Sponsor Licence Compliance: A Practical Guide for UK Small Employers
If you sponsor overseas staff, your licence depends less on the day you got it and more on the records you keep every week after. Here is what UKVI expects from a sponsor, where small shops, restaurants and care providers most often slip, and why the rota and clock-in records you already keep matter so much.
Why this matters more than ever
1,948
Skilled Worker sponsor licences revoked in the year to June 2025, more than double the 937 revoked in the year before, according to Home Office figures.
£60,000
The maximum civil penalty for each person employed without the right to work. Doing the correct Right to Work checks gives you a statutory excuse.
When a licence is revoked, the business can no longer sponsor anyone, and its sponsored workers' permission to stay is usually cut short. For a small business that can mean losing key staff at very short notice. A licence can also be suspended or downgraded while the Home Office looks into concerns.
The duties that never stop
Getting a licence is the start. These duties apply every week for as long as you sponsor anyone.
1. Keep the right records
The sponsor guidance (Appendix D) lists the documents you must keep for each sponsored worker: Right to Work evidence, contract and job details, payslips and pay records, attendance records, and up-to-date contact details. They need to be complete, current, and quick to produce.
2. Report changes within 10 working days
Through the Sponsor Management System you must report certain events within 10 working days, including a worker not starting work when expected, unauthorised absence of more than 10 consecutive working days, the end of their employment, and significant changes to their job, salary or place of work. Missed reports are one of the most common findings on compliance visits.
3. Track attendance, every shift
You need to know whether each sponsored worker is turning up. You can only spot 10 consecutive working days of unauthorised absence if attendance is recorded, and approved holiday and sickness are told apart from no-shows.
4. Re-check Right to Work before it expires
If someone's permission is time-limited, do a follow-up check before it runs out to keep your statutory excuse. Diary the date for every worker. Expiry dates are easy to lose track of.
5. Respect visa work limits
Student visa holders are usually limited to 20 hours a week during term time on a degree-level course, and less on some courses. Their exact limit is shown on their visa. Rostering a student over their limit, even by one shift, puts both them and you at risk.
6. Make sure the job matches the Certificate of Sponsorship
A sponsored worker should be doing the job, hours and pay described on their Certificate of Sponsorship. A worker regularly given fewer hours than certified, or different duties from the stated SOC occupation code, can be a sign that the role isn't genuine.
Be ready for a compliance visit
UKVI compliance officers can visit with notice or without. Expect them to ask for records on specific workers, to speak to the Authorising Officer and Key Contact, and sometimes to talk to the workers themselves. A good test: could you produce every Appendix D record for every sponsored worker within a couple of hours, today?
Quick self-check
- Do you know the Right to Work expiry date for every sponsored worker?
- Would you notice the 10th consecutive day of unauthorised absence, and report it within 10 working days?
- Are students kept within their term-time hours limit on every rota?
- Do rostered hours and pay match each Certificate of Sponsorship?
- Are contact details checked and updated regularly?
- Could you hand over each worker's full record set within a couple of hours?
If you answered "not sure" to any of these, that's where to start. Take the interactive check.
Why your rota is your best evidence
Most sponsor duties come down to one question: what was this person actually doing, and when? The answer is already in your rotas, clock-ins and approved time off. Spreadsheets kept separately from the rota drift out of date, and nobody notices until a compliance visit.
Keeping compliance in the same system that plans the shifts means attendance is recorded as people clock in, absence is told apart from approved leave, and hours can be compared against visa and Certificate of Sponsorship limits before the rota goes out.
Frequently Asked Questions
Who is responsible for compliance in my business?
Your Authorising Officer is ultimately responsible for how the licence is used. The Key Contact and Level 1 users carry out day-to-day tasks in the Sponsor Management System. All of them should know the reporting deadlines.
Do these rules apply if I only sponsor one person?
Yes. Sponsor duties are the same whether you sponsor one worker or fifty, and small businesses have fewer people to spread the work across.
Is a Right to Work check enough for sponsored staff?
It's essential but not enough on its own. Sponsors also have record-keeping, reporting and monitoring duties on top of the Right to Work rules that apply to every employer.
We're building sponsor compliance into MyShifts
Attendance tracking, 10-working-day reporting reminders, Right to Work expiry alerts and rota checks against visa and CoS limits, all from the rota you already run. Join early access and we'll set it up with you.
This guide is general information, not legal or immigration advice, and MyShifts is not affiliated with the Home Office or UK Visas and Immigration. Rules change, so always check the current gov.uk sponsor guidance, illegal working penalties and Right to Work checks, or speak to a qualified immigration adviser. Revocation figures: Home Office immigration statistics, year ending June 2025.