Sponsor licence guidance: the record-keeping duties nobody warns you about

Most sponsor licence guidance stops at the application. The application is the easy part: a form, some evidence that the organisation is real and trading, and a fee. What follows is a permanent set of duties — record keeping, reporting and monitoring — and those duties are what an unannounced compliance visit examines. Licences are suspended and revoked over missing files far more often than over anything in the original application.

What sponsor licence guidance means by "duties"

A licence makes the employer responsible for four things, continuously and for the life of every sponsored worker.

• Record keeping: a file per sponsored worker containing specified documents, retrievable on request.
• Reporting: notifying the Home Office of defined changes, most within ten working days.
• Complying with immigration law, including right to work checks for every hire, sponsored or not.
• Monitoring: knowing where sponsored workers are, what they are paid, and what they actually do.

The migrant file, line by line

Each sponsored worker needs their own file. A compliance officer will ask for a specific worker by name and expect the file in minutes, not after an afternoon of searching shared drives.

1. Right to work evidence, with the date the check was performed and who performed it.
2. The recruitment record for the role — advert, shortlist and interview notes where a genuine vacancy test applied.
3. Contact details kept current: address, telephone and personal email, with the date each was last confirmed.
4. Contract of employment and every variation, showing the job title, duties, hours and salary that were sponsored.
5. Absence records, including annual leave and any unauthorised absence, which is a reportable event.
6. Payroll evidence that pay matches what was recorded on the certificate of sponsorship.
7. A copy of the certificate of sponsorship itself, with the assigned role and occupation code.

Keep the same structure for every worker, in the same order. Consistency is what makes a file look maintained rather than assembled the night before.

Reporting: the ten-day clock

Changes that must be reported include a worker not turning up on their first day, ten consecutive days of unauthorised absence, early termination, a significant change in salary or duties, a change of work location, and changes to the sponsor organisation itself — new premises, a merger, a change of key personnel. The deadline is short and the clock starts when the event happens, not when HR notices. This is why the duty has to live in a system with dates rather than in someone’s inbox.

Keeping the evidence without buying an HR suite

The duties describe a structured record set with dates, owners and attachments — which is a register, not a document pile. Ettex Records holds one row per sponsored worker with columns for each required document and its review date, so an open row is visibly an open duty. Where you need a signed acknowledgement or a variation agreed by the worker, Ettex Signature attaches the executed copy to the same row instead of a separate folder. If you are setting up the underlying hiring checks at the same time, the right to work check is the prerequisite that sits in front of all of this.

What a compliance visit actually tests

• Can you produce a named worker’s file on request, complete and current?
• Do the payroll records match the sponsored salary, including after a pay review?
• Are the reportable events on file reported, with evidence of when?
• Does the person doing the work do the job that was sponsored, in the location that was declared?
• Are your key personnel still in post, and still the people named on the licence?

Answer those five convincingly and the visit is uneventful. The organisations that struggle are rarely acting in bad faith — they simply kept the duties in email, and email cannot show you which of forty files is missing a current address.