relevant.
  • Salary and working hours.

A compliant file should demonstrate a genuine business need rather than relying only on a generic job description.

10. Key-personnel and staff preparation

UKVI may interview:

  • The Authorising Officer.
  • The Key Contact.
  • Level 1 users.
  • HR or recruitment staff.
  • Payroll personnel.
  • Line managers.
  • Directors.
  • Sponsored workers.
  • Other relevant employees.

We can explain the areas likely to be examined and help personnel understand their responsibilities.

Preparation must be based on genuine organisational practices and accurate records. Workers and managers should not be given invented or misleading answers. Their answers should naturally correspond with the role, workplace and systems that actually exist.

Documents commonly examined during a review

Depending on the scope, we may request:

Organisation documents

  • Companies House information.
  • Sponsor licence application documents.
  • HMRC and PAYE registrations.
  • VAT registration where applicable.
  • Business bank statements.
  • Accounts or management information.
  • Employer’s liability insurance.
  • Lease, licence or premises evidence.
  • Organisational chart.
  • Client or service contracts where relevant.
  • Regulatory registrations.
  • Business policies and procedures.

Sponsored-worker documents

  • Passport or identity evidence.
  • eVisa or immigration-status evidence.
  • Right-to-work check.
  • CoS information.
  • Employment terms.
  • Job description.
  • Salary and payroll evidence.
  • Attendance and leave records.
  • Contact details.
  • Qualifications and professional registrations.
  • Recruitment evidence.
  • SMS report confirmations.

Sponsor administration records

  • Key-personnel details.
  • SMS-user list.
  • CoS approval records.
  • Allocation requests.
  • Sponsor notes.
  • Internal compliance checklists.
  • Reporting logs.
  • Staff-training records.
  • Home Office correspondence.
  • Previous compliance findings or action plans.

Documents may be retained electronically or on paper, but the sponsor must be able to make the required information available to the Home Office on request.

Unless another period is stated, sponsored-worker documents must generally be retained throughout sponsorship and until the earlier of:

  • One year after sponsorship ends; or
  • The date a compliance officer examines and approves the documents.

Some records must be retained for longer under right-to-work, employment, tax, accounting or data-protection requirements. Documents submitted with the sponsor licence application should be retained for as long as the organisation holds the licence.

Our sponsor compliance review process

Stage 1: Initial assessment

We discuss the organisation’s sponsor licence, sponsored routes, workforce structure and principal concerns.

Stage 2: Document collection

The organisation provides the agreed documents through an appropriate secure method.

Stage 3: File and system review

We review the agreed worker files, SMS information, HR processes and supporting evidence.

Stage 4: Practical testing

Where included, we test how the organisation would identify and respond to common events, such as:

  • A worker failing to attend.
  • A salary reduction.
  • A change of work location.
  • A Level 1 user leaving.
  • A worker resigning.
  • A change to the organisation’s address.
  • An expiring right to work.
  • A proposed change to job duties.

Stage 5: Findings and recommendations

We identify findings according to their apparent seriousness and provide practical remedial recommendations.

The review may distinguish between:

  • Potentially critical licence risks.
  • Material compliance concerns.
  • Administrative weaknesses.
  • Recommended improvements.
  • Areas where the available evidence appears satisfactory.

Stage 6: Remedial support

Where requested and within our authorised scope, we can help the organisation update procedures, organise records, prepare necessary reports and provide staff guidance.

A review cannot erase a historic breach. Any correction should be accurate, transparent and made using the proper process. Records must never be fabricated, altered dishonestly or backdated.

Preparing for an announced UKVI visit

If the Home Office has notified your organisation of a compliance visit:

  1. Verify the communication and the date of the visit.
  2. Read the request carefully.
  3. Inform the Authorising Officer and relevant personnel.
  4. Obtain advice promptly.
  5. Preserve all relevant records.
  6. Review sponsored-worker files.
  7. Compare actual employment against each CoS.
  8. Check SMS details and previous reports.
  9. Organise requested documents.
  10. Ensure relevant personnel are available.
  11. Inform any affected third-party work location.
  12. Respond to document requests within the specified deadline.

A legal representative may attend where permitted, but the organisation’s personnel must be able to explain their own systems and decisions.

Responding to an unannounced visit

A genuine unannounced visit should be treated seriously.

The organisation should:

  • Check the officers’ identification.
  • Notify the most senior available person.
  • Contact its adviser where appropriate.
  • Cooperate with legitimate requests.
  • Avoid obstructing or delaying the visit.
  • Preserve copies of documents supplied.
  • Keep an internal record of the visit.
  • Ensure answers are accurate and truthful.
  • Avoid guessing where the answer is not known.
  • Arrange prompt provision of documents that are held but not immediately accessible.

Refusing access or failing to cooperate can itself result in adverse compliance findings.

What happens after a UKVI compliance check?

After completing its checks, UKVI will decide whether any action is required and notify the sponsor in writing.

Possible outcomes include:

  • No further action.
  • Reduction of the CoS allocation.
  • Downgrading from an A-rating to a B-rating.
  • A paid and time-limited sponsor action plan.
  • Suspension of the sponsor licence.
  • Revocation of the sponsor licence.
  • Cancellation or shortening of workers’ permission.
  • Referral to another government department or enforcement authority.

The Home Office guidance states that relatively minor, remediable breaches may result in a B-rating and action plan. More serious or systematic failures may result in suspension or revocation.

A B-rated sponsor is generally prevented from sponsoring new workers until its A-rating is restored. A suspended sponsor cannot assign new Certificates of Sponsorship while the suspension remains in place.

If a sponsor receives a suspension notice, the current guidance normally provides 20 working days from the date of written notification to submit a written response and supporting evidence. The exact deadline in the letter must be followed.

There is no ordinary right of appeal against sponsor licence revocation. Employers facing proposed downgrade, suspension or revocation should obtain urgent advice from a suitably authorised specialist.

Where a matter falls outside JISL’s IAA Level 1 authorisation, we will explain the limitation and the need to obtain assistance from an appropriately authorised adviser or legal representative.

Common sponsor compliance risks

Common problems identified during internal reviews include:

  • Missing right-to-work evidence.
  • Incorrect use of the online checking service.
  • No effective immigration-expiry monitoring.
  • Late or missing SMS reports.
  • Outdated organisation or key-personnel details.
  • Shared SMS passwords.
  • Former employees retaining SMS access.
  • Salary differing from the CoS.
  • Sponsored duties differing from the stated role.
  • Workers operating at unreported locations.
  • Incomplete attendance records.
  • Missing worker-contact history.
  • Insufficient evidence of qualifications or registration.
  • Generic job descriptions unsupported by business activity.
  • Inconsistencies between payroll, contracts and bank payments.
  • Poor communication between managers and the Level 1 user.
  • Inaccessible or disorganised worker files.
  • Prohibited sponsorship costs being passed to workers.
  • Failure to retain sponsor licence application documents.
  • Failure to cooperate with a Home Office request.

Frequently asked questions

Can UKVI visit without giving notice?

Yes. Sponsor compliance checks and interviews may be announced or unannounced.

Can UKVI interview sponsored workers?

Yes. Compliance officers may interview sponsored workers, managers, HR personnel and other relevant employees to compare their answers with the CoS and organisational records.

Does every sponsor need a particular HR software system?

No. The Home Office does not prescribe one particular type of software. The organisation’s system must be effective, accurate and capable of producing the required information.

Can records be stored electronically?

Yes. Appendix D permits paper or electronic storage. The sponsor must be able to make the documents available when requested.

Does a compliance review guarantee that our licence is safe?

No. A review can identify apparent risks and recommend improvements, but it cannot guarantee a particular Home Office decision or prevent UKVI from taking compliance action.

Can historic mistakes be corrected?

Some matters can be corrected or explained through the appropriate SMS or Home Office process. However, a later correction does not automatically remove the original breach. Advice should be obtained before submitting a material correction.

Will JISL coach workers for a Home Office interview?

We can explain the process and help workers understand the importance of answering accurately. We do not provide false answers or scripts intended to mislead the Home Office.

How often should a compliance review be completed?

The appropriate frequency depends on the number of sponsored workers and the organisation’s risk profile. A review may be appropriate annually, after major changes or before significant sponsorship activity.

Arrange a sponsor compliance review

If your organisation holds a sponsor licence and would like to assess its HR systems, worker files, SMS records or compliance-visit readiness, contact James Immigration Solutions Ltd.

James Immigration Solutions Ltd
Website: www.jisl.co.uk
Email: admin@jisl.co.uk
Company number: 15056317
IAA organisation reference: F202538614
IAA regulation level: Level 1

This page provides general information and does not constitute advice on any individual sponsor-licence or immigration matter. The applicable requirements depend on the organisation, sponsored route, individual worker and rules in force at the relevant time.

A JISL compliance review is not a Home Office inspection, certification or guarantee of compliance. The Home Office retains responsibility for sponsor-licence and immigration decisions. No outcome can be guaranteed.

Last reviewed: 3 August 2026