Home Office sponsor guidance updates: key changes for employers

09 July 2026 | posted in Immigration law

The Home Office has introduced several updates to its sponsor guidance in recent months. These changes affect sponsor licence holders and sponsored workers across a number of areas, including salary compliance, right to work checks and sponsor licence compliance. We have summarised the key developments below.

Eligible role term introduced

• On 6 March 2026, the guidance containing the Home Office’s Glossary of terms inserted a new definition of an “Eligible role”.
• The new definition reinforces the requirement for sponsors to ensure the role described on the Certificate of Sponsorship (CoS) accurately reflects the worker’s duties, responsibilities, working hours and other employment details. The new definition expressly focuses on the role needing to exist at the time the CoS is assigned to a worker (or that an employer reasonably anticipates it will exist by the time the CoS is assigned) and also on it meeting the salary and skill levels of the route being sponsored under.

Sponsors should ensure job descriptions, working arrangements and sponsorship records accurately reflect the role being undertaken.

Salary compliance per pay period

These changes increase the importance of monitoring salary compliance throughout employment, rather than relying solely on annual salary calculations.

• For Skilled Worker permission holders, from 8 April 2026 sponsors must now ensure the required salary is paid to such workers in pay periods on at least a monthly basis, unless the contract specifies a different frequency.
• In any event, such salary paid in each pay period must equal or exceed the going rate for every hour worked in that period.
• Where a worker is paid either monthly or less frequently than monthly, the salary paid to such a worker over any 3-month period must equate to at least a quarter of the required annual salary.
• If a worker is paid more frequently than monthly, in those circumstances the salary paid to such a worker in any 12-week period must equate to at least 12/52 of the required annual salary.

Record keeping duties

• On 20 May 2026, the Home Office clarified its guidance that sponsors must ensure they retain evidence of carrying out RTW Checks on:
  • Any worker they employ, regardless of whether or not the worker is sponsored.
  • Any worker they sponsor, regardless of whether or not they are the worker’s employer.
• The guidance also confirms that where the sponsor is the worker’s employer, there is a dual reason to carry out such RTW Checks in order to comply with its duties as a sponsor and to establish a statutory excuse (defence) against potentially being liable for a civil penalty for employing someone illegally.

Revocations and refusals of Sponsor Licence applications

The Home Office has also clarified the circumstances in which it may revoke an existing sponsor licence or refuse a new application.

• The Home Office will normally revoke a sponsor licence if a sponsor is sponsoring or employing a worker who does not hold the required permission to work in the UK and the sponsor failed to carry out the correct RTW Checks or where they could have been “reasonably aware” that the worker did not have such permission.
• The Home Office further made clear that they will refuse an application for a sponsor licence if they have “reasonable grounds” to suspect that such an applicant sponsor has been set up or exists to try and “facilitate the entry or residence of a worker who would not otherwise have the relevant permission to work in the UK.”

These changes underline the importance of robust right to work processes and effective sponsor licence governance, as failures can now have wider implications for both existing licences and future applications.

What sponsors should do now

Conduct an audit

Check that sponsored workers are undertaking the role described on their Certificate of Sponsorship, working the correct hours and receiving the required salary.

Review right to work compliance

Ensure appropriate checks have been completed across the workforce, including employed workers and sponsored workers where sponsorship obligations apply.

Review internal processes and record keeping

Ensure salaries for those on Skilled Worker visas are paid in line with the relevant pay period requirements. Retain evidence of right to work checks for all staff and other sponsor compliance records, particularly for sponsored workers.

How we can help

Keeping pace with changes to sponsor guidance can be challenging, particularly for organisations managing larger sponsored workforces or complex compliance obligations.

The UK Immigration team at Moore SGD Law can help you review your current arrangements through a sponsor licence compliance audit or provide refresher training for Authorising Officers and key personnel. Our team can help ensure your policies, processes and record keeping remain aligned with the latest Home Office guidance and your ongoing sponsor licence obligations.