Sponsor Licence Compliance Changes March 2026: What Employers Need to Know

The Home Office introduced a number of important sponsor compliance changes alongside the Immigration Rules update (HC 1691) in March 2026. Updated sponsor guidance published on 6 March 2026 contains several points that sponsor licence holders should review carefully.

Below is a summary of the main changes and the practical steps sponsors should now consider.

1. Sponsors must evidence that workers have been given information about their employment rights

Sponsors must be able to evidence that sponsored workers have been provided with information about their employment rights in the UK.

This means sponsors should have HR systems and records showing how that information has been communicated and retained for each sponsored worker.

Relevant evidence may include:

• written guidance issued to employees
• contractual wording
• induction materials or training records covering workers’ rights

Sponsors should review records for existing sponsored workers as well as new hires to ensure appropriate evidence is in place.

2. The guidance now refers to an “eligible role”

The updated guidance defines an “eligible role” as a role which:

• genuinely exists when the Certificate of Sponsorship (CoS) is assigned
• requires the duties and hours stated on the CoS
• meets the relevant skill and salary requirements for the route
• is appropriate to the sponsor’s business model, scale and operations

UK Visas and Immigration (UKVI) must be satisfied that those requirements are met both at the point of sponsorship and throughout the sponsorship period. Sponsors should therefore ensure that sponsored roles are commercially credible and supported by the business’s operations.

3. Job duties must match the CoS occupation code

The Home Office has reinforced that sponsored workers must undertake the role described on the CoS and reflected in the relevant occupation code.

If UKVI concludes that a worker is carrying out duties which do not match the assigned occupation code, and the change is not otherwise permitted under the rules, this may expose the sponsor to serious compliance action, including revocation.

Sponsors should review:

• job descriptions
• promotions and changes in responsibilities
• internal restructures
• any role changes affecting sponsored workers

In some cases, changes may need to be reported to UKVI or a fresh CoS may be required.

4. Salary must meet the required level in each pay period

From 8 April 2026, sponsors must ensure that the required salary is paid in each pay period. Salary can no longer be averaged across the year for compliance purposes.

This means payroll processes should be checked carefully to ensure that salary levels remain compliant throughout the sponsorship period. An underpayment in any pay period may create compliance issues, subject to any permitted exceptions under the rules and guidance.

What sponsors should do now

Sponsor licence holders should consider carrying out an internal compliance review to ensure that:

• information about employment rights has been issued and recorded
• job descriptions and day-to-day duties match the CoS occupation code
• salary payments meet the required immigration thresholds in each pay period
• sponsored roles remain genuine and appropriate to the business

Businesses which rely on sponsored workers should ensure that HR, recruitment and payroll systems are aligned with the updated guidance.

If your organisation holds a sponsor licence and requires support with a compliance review or mock audit, our immigration team can assist.

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This is a general summary of recent changes and does not address every exception or route-specific requirement.