In 2025 over 3,000 UK sponsor licences were revoked. In 2026, the same pace continues. A perfectly filed folder is useless if your employee describes their job duties differently than the SOC code you assigned. This is why thousands of businesses are seeing their sponsor licence revoked despite having “compliant” folders. It’s the disparity between your internal operations and the declarations you’re making in your SMS where most red flags occur on audits. Today’s compliance is less about maintaining a stack of HR files and more about building a solid structure. If your HR system doesn’t mirror your everyday operations then you are non-compliant.
Why paperwork isn’t enough
Paperwork is only the beginning of a Home Office compliance visit. Officers now prioritise interviewing sponsored workers to see if their day-to-day duties matches the “genuine vacancy” description submitted in the Certificate of Sponsorship (CoS).
FAQ: Can I fail an audit even if my personnel files are complete?
Yes. The Home Office often relies on employee interviews to verify job duties, and if their answers contradict your what is on the CoS, your perfectly filed HR files will be useless.
The paperwork blueprint: Appendix D
To remain compliant, you must treat Appendix D as a non-negotiable legal requirement. Every sponsored worker needs a dedicated HR file containing:
- Identity: passport copies (including entry stamps) and BRP/eVisa status.
- Contractual terms: signed employment contracts matching the job description, hours, and salary submitted in the CoS.
- Recruitment: evidence of the recruitment process, including job adverts and interview shortlists.
- Qualifications: proof of professional registrations required for the role.
- Absence logs: detailed records of all leave. Any unauthorised absence of 10 consecutive working days must be reported via the SMS.
- Payroll: payslips and bank transfer records confirming salary aligns with the CoS.
FAQ: How long must I keep these records after a worker leaves?
You must retain these files for one year after the sponsorship ends, or until a compliance officer has reviewed them, whichever is sooner.
Right to Work (RTW) checks
RTW checks are the most common trigger for licence revocation. Failure here is proof of systemic failure. To ensure you RTW is compliant you must:
- Check: use the Home Office online checking service for eVisa holders. For British/Irish citizens, use a certified Digital Verification Service (DVS) or manual checks (List A/B documents).
- Verify: check the individual’s identity against the document in their presence.
- Record: retain a clear, legible copy of the result, noting the exact date of the check.
- Follow-up: for List B documents (time-limited permission), diarise a repeat check before the expiry date.
In most cases, you should complete a RTW check before the worker starts working for you and have a system in place to automatically notify you to conduct a check before their permission expires.
In addition we also recommend doing an annual check, a check 30 days before expiry, 7 days before expiry and on the day of expiry.
FAQ: What is the consequence of failing an RTW check?
Beyond civil penalties of up to £60,000 per worker, the Home Office views RTW failures as evidence of poor internal controls, which is a primary justification for revoking your sponsor licence.
The “non-genuine” allegation
The Home Office is increasingly targeting roles that appear to exist solely to facilitate a visa. If you cannot produce task logs that demonstrate the worker is performing the specific skilled duties for their SOC code, your licence is at immediate risk.
FAQ: What is the most effective way to prove a role is genuine?
Maintain contemporaneous task logs that map daily activities directly to the specific duties and responsibilities outlined in the original job description.
Automating accountability
Manual tracking is prone to human error, which the Home Office no longer excuses. Moving toward a bespoke or automated HR system ensures that reporting duties and document renewals are triggered systemically.
FAQ: Can software prevent a sponsor licence revocation?
Yes, by automating mandatory reporting deadlines and maintaining a centralised, audit-ready repository of Appendix D documents, you eliminate the risk of human-error-based non-compliance.
When HMRC records blindsides you
With increased data sharing, salary underpayments are now detected almost instantly. From 2026, salary compliance must be met in each pay period.
FAQ: Does the Home Office check payroll data against my licence?
Yes, the Home Office now has direct access to HMRC data to verify that the salary paid to a worker matches the requirements declared on their CoS.
Ready to audit your compliance?
Don’t wait for a surprise Home Office audit. We specialise in mock audits that simulate the Home Office’s compliance visits. Book a mock audit by calling us on +44 203 617 1111 or email hello@visapositive.com to ensure your business isn’t at risk of having it’s sponsor licence revoked.
Disclaimer: This article is for informational purposes and does not constitute legal advice. If you have received a suspension or revocation notice, contact a specialist immediately.
