A sponsor licence can remain in place for years, which makes it easy for an employer to assume everything is fine.
The problem is that the business may have changed considerably since the licence was granted. Staff leave. Directors change. Offices move. HR systems are replaced. The person who originally understood the Sponsor Management System may no longer be responsible for it.
Meanwhile, the Home Office continues to change the rules and guidance. The August 2026 updates make this a sensible time for sponsor licence holders to check what is actually happening inside their business.
Start with the Sponsor Management System
Who currently has access to your SMS?
An employer should know the answer without having to investigate it.
Check the Authorising Officer, Key Contact and Level 1 Users. Make sure the details held by UKVI remain correct and that people who no longer need access have been dealt with appropriately.
Responsibility also needs to be clear. Someone within the business should know what has to be reported to UKVI and when.
Look at real worker files
Appendix D was updated with effect from 3 August 2026. It sets out the records sponsors are required to keep.
Take several current sponsored workers and inspect their files.
Are the required documents there? Are right-to-work records complete? Is the worker's current address recorded? Does the salary information correspond with payroll? Can you identify the employee's current immigration permission?
This exercise often tells you more about the state of a sponsor licence than reading the company's compliance policy.
Check what sponsored workers are actually doing
The role described on a Certificate of Sponsorship needs to correspond with the job the employee performs.
That includes the duties, salary and working arrangements.
Businesses change, and jobs often change with them. A promoted or reorganised employee may now be doing something different from the position originally sponsored.
Those changes should not simply be ignored because the employee already has a visa.
Review how right-to-work checks are carried out
Right-to-work compliance applies to the whole workforce, including employees who are not sponsored.
The business should have a consistent process for carrying out the correct check, retaining evidence and dealing with employees who require a repeat check. The current process is set out in the Home Office's right-to-work checks guidance for employers.
Managers involved in recruitment also need to understand that right-to-work compliance does not give an employer permission to discriminate against candidates because of nationality or immigration status.
Consider what has changed in the company
Think back to when the sponsor licence was granted or last reviewed.
Has the company moved? Have directors changed? Has there been a change in ownership or structure? Has the nature of the business changed? Are sponsored workers now based somewhere different?
Some corporate changes have to be reported to UKVI and, depending on what has happened, can have wider consequences for the licence.
Immigration compliance therefore needs a line into whoever deals with corporate changes within the business.
Would the system work if UKVI checked it?
The fact that the business has successfully sponsored workers before does not answer it.
A sponsor should be able to produce the required records, explain who manages the licence and show that the information supplied to UKVI corresponds with what is actually happening in the workplace.
If that cannot be done quickly, the business should find out why.
How Flashpoint Legal can help
Flashpoint Legal advises employers on sponsor licence applications, sponsored workers and ongoing compliance.
Our sponsor compliance work can include a review of SMS arrangements, sponsored-worker records, right-to-work procedures and the way sponsorship responsibilities are managed within the business.
If your sponsor licence has not been reviewed recently, contact Flashpoint Legal to arrange a compliance review.
Important: This article provides general information and is not legal advice. Immigration Rules and Home Office guidance change regularly. Advice should be based on the circumstances of the employer and worker.