Sponsor licence compliance checklist30 points to go over with your skilled workers

In the case of UK employers sponsoring Skilled Workers, compliance with the Home Office is not just a step you have to complete to obtain a Sponsor License. Rather, it is a continuous process you must maintain to ensure you can continue sponsoring Skilled Workers from outside of the country.

A single mistake in your Right to Work (RTW) process can lead to civil penalties, licence downgrades, suspension, or even a revocation of your Sponsor License.

With Home Office compliance visits becoming more frequent and increasingly detailed, HR teams must ensure that every Skilled Worker on their company's payroll has the correct immigration permission and that the appropriate evidence is on file.

To support internal audits, HR and compliance teams should run a structured internal review checklist. Below is a practical 30-point Sponsor Licence Compliance Audit Checklist, focused specifically on ensuring a Skilled Worker is eligible and correctly processed through a UK Right to Work check.

The 30-Point Skilled Worker Compliance Checklist for HR Teams

1. Ensure the worker’s identity matches all records

You must confirm that the employee’s name, date of birth, nationality, and photograph are consistent across all HR files, their passport, and in records of their immigration status.

2. Verify the individual is sponsored by your organisation

Check that the worker is linked to your Sponsor Licence and not mistakenly employed under another sponsor’s permission. This is an important step when hiring Skilled Workers already in the UK, who were previously working under another organisation’s sponsorship.

3. Confirm visa route

Make sure the Skilled Worker’s immigration category is correct and aligns with the sponsorship documentation.

4. Complete the RTW check

Skilled Workers generally require an online Right to Work Check using their share code. Manual checks are not sufficient unless permitted by Home Office rules.

5. Retain evidence of the online check

You must keep the PDF or screenshot of the online profile showing their permission to work. HR records must also be retained for up to two years after an employee leaves the company.

6. Record the date the RTW check was completed

The evidence must clearly show when the last RTW check was performed.

7. Ensure the RTW check was completed before employment started

Late RTW checks, sometimes conducted after the employee has already started working at an organisation, are among the most common Home Office findings during audits and raids.

8. Confirm permission allows the role offered

Review the immigration profile and confirm there are no restrictions that conflict with the new Skilled Worker's job role.

9. Confirm the visa is valid and has not expired

A simple step, but one that is often overlooked.

10. Check whether a follow-up RTW check is required

If the Skilled Worker's permission to work is time-limited, schedule follow-up checks before the period expires.

11. Confirm a valid CoS was assigned

Check that a Certificate of Sponsorship (CoS) exists and was properly issued.

12. Match CoS details against employment contract

The salary, job title, hours, job description and work location should match the CoS.

13. Ensure the CoS was used within the correct timeframe

Expired or misused CoS records can trigger Home Office checks.

14. Confirm the SOC code is correct

Incorrect Standard Occupational Classification (SOC) codes are a frequent compliance breach, according to the Home Office.

15. Confirm job duties match the SOC code

The Home Office expects job descriptions to reflect the actual duties performed. In the case of a Home Office raid, ensure that any Skilled Workers are familiar with and can quote their designated job descriptions.

16. Ensure salary meets Skilled Worker thresholds

Confirm that the salary being paid to the Skilled Worker meets the minimum requirement for the SOC code and visa rules.

17. Ensure working hours align with sponsorship terms

Part-time or overtime arrangements must not contradict the details of the issued CoS.

18. Ensure the contract is signed and dated

Unsigned contracts can appear as weak or incomplete employment evidence.

19. Confirm the job offer letter is retained

HR should offer documentation confirming the role, description, salary and start date.

20. Confirm the employee is paid through PAYE

Skilled Workers should normally appear on the PAYE payroll, with records available.

21. Keep payslips and payroll history on file

Auditors often request payslips to confirm salary compliance.

22. Confirm job title on payroll matches CoS

Mismatched job titles can raise red flags.

23. Retain proof of recruitment and role justification

Even though the Resident Labour Market Test is no longer applicable, role justification can still matter for credibility.

24. Maintain an up-to-date attendance record

Sponsors must demonstrate that they continuously monitor their employees' attendance.

25. Track unauthorised absences

Absence tracking is essential, especially when patterns of unexplained non-attendance emerge.

26. Report absence breaches via the Sponsor Management System (SMS)

If a worker is absent without permission for more than the allowed period, reporting the discrepancy through SMS is required.

27. Confirm the employee’s work location is correct

If the employee works at a different location than that stated on the CoS, it must be updated as soon as possible.

28. Confirm HR has reported all required changes

This includes salary changes, job title changes, work location updates, or early termination.

29. Check visa status aligns with current role conditions

Promotions, internal transfers, or restructuring may require updates to sponsorship.

30. Ensure the HR file is audit-ready and centrally accessible

Files should be organised, consistent, and immediately available for inspection.

Why does this checklist matter?

Sponsor licence compliance audits are not limited to immigration documents. The Home Office looks at whether your organisation has genuine HR systems, accurate record-keeping, and a consistent process for monitoring Sponsored Workers.

A sponsor licence compliance audit can be triggered by:

• a visa extension or settlement application,
• tip-offs or intelligence reports,
• inconsistencies in reporting,
• payroll mismatches,
• or random compliance visits.

Conclusion

For HR teams, a right-to-work check is not just an onboarding step. It is an ongoing compliance obligation that must be supported by accurate documentation and internal monitoring.

The best approach is to run quarterly internal audits using a structured checklist like the one above. This ensures your business remains protected, your sponsor licence remains secure, and your Skilled Worker hires remain legally employed.

If you are struggling to maintain RTW checklists or proper HR documentation, reach out to A2Z Immigration today for a free consultation and our SMS support services.