Avoiding Pitfalls: Compliance, Monitoring, and Record-Keeping for CoS Sponsors

For HR teams managing a Certificate of Sponsorship (CoS) under the Skilled Worker route or other sponsored visa categories, adherence to compliance requirements is critical. Failure to meet obligations can result in penalties, licence suspension, or complete loss of the sponsor licence—directly impacting the organisation’s ability to hire overseas talent.

This article outlines the key compliance areas for HR professionals, focusing on monitoring, change reporting, and record-keeping.

Compliance Responsibilities of CoS Sponsors

The UK Home Office expects every licensed sponsor to meet strict compliance standards. HR must ensure:

• Accurate and timely issuance of Certificates of Sponsorship
  
• Prevention of misuse or fraudulent documentation
  
• Maintenance of sponsored employees’ lawful employment terms
  
• Adherence to immigration rules for wages, job roles, and working hours
  

Failure to enforce these rules within HR processes increases the risk of enforcement action.

Monitoring Sponsored Employees

Continuous monitoring ensures sponsored workers fulfil the conditions of their visa:

• Tracking attendance and work location (especially when hybrid or remote work arrangements apply)
  
• Verifying ongoing job role alignment with the original CoS
  
• Monitoring salary compliance with visa category minimums
  
• Detecting early signs of non-compliance, such as reduced hours or change in duties without reporting
  

Effective monitoring includes integrating HR systems with real-time reporting tools and regular reviews of visa expiry dates.

Reporting Changes to the Home Office

Any material change in sponsored workers’ circumstances must be reported promptly:

• Change in job title or responsibilities
  
• Salary adjustments
  
• Change in work address or business premises
  
• Absence exceeding permitted levels
  
• Early termination of employment
  

HR teams should establish internal workflows to trigger automatic reporting within the sponsor management system (SMS).

Record-Keeping Obligations

Robust record-keeping protects both the sponsor and the worker:

• Copies of sponsored worker passports, visas, and right-to-work checks
  
• Employment contracts and job descriptions
  
• Records of absences, training, and disciplinary actions
  
• Payroll documents confirming salary compliance
  
• Proof of recruitment practices used to fill the role
  

Records must be easily accessible for Home Office audits and retained for the duration of sponsorship plus an additional year.

Risk Reduction Strategies

To avoid licence suspension or fines, HR should:

• Conduct regular internal compliance audits
  
• Train HR staff and managers on visa-specific requirements
  
• Use centralised platforms for monitoring and reporting obligations
  
• Prepare for unannounced Home Office inspections
  

By embedding compliance into HR operations, organisations reduce exposure to immigration risks while protecting their ability to hire internationally.