Free sponsor licence audit test and checklist

A Home Office compliance officer can ask for your records, interview your sponsored workers, or arrive without notice. Here is what they check, the documents you must be able to hand over, and the 2026 rule changes that are catching sponsors out.

What happens when you click: you jump down this page to a 26-point checklist based on the Home Office’s sponsor guidance. Tick what’s true for your business and you’ll see your score straight away, with any gaps listed high-risk first. It’s 100% free: no account, no email, and nothing you tick is sent to us.

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  • Checked against sponsor guidance version 08/26
  • Last reviewed

The short answer

To be ready for a sponsor licence audit you need four things: a complete record file for every sponsored worker as listed in Appendix D; every reportable change made in the Sponsor Management System (SMS) on time, which is 10 working days for worker changes and 20 for organisation changes; working SMS access, with at least one active Level 1 User set up for the new multi-factor login; and sponsored workers actually doing the job, at the place and salary shown on their Certificate of Sponsorship.

On this page
  1. What changed in 2026
  2. How compliance checks work
  3. The worker file
  4. Reporting deadlines
  5. SMS access and key personnel
  6. Sponsor licence audit test
  7. On the day of a visit
  8. What happens afterwards
  9. Common reasons licences are lost
  10. How MadyHR helps
  11. Questions
  12. Ask Mady
  13. Sources

What changed in 2026

The Home Office updated its sponsor guidance several times this year. If your processes were last reviewed before August 2026, check them against these dates.

  1. New record-keeping rules (Appendix D, version 08/26)

    Visa vignettes stopped for everyone granted entry clearance from 1 July 2026, which changes the evidence you keep for a worker’s date of entry. Biometric residence permits are no longer issued or valid. Appendix D

  2. Sponsor guidance Parts 1 and 3 updated to version 08/26

    Brings in the SMS security changes below, a new process for removing inactive SMS accounts, and an invitation for sponsors not using their licence to surrender it. Part 3, changes

  3. Multi-factor login for the SMS begins

    Every SMS user will need a one-time passcode sent by text or email. It is being switched on sponsor by sponsor and should cover everyone by November 2026. Part 1, L4.67

  4. No new Level 2 Users, and no agency staff as key personnel

    You can no longer add Level 2 Users, or appoint temps supplied by an employment business to any key personnel role. Part 1, L4.14 and L4.58

  5. Right to work checks widen

    The duty to check now also covers people on a worker’s contract, individual sub-contractors and online matching services, for engagements starting on or after this date. Part 3, C7.27

  6. New Home Office fee table takes effect, sponsor fees unchanged

    Worker sponsor licence £611 (small) or £1,682 (large), Skilled Worker Certificate of Sponsorship £525, sponsor action plan £1,579. Fees table Work out your own costs with our free sponsor licence cost calculator.

  7. Deadline for existing Level 2 Users

    Convert them to Level 1 Users if they are eligible, or deactivate them. After this date the Home Office will deactivate any that remain. Part 1, L4.59

How compliance checks work

A check can happen before your licence is granted or at any point after, and a visit or interview can be announced or unannounced. Part 3, C7.9

A compliance check can mean the Home Office asking for documents, verifying what you have told them, visiting any site where your sponsored workers work, interviewing you by video (a “digital compliance check”), or checking with other government departments. It also makes regular checks with HMRC to confirm you are paying sponsored workers correctly. Part 3, C7.6 and C7.7

What the officer may do

  • Verify what you said in your licence application, including taking photographs of your premises
  • Verify what you said in support of each worker’s visa application
  • Interview current and former sponsored workers
  • Interview staff involved in recruiting sponsored workers
  • Inspect your records and HR systems against Appendix D
  • Check your other, non-sponsored staff for illegal working
  • Run criminal record and civil penalty checks on owners, directors, key personnel and others involved in running the business
  • Visit client sites where your sponsored workers are based

Part 3, C7.14 and C7.15

You must give full access
Officers can access any premises under your control on demand. If workers are based at a client’s site, you must make sure the client co-operates too. C7.10
No verdict on the day
The officer won’t tell you how you did during the check. The decision arrives later, in writing. C7.18 and C7.23
Check their identity
Officers carry official Home Office identification. If you doubt it, call 0300 123 4699. C7.19

The worker file

Appendix D lists what you must keep for each sponsored worker. It can be on paper or electronic, but you must be able to produce it when asked. Failing to hand over documents on time is itself a breach. Part 3, C1.38

Right to workAppendix D, section 1

  • A right to work check made before work starts for everyone you employ (sponsored or not) and everyone you sponsor (employed by you or not).
  • For online checks, the GOV.UK service “Check a job applicant’s right to work”. The Home Office says not to use the “check someone’s immigration status” or right to rent services for this.
  • Follow-up checks before any time-limited permission runs out. Part 3, C7.29 Our free guide to right to work checks walks through each type.
  • Date of entry evidence if you sponsored the worker’s visa from overseas: a copy of the page with their UK entry stamp, or, if there is no stamp (for example they used eGates), a record of the entry date after seeing travel evidence such as a boarding pass.

RecruitmentAppendix D, section 2

  • A copy or screenshot of each advert, where it ran and for how long.
  • How many people applied and how many were shortlisted.
  • At least one record of how you picked the successful candidate, such as interview notes, standard questions, scoring or reasons for the decision.
  • If you didn’t advertise, be ready to explain how you found the worker and knew they were suitable.

PayAppendix D, section 3

  • Payslips showing name, National Insurance number, tax code, allowances and deductions.
  • Proof of every salary payment into the worker’s own named bank account. Totals labelled “wages for personnel” are not accepted.
  • A contract or written statement of particulars, with both parties’ names and signatures, start and end dates, the job, hours and pay.
  • The value of any allowances (for example, accommodation) if not shown on the contract or payslips.

SkillsAppendix D, section 4

  • A detailed job description covering duties, skills, qualifications and experience.
  • Copies of qualifications or references. If you waived a qualification your advert called mandatory, written reasons why.
  • Any registration the job legally needs, such as General Medical Council registration for a doctor.

Everything elseAppendix D, section 5

  • Evidence of the worker’s National Insurance number.
  • A history of their contact details (UK address, personal email, phone), always kept up to date.
  • A record of absences.
  • A DBS check, where the role requires one.
  • Evidence you told the worker about their UK employment rights, for example in their contract or through training. Part 1, L2.7
  • Where relevant: an ATAS certificate, or parental consent for a worker under 18.

How long to keep it: for as long as you sponsor the worker, then until one year after sponsorship ends, or until a compliance officer has examined and approved the documents if that happens sooner. Keep the documents from your licence application for as long as you hold a licence. Right to work records are kept longer: the illegal working code requires copies for the whole of the person’s employment and for two years after it ends. Appendix D Code of practice

Reporting deadlines

Most reports go through the “Report migrant activity” function in the SMS. Late or missing reports are among the easiest breaches for an officer to find. Part 3, C1.13 to C1.16 See also our guide to sponsor reporting duties.

Changes to a sponsored workerReport within 10 working days unless shown otherwise
What happenedDeadline
Absent without your permission for more than 10 consecutive working days. Report even if you plan to keep sponsoring them, and say what contact attempts you’ve made.10 working daysafter the 10th day of absence
Absent unpaid, or on reduced pay, for more than 4 weeks in total in a calendar year (that is 20 working days for someone on a 5-day week). Statutory leave and sick leave don’t force you to stop sponsoring, but you should still report the absence. Part 2, S4.19 to S4.2710 working days
Salary reduced below the level on their Certificate of Sponsorship. Pay rises don’t need reporting, except for nurses and midwives completing registration.10 working days
Change of job title, role, core duties or a promotion within the same occupation code10 working days
Normal work location changes, including a new branch or client site, or permanent full-time home working. Hybrid working doesn’t need reporting.10 working days
Doesn’t start work within 28 days of the latest of: the start date on their certificate, the “valid from” date on their eVisa, or the date they were told their visa was granted. Report the new start date and the reason, or that you have stopped sponsoring them. Part 2, S3.15 to S3.1710 working daysafter the 28-day period ends
You stop sponsoring them for any reason, for example resignation, dismissal, redundancy, contract ending early or a required registration being withdrawn. Include their last address, phone number and personal email.10 working days
You know or suspect the worker has breached their visa conditionsAs soon as reasonably practicable
Changes to your organisationReport within 20 working days of becoming aware Part 3, C2.3
What happenedDeadline
Change of name, address, branches or organisation structure20 working days
Change of ownership, merger, takeover, or staff moving under TUPE20 working days
You stop trading, or enter administration, liquidation or a voluntary arrangement20 working days
Anyone covered by “you” in the guidance is convicted of a relevant offence20 working days
Your size (small or large sponsor) or charitable status changes20 working days
You lose a registration or accreditation you legally need to trade20 working days

Replacing your Authorising Officer or Key Contact has its own process: a Level 1 User requests it in the SMS. Do it promptly, because the Home Office will normally revoke a licence if you don’t tell it about a change of Authorising Officer. For any change request that produces a submission sheet, send the signed sheet and supporting documents within 5 working days or the request will be refused. Part 1, L4.38 Part 3, C2.19

SMS access and key personnel

You must have an eligible Authorising Officer and at least one Level 1 User throughout the life of your licence. If you don’t, the Home Office will revoke it. Part 1, L4.6

From 3 September 2026

Multi-factor login

Level 1 Users with a valid mobile get a passcode by text; everyone else gets it by email. Make sure each Level 1 User’s date of birth, mobile and email are correct, and that every email address is personal to that user. L4.68 to L4.70, L4.81 SMS manual 13

From 9 September 2026

Level 2 Users phased out

No new Level 2 Users. Convert existing ones to Level 1 (if eligible) or deactivate them by 8 March 2027. Temps from an employment business can’t be converted. L4.58 to L4.65

Rolling out

Inactive accounts

An account unused for 12 months or more counts as inactive. When contacted, Level 1 Users have 3 months to log in and check their details. If you end up with no active Level 1 User, your licence is suspended and you have 28 days to nominate one; if you don’t, it will normally be revoked. L4.72 to L4.79

Always

Oversight of Certificates of Sponsorship

The Home Office recommends your Authorising Officer checks the certificates assigned at least once a month. SMS users must never assign a certificate to themselves or a close relative or partner. L4.37 C1.42

On the day of a visit

You can’t refuse or delay access, so the best preparation is a plan everyone already knows.

  1. Check the officer’s identification

    Ask to see their Home Office ID. If in doubt, call 0300 123 4699. C7.19

  2. Tell your Authorising Officer and Level 1 User straight away

    They are responsible for your sponsorship and will know where records are kept.

  3. Give full access

    This includes every site where sponsored workers work. If a client’s premises are involved, contact the client so they co-operate. C7.10

  4. Hand over what is asked for, and list it

    Worker files, rotas, attendance and absence records, payslips and bank evidence. Keep a note of each item you provide.

  5. Let interviews run normally

    Officers may speak to sponsored workers and staff who recruited them. Answers should match the certificate and your records; never coach them. You have a duty to act honestly. L6.33

  6. Stay courteous

    The guidance says abusive or intimidating behaviour, harassment, pressure or bribery will not be tolerated. C7.11

  7. Write it up afterwards

    Record who attended, what was asked and what was handed over. You won’t get a verdict on the day. C7.18

Steps 2, 4 and 7 are good practice rather than Home Office requirements.

What happens afterwards

The Home Office writes to you with its decision. Where it finds breaches, action usually escalates in this order, although it can suspend or revoke without downgrading first. Part 3, C7.24 to C7.26

  1. A-rating kept

    No concerns, or none that need action. You carry on sponsoring as normal.

  2. Downgraded to a B-rating

    Used for relatively minor breaches you can put right. You get 20 working days to respond to the proposal first. C8.2 and C8.6

    • Pay the £1,579 action plan fee within 10 working days, or the licence is revoked. Fees
    • The action plan lasts 3 months, followed by another compliance check.
    • No certificates for new workers until your A-rating is restored, and no new branches or routes.
    • You can only be B-rated twice in any rolling 4-year period. C8.12 to C8.24
  3. Suspended

    For serious or systematic failings, or a threat to immigration control.

    • You can’t assign certificates, and you’re removed from the public register while suspended.
    • You have 20 working days to respond in writing. There is no oral hearing.
    • Outcome: reinstated as A or B-rated, or revoked. C9.1 to C9.16
  4. Revoked

    Revocation applies to every route on your licence, and there is no right of appeal.

    • You normally can’t reapply for at least 12 months, or 24 months if revoked before. Longer after some civil penalties or convictions.
    • Sponsored workers who weren’t involved usually have their permission cut to 60 days. C10.2 to C10.16

    Are you a sponsored worker whose employer lost its licence? Use our free sponsor licence register to see which UK employers hold a licence, and look for your next role on MadyJobSearch.com, which is 100% free.

Common reasons licences are lost

These come straight from the grounds the guidance sets out.

  • The worker is doing a different jobIf a sponsored worker’s role doesn’t match the occupation code or job description on their certificate, and it isn’t a permitted change, that is a mandatory ground for revocation. Part 3, C1.45
  • Passing sponsorship costs to the workerRecovering the licence fee, certificate fee, Immigration Skills Charge or related admin costs from a worker normally leads to revocation. Part 1, L6.17
  • Missing right to work checksA civil penalty of up to £45,000 per illegal worker for a first breach, or £60,000 for a repeat breach, with revocation likely and possible prosecution. Code of practice Part 3, C7.30
  • Paying wages in cashEvery salary payment must go into the worker’s own bank account (or a prepaid card you can evidence). Paying in cash is likely to lead to revocation. Part 2, S4.18
  • Unreported changesAbsences, pay cuts, location changes and leavers that never reached the SMS. Part 3, C1.15
  • Losing SMS accessNo eligible Authorising Officer, or no active Level 1 User. Part 1, L4.6 and L4.78
  • Breaking wider employment lawSponsors must follow UK law generally, including the National Minimum Wage, the Working Time Regulations, pension auto-enrolment and DBS requirements. Part 3, C1.53
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MadyHR.ai is affordable HR software for UK employers, with your sponsor licence duties built in. It keeps each worker’s records and evidence in one place, so a compliance visit means showing records, not hunting for them.

  • Right to Work evidenceEach worker’s check, expiry date and evidence file in one place, with follow-up checks scheduled
  • Reporting clockLog a change and MadyHR.ai counts the 10 working days you have to report it in the SMS
  • Reminders90, 60 and 30 days before a visa, passport, DBS or EUSS document expires
  • Needs attentionOverdue and expiring checks in one queue, ordered by urgency
  • Audit logEvery change to Right to Work status, salary or permissions, with who made it and when
  • Ask MadyAsk about compliance, leave, attendance or one person’s record in plain English

Plus employee records, documents, leave, attendance and rota, recruitment, an organisation chart and learning. Every module is on every plan.

MadyHR.ai doesn’t submit reports to the Home Office for you: your Level 1 User still reports through the SMS. It doesn’t run payroll, and it isn’t legal or immigration advice.

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Questions

What is a sponsor licence audit?

It’s a Home Office compliance check, often an unannounced visit, of whether a sponsor is meeting its duties under the sponsor guidance: keeping the right records, reporting changes on time, doing right to work checks and only sponsoring genuine vacancies. Part 3, C7 Read the Home Office sponsor guidance on GOV.UK.

Is this an official Home Office audit test?

No. It’s an independent, free self-check by MadyHR.ai based on published Home Office sponsor guidance. It isn’t a Home Office or UKVI tool, a good score doesn’t mean a compliance check will find nothing, and only the Home Office decides the outcome of a compliance visit.

Does the Home Office give notice before a compliance visit?

Not always. Checks that involve visiting or interviewing you can be announced or unannounced, and can take place before or after a licence is granted. Part 3, C7.9

Can a compliance check be done online?

Yes. Besides on-site visits, the Home Office can run a digital compliance check by video conference, and can ask for evidence by phone, video or letter. Part 3, C7.6 and C7.16

How long must I keep sponsor records?

For as long as you sponsor the worker, then until one year after sponsorship ends, or until a compliance officer has examined and approved them if sooner. Keep licence application documents for as long as you hold a licence. Appendix D

What does a B-rating cost?

The Home Office action plan fee is £1,579, unchanged in the fee table that takes effect on 8 October 2026. The plan lasts 3 months, and you can’t sponsor new workers until your A-rating is restored. Fees table Part 3, C8

Do I have to report a sponsored worker’s pay rise?

No. You must report a reduction below the salary on the certificate, but not increases, except for a pre-registration nurse or midwife who has completed registration. Part 3, C1.15

What changes for right to work checks on 1 October 2026?

The duty to check extends to people engaged under a worker’s contract, individual sub-contractors and online matching services, for engagements starting on or after 1 October 2026. As a sponsor, you must already check every worker you sponsor, whatever the working relationship. Part 3, C7.27 and C7.28 See also our guide to the October 2026 right to work changes.

Is MadyHR free?

Creating your account is free, takes about a minute and needs no card. You can set up your company and look around the whole product. To add employees, choose a plan: £50 a year (about £4.17 a month) or £240 paid once for 10 years (£2 a month). Both cover unlimited employees and every module. Create your free account.

Can I appeal if my licence is revoked?

No. There is no right of appeal, and you normally can’t apply again for at least 12 months, or 24 months if you’ve had a licence revoked more than once. Part 3, C10.3

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Sources

Every rule on this page comes from these official documents. Guidance changes often, so check the version number on GOV.UK before relying on it.

  1. Workers and Temporary Workers: guidance for sponsors, Part 3: Sponsor duties and complianceUK Visas and Immigration. Version 08/26, valid from 28 August 2026 (GOV.UK page updated 2 September 2026).
  2. Workers and Temporary Workers: guidance for sponsors, Part 1: Apply for a licenceUK Visas and Immigration. Version 08/26, valid from 28 August 2026 (GOV.UK page updated 3 September 2026).
  3. Workers and Temporary Workers: guidance for sponsors, Appendix D: record-keeping dutiesUK Visas and Immigration. Version 08/26, valid from 3 August 2026.
  4. Right to work checks: an employer’s guideHome Office. The live guide is dated 26 June 2025; a draft guide dated 11 September 2026 covers checks from 1 October 2026.
  5. Code of practice on preventing illegal working: right to work scheme for employersHome Office. In force from 13 February 2024; sets the £45,000 and £60,000 maximum penalties. A replacement code, published in draft on 30 June 2026, applies from 1 October 2026 with the same maximum penalties.
  6. Home Office immigration and nationality fees, 8 October 2026UK Visas and Immigration. Published 10 September 2026; section 11 covers sponsorship fees.
  7. SMS Manual 9: reporting worker activityUK Visas and Immigration.
  8. Worker and Temporary Worker sponsor compliance visits: caseworker guidanceHome Office guidance for compliance officers, last updated 25 March 2026.
  9. Register of licensed sponsors: workersHome Office. You can also search it with a map on the free MadyHR sponsor licence register.
  10. Workers and Temporary Workers: guidance for sponsors, Part 2: Sponsor a workerUK Visas and Immigration. Version 08/26, valid from 3 August 2026.
  11. Multi-factor authentication for UK visa sponsors: SMS manual 13UK Visas and Immigration. Published 28 August 2026, updated 7 September 2026.
This guide is general information, not legal advice. It reflects Home Office guidance in force on 29 September 2026. MadyHR.ai is HR software, not a law firm, and it doesn’t give legal or immigration advice. For advice on your own situation, speak to a solicitor or an adviser regulated by the Immigration Advice Authority.

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