The Home Office introduced important changes to sponsor licence compliance duties on 6 March 2026, and sponsors must ensure they are fully compliant to avoid licence suspension or revocation. These changes affect reporting duties, right to work compliance, and general sponsor responsibilities.
UK employers who sponsor Skilled Workers must treat these changes as a priority, as the Home Office is increasing compliance audits and enforcement action.
Key Sponsor Compliance Changes
Sponsors must ensure they are complying with their duties under the Immigration Rules, the Sponsor Guidance, and the Immigration, Asylum and Nationality Act 2006.
Introduction of the new eligible role test
The long-standing genuine vacancy requirement has been replaced by a new four-part test for an “eligible role.” Employers must now ensure the role remains eligible throughout the sponsorship period, not only when assigning a Certificate of Sponsorship (CoS).
As of March 6, 2026, sponsors must now ensure their sponsored workers are informed and understand their employment rights including (but not limited to):
- Minimum salary entitlements
- Maximum working hours
- Pension auto-enrolment and opt-outs
- Statutory leave and pay
- Health and safety protections
- Trade union membership and activity
- Rules regarding discrimination
- Access to grievance procedures
All sponsor licence holders must have a process to retain evidence demonstrating that they provide the above information to employees and must retain this evidence for any workers they sponsor.
Pay period threshold changes
The Immigration Rules have been amended to tighten salary compliance under the Skilled Worker route by requiring sponsors to meet the minimum salary in each pay period, rather than relying on an annual calculation for any COS assigned on or after after 8 April 2026.
Additionally, new National Minimum Wage rates (e.g., £12.71/hr for aged 21+) take effect for pay periods starting on or after 1 April 2026.
Requirement for sponsors to read sponsor guidance
Effective March 6, 2026, sponsor licence holders and prospective sponsors are expressly required to have read all relevant parts of the sponsor guidance : Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance – GOV.UK
The main areas sponsors should review immediately include:
1. Reporting Duties
Sponsors must report certain changes via the Sponsor Management System (SMS), including:
- Changes to job title or duties
- Salary changes
- Work location changes
- Employee resignations or dismissals
- Significant changes to business structure
- Unauthorized absences
Failure to report changes within the required timeframe can lead to licence suspension or revocation.
2. Right to Work Checks
Sponsors must ensure:
- Correct right to work checks are completed before employment begins
- Follow-up checks are completed where required
- Digital checks are carried out correctly
- Records are properly stored
Failure to carry out compliant right to work checks may result in civil penalties of up to £60,000 per illegal worker.
3. Genuine Vacancy Requirement
The Home Office is increasingly assessing whether sponsored roles are genuine vacancies. Sponsors must ensure:
- The role actually exists
- The job description matches the SOC code
- The salary meets the Skilled Worker requirements
- The worker has the skills and experience required
This is particularly important for small businesses and family-run businesses where directors sponsor relatives.
4. Record Keeping Duties
Sponsors must keep records such as:
- Employment contracts
- Payslips
- Contact details
- Absence records
- Right to work documents
- Evidence of recruitment where relevant
These must be available in the event of a Home Office compliance visit.
Home Office Compliance Visits Are Increasing
The Home Office has significantly increased:
- Compliance audits
- Unannounced visits
- Sponsor licence suspensions
- Sponsor licence revocations
If a sponsor licence is revoked, all sponsored workers may have their visas cancelled, which can have serious consequences for both the business and employees.
What Sponsors Should Do Now
Sponsors should:
- Conduct an internal compliance audit
- Review HR systems and reporting procedures
- Ensure Level 1 Users understand SMS reporting duties
- Review sponsored worker files
- Ensure job roles and salaries remain compliant
- Seek legal advice if unsure about compliance