Sponsor Licence Audit

Book a Quick Assessment
Quick links
  1. What is a Sponsor Licence Audit?
  2. What does a Home Office compliance visit consist of?
  3. Are Home Office compliance visits announced?
  4. What can be an outcome of a compliance audit?
  5. What will the Home Office review during the audit?
  6. What should we do to prepare for a sponsor licence audit?
  7. What typically triggers a Home Office compliance visit?
  8. What powers do compliance officers have during a visit?
  9. How long does a compliance visit typically last?
  10. What is the difference between a pre-licence visit and a post-licence compliance audit?
  11. What HR records must a licensed sponsor maintain?
  12. How long must sponsorship records be retained?
  13. What contact and tracking obligations does a sponsor have?
  14. What must a sponsor report to UKVI and within what timeframe?
  15. How should absences of sponsored workers be handled?
  16. What are the compliance obligations for sponsored workers working remotely?
  17. Who within our organisation should be responsible for sponsor licence compliance?
  18. What is the Sponsorship Management System and how important is it?
  19. What does a B-rating mean and how does it affect our organisation?
  20. What happens to our sponsored workers if our licence is suspended or revoked?
  21. Can we challenge a decision to revoke or suspend our sponsor licence?
  22. What are the most common reasons sponsors fail compliance audits?
  23. What is a mock audit and should we consider one before a compliance visit?
  24. How can Morgan Smith Immigration assist with our sponsor licence compliance?
  25. Are Home Office visits announced? 
  26. What can be an outcome of a Compliance Audit?
  27. What will the Home Office Review during the Audit?
  28. What should I do to prepare for a Sponsorship Licence Audit?

What is a Sponsor Licence Audit?

The Home Office conducts compliance audits of sponsor licence holders to verify that sponsors continue to meet the requirements set out in the Immigration Rules and the Sponsor Guidance. Officers will assess whether the information provided in your original licence application remains accurate and whether your organisation is genuinely maintaining all sponsorship duties. Failure to satisfy the audit can have serious consequences for your licence.

What does a Home Office compliance visit consist of?

During a compliance visit, Home Office officers will verify that:
– All information submitted to UKVI is accurate and complete
– Your organisation is a genuine trading entity and can offer employment at the required skill level
– There is no reason to believe your organisation poses a threat to immigration control
– Your HR systems, policies, and record-keeping meet the required standard
– Each sponsored worker is being managed in accordance with your sponsorship duties

Are Home Office compliance visits announced?

The Home Office may conduct both announced and unannounced compliance visits. An announced visit gives you the opportunity to ensure your records are in order, but an unannounced visit is designed precisely to assess your day-to-day compliance rather than a prepared snapshot. Sponsors must be ready to demonstrate compliance at all times, not merely when a visit has been signalled.

What can be an outcome of a compliance audit?

The possible outcomes range from no action, where full compliance is confirmed, through to a B-rating, suspension, or full revocation of your sponsor licence. Where officers identify minor issues, your licence may be downgraded to a B-rating with an action plan imposed. More serious breaches can result in immediate suspension pending investigation, or outright revocation. Any adverse outcome carries significant consequences for your sponsored workers and your ability to recruit internationally.

What will the Home Office review during the audit?

Officers will examine your organisation’s HR systems and processes, internal policies and procedures, record-keeping practices, management of each sponsored worker, and your overall compliance with the Immigration Rules. Particular scrutiny is given to right to work checks, contact and tracking obligations, reporting obligations to UKVI, and whether salary and role conditions match those recorded on the Certificate of Sponsorship.

What should we do to prepare for a sponsor licence audit?

Preparation begins long before any visit is announced. You should conduct a thorough internal audit of all sponsored worker files, verify that right to work checks are current and properly recorded, review your HR policies against the current Sponsor Guidance, and ensure your Authorising Officer and key contact details are up to date on the Sponsorship Management System. Staff involved in HR and payroll should be trained on their sponsorship obligations. Engaging an immigration law firm to conduct a mock audit is strongly advisable.

Concerned about your sponsor licence compliance position?

Many businesses only discover compliance gaps when the Home Office is already at the door. Our immigration lawyers work with employers across the UK to assess their compliance posture, identify risks before they become problems, and implement robust HR frameworks that satisfy UKVI requirements. Contact our team for a confidential review.

Request a Call Back

Request a Compliance Review

What typically triggers a Home Office compliance visit?

Compliance visits can occur at any point during your licence period and are not always triggered by a specific complaint or report. The Home Office operates a risk-based approach, and visits may be prompted by factors including a significant increase in your number of sponsored workers, intelligence received from third parties, an application to add or change routes, a change in your organisation’s circumstances, or simply as part of routine monitoring of licenced sponsors.

What powers do compliance officers have during a visit?

Compliance officers are entitled to inspect your premises, request access to HR files and payroll records, interview members of staff and sponsored workers, and review your SMS records. They may request documentary evidence on the day and follow up in writing after the visit. They do not have powers of entry under a warrant in most circumstances, but refusing or obstructing a legitimate compliance visit is itself a ground for adverse action against your licence.

How long does a compliance visit typically last?

A compliance visit can last anywhere from a few hours to a full working day, depending on the size of your organisation and the number of sponsored workers. For larger employers with multiple sites, officers may visit on more than one occasion. The visit concludes with the officers informing you of their initial findings, though formal written outcomes may take several weeks to follow.

What is the difference between a pre-licence visit and a post-licence compliance audit?

A pre-licence visit occurs before the Home Office decides your initial sponsor licence application. Officers will attend your premises to verify that your organisation is genuine, that you have the HR infrastructure to meet sponsorship obligations, and that the roles you intend to sponsor are credible. A post-licence compliance audit, by contrast, takes place after your licence has been granted and is designed to confirm that you are maintaining those obligations in practice.

Have you received notice of a Home Office compliance visit?

If you have been notified of an upcoming compliance visit — or officers have arrived unannounced — our lawyers can advise you on your immediate obligations, help you locate and prepare the required documentation, and accompany you through the process. Time is critical. Speak to us today.

Request a Call Back

Request Urgent Advice

What HR records must a licensed sponsor maintain?

Licensed sponsors are required to keep the following records for each sponsored worker: a copy of their current passport and any relevant visa or leave to remain documentation, their national insurance number, their contact details including home address and telephone number, evidence of the right to work check carried out before employment commenced, copies of all relevant qualifications where these are a condition of sponsorship, and a record of their current salary and working pattern.

How long must sponsorship records be retained?

Most records relating to a sponsored worker must be kept for the duration of employment plus at least one year after the worker leaves your organisation. Right to work check documentation must be retained for two years after employment ends. Given that UKVI may audit historical records, many immigration advisers recommend a minimum retention period of six years for all sponsor-related documents, consistent with general HR best practice.

What contact and tracking obligations does a sponsor have?

Sponsors must maintain up-to-date contact details for every sponsored worker and must take reasonable steps to maintain contact throughout the period of sponsorship. This includes recording any change of address or telephone number promptly on the SMS. Where a sponsored worker cannot be contacted, sponsors must report this to UKVI within ten working days and document the attempts made to re-establish contact. Failure to track the whereabouts of sponsored workers is a common compliance failure.

What must a sponsor report to UKVI and within what timeframe?

Sponsors have a legal obligation to report certain events to UKVI via the Sponsorship Management System within ten working days of the event occurring. Reportable events include: a sponsored worker not starting the role as expected, unauthorised absence or failure to report for work for ten consecutive working days, a significant change to the worker’s role or salary, and the early termination of employment. Certain changes, such as a change of job title or work location, may also require prior approval from UKVI.

How should absences of sponsored workers be handled?

Sponsors must monitor attendance and record absences for all sponsored workers. Unpaid absences of four weeks or more must be reported to UKVI and may require a reduction in the worker’s sponsor-reported salary. Sponsors should have a clear internal absence policy that distinguishes between authorised leave, sickness absence, and unauthorised absence. Any absence that cannot be satisfactorily explained or that exceeds the permitted threshold must be reported promptly.

What are the compliance obligations for sponsored workers working remotely?

Remote and hybrid working arrangements are permissible but must be properly managed. Where a sponsored worker works from a location other than the address specified on their Certificate of Sponsorship, sponsors should consider whether this constitutes a reportable change. Workers who move to a fully remote arrangement or change their primary work location may require a new CoS. Sponsors should maintain records of the worker’s usual working address and ensure it is reflected accurately in their SMS records.

Who within our organisation should be responsible for sponsor licence compliance?

Every licensed sponsor must designate an Authorising Officer, a Level 1 User, and where appropriate a Level 2 User on the SMS. The Authorising Officer holds ultimate responsibility for the licence and must be a senior person within the organisation. Day-to-day compliance is usually managed by the Level 1 User. It is critical that these roles are filled by suitable, vetted individuals and that any change in personnel is updated on the SMS without delay.

What is the Sponsorship Management System and how important is it?

The Sponsorship Management System (SMS) is the online portal through which all sponsor activity is managed. It is used to assign Certificates of Sponsorship, report changes and events, and manage user access. Keeping the SMS accurately updated is itself a compliance obligation. An out-of-date or inaccurate SMS record — for example, a former employee still listed as Level 1 User — can be treated as evidence of poor compliance management and will attract adverse scrutiny during an audit.

Not confident your HR records meet UKVI standards?

Sponsor licence compliance is an ongoing obligation, not a one-off exercise. Morgan Smith Immigration offers a thorough mock audit service, reviewing your sponsored worker files, SMS records, right to work documentation, and reporting history against the current Sponsor Guidance. Identify and fix gaps before the Home Office does.

Request a Call Back

Book a Mock Audit

What does a B-rating mean and how does it affect our organisation?

A B-rating is imposed when the Home Office determines that a sponsor is not fully compliant but the issues identified do not warrant immediate suspension or revocation. A sponsor given a B-rating will be required to follow an action plan specifying steps to be taken within a defined period to achieve full compliance. During a B-rating period, sponsors pay a fee and are restricted in their ability to assign new Certificates of Sponsorship. If the action plan is not completed satisfactorily, the licence may be revoked.

What happens to our sponsored workers if our licence is suspended or revoked?

If your licence is suspended, the leave of workers whose Certificates of Sponsorship are tied to that licence may be curtailed, giving them a limited period to find alternative sponsorship or leave the UK. If the licence is revoked, this process proceeds more rapidly. Workers in this position face considerable uncertainty, and the reputational and operational impact on the employer can be significant. Early legal advice is essential if you receive notice of suspension proceedings.

Can we challenge a decision to revoke or suspend our sponsor licence?

Where the Home Office decides to revoke a sponsor licence, sponsors have the right to request an administrative review of that decision within a set timeframe. This is not an appeal in the traditional sense but a review of whether the decision was correctly made on the facts. If the administrative review is unsuccessful, judicial review may be available in limited circumstances. Given the strict timescales and complexity of the Immigration Rules, it is strongly advisable to instruct experienced immigration solicitors as soon as possible after receiving a revocation notice.

What are the most common reasons sponsors fail compliance audits?

The most frequently identified compliance failures include: inadequate right to work check records; failure to monitor and report worker absences; out-of-date SMS records; discrepancies between the salary or role recorded on the CoS and what is actually being paid or undertaken; failure to report changes in employment conditions; poor record-keeping of sponsored worker documents; and HR staff who are unaware of or untrained in sponsorship obligations. Many of these failures are preventable with a proper internal compliance framework.

What is a mock audit and should we consider one before a compliance visit?

A mock audit is a structured review of your compliance position conducted by immigration lawyers or compliance specialists in advance of a Home Office visit. It replicates the scrutiny that compliance officers will apply to your records and processes, identifies gaps or deficiencies, and gives you the opportunity to remediate issues before they are identified by the Home Office. We strongly recommend that all licensed sponsors undertake a mock audit at least annually, and particularly before any anticipated increase in sponsored worker headcount.

How can Morgan Smith Immigration assist with our sponsor licence compliance?

Morgan Smith Immigration provides a comprehensive sponsor licence compliance service. This includes an initial audit of your HR systems and sponsored worker records, a detailed compliance report identifying areas of risk, training for your HR and management teams, assistance with reporting obligations and SMS management, and representation in the event of a compliance visit or adverse decision. Our immigration lawyers have extensive experience advising employers across a wide range of sectors and can provide practical, commercially focused guidance tailored to your organisation.

Need help with preparing for your Sponsor Licence Audit?

Morgan Smith Immigration can help a company with their Sponsorship Licence Audit by providing expert immigration advice and guidance on how to comply with their duties and responsibilities as a licensed sponsor. They can also assist with preparing for a Home Office visit, reviewing the HR systems, policies, procedures, and management of sponsored workers, and resolving any issues that may arise during the audit process.

Contact us

Are Home Office visits announced? 

The Home Office may check sponsors at random. These visits can be announced or unannounced. 

What can be an outcome of a Compliance Audit?

If the compliance officers discover a problem before deciding on the sponsor licence application, the application may be refused. 

Alternatively, If the compliance officers find discrepancies with the compliance of the licence during an audit, actions will be taken against the licensed business. This could lead to their licence being revoked, suspended, or downgraded, with repercussions for sponsored employees. 

What will the Home Office Review during the Audit?

The Home Office’s responsibility is to make sure that the Business granted a Sponsorship Licence remains compliant as a Sponsor.

They will also check the following during an Audit:

– The sponsor’s HR systems and processes
– The sponsor’s company policies and procedures
– The sponsor’s compliance with the Immigration Rules
– The sponsor’s management of sponsored workers

What should I do to prepare for a Sponsorship Licence Audit?

Here are some tips for ensuring compliance with your Sponsorship Licence:
– Keep accurate records of all sponsored workers, including their visa status, payslips, and employment contracts.
– Have clear and concise policies and procedures in place for all aspects of sponsoring workers, such as recruitment, onboarding, and termination of employment.
– Train all staff who are involved in the sponsorship process on the requirements of the licence and the Immigration Rules.
– Respond promptly to any requests for information from the Home Office.

How can Morgan Smith Immigration Help?

Book an Assessment

Book an Assessment

Call Now
Call Now
Scroll to Top