In today’s competitive and highly regulated labour market, the ability to hire international talent is a key differentiator for many organisations. But with that opportunity comes significant responsibility. For UK employers using a sponsor licence, effective compliance is no longer optional, it’s essential. This article offers practical guidance for HR teams and legal advisors navigating the updated rules around the UK Visas and Immigration (UKVI) sponsor-licence regime.
Why the increased focus on compliance?
Holding a sponsor licence opens the door to hiring foreign workers, and with this, comes with high responsibility for the employer to ensure that each employees being sponsored continue to comply with the UK Immigration laws.
UKVI’s guidance for sponsors under the Worker and Temporary Worker routes emphasises that licensed employers must maintain a robust system and process to manage and monitor their sponsored workers. Recent updates mean things like having at least one “Level 1 User” who is a settled worker (or equivalent) inside the UK are set out to ensure that key compliance roles are staffed with personnel firmly based in the UK.
Any non-compliance can lead to downgraded ratings, action plans, suspension and even revocation of the licence. This can have a cascading operational impact, which will not only affect the Sponsor, but also the employees being sponsored as their visa can be curtailed.
For HR and legal teams, this means sponsor-licence management must be treated as a core operational risk, not just a tick-box exercise.
The key obligations (and how to make them manageable)
Here are some suggestions on things for you to keep on top of.
- Record-keeping & right-to-work checks
You must keep accurate records for each sponsored worker: passport or BRP copies, evidence of immigration status, NI number, employment contract, payslips and recruitment documentation.
Create and maintain a well-organised file (paper or electronic) for every sponsored worker. Retain documents for at least one year after sponsorship ends and ensure right-to-work checks are completed correctly, recorded properly, and monitored throughout employment. - Monitoring sponsored workers
Compliance continues well beyond onboarding. Organisations must track attendance and ensure each employee is performing the role stated on their Certificate of Sponsorship (CoS).
Introduce HR alerts and conduct regular, ideally quarterly reviews to ensure job title, salary, work location and duties remain aligned with the CoS. - Reporting changes via the SMS
Changes such as restructuring, staff departures, role changes or new key personnel must be reported through the Sponsorship Management System (SMS) within required deadlines which is usually either 10 or 20 days.
Assign a trained Level 1 User to closely manage reports and keep a clear audit log of updates submitted. - Appointing the right compliance leads
Every sponsor licence requires an Authorising Officer, Key Contact and Level 1 User who understand their responsibilities.
Ensure job descriptions and training records reflect compliance duties and are kept up-to-date. - Role eligibility, genuineness & related fees
A CoS may only be assigned for a genuine role that meets the correct skill and salary thresholds. Sponsors cannot recoup licence or administrative fees from workers—doing so could lead to enforcement action.
Building a compliance-first culture (that sticks)
To reduce risk and maintain your licence rating:
- Include sponsorship rules in HR policies covering recruitment, onboarding, payroll, absence and exits.
- Run internal audits every quarter to check documentation, reporting history and job compliance.
- Train HR, payroll and legal teams on key responsibilities, not just processes.
- Use monitoring tools to highlight visa expiry dates, long absences or role changes.
- Be prepared for UKVI compliance visits, which may be unannounced.
- Stay updated—immigration rules change frequently and early action prevents issues.
- Plan ahead by reviewing future CoS requirements and seeking legal advice before corporate changes impact the licence.
These steps embed compliance into everyday operations and avoid last-minute surprises.
What happens if you don’t comply?
Outcomes can be severe: licence downgrades, costly Sponsor Action Plans, restricted CoS allocation, and in the worst scenarios, licence revocation.
This can trigger disruption for the business and uncertainty for sponsored workers who may need to secure alternative sponsorship placing reputations, recruitment pipelines and business continuity at risk.
Non-compliance is more than an administrative issue; it is a strategic risk.
Quick practical checklist
- Keep a central register of your sponsored workers with key dates and compliance obligations.
- Ensure you have a named Authorising Officer, Key Contact and Level 1 User in place at all times and that they are aware of their responsibilities.
- Review job descriptions for workers coming in on a CoS—make sure they meet the right skill/ salary threshold and you have justification for sponsorship.
- Conduct documented right-to-work checks and maintain a complete file.
- Track long absences, and ensure work done matches what was approved on the CoS.
- Use the SMS proactively; report changes, keep records of when you reported.
- Train the key people in your business who handle HR, payroll and legal so they know what you’re responsible for.
- Audit the process internally at least every quarter so nothing slips through the cracks.
Final thoughts
Hiring globally gives businesses access to valuable talent, but as scrutiny increases, compliance must be fully integrated into operational processes. HR and legal teams should proactively plan, review and audit their sponsorship systems to protect both the business and its sponsored workers.
When in doubt, professional guidance makes all the difference and at Bishop & Sewell LLP, we are here to provide clear, comprehensive support to help you maintain full confidence in your sponsor-licence management.
