Key Takeaways
- The Home Office can conduct compliance visits to sponsor licence holders at any time, with or without advance notice.
- Visits assess whether the business genuinely needs the licence, has appropriate HR systems and is meeting its ongoing reporting and record-keeping duties.
- A failed compliance visit can result in the licence being suspended, downgraded to B-rated or revoked entirely.
- From 8 April 2026, sponsors must ensure every sponsored worker is paid the required salary in each individual pay period, not just as an annual average.
Holding a sponsor licence is not a one-off exercise. The Home Office monitors licence holders on an ongoing basis, and compliance visits, announced or unannounced, are part of how it does that. For many businesses, the prospect of a Home Office visit is stressful precisely because the consequences of failing one can be severe.
This article explains what happens during a sponsor licence compliance visit, what the Home Office looks for and how to make sure your business is ready. Our UK immigration solicitors at Osbourne Pinner offer a free 30-minute consultation and can advise on your compliance position.
Why the Home Office Conducts Compliance Visits
The sponsor licence system relies on employers taking responsibility for the workers they sponsor. The Home Office cannot individually monitor every sponsored worker in the country, so it audits licence holders to check that the system is working as it should. Compliance visits are one of the main tools it uses.
Visits can be triggered in a number of ways. Some happen as part of routine monitoring. Others are prompted by a specific concern: a report from a sponsored worker, a discrepancy in the Sponsor Management System, or intelligence gathered through HMRC or other government bodies. A visit can also occur as part of the pre-licence application process before a licence is granted.
Announced vs Unannounced Visits
The Home Office can visit with advance notice or without any warning at all. Announced visits are more common for pre-licence assessments, where the officer wants to see the business premises and meet the relevant personnel. Unannounced visits are more likely where the Home Office has a specific concern it wants to investigate before the business has a chance to prepare.
Whether the visit is announced or not, your obligation to cooperate is the same. Refusing entry to a compliance officer or failing to produce records on request is itself a breach of your sponsor duties and can lead to action against the licence.
What the Home Office Looks For
Compliance officers are assessing whether your business is a genuine organisation with a real need to sponsor workers, and whether you are meeting your duties as a licence holder. The main areas they examine are:
- HR records: Whether you are keeping up-to-date records for each sponsored worker, including passport copies, right to work evidence, contact details, work location and salary.
- Reporting obligations: Whether you have reported changes to the Home Office via the SMS within the required 10 working days, including changes to job role, salary or work location, and whether you reported any workers who did not start or who left the business.
- Salary compliance: Whether sponsored workers are actually being paid the salary stated on their Certificate of Sponsorship and meeting the applicable minimum salary threshold.
- Key personnel: Whether the Authorising Officer, Key Contact and Level 1 User are still in post and fulfilling their responsibilities.
- Business genuineness: Whether the business is operating as described in its licence application, with real premises, genuine commercial activity and actual roles for sponsored workers.
The April 2026 Salary Compliance Change
From 8 April 2026, salary compliance is assessed on a per-pay-period basis for all Certificates of Sponsorship issued on or after that date. Previously, an annual average was acceptable. Under the new rules, a sponsored worker’s gross pay in each individual pay period must meet the required salary threshold.
This change has a direct impact on compliance visits. Home Office officers examining payroll records will now be looking at whether each pay period individually meets the threshold, rather than whether the annual figure adds up. Businesses that use salary sacrifice arrangements, variable hours or irregular pay structures need to review their payroll carefully before any visit.
See also: What Happens When You Lose an A-Rating on Your Sponsor Licence?
What Happens After a Compliance Visit
Following a visit, the Home Office will produce a report. In most cases, no immediate action is taken and the licence continues on A-rated status. Where minor issues are identified, the officer may issue recommendations or a corrective action plan. Serious issues can result in the licence being suspended pending investigation or downgraded to a B-rated licence.
A B-rated licence means the business cannot issue new Certificates of Sponsorship. An action plan will set out the steps needed to restore A-rated status. If the Home Office concludes that the business has seriously breached its duties, the licence can be revoked entirely.
Revocation is the most serious outcome. A revoked licence cannot be reapplied for within 12 months, and any sponsored workers currently employed will face curtailment of their leave to remain, typically curtailed to 60 days, giving them a short window to find a new sponsor or leave the UK.
Related: Revoked Sponsor Licence: What to Do
How to Prepare for a Compliance Visit
The best preparation for a compliance visit is to run your HR and reporting systems as if a visit could happen at any time. Because it can. In practical terms, this means keeping records current for every sponsored worker, diarising the 10-working-day reporting windows for any changes, checking your payroll against the salary compliance requirements after the April 2026 changes, and ensuring your Authorising Officer is actively overseeing the licence.
If you receive notice of an announced visit, use the time to review your records for each sponsored worker, check that all required reporting has been done and ensure your key personnel are available on the day. Getting legal advice before a visit, particularly where you know there are gaps, gives you the best chance of resolving issues before they are put in front of an officer.
Speak to an Immigration Solicitor about Sponsor Licence Compliance
A compliance visit can happen without warning. Businesses that are not keeping records properly, reporting changes on time or meeting the per-pay-period salary rules introduced in April 2026 are at real risk of losing their licence. The cost of getting it wrong is significant, both for the business and for the sponsored workers employed.
At Osbourne Pinner, our sponsor licence compliance solicitors advise licence holders on their ongoing compliance duties, help them prepare for Home Office visits and represent them if the licence is suspended or revoked.
Please note that this article is for informational purposes only and does not constitute legal advice. We always recommend speaking to a qualified solicitor for advice tailored to your specific circumstances.
We offer a free 30-minute consultation to discuss your situation. You can speak with us via video call or visit our offices in Harrow, Canary Wharf, Piccadilly Circus or Manchester. To arrange your consultation, call 0203 983 5080, email [email protected] or complete the form below.
