The Checklist

1. 1

   Map and refresh your Appendix D records

   Appendix D of the sponsor guidance lists the documents sponsors must keep for each sponsored worker, including right to work evidence, contact details, attendance records and contracts. Map every category to a named owner and storage location, and check that records are complete, current and easily retrievable. Missing or stale records are the single most common compliance failing.

2. 2

   Run a mock right to work audit

   Sample a cross-section of sponsored and non-sponsored workers and re-perform the right to work check end to end against current Home Office guidance. From 1 October 2026, the statutory regime extends beyond conventional employees to relevant workers and certain individual subcontractors. Genuine business-to-business arrangements do not automatically fall within the scheme, so classify each working relationship carefully. Confirm the correct method was used, that records bear the required check date, and that follow-up dates are diarised.

3. 3

   Confirm SMS reporting is up to date

   Many changes — including changes of address, role, salary, working pattern and absences — must be reported via the Sponsorship Management System (SMS) within 10 working days. Review the last 12 months of HR changes against SMS activity to identify any missed or late reports. Late reporting cannot always be undone, but a self-correction recorded in good faith is better than waiting for a visit.

4. 4

   Brief key personnel and managers

   Officers may interview the Authorising Officer, Key Contact, Level 1 User and line managers, as well as sponsored workers. Brief each on what their role involves, the genuineness of the relevant vacancies, the recruitment process, and how SMS reporting and right to work checks operate. Inconsistent or vague answers can themselves trigger further action.

5. 5

   Check the genuine vacancy and role match

   Officers will compare the role described on the CoS against what the worker actually does, the worker's qualifications, the salary paid, and the wider business need. Ensure job descriptions, organisation charts, payroll records and the CoS narrative tell a consistent story. Any drift since the CoS was assigned should be reportable and supportable.

6. 6

   Prepare a logistics pack for an unannounced visit

   Have a written process for receiving officers on site: a named contact, access to a meeting room with a screen, a printed Appendix D index, copies of the licence and current CoS records, and the contact details of your immigration adviser. A calm, organised reception sets the tone for the rest of the visit.

Common Mistakes

• Treating compliance as a one-off exercise at licence stage. Compliance is continuous and the licence can be downgraded, suspended or revoked if sponsor duties are breached.
• Relying on individual diaries for follow-up checks. When the owner leaves or is absent, time-limited visas expire without a check and the statutory excuse is lost.
• Failing to report changes within 10 working days via SMS. Late or missing reports are routinely identified during visits and frequently lead to action against the licence.
• Mismatch between CoS and the actual role. Where pay, duties or hours have drifted from the CoS without a reportable change, officers may conclude the vacancy was not genuine.
• Weak preparation of interviewees. Inconsistent answers between the Authorising Officer, line managers and sponsored workers undermine credibility even where records are sound.

Frequently Asked Questions

Visa Professionals Ltd is authorised and regulated by the Solicitors Regulation Authority. SRA number: 8016160. This guide provides general information only and does not constitute legal or immigration advice. Immigration rules, fees and Home Office guidance change frequently; this page reflects the position as understood at the time of publication. For advice on your specific circumstances, please contact us directly.