HR Immigration Compliance Audits: Preparing for Home Office Visits

Introduction

For internal audit and compliance officers, preparing for Home Office compliance audits is essential to maintaining a UK Sponsor Licence and ensuring lawful employment of sponsored workers. These audits, conducted by UK Visas and Immigration (UKVI), verify adherence to sponsor duties under routes like the Skilled Worker or Global Business Mobility visas. With intensified enforcement in 2025—including a record 1,948 licence revocations from July 2024 to June 2025 and tougher measures announced in the May 2025 Immigration White Paper, Restoring Control over the Immigration System, robust preparation is critical. This guide outlines audit triggers, what to expect, key focus areas, preparation strategies, and best practices to navigate audits successfully amid the eVisa transition by 31 December 2026.

What are Home Office Compliance Audits?

Home Office compliance audits, also known as UKVI compliance visits, are inspections to ensure sponsors meet their duties under the Immigration Rules. These duties include accurate record-keeping, timely reporting via the Sponsor Management System (SMS), and preventing illegal working. Audits can be pre-licence (before granting a Sponsor Licence) or post-licence (to monitor ongoing compliance). Non-compliance can result in licence downgrade, suspension, revocation, or civil penalties up to £20,000 per illegal worker

Triggers for Visits

Compliance visits can be triggered by various factors, including:

• Pre-Licence Concerns: Doubts about the organization's ability to comply or verify application details.‍
• Post-Licence Issues: Late SMS reporting, intelligence from government agencies, anonymous tips, or suspected breaches (e.g., illegal working)‍
• Routine Monitoring: Random selections or risk-based targeting, especially for high-risk sectors or sponsors with prior issues.‍
• Specific Red Flags: Changes in company structure, high worker turnover, or non-compliant roles (e.g., below RQF Level 6)
  

Compliance Action: Monitor SMS reports and internal audits to address potential triggers proactively.

Types of Visits

Home Office visits vary in format and notice:

• Announced Visits: Scheduled in advance, allowing preparation time.
• Unannounced Visits: Surprise inspections to assess real-time compliance.‍
• Desk-Based Audits: Remote reviews requiring document uploads within 5–10 working days, followed by calls or further requests‍
• On-Site Inspections: Involve officers examining files, interviewing staff and workers, and verifying HR systems

In 2025, digital compliance inspections have been introduced, focusing on remote and hybrid work arrangements.

Key Areas of Focus in 2025

Audits in 2025 emphasize stricter enforcement, with key checks including:

• Record-Keeping: CoS assignments, payslips, contracts, and right-to-work documents retained for sponsorship duration plus 1 year
• Reporting Duties: Timely SMS updates for worker changes (10 working days) and organisational changes (20 working days), including hybrid/remote work.‍
• Right-to-Work Checks: Pre-employment and annual verifications, transitioning to eVisa share codes by 2026‍
• Job Compliance: Roles meet RQF Level 6 or Temporary Shortage List criteria, with salaries at £41,700 (Skilled Worker) or £48,500 (GBM Senior/Specialist)‍
• HR Systems: Robust processes for monitoring workers, preventing illegal working, and training key personnel‍
• New 2025 Measures: Prohibition on passing CoS fees to workers, offshore worker duties, and extended action plans (up to 24 months) for breaches.‍
• Internal Audit Action: Focus audits on these areas, incorporating 2025 updates like longer cooling-off periods (24 months for revocations).

Preparation Steps: Audit-Ready Checklist

To prepare for visits:

1. Review Policies and Procedures: Ensure HR policies cover sponsored worker management, right-to-work checks, and SMS reporting. Update for 2025 changes (e.g., hybrid work reporting)

2. Train Staff: Educate key personnel (Authorising Officer, Level 1 Users) on duties and audit processes. Include eVisa verification training

3. Conduct Mock Audits: Simulate visits with internal reviews of records, interviews, and HR systems. Address gaps promptly

4. Organize Records: Maintain digital files for CoS, payslips, contracts, and right-to-work evidence. Ensure accessibility for desk-based audits

5. Verify Job Compliance: Check roles against RQF Level 6 and salary thresholds. Document recruitment practices

6. Prepare for eVisa: Assist workers with UKVI accounts for share code verification by 2026

7. Use HR Software: Automate tracking of deadlines, records, and reports to ensure compliance.

Compliance Action: Develop a checklist and schedule quarterly mock audits to stay prepared.

During the Visit

• Cooperate Fully: Provide access to premises, records, and staff. Be honest and responsive‍
• Have Key Personnel Available: Ensure AO and Level 1 Users are present or contactable‍
• Document the Visit: Note questions asked and information provided for post-visit follow-up.‍
• Internal Audit Action: Designate a lead contact for visits to coordinate responses.

Post-Visit Actions

• Review Feedback: Address any issues raised, such as action plans for minor breaches (now up to 24 months)‍
• Implement Improvements: Update processes based on findings to prevent future issues.‍
• Appeal if Necessary: Challenge penalties or sanctions within 28 days if applicable
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Compliance Action: Log post-visit actions in HR systems for audit trails.

Common Pitfalls and How to Avoid Them

• Incomplete Records: Avoid by using digital storage and regular spot-checks‍
• Late Reporting: Mitigate with automated SMS alerts‍
• Non-Compliant Roles: Verify against 2025 rules during onboarding‍
• Untrained Staff: Provide ongoing training to bridge knowledge gaps
  

Internal Audit Action: Include pitfalls in audit frameworks to proactively identify risks.

Conclusion

HR immigration compliance audits in 2025 demand proactive preparation from internal audit and compliance officers. By understanding triggers, focusing on key areas like record-keeping and eVisa transitions, and implementing checklists and mock audits, teams can navigate Home Office visits successfully. Robust systems and training will mitigate risks, ensure licence retention, and support compliant workforce management.

Disclaimer‍

Immigration laws and policies change frequently and may vary by country or nationality. While we strive to provide accurate and up-to-date information, we recommend doing your own due diligence or consulting official sources. You are also welcome to contact us directly for the latest guidance. Jobbatical is not responsible for decisions made based on the information provided.

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