What a Home Office sponsor compliance visit checks: the five HR areas
The Home Office publishes the guidance its own compliance officers follow. Read with Part 3 of the sponsor guidance, it tells a licensed sponsor exactly what a visit looks for. This is that list, in the officer’s order, with the paragraphs.
In short
- A check can come at any time, announced or not, on site or by video, and can include interviews with sponsored workers and with the people who recruited them.
- Documents the sponsor has but cannot show on the day must be produced within a reasonable time, in most cases 48 hours. “We don’t have them” can be marked Not Met.
- Five HR areas are rated; the sponsor scores Met overall only when all five are Met.
- Officers are told to assess systems that work, not paperwork: no written procedure is required, but “they will tell me” fails.
Section names follow the caseworker guidance v17.0; the first is labelled “Area 1: Monitoring Immigration Status” on the visit report.
When and how a check happens
C7.9. We may check sponsors at any time, including before we make a decision on your licence application or after your licence has been granted. If we conduct a compliance check which involves visiting or interviewing you, this can be on an announced or an unannounced basis.
C7.6 lists the forms a check can take: asking for documents or information, verifying what you provided, an on-site visit, a digital check by video interview, checks with other departments, and anything that comes to light from workers’ applications or from the public. C7.7 adds regular checks with HMRC on pay. C7.10: you must co-operate and allow full access to any premises under your control, and if sponsored workers do their job at a third party’s office, you must make sure the third party knows an unannounced visit may come there too.
What the officer may want to do (C7.15): verify the licence application, including photographs of the premises; verify what was said in support of any worker’s application; speak to any sponsored workers, including former ones; speak to employees involved in recruiting sponsored workers; inspect records and systems against Appendix D; check other workers for illegal working; and run criminal-record and civil-penalty checks on the people behind the organisation.
What the officer is assessing
You are primarily assessing: that a licensed sponsor is meeting their sponsorship obligations; that a prospective sponsor has the necessary systems and procedures in place to meet their sponsorship obligations; the accuracy of information given on the sponsor licence application; whether the sponsor is complying with their obligations to prevent illegal working.
On a post-licence visit the officer must be satisfied that “acceptable systems are actually being applied for any sponsored workers”, not just described.
Producing the documents
If the sponsor tells you they have the documents requested but they are not immediately available, you must allow reasonable timescales for the documents to be produced. … In most cases, 48 hours from the date of the visit, as the sponsor should have reasonable access to them.
Format is the sponsor’s choice: “They do not have to store documents in any particular format or in any particular way … but they must allow you to look at them if you ask.” The list itself is Appendix D.
The five HR areas
1. Immigration status monitoring
The officer checks the sponsor “has a system for monitoring a worker’s immigration status, so that it can stop sponsoring any who no longer has permission to work in the UK”, carries out right to work checks “on all who carry out work on their behalf, including checking e-visas where applicable”, and keeps copies of passports (including pages with leave stamps), immigration status documents showing the period of permission, and biometric residence permits where applicable. A sponsor without those copies and checks “automatically fail[s] the record keeping and maintaining documents section of the visit report”.
On expiry dates the guidance is specific about what passes and what does not. An Outlook calendar, a diary, a spreadsheet, a small HR file or copies of the visas all count. What fails:
You must mark the sponsor as ‘Not Met’ in ‘Area 1: Monitoring Immigration Status’ on the visit report if they answer: ‘because they will tell me’; ‘I don’t know’; ‘I didn’t know I had to know’; any similar answer.
And what must not be marked down: no alert 1, 2 or 3 months ahead; no written procedure; electronic only; paper only; no workers to monitor. A report that marks a sponsor down for those reasons “will be rejected by the suspensions or re-rates teams”.
2. Worker contact details
The sponsor must keep a history of each sponsored worker’s UK address, telephone numbers and email, with a system to keep them up to date, and be able to produce both the current details and the history. The officer cannot dictate the system, insist on paper and electronic copies, or require a back-up, and cannot penalise a sponsor with no history where nothing has changed. But “consider any differences in contact details between those the sponsor provided and those any worker provided when interviewed. If you find any differences, this indicates that the sponsor may not be fulfilling its duties”.
3. Record keeping and recruitment practices
A system for keeping the Appendix D documents for each worker, including professional accreditations and registrations; evidence that a CoS “was assigned within 6 months of the first advert for the vacancy being placed, if applicable to the route”; a copy of the National Insurance number; payslips or other evidence of pay; documents showing how the sponsor confirmed the worker can do the job; and details of all applicants shortlisted for interview, where applicable. The guidance also says an officer must not mark a sponsor Not Met for not having issued an employment contract.
4. Worker tracking and monitoring
A system for monitoring attendance, and the ability to report within 10 working days a worker who does not start within 28 days of the recorded start date, who has 10 consecutive days of unauthorised absence (the clock starts after the tenth day), who is dismissed or otherwise stops being sponsored, or who takes more than 4 weeks’ unpaid leave without an exception; and that Key Personnel are still employed and any change has been reported through the SMS. These are the same events as Part 3 C1.15 and C1.19.
5. General sponsor duties
Route and sector guidelines followed; no sponsored worker paid in cash; the appropriate rate in the relevant code of practice paid where required; SMS users not sharing passwords; CoS assigned in line with the guidance, with true information; changes to the organisation’s name, address, structure, branches and sites reported through the SMS; mergers, takeovers and sales reported in time (Part 3 C2 gives 20 working days); TUPE effects reported; Key Personnel permanently based in the UK; and no illegal workers.
The rating
Where sponsors have met the requirements of all 5 of the HR compliance areas, their overall HR score will be ‘Met’. They cannot score ‘Met’ overall if you have given them a ‘Not Met’ for any of the 5 areas.
The consequences sit in Part 3: a civil penalty of up to £60,000 per illegal worker where the right to work scheme is breached, revocation likely to follow a penalty, and the revocation grounds in Annexes C1 to C3. The guidance also tells officers what they must not do at an action plan’s first contact: “tell the sponsor what type of human resource (HR) procedures to put in place”. The system is yours to design; it has to work.
A checklist you can run this week
| Area | Ask yourself | Where it comes from |
|---|---|---|
| 1 | For each sponsored worker, can I say today when their permission expires, and show the passport and status copies? | Status monitoring; Monitoring expiry dates |
| 1 | Has every worker, sponsored or not, had a right to work check before starting, with a follow-up where permission is time-limited? | Part 3 C7.27 to C7.29; Appendix D 1.1 |
| 2 | Do I hold each worker’s current address, phone and email, with the history of changes? | Contact details; Appendix D 5(b) |
| 3 | Is the Appendix D file complete per worker: NI number, payslips, contract, qualifications, the advert and shortlist? | Record keeping; Appendix D 2 to 5 |
| 3 | Could I produce any of it within 48 hours? | Timescales for producing documents |
| 4 | Do I know on the day when a worker fails to start within 28 days, reaches 10 days’ unauthorised absence, or goes unpaid for 4 weeks, and can I report within 10 working days? | Worker tracking; Part 3 C1.15, C1.19 |
| 4 | Are my Authorising Officer, Key Contact and Level 1 User still in post, with any change reported? | Worker tracking |
| 5 | Is every sponsored worker paid by transfer, at or above the CoS salary and the going rate, and is every organisation change reported within 20 working days? | General duties; Part 3 C1.13, C2 |
How SponsorGuard fits
Area 1 is the staff and checks register: expiry dates, right to work with ID capture and follow-up dates. Area 2 is the contact history on each worker. Area 3 is the sponsor file by worker, and for law firms the Appendix D evidence pack. Area 4 is the reporting diary that counts the 10 and 20 working days and emails before they run out. Area 5 is the pay-run check against the CoS and the going rate, and the Key Personnel register. You make the reports on the SMS; SponsorGuard keeps the record.
Questions people ask
Can the Home Office visit a sponsor without notice?
Yes. Part 3 C7.9: “We may check sponsors at any time, including before we make a decision on your licence application or after your licence has been granted. If we conduct a compliance check which involves visiting or interviewing you, this can be on an announced or an unannounced basis.” Checks can also be digital, by video interview, or by asking for documents (C7.6).
How quickly must a sponsor produce documents at a compliance visit?
The caseworker guidance says the Appendix D documents must be made available but the guidance does not say at the time of the visit; if the sponsor has them but they are not immediately available, the officer must allow a reasonable time, “in most cases, 48 hours from the date of the visit”. A sponsor that says it does not have the documents may be marked ‘not met’.
What are the five HR compliance areas in a sponsor visit?
The caseworker guidance works through immigration status monitoring, maintaining worker contact details, record keeping and recruitment practices, worker tracking and monitoring, and general sponsor duties, then gives an overall HR score: Met only when all five areas are Met.
Does a sponsor need a written procedure for monitoring visa expiry dates?
No. The caseworker guidance tells officers they must not mark a sponsor Not Met because it has no written procedure, no 1-, 2- or 3-month alert, or only an electronic or only a paper record. What fails is an answer like “because they will tell me” or “I didn’t know I had to know”. The sponsor must be able to show an effective way of knowing when each worker’s permission expires.
What is the penalty for employing an illegal worker as a sponsor?
Part 3 C7.30: a civil penalty of up to £60,000 for each illegal worker where the statutory right to work scheme is breached; a civil penalty is likely to lead to the licence being revoked, with no new licence for at least 12 months after it is paid in full; and possible prosecution for knowingly employing an illegal worker (up to 2 years’ imprisonment and an unlimited fine).
Sources
- Worker and Temporary Worker sponsor compliance visits: caseworker guidanceVersion 17.0, published 19 March 2026 · GOV.UK
- Workers and Temporary Workers: guidance for sponsors, Part 3: sponsor duties and complianceVersion 08/26, valid from 3 August 2026 · GOV.UK
- Workers and Temporary Workers: guidance for sponsors, Appendix D: keeping records for sponsorshipVersion 08/26, valid from 3 August 2026 · GOV.UK
- Right to work checks: an employer's guide (GOV.UK)As published on GOV.UK; retention wording quoted · GOV.UK
SponsorGuard provides compliance software and record-keeping tools. It is not a law firm or an immigration adviser and does not give legal or immigration advice, which are regulated activities (Immigration and Asylum Act 1999, section 84). This page describes what the published Home Office guidance and the Immigration Rules say, with the paragraph for each point, so you can read the source yourself. Guidance versions and figures are those in force on the date shown; the Home Office changes them, so check the current version before you rely on any of it.
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Staff and checks register, right to work with ID capture, pay-run salary check, the 10 and 20 working-day reporting diary, Key Personnel and SMS users, five sponsor policies. £99 a month + VAT, 30 days free, no card.
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