Immigration compliance training is practical preparation for directors, HR specialists and key personnel on how to meet the duties of a UK sponsor licence holder. It helps a business organise right to work checks, record-keeping and reporting to the Home Office so that it is ready for a compliance check at any time, rather than learning about breaches from a compliance officer.
What immigration compliance training is and why employers need it
A sponsor licence allows a company to employ overseas workers on sponsored work routes, most commonly the Skilled Worker visa. With that permission comes a set of duties: monitoring workers’ immigration status, keeping specific documents, reporting changes to UK Visas and Immigration (UKVI) on time and co-operating with compliance officers. GOV.UK sets out these duties in the “Your responsibilities” section of its guide for employers, and the detailed rules in Part 3 of the sponsor guidance (Sponsor duties and compliance).
Immigration compliance means meeting all of these requirements in practice, in the day-to-day work of an HR team. The difficulty is that the rules are spread across lengthy documents, are updated regularly, and the responsibility sits with specific people inside the business. If an HR specialist does not know that a change of a worker’s work location must be reported within a set deadline, or accepts a document that no longer proves the right to work, the company breaches its duties without realising it.
Training closes the gap between the text of the guidance and real processes. Imperial & Legal advisers explain sponsor duties using examples from your sector, show what typical breaches look like and help embed the correct steps in internal procedures. The result is a team that understands not only what to do but why, and is therefore less likely to make mistakes in unusual situations.
Training is useful at any stage: before applying for a licence, straight after it is granted, when key personnel change or ahead of an expected compliance check. The earlier the team gains structured knowledge, the fewer errors build up in HR records.
Who needs training on sponsor duties
Sponsor duties are shared between several roles. When applying for a licence, a company appoints key personnel: an Authorising Officer, a senior person responsible for the actions of staff who use the Sponsorship Management System (SMS); a Key Contact, the main point of contact with UKVI; and a Level 1 User, who manages the licence in the SMS day to day. The requirements for these roles are set out on the GOV.UK page “Sponsorship management roles”.
The same roles can be held by one person or by different members of staff. In small companies a director often holds all three roles and has little time to follow updates to the guidance. In larger organisations the duties are split between HR, payroll and line managers, and each sees only part of the process. In both cases training helps bring the full picture together.
Who immigration compliance training is designed for in a business
- Companies preparing to apply for a sponsor licence
- New licence holders starting to recruit overseas workers
- Authorising Officers, Key Contacts and Level 1 Users taking on a role
- HR teams responsible for right to work checks
- Branch and line managers overseeing sponsored workers
- B-rated sponsors following a Home Office action plan
- Businesses expanding their workforce with overseas talent
Companies that are only planning to apply for a licence deserve a separate mention. The Home Office may check an organisation before deciding on its application, so record-keeping and monitoring processes are best put in place in advance. More about the procedure itself is available on the page on the UK sponsor licence and in the article on how to apply for a sponsor licence and what it is for.
Key duties of a sponsor licence holder
The sponsor guidance groups duties into several categories: reporting, record-keeping, complying with immigration law and wider UK law, and not engaging in behaviour that is not conducive to the public good. A company’s responsibility for an individual worker starts when it assigns them a Certificate of Sponsorship (CoS) and continues for as long as it sponsors them.
Reporting to UKVI
Most changes affecting sponsored workers must be reported through the SMS within 10 working days, and changes to the organisation itself within 20 working days. The table below shows the main events and deadlines under the current version of the guidance.
| Event | Reporting deadline |
|---|---|
| Worker does not start work within 28 days | 10 working days |
| Unauthorised absence for more than 10 consecutive working days | 10 working days after the 10th day of absence |
| Salary reduced below the level stated on the CoS | 10 working days |
| Change of the worker’s normal work location | 10 working days |
| Sponsorship of the worker ends | 10 working days |
| Significant changes to the organisation: merger, change of business, insolvency | 20 working days |
In addition, a sponsor must report as soon as reasonably practicable if it suspects that a worker is breaching the conditions of their visa, without waiting for the standard deadline.
Record-keeping and monitoring workers
GOV.UK requires sponsors to have HR systems that let them monitor workers’ immigration status, keep copies of documents (including evidence of right to work checks), track attendance, keep workers’ contact details up to date and report problems promptly. The list of documents to be kept for each sponsored worker is set out in Appendix D to the sponsor guidance.
Right to work checks
The duty to check the right to work applies to all employees, not only sponsored workers: it derives from section 15 of the Immigration, Asylum and Nationality Act 2006. The right to work can be checked online using a share code, by checking original documents, or through a certified identity service provider using IDVT. Biometric residence cards and permits can no longer be accepted. Copies must be kept throughout employment and for 2 years after it ends, and where the right to work is time-limited a follow-up check is required. The process is described on the page “Checking a job applicant’s right to work”.
What the Home Office checks when reviewing sponsor licence holders
- Accuracy of information given in the licence application and the CoS
- Consistency between the worker’s actual role and the CoS description
- Payment of a salary no lower than the level stated when sponsoring
- Availability and completeness of records for each sponsored worker
- Correct and timely right to work checks for all employees
- Timely reporting of changes through the sponsorship management system
- Understanding of sponsor duties among staff involved in recruitment
A compliance check can be announced or unannounced. Compliance officers may visit any address where sponsored workers carry out their duties, including a client’s offices, or carry out a digital compliance check by remote video interview. The Home Office also makes regular checks with HMRC to make sure workers are paid in line with the rules.
Changes to the rules for sponsors in 2026
The sponsor guidance is updated several times a year, which is why knowledge gained when applying for a licence goes out of date over time. The current version of Part 3 has applied since 28 August 2026 and reflects several changes that directly affect the day-to-day work of HR teams.
- Wider right to work checks. From 1 October 2026, the duty to carry out these checks also applies to organisations that engage individuals under a worker’s contract or as individual sub-contractors, and to online matching services that connect service providers with clients. The updated employer’s guide to right to work checks is published on GOV.UK.
- Mandatory multi-factor authentication in the SMS. From 3 September 2026, SMS users sign in with a one-time passcode. Disclosing a password or passcode to another person is listed in the guidance as one of the grounds on which the Home Office may revoke a licence.
- Phasing out of Level 2 Users. New Level 2 Users can no longer be appointed. Before 9 March 2027, existing Level 2 Users must be changed to Level 1 Users or deactivated, and such accounts will be deactivated automatically after 8 March 2027.
Each of these changes requires not just a formal decision but also an update to internal procedures: who enters access codes, which users should move to the new level, which contractor agreements now fall within the scope of right to work checks. The training covers the changes that apply to your company specifically.
What the training programme includes
The programme is tailored to the individual company: the number of sponsored workers, the sector, the office structure and who holds the key personnel roles. The core set of topics covers all sponsor duties, while the depth of each topic depends on where the company’s risks are greatest.
Compliance training
Training programme for key personnel and HR teams
Sponsor duties
Reporting deadlines, record-keeping and monitoring worker status
Using the SMS
Key personnel roles, reporting changes and secure account access
Right to work checks
Share codes, original documents, follow-up checks and retention
Compliance visit readiness
Mock audit, staff interview practice and a remediation plan
In addition to the core modules, the programme can include specific topics: recruiting graduates of UK universities, intra-company transfers on Global Business Mobility visas, and workers based at client sites or working remotely. Participants receive guidance notes and templates for internal documents that remain with the company after the training.
How the training works: stages
The work moves from an assessment of the current position to training and follow-up support. This order ensures the sessions are based on the company’s real processes rather than general examples from the guidance.
Consultation and company risk assessment
Audit of HR records and processes
Design of a programme tailored to the company
Delivery of training for key personnel
Ongoing support and knowledge updates
The timeframes for each stage are indicative and depend on the number of workers and the volume of records. If a Home Office compliance check has already been scheduled, the stages can be shortened, starting with an audit of the highest-risk areas.
Training formats and cost
The cost of training is calculated individually and depends on the number of participants, the session format, whether an audit is needed and the volume of records. Comparing the main options helps choose the right format.
| Format | Who it suits | What it includes |
|---|---|---|
| One-to-one session | A director or Authorising Officer of a small company | Review of sponsor duties based on your licence, answers to your questions |
| Group training | HR team, key personnel, line managers | Modules on reporting, right to work checks and the SMS, practical exercises |
| Audit and training | Companies preparing for a check or with a B-rating | Mock audit of records, report with recommendations, training based on the findings |
When planning a budget, it is worth considering what breaches cost. The figures below are taken from GOV.UK and show the direct consequences, excluding the business impact of being unable to recruit new staff.
| Consequence | What it means |
|---|---|
| Downgrade to a B-rating | No CoS can be assigned to new workers; the action plan costs £1,579 and must be paid within 10 working days |
| Licence suspension | No CoS can be assigned while the investigation is ongoing; the company has 20 working days to respond |
| Licence revocation | No right of appeal; a new application cannot be made for at least 12 months, or 24 months after a second revocation |
| Illegal working penalty | Up to £60,000 for each illegal worker where checks were not carried out or were carried out incorrectly |
Details on licence ratings and action plans are on the page “Your licence rating”, and on penalties on the page “Penalties for employing illegal workers”. By comparison, preventive training and an audit usually involve far lower costs and do not interrupt recruitment.
Common mistakes training helps prevent
Most breaches identified during compliance checks repeat from one company to the next. They are rarely deliberate and almost always arise because the responsible member of staff did not know the rule or did not understand what it means in practice.
- Incomplete document copies. When checking a passport, every page with personal details, the expiry date and any work endorsements must be copied, and the date of the check recorded.
- Missed follow-up checks. Where a worker’s right to work is time-limited, the check must be repeated before it expires, otherwise the company loses its protection against a penalty.
- Unreported changes. Significant changes to a worker’s employment, a move to another branch or permanent remote working must be reported in the SMS.
- Mismatch between the CoS and the actual job. Duties and salary must match what was stated when the worker was sponsored.
- Passing costs to the worker. The guidance prohibits asking a sponsored worker to pay the sponsor licence fee, the Immigration Skills Charge or associated costs.
- Careless SMS access. A password shared between several people or a passcode passed to someone else is now expressly listed in the guidance as grounds for action.
Each of these mistakes looks minor, but during a compliance check the officer assesses the overall picture: several minor breaches taken together may indicate a more serious failing and lead to suspension of the licence without a prior downgrade.
Practical examples
The situations in which employers seek training tend to repeat. Here are several typical scenarios showing how gaps in knowledge turn into risks for the licence.
A change of HR manager without a handover
A typical situation: after the licence is granted, one member of staff runs all the processes, and after they leave, the new HR manager is unaware of reporting deadlines and follow-up right to work checks. In this case a mock audit helps identify missed reports before a compliance officer visits, and training embeds the correct steps in a procedure that does not depend on any single person.
Workers based at client sites
IT and consultancy firms often place sponsored specialists at their clients’ offices. If these new work locations are not recorded in the SMS, the company breaches its duty to report changes. The guidance also states that compliance officers may visit a third party’s premises, and the sponsor is responsible for making sure the client is prepared for this. Training helps set up a record of work locations and a process for informing clients.
Rapid growth and new roles
Restaurant chains, retailers and care providers often recruit through local managers, and right to work checks are carried out differently at each site. For such businesses, group training for managers and a single checklist that standardises the process across the whole network are particularly useful.
If a company has already been downgraded or had its licence suspended, training becomes part of the action plan. Real stories of Imperial & Legal clients who went through Home Office compliance checks and kept or restored their ability to recruit are collected below.
Client stories about sponsor licences
Reinstating Sponsorship Licence after Unexpected Home Office Visit
It has been nearly four years since Company A applied for and received a sponsorship licence for hiring foreign specialists in the UK....
Reinstating Suspended Sponsor Licence after Unjustified Accusations
Travel Agency C’s main clients are Chinese tourists. Because of that, all employees need to have knowledge of Chinese traditions and culture and speak...
Obtaining UK Skilled Worker Visa after Your Employer Changes Their Sponsorship Licence
Li Qian is an experienced chef. He had been working in one of the well-known restaurants in West London for a year. Then the owner decided to set up a...
Sponsor Licence: How to Hire Foreign Specialists to Work in the UK?
Today’s labour market knows no boundaries. It is common for large, fast growing companies to employ foreign specialists. If your company...
Obtaining Sponsorship Licence for Pharmaceutical Company To Employ Foreign Specialist
A foreign specialist cannot come to the UK to look for a job; there is no such visa. But they can apply for a work visa after getting employed by a...
One of these clients described how an unexpected licence suspension put the whole business at risk.
Our agency’s main clients are Chinese tourists. Therefore, we needed our employees to speak fluent Chinese and have a strong understanding of Chinese culture and traditions. We got registered as sponsors and employed several Chinese specialists. When the Home Office came with an inspection and suspended our sponsor licence, we were in shock. That could have jeopardised the entire business. But Imperial & Legal’s immigration advisors solved the problem.
How to keep your sponsor licence in good order
A sponsor licence usually stays valid for as long as the company continues to meet the requirements, and the Home Office can check this at any time. Immigration compliance is therefore not a one-off task but part of HR processes that must be maintained as staff and rules change. If a licence has been downgraded or revoked and workers have been refused visas, separate support with administrative reviews and appeals may be needed.
Key takeaways
- Sponsor duties cover record-keeping, reporting and right to work checks
- Most changes affecting workers must be reported in the SMS within 10 working days
- A Home Office compliance check can be unannounced, on site or by video call
- New rules in 2026 include wider right to work checks and multi-factor authentication in the SMS
- Training and a mock audit help find gaps before a compliance check, not during it
The information on this page is general in nature and does not constitute individual legal advice. Requirements for sponsors depend on the circumstances of each company and may change, so it is worth discussing your situation with an adviser before making decisions. Answers to employers’ frequently asked questions are below.
