A technology company in Reading sponsored twelve overseas workers on Skilled Worker visas over the course of eighteen months. The hiring was straightforward — talented developers, properly assigned Certificates of Sponsorship, salaries well above the threshold. The company was growing and the sponsored workers were integral to its delivery capability.
Then the Home Office compliance team arrived for an unannounced visit. Within an afternoon, they had identified four failures: two sponsored workers had changed roles internally without new Certificates of Sponsorship being assigned, one worker had been absent for more than ten consecutive working days without the absence being reported, and the company could not locate the contact details file for a fourth worker who had moved house six months earlier.
The company received a B-rating. It had 28 days to demonstrate an action plan to rectify the failures. If it failed to satisfy the Home Office, its licence would be revoked — and all twelve sponsored workers would lose their permission to work.
This is not an unusual outcome. The obligations that come with holding a sponsor licence are detailed, specific, and unforgiving. And the 3,100 businesses that lost their licences in 2024-25 demonstrate that the Home Office is enforcing them with increasing rigour.
What you sign up for when you become a sponsor
Obtaining a sponsor licence is the beginning, not the end, of the compliance obligation. The Sponsor Guidance, published by the Home Office, runs to several hundred pages across three parts. It describes in granular detail what is expected of sponsors.
The obligations fall into five broad categories, each with specific requirements that must be maintained for the entire duration of the sponsorship.
1. Assigning Certificates of Sponsorship correctly
A Certificate of Sponsorship (CoS) is not a physical certificate. It is a virtual document assigned through the Sponsorship Management System (SMS), containing details of the job, the salary, the worker, and the conditions of the sponsorship.
The genuine vacancy requirement. Every CoS must relate to a genuine vacancy — a real job that exists, is being recruited for in good faith, and meets the skill level and salary requirements for the Skilled Worker route. The Home Office can and does question whether a vacancy is genuine, particularly where multiple CoS are assigned for similar roles in quick succession.
Salary thresholds. The role must meet the minimum salary threshold for the Skilled Worker route. As of 2025, the general threshold is £38,700 per annum (or the "going rate" for the specific occupation code, whichever is higher), with lower thresholds available for certain roles including those on the Immigration Salary List.
Getting the salary threshold wrong — even marginally — can invalidate the CoS. If the going rate for an occupation is £40,000 and you assign a CoS at £39,500, the application will be refused and the CoS is wasted.
Role descriptions must be accurate and specific. The CoS must accurately describe the role the worker will perform. Vague descriptions ("IT support") or inflated descriptions (claiming a junior role meets a senior occupation code) can result in refusal of the visa application and, if the discrepancy is discovered after the visa is granted, compliance action against the sponsor.
2. Ongoing monitoring obligations
This is where most sponsors fail. The initial CoS assignment and visa application are relatively structured — they follow a clear process with defined steps. The ongoing obligations are less visible but equally enforceable.
Record keeping
You must maintain up-to-date records for every sponsored worker. The Home Office prescribes specific documents and information that must be retained:
- Contact details — current home address and personal phone number, updated whenever they change
- Copy of passport and visa — the biometric residence permit or visa vignette, including any replacement documents
- Evidence of right to work — a record of the right-to-work check conducted and any follow-up checks
- Attendance records — evidence that the worker is attending work as expected. This does not require a formal clocking-in system, but you must be able to demonstrate that you are monitoring attendance
- Job description and employment contract — reflecting the role described in the CoS
These records must be accessible at short notice. The Home Office compliance officer who arrives for an unannounced visit will ask to see them. If you need to request files from an off-site storage facility or search through email archives, you have a problem.
Tracking absences
You are required to report to the Home Office if a sponsored worker is absent from work without permission for ten consecutive working days. This is a specific, measurable obligation with a reporting deadline.
The ten-day rule catches many employers out. A sponsored worker takes an extended period of unauthorised leave, or stops attending without formal notification. The line manager is aware but assumes it is being handled by HR. HR is aware but does not realise it needs to be reported to the Home Office. By the time anyone checks, the reporting window has passed.
Unreported absences are one of the most common findings in compliance visits.
Salary monitoring
The salary paid to a sponsored worker must remain at or above the threshold specified in the CoS for the duration of the sponsorship. This seems straightforward, but it creates traps:
- Pay reviews that reduce salary — a company-wide pay restructuring that reduces the sponsored worker's salary below the threshold invalidates the sponsorship
- Reduced hours — moving a sponsored worker from full-time to part-time reduces their pro-rata salary, potentially below the threshold
- Bonus structures — only guaranteed salary counts toward the threshold. If the CoS salary includes a performance bonus that is not guaranteed, the base salary alone must meet the threshold
A salary that falls below the threshold — even temporarily — is a compliance failure that must be rectified immediately or reported.
3. Reporting duties
The reporting obligations are among the most detailed and most frequently breached requirements. You must report changes to the Home Office within 10 working days through the SMS for:
- Worker no longer working for you — termination, resignation, redundancy, or end of contract
- Worker absent without permission for 10+ consecutive working days
- Change of job role — a new CoS must be assigned if the change is significant (different occupation code, different core duties)
- Change of work location — if the worker moves to a different site
- Significant change in salary — including reductions below the threshold
- Change of your organisation's details — mergers, acquisitions, change of address, change of key personnel
The 10-working-day deadline is strict. Missing it, even by a day, is a recordable compliance failure. Multiple missed deadlines constitute a pattern that can lead directly to a B-rating or revocation.
4. Cooperating with compliance visits
The Home Office can visit your premises without notice. The visiting officer will expect:
- Access to the premises where sponsored workers are employed
- Access to compliance records for all sponsored workers — within the visit, not "we'll send them later"
- An interview with a relevant representative — someone who can answer questions about how the organisation manages its sponsorship obligations
- Evidence of the worker's presence — that the sponsored workers are actually working at the location specified in the CoS
Failure to cooperate with a compliance visit — including being unable to produce records, being evasive about worker locations, or having no knowledgeable representative available — is itself a compliance failure.
Common pitfalls that lead to B-ratings and revocations
The most frequent failures identified in compliance visits are not dramatic. They are operational:
Role changes without new CoS. An employee moves from a development role to a team lead position. The duties change, the occupation code changes, but nobody considers whether a new CoS is required. This is one of the most common single-point failures.
Salary falling below threshold after organisational changes. A pay restructure, a move to part-time, or a change in bonus structure reduces the salary below the CoS threshold. The employer does not recognise this as a sponsorship issue.
Not reporting leavers promptly. A sponsored worker leaves. The offboarding process updates payroll, revokes system access, and collects equipment. Nobody reports the departure to the Home Office via the SMS within 10 working days.
Contact details not maintained. A sponsored worker moves house. They tell their line manager but the change is not recorded in the compliance file. When the Home Office asks for the worker's current address, the file shows an address that is two years out of date.
Multiple sponsored workers at a site that cannot be verified. The CoS states the worker is based at the London office. The worker has been working remotely from Manchester for six months. The compliance visit is at the London office. The worker is not there. Questions follow.
Building a compliance infrastructure that works
Sponsor licence compliance is not a periodic task. It is an ongoing operational obligation that runs for as long as you hold the licence and employ sponsored workers. The infrastructure to support it needs to match that reality.
Centralise your records digitally. Every sponsored worker should have a digital compliance file that is accessible from any location within minutes. Physical files in a cabinet at head office do not survive unannounced visits at satellite locations.
Automate deadline tracking. The 10-working-day reporting deadlines, visa expiry dates, CoS validity windows, and annual salary reviews all need to be tracked with automated alerts. Relying on individuals to remember is how deadlines are missed.
Integrate compliance into HR processes. Role changes, pay changes, site transfers, absences, and leavers all trigger sponsorship obligations. If your HR processes do not include a compliance checkpoint for sponsored workers at each of these points, the integration is insufficient.
Designate a compliance owner. Not "the HR team" but a named individual whose responsibilities explicitly include sponsor licence compliance and who has the authority to intervene when obligations are at risk of being breached.
Conduct internal compliance audits quarterly. Not the compliance theatre kind — the kind that specifically tests whether you could survive an unannounced visit today. Pull a random sample of sponsored worker files. Check that records are complete and current. Test whether the 10-day reporting obligation is being met. If it is not, fix it before the Home Office discovers the gap.
Certifyd's Right to Work Portal provides the compliance infrastructure that sponsor licence holders need — centralised digital records, automated expiry and deadline tracking, audit-ready reporting, and real-time compliance status for every sponsored worker. When the Home Office arrives unannounced, your records are one click away.