Record revocations and sweeping new compliance duties mean UK employers who sponsor overseas workers face more risk than ever in 2026.
Revocations hit a record high in 2025
Over 3,100 sponsor licences were revoked in 2025 — the most since records began in 2012. In Q4 2025 alone, more than 1,500 licences were pulled. The Home Office now uses HMRC, PAYE and Companies House data to identify compliance concerns without needing a physical site visit, meaning problems can be flagged silently before the employer is even aware.
New rule: salary compliance per pay period (from April 2026)
From 8 April 2026, sponsored Skilled Workers must be paid at or above the required salary in every individual pay period — not just averaged across the year. This is a significant tightening of the previous rule.
- ✓Salary must meet the going rate for the occupation code in every pay period
- ✓Average across any 3-month (monthly pay) or 12-week (weekly pay) period must also hit the minimum
- ✓Paying above the minimum in later months to "compensate" for a shortfall no longer protects you
- ✓Hourly rate must also meet the going rate — overtime without extra pay can be a breach
💡 Tip
Review your payroll records immediately. Any month where a sponsored worker's pay dipped below the required level — even due to sickness, bank holidays, or pro-rating — could be flagged as a compliance breach.
New duty: employee rights briefings
Appendix D of the sponsor guidance now requires sponsors to retain evidence that they have told each sponsored worker about their employment rights in the UK — covering minimum wage, working hours, holiday entitlement, and the right to join a union. Simply having an employment contract is no longer enough; you need a documented briefing.
What triggers a Home Office investigation?
- ✓Mismatch between PAYE records and the salary on the Certificate of Sponsorship
- ✓Late annual accounts or concerns at Companies House
- ✓Sponsored worker filing a complaint with ACAS or an employment tribunal
- ✓UKVI random audit or a third-party tip-off
- ✓Data flags from HMRC or Universal Credit system showing salary anomalies
Can a licence be revoked for unintentional breaches?
Yes. The updated 2026 guidance makes clear that sponsor licences may be revoked even where the employer did not intend to breach their duties. The onus is entirely on the sponsor to have adequate systems in place. "We didn't know" is not an accepted defence.
How to stay compliant in 2026
- ✓Audit sponsored workers' pay every month, not just at year-end
- ✓Keep Appendix D records current and document every sponsored worker briefing
- ✓Train your HR and payroll teams on the new per-pay-period salary rule
- ✓Assign a Level 1 User who actively monitors SMS alerts from the Sponsor Management System
- ✓Check the GOV.UK Register of Licensed Sponsors periodically to confirm your listing is active
Need a sponsor licence compliance audit? Speak to a UK immigration solicitor
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