
Home Office compliance checks can happen at any time, before or after a licence is granted, and are often unannounced. This guide explains what a compliance check involves, what happens when it goes badly, and the failures sponsors can prevent.
A sponsor licence is a promise that your organisation will meet its sponsor duties for as long as it holds the licence. A compliance check is how the Home Office tests that promise.
What a compliance check can involve
According to Part 3 of the sponsor guidance, compliance checks can happen before or after a licence is granted and may be announced or unannounced. The Home Office's guidance for its compliance staff says visits should normally be unannounced, and you must give officers access to premises under your control. Checks can include:
- Asking you for documents
- Verifying information you have provided
- Visiting you on site
- A digital compliance check, interviewing you by remote video
- Checks with other government departments, including regular checks with HMRC on how sponsored workers are paid
Checks may be routine, or triggered by reasonable suspicion or a poor compliance record. If sponsored workers are based at a client's premises, make sure that client knows a visit could happen there too.
What officers are looking for
In practice, a compliance check tests the four sponsor duties against real records:
- Record keeping: are the documents listed in Appendix D of the sponsor guidance held for each sponsored worker?
- Reporting: were reportable changes made in the Sponsor Management System, and on time?
- Monitoring: are right to work, immigration status, attendance and contact details actually monitored?
- Complying with the law: do each worker's role, pay and location match their Certificate of Sponsorship, and do pay records support it?
What happens if it goes badly
The guidance lists the actions the Home Office can take, including:
- Reducing your CoS allocation
- Downgrading your licence to a B-rating
- Suspending your licence
- Revoking your licence
- Cancelling sponsored workers' permission
- Reporting matters to the police
Revocation is the outcome every sponsor fears, because it affects every worker you sponsor. Surrendering a licence while under compliance action does not avoid the consequences: the guidance sets a period of 12 months, or 24 months in some cases, before a new application can be made.
The most common, and most preventable, failures
- Appendix D documents missing or scattered. The documents usually exist; producing them quickly is the problem.
- Right to work checks done the old way. Since BRPs stopped being issued in 2024, a manual check of an expired BRP is not acceptable proof of right to work.
- Changes not reported. A pay cut, a move to a new client site or a leaver that never reached the SMS user.
- Role drift. A worker sponsored for one job doing another. A role that no longer matches the occupation code or job description on the CoS is a mandatory ground for revocation.
- Unmonitored absence. More than 10 consecutive working days of unauthorised absence that nobody counted.
- Out-of-date SMS users. Leavers still listed, shared logins, or no Level 1 User at all. SMS users have had to use multi-factor authentication since September 2026.
- Stale contact details for sponsored workers.
A self-check you can run today
- Appendix D documents on file for every sponsored worker, retrievable quickly
- Right to work checks recorded with date, method and result, and follow-ups diarised
- Each worker's job, pay, hours and work locations still match their Certificate of Sponsorship
- Every reportable change made in the SMS on time, with the reference kept
- Attendance and absence records that show the worker is doing the sponsored job
- Current contact details for every sponsored worker
- Key personnel and SMS users up to date, with no shared logins
- Payroll records consistent with what each CoS says (the Home Office runs regular checks with HMRC)
Running your own mock audit
The best preparation is a regular internal audit run as if an officer had just arrived:
- Pick a sample of sponsored workers.
- Ask for each worker's full file, and time how long it takes to produce it.
- Compare their CoS with their current job title, hours, pay and the sites they actually worked at.
- Check every reportable event in the last year against your SMS reporting log.
- Record what you found and what you will fix, with owners and dates.
Keep the results. A dated history of self-audits and the improvements that followed shows a sponsor that takes its duties seriously.
What to have ready on the day
- A named person, and a deputy, who will meet the officer and can access every sponsored worker's file.
- A current list of sponsored workers, with their CoS numbers, roles, work locations and permission end dates.
- Your SMS reporting log for the last twelve months, with references.
- Right to work evidence for every sponsored worker, including follow-up checks.
- Recent attendance, absence and pay records for each sponsored worker.
- Contact details for key personnel, and for any client sites where sponsored workers are based.
After a compliance check
Write down what the officer asked for and anything you could not produce straight away. Fix gaps immediately, and keep evidence that you did. If the Home Office later raises concerns, a record showing that you found and corrected problems yourself is far better than one showing nothing changed.
How ProRota helps
Available in ProRota today: right to work records with follow-up dates, visa expiry monitoring, GPS attendance, leave and absence records, and contact history. For the reporting rules in detail, read sponsor licence reportable events; for 2026 changes, read sponsor licence duties in 2026.
Sponsor Licence Readiness runs the self-check continuously, keeps a compliance file for every sponsored worker, and produces a dated mock audit report whenever you need one.
Frequently asked questions
Are Home Office compliance visits unannounced?
They can be either. Part 3 of the sponsor guidance says checks may be announced or unannounced, and the Home Office's guidance for compliance staff says visits should normally be unannounced.
What can the Home Office do if a sponsor is not compliant?
Actions include reducing the CoS allocation, downgrading the licence to a B-rating, suspension, revocation, cancelling sponsored workers' permission and reporting matters to the police.
Does the Home Office check payroll?
Yes. The sponsor guidance says compliance checks include regular checks with HMRC on how sponsored workers are paid.
Sources
- GOV.UK: Workers and Temporary Workers, guidance for sponsors Part 3: sponsor duties and compliance (version 08/26)
- GOV.UK: PBS Worker and Temporary Worker sponsor compliance visits
- GOV.UK: Right to work checks, an employer's guide (1 October 2026)
This article is general information, not legal advice. Guidance changes; always check the current version of the sources above.


