A UK company or organisation that has received a UK sponsor licence from the office to hire foreign workers is required to comply with their sponsor’s duties to retain its licence. If they fail to meet their sponsorship duties, their licence can be suspended, downgraded, or even revoked. The primary duties of a licenced sponsor include:
Reporting Duties
Record Keeping Duties
Complying with the UK’s Immigration Laws, including the Worker and Temporary Worker route specific sponsor guidance
Complying with UK’s Wider Law
Not engaging in actions or behaviour that are not conducive to the Public good
A key component of compliance with the sponsor’s duties is the ‘Record Keeping’ duty.
An approved sponsor must keep certain documents for each worker they sponsor. Sponsors can find the list of documents and how long they must keep them in Appendix D of the sponsor guidance. The documents can be kept in either paper or electronic form. If a sponsor keeps the documents in electronic form, they must ensure that all the relevant parts of the documents are visible as described in Appendix D.
A sponsor must give the Home Office, when asked, any documents relating to their sponsored workers or the running of their organisation that the Home Office considers relevant to assessing their compliance with their sponsor’s duties.
Appendix D is an appendix to the full policy guidance on sponsoring a worker or temporary worker. This appendix outlines the documents that all approved sponsors must maintain to fulfil their sponsorship record-keeping duties.
In this Appendix, unless otherwise stated, “worker” or “sponsored worker” includes people sponsored by a UK employer on:
The Worker routes (Skilled Worker Visa, Global Business Mobility Route – Senior or Specialist Worker Visa, T2 Minister of Religion Visa, International Sportsperson Visa)
The Temporary Worker routes (Creative Worker Visa, Charity Worker Visa, Global Business Mobility routes (other than Senior or Specialist Worker Visa), International Agreement, Government Authorised Exchange, Religious Worker Visa, Scale-up or Seasonal Worker Visa)
The predecessor routes of the above Worker and Temporary Worker routes, including the Intra-Company routes before 11 April 2022, and the Tier 2 and Tier 5 (Temporary Worker) routes before 1 December 2020
Format of documents guide
One can keep documents in either paper or electronic format. No method has been prescribed for storing the documents, but sponsors must be able to make them available to the Home Office when requested.
Normally, all documents relating to a sponsored worker must be kept throughout the period that an employer sponsors them and until whichever is the earlier of either:
One year after the date on which the employer’s sponsorship of the relevant worker ended
The date on which documents were examined and approved by a compliance officer, if this date is less than one year after the employer’s sponsorship of the relevant worker ended
In addition to the documents set out in this Appendix, an employer must also keep the documents they provided as part of their sponsor licence application. They must keep this information for as long as they hold a sponsor licence.
An employer may need to retain some documents for other purposes (such as, to comply with their responsibility to prevent illegal working) as specified in Appendix D, and for longer periods of time.
Employers must ensure that they meet any other legal requirements for record keeping, such as ones set either by the Home Office or another government department.
An employer must retain evidence that they have checked that each of the workers they have sponsored has the legal right to work in the UK and do the work in question for them.
They must have conducted these right-to-work checks before the worker starts working for them, and as prescribed in ‘Right to work checks: an employer’s guide’.
Employers must carry out these checks both to comply with their sponsor duties and to establish a ‘statutory excuse’ (an employer's defence against a civil penalty) under illegal working legislation.
Where relevant, employers must retain evidence of the worker’s date of entry to the UK.
If the worker has a vignette sticker in their passport that shows their permission to enter the UK, their date of entry to the UK can be checked by looking for an entry stamp from an immigration officer. This will normally be endorsed on the vignette. The employer must make and retain a copy of the page containing the vignette and entry stamp.
If the worker applied for entry clearance on or after 15 July 2025 (other than as a Scale-up Worker, Seasonal Worker, or Minister of Religion), they will normally be issued with an eVisa (an electronic record of their identity and immigration status) only and not a vignette. In this case, the entry stamp will be endorsed on a blank page of their passport or travel document. The employer must make and retain a copy of the page that has the entry stamp.
Please note that not all workers will have an entry stamp in their passport.
An employer must be able to show the Home Office how they have recruited their sponsored migrant workers. For some immigration routes, they must have carried out a formal resident labour market test before employing a worker, or taken other steps to protect the settled workforce.
For other immigration routes, there is no formal resident labour market test, but the employer must still be able to explain (and, where appropriate, provide evidence of) how they recruited the migrant worker. This is required to help the Home Office assess whether the vacancy for which the migrant worker is sponsored is genuine.
If an employer was required, before employing a migrant worker, to conduct a formal resident labour market test, or otherwise take steps to ensure they are not displacing a suitable settled worker, they must keep evidence that they have done it.
The evidence they are required to keep depends on the immigration route in which they are, or were, sponsoring the migrant worker.
1. The Tier 2 (General) route that was in place before 1 December 2020
Evidence Required - See paragraphs (a) to (i) below
2. The Religious Worker route that is currently in place
The T5 (Temporary Worker) Religious Worker route that was in place between 1 December 2020 and 10 October 2021 (inclusive)
The Tier 5 (Temporary Worker) Religious Workers route that was in place before 1 December 2020
The Tier 2 (Minister of Religion) route that was in place before 1 December 2020
Evidence required for these routes - See paragraphs (a) to (f) and (j) below
3. The Creative Worker route that is currently in place
The creative provisions of the Creative Worker or Sporting Worker (T5) route that were in place between the dates of 1 December 2020 and 10 October 2021 inclusive
The creative provisions of the UK Tier 5 Temporary Worker - Creative and Sporting route that were in place before 1 December 2020
Evidence required for these routes - See paragraphs (a) to (f) and (k) below
4. The International Sportsperson route that is currently in place
The T2 Sportsperson immigration route and the sporting provisions of the Creative or Sporting Worker (T5) route that were in place between the dates of 1 December 2020 and 10 October 2021 inclusive
The Tier 2 (Sportsperson) route and the sporting provisions of the Tier 5 Temporary Worker - Creative and Sporting route that were in place before 1 December 2020
Evidence required for these routes - See paragraph (l) below only.
a. A copy of each job advertisement the employer placed (where this is, or was, a requirement), which must include all of the following:
The job title
The job location
The job’s main duties and responsibilities
The qualifications, skills, and experience needed for the job
An indication of the salary package or range
The applications’ closing date
b. Where the job vacancy was advertised online on the internet (including the employer’s website, where the sponsor guidance permits this), the employer must take and keep a screenshot from their website hosting the advertisement, on the day the job vacancy is first advertised, which clearly shows all of the following:
Website name
Advert’s contents
The URL of the website
Date on which the vacancy was first advertised (if stated)
Applications’ closing date
c. Where the employer was required or otherwise chose to advertise through a relevant online government job-search service, they must take and keep a screenshot from the relevant government website on the day the job vacancy is first advertised, which must clearly show all of the following:
The logo of the government website hosting the job advertisement
The URL of the website
Advert’s contents
Date on which the vacancy was first advertised (if stated)
Applications’ closing date
Any job reference number (if stated)
d. For any online advertisement that is not on the employer’s own website and does not show the name of their organisation, the employer must provide a copy of a letter or invoice from the relevant website to show that an advertisement was placed.
e. If the vacancy was advertised in a relevant professional journal or a national newspaper, the employer must keep a copy of the job advertisement as it appeared in the given medium. The copy of the job advertisement must clearly show the title and date of the publication and the application’s closing date. If the advertisement does not show the name of the employer’s organisation, they must provide a copy of a letter or invoice from the journal and/or newspaper to show they placed an advertisement.
f. An employer must retain the following documents from any recruitment process where they were required to conduct a formal resident labour market test:
All applications the employer shortlisted for the final interview, in the medium they received them, for example: CVs, emails, and application forms – this should include the applicant’s details, such as their name, date of birth, and address
The total number and names of applicants shortlisted for the final interview
For each settled worker who was either rejected or did not accept the offer of employment, interview notes or other documentation showing the reasons why they have not been employed
g. Where the employer used a rolling recruitment programme, they must provide any evidence stated under paragraphs (a) to (e) that shows that this is a rolling recruitment programme and must also indicate the period of the recruitment exercise.
h. If the employer used a milk round (where the sponsor guidance permitted this), they must keep a letter from each university, on their headed paper, confirming the milk round, the dates it was carried out, and the method that was used – for example, interview and/or presentation method.
i. If the employer hired a sponsored researcher, they must keep evidence of the competitive process used. This could be a programme for the selection process, an advertisement for the grant, the judging criteria, or any other relevant evidence.
k. The employer must retain evidence of their compliance with the relevant code of practice in Immigration Rules Appendix Creative Worker Codes of Practice or, where no code exists for the job role, evidence that the role is otherwise eligible to be sponsored on the UK Creative Worker route.
l. For each sponsored worker on these routes, the employer must keep:
The endorsement letter’s copy for the worker issued by the relevant sports governing body; and
All information and documents submitted as part of their application to get that endorsement
The employer must retain this information for 2 years after the endorsement expires.
If an employer is sponsoring a worker on a route that does not need a formal resident labour market test, or the role was otherwise exempt from a formal resident labour market test, the employer must still retain evidence of any recruitment activity they have undertaken.
If they did not advertise the job role, they must be able to explain how they recruited the worker. This information will help the Home Office establish, where necessary, that the job role offered is a genuine vacancy.
This requirement applies to all UK Worker and Temporary Worker routes and their predecessor routes, where there is, or was, no requirement for a formal resident labour market test, or where the specific role is, or was, exempt from that requirement.
It also applies if the employer is a Skilled Worker sponsor and the job role was subject to the ‘care worker recruitment requirement’ that is described in section SK4 of Sponsor a Skilled Worker in force for Certificates of Sponsorship assigned between the dates of 9 April 2025 and 21 July 2025 (inclusive).
a. Copies of the sponsored worker’s payslips, NI number, tax code, any allowances paid, and deductions made. For LLP (Limited Liability Partnership) members, the employer must keep copies of the worker’s evidence of drawings and profit share.
b. Evidence of the amount and frequency of all salary payments made to each worker, showing the transfer of each payment into the named worker’s bank account or onto their pre-paid card, for example, a FOREX card.
If an employer is sponsoring a worker on the GBM (Global Business Mobility) – Service Supplier route, under the provisions for independent professionals or contractual service suppliers on the International Agreement route that was in place before 11 April 2022, or on the GBM – Secondment Worker route, the contract between the employer and the linked overseas business does not have to specify how much an individual worker will be paid.
Please note that the above is not the full list of evidence of salary for sponsored workers.
a. A specific and detailed job description outlining the duties and responsibilities of the job post which must include the qualifications, skills, and experience required for the post.
b. Copies of any relevant qualifications of the worker to confirm their skill level, such as a degree certificate and/or documents showing that the worker had the skills and experience to do the job. This document could be references from a previous employer or other evidence showing the worker’s experience.
If an employer clearly stated in their advertisement for the job that a certain qualification is mandatory for the job, they must retain evidence that the worker being sponsored for the role has that qualification. If they sponsored a worker who does not have that qualification, the employer must retain detailed reasons as to why they waived the qualification requirement for that particular worker.
c. Copies of professional accreditation documents and/or any registration and/or any confirmation letter the worker needs to have to do their job. For example, proof of a worker’s registration with the General Medical Council, if they are a doctor.
d. An employer must retain details of the technical or specialist skills of the workers coming to the UK under the entourage provisions of the Creative Worker route.
An employer must retain, to the extent they are relevant, a copy of all of the following:
a. A copy of the worker’s NI (National Insurance) number, unless they are exempt from having one.
b. A history of the migrant worker’s contact details, including their up-to-date residential address in the UK, telephone number (mobile and/or landline), and personal email address.
c. In case of the employment of a child below the age of 18, the employer must make a copy of a letter from the parents or legal guardians of the child, or from one parent if the parent in question has sole responsibility for the child. In the letter, the child's parent (s) or legal guardians must be consenting to the arrangements made with regard to the application, travel, reception, and care arrangements of the child in the UK.
d. A copy of the worker’s DBS (Disclosure and Barring Service) check where required for the job role undertaken by the sponsored migrant worker.
e. A record of the worker’s absences. The record may be kept electronically or manually.
f. Any other document set as out in the relevant immigration route-specific sponsor guidance or, where relevant, Immigration Rules Appendix Creative Worker Codes of Practice or the Immigration Rules sporting code of practice.
g. An employer who is licensed on the GBM – Service Supplier route must keep a copy of any contract they have awarded for the supply of service to them and either of the following:
The tender document for that contract
Evidence showing how the contract was awarded if it was not formally tendered
h. An employer licensed on the GBM – Secondment Worker route must keep a copy of any relevant contract or agreement for goods or investment to which both the employer and the overseas business are parties.
i. If an employer is sponsoring any worker who needs an ATAS (Academic Technology Approval Scheme) certificate for the job role they are undertaking, the employer must keep a copy of their ATAS certificate or of the electronic approval notice they received from the Foreign, Commonwealth and Development Office.
j. If an employer is sponsoring a child below school-leaving age on the UK Creative Worker immigration route to
Take part in plays, concerts, films, or other public performances that an audience pays to see, or that performance takes place on licensed premises, or
Modelling assignments for which the child is paid,
The employer must provide evidence that they (or the individual or organisation who is responsible for the event or production) obtained a child performance licence from the local authority.
k. If an employer is a ‘PB1 sponsor’ and is sponsoring migrant workers on the Government Authorised Exchange immigration route via the Sponsor UK service, a record of the information the employer provided to the worker about their sponsored job role to enable the worker to complete their visa application form.
UK Sponsor licence compliance can be best approached as a daily concern. Approved sponsors can ensure compliance and consistency, and avoid enforcement action from the Home Office by integrating good record-keeping practices into the standard HR and personnel processes of the organisation.
Our business immigration specialists have vast experience in supporting companies and organisations through the lifecycle of their sponsorship licence, from the initial application to ongoing compliance with the sponsor’s duties and licence management.
For advice on any aspect of obtaining and managing your sponsor licence, including record-keeping, please call us at +44 (0)20 3411 1261.
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