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· 10 min read

How to prepare for a Home Office sponsor compliance visit

Most sponsors find out about a compliance visit in one of two ways: a short notice letter, or a knock on the door. Either way, there's little time to fix anything on the day. What decides the outcome is how you've been running sponsorship all along, and whether your records show it.

This guide explains what the Home Office can check, what usually goes wrong, and how to build a readiness routine. It's written for HR teams and Authorising Officers, and for the immigration solicitors and advisers who prepare clients for visits. It isn't legal advice.

What a compliance check is (and why it might happen)

Part 3 of the sponsor guidance says the Home Office "may check sponsors at any time", before or after a licence is granted (para C7.9). A check can involve (C7.6):

  • asking for extra documents or information
  • verifying documents you've already provided
  • an on-site visit
  • a digital compliance check, with interviews over video
  • checks with other government departments, agencies or local authorities
  • looking at information that comes up in workers' applications or in allegations from the public

Checks can also be prompted by "a reasonable suspicion" that you've breached your duties, for example a poor compliance record (C7.4). Separately, the Home Office makes regular checks with HMRC on whether you're paying workers properly (C7.7). (Part 3: sponsor duties and compliance)

Announced or unannounced

C7.9 says a visit or interview "can be on an announced or an unannounced basis". Plan as if you'll get no notice at all.

What the compliance officer may do

According to C7.15, the officer may want to:

  • verify what you said in your licence application, which can include photographing the premises
  • verify information you gave in support of any worker's application
  • check that you're meeting all your sponsor duties
  • speak to sponsored workers, including people you used to sponsor
  • speak to employees involved in recruiting sponsored workers
  • inspect records and systems against Appendix D
  • check other workers to make sure you're preventing illegal working
  • carry out criminal record and civil penalty checks on people connected to the organisation

Two more points from the guidance are worth knowing in advance:

  • Officers won't tell you how it went on the day. The officer "will not give an indication of their assessment" during the check (C7.18). You'll get the decision in writing afterwards (C7.23).
  • Visitors will carry official ID. If you doubt someone is genuine, Part 3 gives a number to call: 0300 123 4699 (C7.19).

Client sites and third parties

If your sponsored workers are based at a client's or another third party's premises, it's your responsibility to make sure that party knows about possible unannounced visits, and to secure their full co-operation. If they don't co-operate, the Home Office says it will take action against you (C7.10). This catches out staffing, care, cleaning, security and IT services businesses in particular.

Possible outcomes

After a check, the Home Office decides what action, if any, to take (C7.23 to C7.26):

  • No action, if everything's in order.
  • Downgrade to a B-rating with an action plan, for relatively minor breaches you're willing and able to fix. While B-rated you can't assign a CoS to new workers. The action plan has a fee and lasts a fixed 3 months (C8.3, C8.17).
  • Suspension, with a view to revocation, while they investigate further.
  • Revocation, which can happen without suspension first in serious cases.

A practical preparation plan

Step 1: name the people and the process

  • Confirm who would meet an officer at each site, including a deputy for each person.
  • Make sure the Authorising Officer and at least one Level 1 User are current and reachable. You must have a Level 1 User at all times (C2.16).
  • Brief reception and site managers. Who do they call, and where's the visit plan kept?
  • Write a one-page "visit plan" covering who attends, which room you'll use, and how records will be shown.

Step 2: run an Appendix D check on every sponsored worker

Appendix D (valid from 3 August 2026) is what officers check records against. For each worker, confirm you can produce: (Appendix D)

  • right to work check evidence, with the date and method, plus follow-up checks for time-limited permission
  • payslips showing name, NI number, tax code, allowances and deductions
  • evidence of each salary payment into the named worker's account (not just "wages for personnel")
  • the contract or written statement of particulars
  • a detailed job description and evidence of qualifications or registration
  • an NI number and an up-to-date history of contact details
  • recruitment evidence, where a labour market test or similar requirement applied

Start with a sample: pick 3 to 5 workers at random and time how long it takes to pull everything together. That number tells you a lot.

Step 3: reconcile your SMS against reality

For each sponsored worker, compare the CoS with what's actually happening:

  • Job: do the actual duties still match the occupation code and job description? A mismatch that isn't a permitted change is a mandatory ground for revocation (C1.45).
  • Pay: does payroll match the CoS salary, and since 8 April 2026, does it pass the pay-period tests in Sponsor a Skilled Worker (SK7.20 to SK7.24)? (Sponsor a Skilled Worker)
  • Location and hours: has anyone moved site, started working entirely from home, or changed their working pattern?
  • Reports: were all reportable events reported on time (within 10 working days for worker changes and 20 for organisation changes)?

If you find an unreported change, get advice on reporting it now rather than waiting for the visit.

Step 4: prepare your people

Officers can interview sponsored workers and recruiting staff. Workers shouldn't be coached, but they should know a visit might happen, and their own understanding of their job, hours and pay should match what the paperwork says. If it doesn't, that's a records problem to fix, not a script to rehearse.

Step 5: check right to work for everyone, not just sponsored workers

C7.15 allows checks on other workers too. The code of practice in force from 1 October 2026 extends the Right to Work Scheme to workers' contracts, individual sub-contractors and some online matching services. It also confirms the civil penalty starting points: £45,000 per illegal worker for a first breach and £60,000 for a repeat breach within 3 years. (Code of practice on preventing illegal working)

Step 6: make readiness routine

A mock audit once a year helps, but records drift between reviews. A monthly 30-minute routine works better:

  • open SMS reports, and anything due in the next 10 working days
  • RTW and eVisa re-checks due in the next 90 days
  • workers with absences, pay changes or role changes this month
  • missing or expired documents

Common gaps, in the guidance's own words

Part 3 lists what a B-rating action plan might require (C8.13): better record-keeping, tighter control over staff who assign CoS, and better communication between branches so you know when a sponsored worker hasn't turned up for work. These are everyday process gaps, not technicalities. If your sponsor compliance relies on one person's inbox, these are the gaps to close first.

For immigration solicitors and advisers

Visit preparation is often where a firm adds the most visible value. A standard pre-visit pack per client makes the work repeatable across a portfolio: a visit plan, a sample Appendix D check, an SMS reconciliation and a people briefing. Agree in advance who decides what if a client is B-rated. The window to accept an action plan and pay the fee is 10 working days (C8.14).

Where SponsorGuard helps

SponsorGuard is built for the routine described above. Based on what's live on the product today:

  • Per-worker Appendix D evidence packs, drawn from a running evidence record (documents, review status, RTW history, absences and SMS event logs), exportable as PDF or ZIP
  • A pre-visit self-assessment questionnaire grounded in current Home Office guidance
  • Automated GOV.UK share-code checks: SponsorGuard automates the GOV.UK right-to-work share-code check. Your team still confirms the photo and the result, and anything unclear is flagged for review.
  • Monitoring of RTW re-checks (alerts at 90, 60, 30, 14 and 7 days and when overdue), eVisa expiry, the 10 and 20 working day SMS windows, absences and missing documents
  • SMS history: imported CoS PDFs kept as a permanent, searchable record and reconciled against your workforce
  • A multi-client dashboard for solicitor and adviser firms

SponsorGuard helps you prepare. It doesn't guarantee how a compliance check will turn out, it doesn't give legal advice, and it never submits anything to the Home Office. Your team reviews and authorises everything before it's used.

FAQ

Does the Home Office give notice before a sponsor compliance visit?

Not always. Part 3 of the sponsor guidance says visits and interviews can be announced or unannounced (C7.9).

Can a compliance check be done remotely?

Yes. The guidance describes a digital compliance check, with interviews over video, alongside on-site visits (C7.6, C7.14). The Home Office can also check by phone, video or letter (C7.16).

Will the officer tell me the result at the end of the visit?

No. The officer won't indicate their assessment during the check (C7.18). The decision is sent in writing afterwards (C7.23).

What documents should I have ready?

Everything Appendix D requires for each sponsored worker, including right to work evidence, payslips and payment evidence, contracts, job descriptions, qualifications, NI numbers and contact details history.

What happens if problems are found?

For relatively minor breaches you're willing and able to fix, the usual outcome is a B-rating and a 3-month action plan. More serious breaches can lead to suspension or revocation (C7.25, C7.26, C8).

Our workers are based at a client's site. Can officers visit there?

Yes. You must make sure the client knows about possible unannounced visits and will co-operate (C7.10).

Sources

Preparing for a visit, or want to be ready before one is announced? SponsorGuard is running an invite-only pilot for up to 8 sponsor employers and immigration firms. It lasts 30 days, opening in October 2026. Request access at sponsorguard.com.