A sponsor licence audit should answer one simple question:
If the Home Office examined the business today, would the sponsorship records match what is actually happening?
That sounds straightforward.
In practice, sponsor compliance can drift.
A worker was sponsored two years ago and has since been promoted. Someone moved office. Payroll changed an allowance. A Level 1 User left the business. An employee’s home address was updated in one HR system but not another. The organisation moved premises and assumed somebody else had reported it.
None of those events necessarily involves serious misconduct.
Taken together, however, they can create a sponsor licence that no longer reflects the organisation it is supposed to describe.
That is why periodic sponsor licence audits are useful.
The purpose is not to produce another policy document.
It is to compare the Home Office record, the employee record and the reality of the employment, identify differences, and decide what needs to be corrected.
The Home Office can conduct compliance checks before or after a licence is granted, on an announced or unannounced basis.
A sensible sponsor should therefore know what UKVI would find before UKVI comes looking.
What is a sponsor licence audit?
There is no single Home Office form called a sponsor licence audit.
An internal sponsor compliance audit is a review carried out by the business, or on its behalf, to test whether it is meeting its sponsorship duties.
That usually involves reviewing three things at the same time:
The licence itself.
Does the Sponsorship Management System contain accurate information about the organisation and the people managing it?
The sponsored workers.
Does each worker’s Certificate of Sponsorship still correspond with their actual job, salary, hours and work location?
The systems behind the licence.
Can the business identify immigration expiry dates, absences, employment changes and other events that may need to be reported?
A useful audit does not stop when the correct document exists.
It asks whether the document is accurate.
Why audit a sponsor licence when there is no Home Office visit scheduled?
Because waiting for a compliance visit is a poor way to discover a compliance problem.
UKVI can carry out announced or unannounced checks at any point while the organisation is licensed.
The business may receive notice in advance.
It may not.
A compliance check may also arise at an inconvenient moment, perhaps during a new sponsor application, following intelligence received by the Home Office or after particular sponsorship activity attracts closer scrutiny.
A business that audits itself periodically has an opportunity to identify mistakes while it still controls the timetable.
That matters.
A worker’s old residential address can be updated.
An outdated Level 1 User can be removed.
A missed report may need consideration.
A payroll discrepancy can be investigated.
A changing job can be reviewed before further changes are made.
Problems are generally easier to understand when the people who made the original decision still remember what happened.
Start with the sponsor licence, not the employees
Before opening individual worker files, look at the licence.
The Sponsorship Management System should describe the organisation that exists today.
Ask:
Is the legal name correct?
Is the organisation’s address correct?
Are all relevant branches or sites properly reflected?
Are the Authorising Officer and Key Contact still in post?
Are the Level 1 Users still employed, eligible and genuinely using the system?
Has the organisation changed ownership?
Has there been a merger, acquisition or restructure?
Has the nature of the business changed materially?
Have required regulatory registrations changed?
Has the business opened or closed significant locations?
This first stage often exposes issues that have nothing to do with an individual sponsored worker.
A company may have managed every Skilled Worker perfectly but still have an inaccurate licence because its own organisational changes were not reported.
Specified changes concerning the sponsor organisation will generally need to be reported within 20 working days.
That makes the corporate record an important part of any audit.
Audit the people managing the licence
Sponsor compliance depends heavily on Key Personnel.
The business should confirm that its Authorising Officer remains eligible and genuinely capable of carrying out the role.
It should also review everyone with SMS access.
This is particularly important in 2026 because the Home Office has changed the way SMS users are managed.
New Level 2 Users can no longer be appointed from 9 September 2026. Existing Level 2 Users need either to be converted to eligible Level 1 Users or deactivated by 8 March 2027.
Mandatory multi-factor authentication is also being introduced across SMS accounts.
At the same time, the Home Office has introduced a process for dealing with inactive SMS users.
An account is considered inactive where the user has not accessed it for 12 months or more. If the process ultimately leaves a sponsor with no active Level 1 User, the licence can be suspended and may subsequently be revoked if an eligible Level 1 User is not appointed within the required period.
A sponsor audit should therefore check more than the names displayed on the system.
Are those people still there?
Do their personal email addresses and mobile numbers work?
Are their details accurate for MFA?
When did they last access the SMS?
Does anyone have access who no longer needs it?
Is there enough continuity if the principal Level 1 User becomes unavailable?
The Home Office recommends that a Level 1 User accesses the account at least once a month.
That is a sensible minimum discipline.
“An SMS account should not become something the business logs into only when it needs a Certificate of Sponsorship. The licence is a live record. If the people managing it have changed, the business has changed address or a Home Office message has been sitting unread, that can become a compliance issue before anyone has looked at a worker file.”
Abdul Jabbar, Principal Immigration Adviser
Build an accurate list of every sponsored worker
The next stage is establishing the sponsored population.
Do not assume the HR system already gives you the answer.
Compare the SMS, immigration records and current payroll.
For each sponsored worker, identify:
their name,
immigration route,
Certificate of Sponsorship reference,
visa or permission expiry date,
job title,
occupation code,
salary,
contracted hours,
normal work location,
manager,
and current employment status.
Then ask whether anyone appears on one system but not another.
A person may still appear within historic sponsorship records after leaving the organisation.
Someone may have changed immigration category and no longer require sponsorship.
A sponsored worker may have transferred into another part of the business.
The audit needs a clean population before individual files can sensibly be reviewed.
Compare every Certificate of Sponsorship with the actual job
This is one of the most valuable parts of the exercise.
Take the Certificate of Sponsorship.
Then look at what the employee actually does today.
Does the job title still broadly make sense?
Do the duties match?
Is the occupation code still appropriate?
Has the worker been promoted?
Have their responsibilities become materially different?
Has the business reorganised their department?
Would their manager describe the job in roughly the same terms as the CoS?
Roles naturally evolve.
That is not prohibited.
A Skilled Worker does not have to perform exactly the same task every day for five years.
But substantial changes can have immigration consequences.
Some changes can be reported.
Others may require a fresh Certificate of Sponsorship and new immigration application before the new job begins.
A sponsor audit should therefore look for role drift.
That is the gradual movement from the job originally sponsored into something meaningfully different.
It can happen without anyone deliberately changing the employee’s immigration position.
Speak to managers where the paperwork is not enough
Job descriptions can be misleading.
Sometimes they were written years ago.
Sometimes they describe the job the business intended to recruit rather than the job that developed later.
Where there is doubt, speak to the manager.
Ask what the employee spends their time doing.
Who do they report to?
Do they manage anyone?
What decisions do they make?
What projects are they responsible for?
A manager’s explanation should not be rehearsed to match the CoS.
It should help establish the reality.
If the reality no longer matches the sponsorship record, that is what the audit needs to identify.
Compare sponsored salary with payroll
This should be done worker by worker.
Start with the salary recorded on the Certificate of Sponsorship.
Then check:
the current employment contract,
recent payslips,
payroll records,
working hours,
and any salary change history.
If the figures differ, find out why.
There may be a perfectly lawful explanation.
The worker may have received a pay rise.
They may have taken statutory leave.
A temporary permitted absence may have affected pay.
Their contracted hours may have changed.
Or there may be a compliance problem.
Salary reductions from the level stated on the CoS are generally reportable, and the sponsor must also ensure that the worker continues to satisfy the salary rules applicable to their immigration route.
Do not assume that because payroll processed a change, immigration permitted it.
The Home Office can compare sponsor records with HMRC information.
A sponsor audit should do something similar internally before any discrepancy becomes an external question.
Check hours as well as annual salary
An annual salary figure can conceal an issue.
Suppose two employees are both paid £45,000.
One works 37.5 hours per week.
The other has moved to a significantly longer working week.
Depending on the immigration route and salary calculation involved, those arrangements may not be equivalent.
Likewise, someone reducing from full-time to part-time hours can change both salary and the way the relevant immigration requirements apply.
The audit should therefore record contracted hours, not just annual pay.
Salary and hours need to be read together.
Review work locations and remote-working arrangements
Where does each sponsored worker actually work?
Compare that answer with the Certificate of Sponsorship and any subsequent SMS reports.
A change in normal work location can be reportable.
That includes moves to another branch or a new regular client site.
Permanent or substantially full-time home working also needs to be reported.
Ordinary hybrid working is different.
The Home Office does not require a report simply because a worker moves into a hybrid pattern, provided the main office position remains appropriately recorded. The sponsor should still maintain suitable evidence of working patterns and report relevant changes to normal locations.
A sponsor audit should therefore distinguish:
occasional home working,
hybrid working,
permanent home working,
temporary client assignments,
and regular changes to the worker’s normal workplace.
The words “works remotely” are not precise enough.
Check whether absences are visible
Sponsor duties include monitoring attendance sufficiently to identify events that matter.
The audit should examine how absence information moves through the organisation.
Does the line manager record absence?
Does HR receive it?
Can the sponsor team see it?
What happens when somebody simply stops attending?
A sponsored worker who is absent without permission for more than 10 consecutive working days must be reported under the sponsor guidance.
There are also separate rules dealing with periods of unpaid or reduced-pay absence.
An organisation may have an excellent absence system for employment purposes but no process for escalating immigration-relevant absence to the person responsible for sponsorship.
That communication gap is exactly what an audit should reveal.
Review right to work checks properly
A sponsor licence does not replace right to work compliance.
Appendix D requires sponsors to retain evidence that appropriate right to work checks have been conducted for workers they sponsor.
Where the sponsor is also the employer, the check also matters for establishing the statutory excuse against a civil penalty for illegal working.
The audit should test more than whether a screenshot exists.
Was the correct type of check conducted?
Was it done before employment began?
Does the check relate to the correct person?
Does the immigration permission allow the work in question?
Was the evidence retained properly?
If the worker’s permission is time limited, is any follow-up requirement being monitored?
For eVisa holders, sponsors will commonly use the Home Office online right to work service.
Do not confuse an immigration decision email with a right to work check.
They are not the same thing.
Check dates of entry where relevant
For workers granted entry clearance from overseas, Appendix D can require the sponsor to keep appropriate evidence of the worker’s date of entry to the UK where that is relevant.
This has become more operationally important as the immigration system has moved away from physical entry-clearance vignettes.
The audit should therefore ask whether required entry evidence exists and where it is stored.
A sponsor should not wait until a compliance visit to discover that nobody retained the relevant information.
Audit contact details
This is simple, but often overlooked.
Sponsors must maintain a history of each sponsored worker’s contact information, including their UK residential address, personal email address and telephone number, and keep it up to date.
Take a sample of sponsored employees.
Ask them for their current address and contact number.
Compare it with the HR record.
If several do not match, there may be a process problem.
Perhaps employees tell payroll but not HR.
Perhaps changes are updated in an employee portal but not retained historically.
The audit should establish not only whether the current information is right, but whether the business has a reliable way of keeping it right.
Review recruitment evidence
Where recruitment took place, the sponsor should retain the records required by Appendix D.
There is no general resident labour market test for Skilled Worker sponsorship.
That does not make recruitment records irrelevant.
The Home Office may want to understand how a particular person came to be employed, particularly where there are questions about whether the vacancy was genuine.
For each relevant worker, ask:
How were they identified?
Was the role advertised?
If so, can the business evidence the recruitment activity?
Was the worker already employed under another immigration route?
Was the person introduced through an agency?
If the role was not advertised, can the business explain how the individual was recruited?
The objective is not to recreate a recruitment campaign that never happened.
It is to preserve an accurate record of what did happen.
Look at historic SMS reporting
This is where a good audit becomes more than a file check.
Take each sponsored worker’s employment history and compare it with SMS reporting.
Did they change work location?
Was that reported?
Was their salary reduced?
Did their job title or duties change?
Did they move into permanent remote work?
Was there a lengthy unauthorised absence?
Did someone resign?
When did sponsorship end?
Current sponsor guidance generally requires specified changes in worker circumstances to be reported within 10 working days.
The audit should therefore look not only at whether a report exists, but whether it was made on time.
A late report and no report are not identical problems.
Both deserve attention.
Audit organisational reporting separately
The same exercise should be carried out for the business itself.
Review the period since the last audit and ask what changed.
Did the organisation move office?
Did its legal name change?
Did the Authorising Officer leave?
Was there a merger or acquisition?
Did ownership change?
Was part of the business sold?
Were sponsored workers acquired under TUPE?
Did the organisation enter insolvency proceedings?
Did a regulatory registration change?
Certain organisational changes generally need to be reported within 20 working days.
Some events, particularly ownership changes and corporate transactions, can have consequences beyond a simple SMS update.
Do not treat this part of the audit as an administrative afterthought.
Look for differences between departments
This is often where the most useful findings appear.
Ask HR what salary the sponsored worker receives.
Ask payroll.
Check the contract.
Check the CoS.
If all four answers agree, good.
Now ask where the person works.
HR may say Leeds.
Their manager may say they moved permanently to Manchester six months ago.
The employee’s contract may still show Leeds.
The SMS may show Leeds.
That tells you something.
An audit should deliberately test information across departments because sponsor failures often occur between systems rather than within them.
“Most sponsor problems I see are not caused by someone deliberately ignoring the rules. They happen in the gaps. Payroll knew about the salary change, the manager knew about the new role, HR knew about the office move, but nobody recognised that the sponsorship record also needed attention. A useful audit looks for those gaps.”
Abdul Jabbar, Principal Immigration Adviser
Check the business against its own policies
If the business has written sponsor compliance procedures, test them.
Suppose the policy says HR reviews immigration expiry dates every month.
Ask for the last review.
If the policy says managers report unauthorised absence after five working days, ask a manager how that process works.
If the policy says salary changes involving sponsored employees require immigration approval, examine a recent salary change.
The purpose is not to catch staff out.
It is to distinguish the system described on paper from the system operating in practice.
A shorter policy that people actually use is considerably more valuable than an elaborate manual nobody follows.
Review document retention
Appendix D contains detailed record-keeping requirements.
Unless a specific rule says otherwise, documents relating to a sponsored worker generally need to be kept throughout the period of sponsorship and until the earlier of:
one year after sponsorship ends, or
the date on which a Home Office compliance officer has examined and approved the documents, where that happens sooner after sponsorship ends.
Other laws may require particular documents to be kept for longer.
The sponsor licence application documents themselves should also be retained for the period required by the sponsor guidance.
An audit should therefore consider whether records are being deleted too early.
This can happen unintentionally when ordinary HR retention policies are applied without considering sponsorship.
Do not audit only current sponsored workers
Former sponsored workers matter too.
Take a sample of people whose sponsorship ended during the relevant audit period.
Was the end of sponsorship reported?
Is the record retained?
Can the organisation still explain when and why their employment ended?
If the person switched into an immigration category that no longer required sponsorship, did the business update its understanding of their status?
Historic files can reveal whether compliance processes work consistently over time.
Audit pending sponsorship as well
Do not limit the review to people already employed.
Look at Certificates of Sponsorship that have been assigned but not yet used.
Are any approaching the end of their validity period?
Does the role still exist?
Has the intended start date changed?
Has the candidate’s situation changed?
Are there Defined CoS requests still pending or no longer needed?
This reduces the risk of old sponsorship activity being forgotten inside the SMS.
What should happen when the audit finds a problem?
First, establish the facts.
Do not immediately alter records until you understand what happened.
A missing document may exist elsewhere.
A salary discrepancy may have an explanation.
A missed SMS report may still need to be made.
A job change may be more significant than originally thought.
Then classify the issue.
Is it an administrative correction?
A late reporting problem?
A worker-specific immigration issue?
A wider system failure?
A potential breach serious enough to require careful advice before any Home Office communication?
The answer determines the response.
Do not manufacture historic compliance
If the audit discovers that a process was not followed, do not create a backdated record suggesting that it was.
There is a legitimate difference between reconstructing what happened and pretending something happened when it did not.
Suppose an employee moved address six months ago.
The business can retain evidence showing when it became aware of the issue, update the current record and consider any wider process improvement.
It should not create a document dated six months earlier claiming the HR record was updated at the time if that is untrue.
An honest compliance problem is one issue.
False evidence creates another.
Remediation should match the cause
Suppose the audit finds that salary changes involving sponsored workers are not being checked.
The response should not simply be:
“HR staff have been reminded of sponsor duties.”
Ask why the failure happened.
Was payroll unaware of which employees were sponsored?
Did managers bypass HR?
Was there no approval process for contractual changes?
Did the Level 1 User sit outside the HR structure?
Then fix that mechanism.
For example, the business might flag sponsored workers within payroll, require HR approval before specified salary changes and add an immigration review step for sponsored employees.
The remediation should make the same error less likely.
Should missed reports be submitted late?
Sometimes a missed report can and should be made through the SMS with an appropriate explanation.
But this should be assessed on the facts.
The nature of the event matters.
How late is the report?
Does the underlying change remain permissible?
Does it affect the worker’s immigration status?
Is there a wider compliance issue?
For significant historic failures, making a hurried report before understanding the consequences can create further difficulty.
The aim is to correct the position accurately, not simply to make the SMS look complete.
Carry out a mock compliance interview
Documents only tell part of the story.
A useful audit can include short interviews with people involved in sponsorship.
Ask the Authorising Officer:
Who carries out right to work checks?
How do you know when a sponsored worker’s salary changes?
Who reviews CoS assignments?
Ask the Level 1 User:
When do you report a change?
What happens if you are on leave?
When did you last access the SMS?
Ask a line manager:
What would you do if a sponsored worker stopped attending?
Ask a sponsored employee:
What is your job?
Where do you normally work?
Who is your manager?
These should not be theatrical mock interrogations.
They are simply a way of checking whether the business’s process is understood by the people who actually use it.
How often should a sponsor licence audit be carried out?
The Home Office does not prescribe one universal annual audit for every sponsor.
Frequency should reflect risk.
A small business sponsoring two stable employees may need a different review cycle from a company sponsoring hundreds of workers across several sites.
A useful approach is to combine periodic formal reviews with shorter recurring checks.
For example, the business might undertake a more detailed annual audit, while the Authorising Officer or sponsorship team reviews worker changes, SMS activity and upcoming immigration dates monthly.
A transaction, rapid recruitment programme, compliance concern or major organisational change may justify an additional review.
The key is not the calendar.
It is avoiding long periods during which nobody compares the sponsorship record with reality.
A practical sponsor licence audit framework
A complete audit should leave the business able to answer the following.
The licence
Are the organisation’s details accurate?
Are all relevant corporate changes reported?
Key Personnel
Is the Authorising Officer suitable?
Are SMS users current, active and secure?
Sponsored workers
Do we know exactly who is being sponsored?
Jobs
Do actual duties match the occupation code and CoS?
Salary and hours
Does payroll support what the Home Office has been told?
Work locations
Are regular working arrangements accurately recorded?
Absence
Can immigration-relevant absence be identified?
Right to work
Were correct checks carried out and retained?
Records
Are Appendix D documents complete and accessible?
Recruitment
Can the business evidence how sponsored workers were recruited?
Reporting
Were relevant worker and organisational changes reported on time?
Systems
Does information actually move between HR, payroll, managers and whoever controls the sponsor licence?
Remediation
Have identified weaknesses been genuinely corrected?
The answers matter more than the existence of the checklist.
Frequently asked questions
What is a sponsor licence audit?
A sponsor licence audit is a review of the organisation’s compliance with its Home Office sponsorship duties.
It commonly examines the sponsor licence, Key Personnel, sponsored workers, Certificates of Sponsorship, right to work checks, payroll, records, reporting history and internal HR systems.
Is a sponsor licence audit required by law?
There is no general Home Office rule requiring every sponsor to conduct an annual internal audit.
Sponsors are, however, required to comply continuously with their sponsorship duties, and UKVI can conduct compliance checks at any time.
Periodic internal audits are therefore a practical way of testing compliance.
What does the Home Office check during a sponsor compliance visit?
UKVI can examine areas including right to work processes, HR systems, sponsored worker records, jobs, salaries, work locations, reporting and whether the sponsor is meeting its wider duties.
Officers can also interview sponsored workers and other relevant staff.
How often should we review our sponsor licence?
There is no universal Home Office timetable.
The appropriate frequency depends on the size and complexity of the sponsor.
Monthly operational checks combined with a more detailed periodic audit may be appropriate for many organisations.
Should we audit every sponsored worker?
For a smaller sponsor, reviewing every sponsored worker is usually practical.
A very large sponsor may use a structured sampling method alongside targeted review of higher-risk cases, although material issues identified in the sample may justify widening the exercise.
What if an audit discovers a missed Home Office report?
The business should establish what happened, whether the event remains reportable and whether there are wider immigration consequences.
A late report may be appropriate in some circumstances, but significant historic issues should be considered carefully before action is taken.
Can the Home Office compare sponsor records with HMRC?
Yes.
Current sponsor guidance confirms that UKVI makes checks with HMRC concerning whether sponsored workers are being paid appropriately.
Can a sponsor licence be suspended because of poor record keeping?
Sponsor record keeping forms part of the sponsor’s duties.
Material or systematic compliance failures can lead to Home Office action, including downgrade, suspension or revocation depending on the circumstances.
Do we need an external adviser to conduct an audit?
Not necessarily.
An organisation with knowledgeable internal staff can carry out its own review.
External review can be useful where the business wants independent scrutiny, has identified potential breaches, is preparing for a Home Office visit or has a large or complicated sponsored workforce.
The value of an audit is finding what does not match
A sponsor licence audit should not be designed to prove that the business is compliant.
If that is the objective, people naturally start looking for evidence that confirms what they already believe.
The purpose is to find the differences.
The Certificate of Sponsorship says one thing.
Payroll says another.
The HR system shows an old address.
The manager describes a changed job.
The SMS still lists someone who left nine months ago.
The company moved office and nobody remembers reporting it.
Those are useful findings.
They give the organisation the opportunity to investigate, correct and improve the position before a Home Office officer asks the same questions.
A sponsor licence is not a static approval.
It is a continuing record of a business and the workers it sponsors.
Businesses change.
People change jobs.
Salaries change.
Offices move.
Corporate structures evolve.
Compliance depends on making sure the sponsorship record keeps up.
That is what a good sponsor licence audit is really for.
Would you like your sponsor licence reviewed?
If your business already holds a sponsor licence and you would like to review its sponsored workers, SMS records, payroll, reporting history or wider compliance arrangements, you can request a Free Case Assessment.
Tell us how many workers you sponsor, when the licence was granted and whether there are any particular issues you already want to examine.
We can then consider whether Knightsbridge Immigration can assist with a sponsor licence compliance review.
