Sponsor Licence Compliance: What UK Businesses & Individuals Need to Know
In today’s evolving immigration landscape, maintaining sponsor licence compliance is essential for any UK employer seeking to hire non-UK nationals under the Skilled Worker route, or those holding existing sponsor licences. Non-compliance can lead to fines, licence suspension or revocation, and serious reputational harm. This article offers a detailed guide for both businesses and individuals seeking expert guidance in UK immigration and employment law. We’ll also show how NA Law Solicitors can support you every step of the way.
What Is a Sponsor Licence, and Why Does Compliance Matter?
A Skilled Worker Sponsor Licence, issued by UK Visas and Immigration (UKVI), allows UK employers to recruit eligible international workers by issuing Certificates of Sponsorship (CoS). Without this licence, employing overseas nationals in skilled roles can breach immigration law.
Compliance matters because once granted, a sponsor licence comes with ongoing legal duties. UKVI requires employers to maintain accurate records, carry out right-to-work checks, report changes in worker circumstances, and ensure roles meet required salary and skill thresholds. Failure in any of these areas can result in enforcement action.
Key Legal Duties for Sponsor Licence Holders
Here are the core requirements all sponsor licence holders must meet:
1. Record-keeping Duties
You must retain specific HR, immigration and payroll records for each sponsored worker in accordance with Appendix D of the sponsor guidance. Missing documents or gaps in records are one of the most common compliance failures.
2. Monitoring and Reporting Duties
Employers must report changes in a worker’s job role, salary, or location within 10 working days; organisational changes like relocation or mergers within 20 working days. You must also notify UKVI of unauthorised absences, terminations, and suspicions of visa misuse.
3. Right to Work Checks
All employees—sponsored or otherwise—must undergo proper right to work verification before employment begins. Checks must be repeated when time-limited immigration status expires. Evidence of checks must be stored securely.
4. Key Personnel Roles & Suitability
Your sponsor licence must have designated individuals: an Authorising Officer, Key Contact, Level 1 User, and optionally, Level 2 Users. These individuals must meet suitability criteria—including no unspent criminal convictions and being based in the UK—and be capable of fulfilling their roles.
5. Compliance Visits & CoS Responsibilities
UKVI may carry out announced or unannounced visits to test compliance. Certificates of Sponsorship must be issued only for genuine vacancies, at appropriate skill levels and salary. Misuse of CoS—such as roles that don’t align with actual duties—is strictly prohibited.
Penalties and Risks for Non-Compliance
Failing to comply with your sponsor duties can lead to a range of serious consequences:
Licence Downgrade, Suspension, or Revocation
Minor or one-off breaches may lead to a downgrade (for example, from A-rating to B-rating), while multiple or serious failures can cause suspension or revocation.
Curtailment for Sponsored Workers
If a licence is revoked, sponsored workers may have their leave curtailed, often resulting in a limited timeframe (e.g. 60 days) to find another sponsor or leave the UK.
Civil Penalties and Fines
Employing someone without the right to work or failing to perform required checks can lead to civil penalties—up to £20,000 or more per illegal worker for first offences, increasing for repeat cases.
Reputational Damage and Operational Disruption
Losing your licence or having enforcement action against you can erode trust, deter investors or clients, and disrupt recruitment and business operations.
Legal Consequences
In cases involving deliberate misconduct—fraud, deception or knowingly hiring illegal workers—criminal liability may be imposed.
Recent Trends & Regulatory Priority Areas
UKVI is increasing scrutiny across the sponsoring regime. Key trends include:
– Increased licence revocations: Nearly 1,948 sponsor licences were revoked between June 2024–June 2025, more than double the number in the preceding year.
– Stronger enforcement in high-risk sectors such as adult social care, hospitality, retail and construction.
– Tighter rules around matching job descriptions and SOC codes, respecting salary thresholds, and avoiding unfair clawback agreements.
These trends show Home Office’s commitment to enforcing regulatory standards with increased intelligence sharing and data analysis.
How NA Law Solicitors Help You Stay Compliant
NA Law Solicitors offers specialist corporate immigration services designed to help employers avoid compliance pitfalls. We are based in Brentford, West London, SRA-authorised, and we operate on a fixed fee, ensuring transparency.
Here’s how we assist:
Sponsor Licence Application & Skilled Worker Sponsor Licence: End-to-end support—from eligibility assessment and gathering documents to priority handling of CoS assignments.
Audit & Compliance Review: We audit your HR systems, conduct mock compliance visits, and draft policies to meet UKVI’s record-keeping, monitoring, and reporting requirements.
Right to Work Checks & Reporting Advice: Guidance on performing checks correctly, maintaining evidence, and reporting changes through the Sponsorship Management System (SMS).
Defending Enforcement Action: If you receive a civil penalty or are threatened with revocation or suspension, we represent you, advise on corrective action plans and liaise with UKVI.
Training & Strategic Planning: Tailored in-house workshops for HR teams and strategic immigration planning to align your recruitment needs with regulatory obligations.
Best Practices: Tips to Maintain Sponsor Licence Compliance
– Maintain a compliance calendar that tracks visa expiry dates, certificate deadlines, and reporting obligations.
– Ensure key personnel are well-trained and understand their responsibilities. Keep names updated in the sponsor record.
– Conduct internal audits—quarterly or semi-annually—to check documentation, payrolls, work duties, and compliance with the CoS.
– Use the SMS effectively—report changes on time, respond to Home Office notices.
– Prepare for audits and inspections; keep premises, files, and personnel ready.
– Never impose illegal or unfair clawback agreements or attempt to shift sponsorship costs to workers in breach of Home Office policy.