UK Sponsor Licence Documents: What Employers Must Prepare

For a UK business, obtaining a sponsor licence is not just an administrative hurdle but a commitment to acting as an extension of the UK's border enforcement to manage work migrants that are being or will be sponsored. Failure to maintain impeccable records or recruitment trails can lead to refusal of a licence application or revocation of an existing licence, which triggers the immediate curtailment of all sponsored employees' visas.

Apart from the typical mandatory documents for a sponsor licence application, sponsors must keep the following compliance records for when the Home Office requests further information or performs audit checks:

Existing Migrant Details

The Home Office expects you to know exactly who your sponsored workers are and where they are at all times. This is governed by Appendix D of the sponsor guidance. For every sponsored employee, you must maintain a dedicated file containing:

Right to Work (RTW) Evidence

For most migrants, this is now a digital check via a Share Code. You must retain the dated PDF or screenshot of their RTW check, which clearly shows their personal details and visa expiry date. It is also important to provide evidence of keeping track of any existing migrant's visa expiry.

Personal Details

A history of their residential addresses, personal phone numbers, relevant employment dates, and emergency contact details.

Payroll Records

Copies of payslips and P60s for existing employees and, for sponsor migrants, to prove you are paying the salary promised on the Certificate of Sponsorship (CoS). During compliance audits, the Home Office cross-references your reports with HMRC data to ensure this is consistent.

Absence/Sick Leave Tracking

You must track any authorised and unauthorised absence and report it via the Sponsorship Management System (SMS) within 10 working days where the worker has been absent from work without your permission for more than 10 consecutive working days.

Recruitment Compliance: Proving the "Genuine Vacancy"

The Home Office will require you to pass a "Genuine Vacancy" test during the sponsor licence application by providing the relevant documents showcasing the job you intend to fill and any migrants you have identified. Even if you did not have to advertise formally, you must be able to prove why the role exists and how you selected the candidate. You should have the following documents in place:

• A copy of the job description
• A record of any advertisements placed (if any)
• The sponsor migrant's CV and copies of their qualifications/references
• Interview notes or a summary of why the migrant was the best fit for the role
• Any form of correspondence during the migrant's recruitment

Other Common Further Information Requests

Below are some other information/documents that the Home Office frequently asks for during sponsor licence applications, however do note that this is a non-exhaustive list:

Hierarchy Charts: A visual map of your company showing every employee, their names, immigration status, and work start dates.

Business Rationale: An explanation of why you specifically need to hire from abroad rather than from the local labour market.

Financial Scrutiny: An explanation of how you will be funding the salaries of your proposed workers, as well as the relevant documents (annual accounts, bank statements, sources of income, etc.) to support your claim.

Evidence of any workplace pension schemes offered to employees, and any opt out evidence of employees that are not enrolled in the scheme.

Employment contracts for current employees as well as draft contracts for future roles.

Typically, when the Home Office requests additional documents, you have only 5 working days to respond.

Conclusion

The best way to secure your UK sponsor licence is to be "audit-ready" before you even click submit. Treat the Home Office's standards as your current operational baseline rather than a future goal – ensure your hierarchy charts, recruitment trails, and HR systems are already in place before applying. When the Home Office asks for more information, being able to submit perfect documents demonstrates you are a low-risk, trustworthy sponsor. It is also important to remain vigilant in reporting changes to worker circumstances and details on the SMS within 10 days and auditing your own files regularly.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.