7 Common Sponsor Duties HR Teams Miss

Right to work checks are a legal requirement for all employees, and the Home Office has significantly increased civil penalties for breaches (up to £60,000 per illegal worker).

Common issues:

• Incomplete records (e.g. no date or signature)
• Screenshots stored incorrectly or not at all
• Failure to repeat checks when visas are time-limited
• No internal training for new starters handling onboarding

Sponsor-specific risk:
Failing to carry out proper checks can directly affect your sponsor licence rating—even if the issue doesn’t involve a sponsored worker.

4. Not Keeping Records Required Under Appendix D

Appendix D of the immigration rules outlines the documents you must keep for every sponsored worker. These include:

• ID documents and visa evidence
• Job descriptions and signed contracts
• Recruitment records (CVs, interview notes, adverts)
• Absence tracking and annual leave logs
• Evidence of payment (payslips, bank transfers)

Issue:
Many businesses lack a consistent file structure or checklist, leading to gaps that are only discovered during audits.

Fix:
Create a digital sponsor file for each worker and audit these every 6–12 months.

5. Overlooking Absence Monitoring and Reporting

You must be able to show that all sponsored workers are:

• Regularly attending work
• Paid in line with their CoS
• Not exceeding unauthorised absences

You are required to report any:

• Unauthorised absence of 10 consecutive working days
• Prolonged absences due to illness, study, or travel (in some cases)

Risk:
Failure to track and report absences can be interpreted as losing contact with the worker, leading to enforcement action or revocation.

6. Missing the 10 Working Day Reporting Deadline

Sponsor duties include timely reporting of changes. Most reportable events must be updated on the SMS within 10 working days. That includes:

• Change of address
• Salary or job title change
• Early termination or resignation
• Changes to Key Personnel

Why this gets missed:
Updates are sometimes made in HR systems or discussed informally, but they are not escalated to the Level 1 User for SMS reporting.

Fix:
Build this reporting window into your internal workflows and trigger points.

7. Lack of Internal Training on Sponsor Compliance

One of the biggest risks is relying on a single person—often the Authorising Officer or Level 1 User, to manage all sponsor-related tasks without cross-training.

Problems arise when:

• Line managers change a worker’s role without realising it’s reportable
• Payroll adjusts salary without linking it to the worker’s CoS
• Onboarding teams skip right to work checks under pressure

Solution:
Train anyone who manages recruitment, onboarding, or people operations. Compliance should be everyone’s responsibility—not just the sponsor team’s.