Employer guide
Employer guide
Suspension and revocation rarely arrive out of nowhere. They arrive at sponsors who followed the rules in substance but could not prove it on the day. The organising principle of modern sponsor compliance is uncomfortable and simple: the evidence is the compliance.
UKVI can ask a sponsor to produce specified documents for any sponsored worker and expects them within five working days. During an unannounced visit, the practical expectation is the same day. A duty you performed but cannot evidence is treated as a duty you did not perform: the right to work check without a proper record, the report submitted on time with no confirmation retained, the salary that was paid correctly but cannot be shown per pay period.
The test worth running on your own organisation: if a compliance officer walked in this morning and asked for the complete file on any sponsored worker you employ, could you hand it over within hours? If the honest answer is no, the gap between you and the sponsors on the suspension page is luck, not compliance.
Reporting. Most worker events, from a resignation to a change of duties to a salary reduction, must be reported through the sponsorship management system within 10 working days of the sponsor becoming aware. Late by a day is late. Keep the SMS confirmation for every report, plus a note of when the event happened and when you learned of it.
Records. Appendix D prescribes what each worker's file must hold, from the right to work check output to the certificate of sponsorship details to, since March 2026, the signed acknowledgement of the employment rights information pack. Retention runs for the whole sponsorship plus a year.
Right to work. Workers with digital status must be checked online via a share code, and the full output retained. A manual check of the wrong document gives no statutory excuse against a civil penalty of up to £60,000 per illegal worker.
Salary. Since July 2026, both the general threshold and the going rate must be met within each pay period, not merely on an annualised view. Guaranteed basic gross pay is what counts; overtime, bonuses and allowances do not.
The role itself. The job actually being done must match the certificate it was assigned under. Roles drift; certificates do not. An annual documented review of each sponsored role against its certificate, with a report where things have changed, closes the gap UKVI most likes to find.
Cost recoupment. Requiring workers to repay licence fees, certificate fees or the Immigration Skills Charge, through clawback clauses, loans or otherwise, carries a presumption of revocation. Audit the contracts now, not during a visit.
A consistent digital file for every sponsored worker, each document date stamped at the point of collection, with an index of what is held. Test retrieval quarterly and record the result: the test itself becomes evidence of a functioning system.
Review every duty area against a written checklist, rate it honestly, and close out the actions arising. Retained over time, these audits are the strongest possible answer to an allegation that the organisation does not take its duties seriously.
An authorising officer who actually engages, level 1 users who know the reporting triggers, a training log, and a written succession plan for key personnel. Licences have been suspended for the vacancy alone.
The free tool at sponsorlicence.online generates a starter UKVI action plan for your organisation. And if you are applying for a licence rather than defending one, SponsorServe is Lawyery's fixed fee, end to end sponsor licence application service. For a solicitor led mock audit of an existing licence, book a consultation below.
Lawyery runs mock audits against the current sponsor guidance and leaves you with the evidence trail UKVI expects to see, before UKVI asks to see it.
Book a compliance review