Record Keeping Requirements for UK Visa Sponsors

Introduction

For data management professionals and compliance officers, meticulous record keeping is a cornerstone of maintaining a UK Sponsor Licence and ensuring compliance with UK Visas and Immigration (UKVI) regulations. Proper documentation supports the employment of non-UK nationals under routes like the Skilled Worker or Global Business Mobility (GBM) visas, while safeguarding against penalties during Home Office audits. With the full rollout of eVisas from January 2026 and ongoing stricter enforcement as per the May 2025 Immigration White Paper, Restoring Control over the Immigration System, robust record-keeping systems are essential. This guide details mandatory record-keeping requirements, retention periods, audit preparation, and best practices for 2026 compliance.

Why Record Keeping Matters

Effective record keeping ensures compliance with Sponsor Licence obligations, facilitates Home Office audits, and mitigates risks of penalties, including fines up to £20,000 per illegal worker or licence revocation. Key benefits include:

• Audit Readiness: Organized records streamline responses to unannounced or desk-based audits.
• Compliance Verification: Documents prove adherence to salary thresholds, right-to-work checks, and reporting duties.
• Penalty Avoidance: Proper records prevent sanctions like licence suspension or revocation (1,948 revocations from July 2024 to June 2025).
• eVisa Implementation: Digital records now fully support verification via eVisa share codes.

Data Management Action: Prioritize secure, accessible record-keeping systems to align with 2026 digital regulations.

Mandatory Record-Keeping Requirements

UKVI mandates sponsors to maintain specific records for all sponsored workers and organizational details, as outlined in Appendix D of the Sponsor Guidance (version November 2025).

1. Sponsored Worker Records

Sponsors must retain the following for each worker under routes like Skilled Worker or GBM:

• Certificate of Sponsorship (CoS):
  • CoS reference number, job title, salary, and duration.
  • Evidence of compliance with RQF Level 6 or Temporary Shortage List criteria.
• Right-to-Work Documents:
  • eVisa share codes or UKVI account verification details (mandatory for new applications from 15 January 2026; legacy Biometric Residence Permits (BRPs) or passport vignettes valid until expiry).
  • Records of pre-employment and annual right-to-work checks.
• Employment Records:
  • Employment contracts detailing role, salary (£41,700 for Skilled Worker, £48,500 for GBM Senior/Specialist), and work location.
  • Payslips showing salary payments, aligned with CoS details.
  • Absence records for leaves exceeding 4 weeks (except maternity/paternity).
• Recruitment Evidence:
  • Job advertisements, CVs, or interview notes proving genuine vacancy.
  • For GBM routes, proof of 12-month prior employment (or 3 months for graduate trainees) with the overseas entity.
• Qualification Documents:
  • Certificates or transcripts for roles requiring specific qualifications (e.g., RQF Level 6).
  • English language test results (CEFR B2 for Skilled Worker, effective 8 January 2026).

2. Organizational Records

Sponsors must maintain records to prove operational legitimacy and compliance:

• Sponsor Licence Documents:
  • Licence application records, including submission sheets and supporting documents (e.g., Companies House registration, VAT certificate).
  • Details of key personnel (Authorising Officer, Key Contact, Level 1 Users).
• Financial Records:
  • Bank statements, audited accounts, or tax records to demonstrate solvency.
  • Evidence of company size (e.g., ≤50 employees, £15M turnover for small sponsor status).
• Corporate Linkage (GBM Routes):
  • Shareholder agreements or organizational charts proving linkage between UK and overseas entities.
• Compliance Systems:
  • HR policies for monitoring workers, reporting changes, and conducting right-to-work checks.
  • Records of SMS reporting (e.g., worker or organizational changes).

3. Retention Periods

• Sponsored Worker Records: Retain for the duration of sponsorship plus 1 year, or until a Home Office audit is completed, whichever is longer.
• Right-to-Work Records: Retain for employment duration plus 2 years.
• Organizational Records: Retain while the Sponsor Licence is in force plus 1 year after surrender or revocation (licences no longer require renewal and remain active indefinitely unless revoked).

Compliance Action: Create a record retention schedule in data management systems to meet UKVI requirements.

2026 Compliance Considerations

The 2026 regulatory landscape builds on 2025 changes with a focus on digital transformation:

• Stricter Audits: Increased inspections emphasize salary compliance (£41,700/£48,500), hybrid work reporting, and eVisa verification via share codes.
• Full eVisa Implementation: From 15 January 2026, all new visas are digital; records must prioritize eVisa share codes and UKVI account details for right-to-work checks.
• RQF Level 6 Rules: Document job roles to prove degree-level standards or Temporary Shortage List eligibility.
• Fee Documentation: Retain records of CoS (£525), Immigration Skills Charge (£1,320/year for large sponsors, Skilled Worker; increased from 16 December 2025), and Immigration Health Surcharge (£1,035/year).

Data Management Action: Update record systems to fully integrate eVisa data, B2 English proofs, and elevated ISC details.

Penalties for Non-Compliance

Failure to maintain or produce records risks severe consequences:

• Licence Downgrade: B-rating with a £1,476 action plan, halting new CoS issuance.
• Licence Suspension: Temporary stop to sponsorship activities, risking visa curtailments.
• Licence Revocation: Permanent loss, with a 12-month reapplication ban and £525/CoS losses.
• Civil Penalties: Up to £20,000 per illegal worker for failed right-to-work checks.
• Criminal Penalties: Up to 7 years’ imprisonment for knowingly employing illegal workers.

Compliance Action: Quantify penalty risks (£20,000–£100,000 for multiple violations) in data management audits to justify robust systems.

Best Practices for Record Keeping

1. Implement Digital Systems:
   • Use HRIS platforms (e.g., Workday, SAP SuccessFactors) to store CoS, right-to-work, and employment records securely.
   • Ensure cloud-based backups with encryption and audit trails.
2. Automate Compliance Tracking:
   • Integrate HRIS with SMS for real-time CoS and reporting updates.
   • Set automated alerts for right-to-work checks and retention deadlines.
3. Conduct Regular Audits:
   • Perform quarterly internal audits to verify record completeness and compliance with RQF Level 6, salary rules, and B2 English standards.
   • Simulate Home Office visits to test record accessibility.
4. Centralize Record Management:
   • Create a compliance hub for CoS, right-to-work, and organizational records, accessible to key personnel (Level 1 Users, Authorising Officer).
   • Use standardized naming conventions (e.g., “WorkerName_CoS_2026.pdf”).
5. Leverage Full eVisa Integration:
   • Routinely store eVisa share codes and UKVI account details in HRIS.
   • Train staff on online right-to-work verification processes for seamless digital checks.
6. Engage Experts:
   • Consult immigration advisors for complex cases (e.g., audit responses), budgeting £2,000–£5,000.
   • Partner with legal teams to validate record-keeping policies.

Data Management Action: Build a centralized HRIS module for record storage, integrating automation and audit tools.

Challenges and Mitigation Strategies

• Volume Overload: Managing records for multiple workers is complex. Mitigate with HRIS automation and bulk upload features.
• Incomplete Records: Missing documents risk audit failures. Use checklists and regular spot-checks to ensure completeness.
• eVisa Integration: Legacy BRP transitions may cause verification hiccups. Provide IT support and guidance for full digital adoption.
• Hybrid Work Reporting: Documenting remote work locations remains critical. Include work patterns in contracts and SMS reports.

Compliance Action: Incorporate challenges into data management workflows, prioritizing automation and training for 2026 digital mandates.

Conclusion

Record keeping is a critical function for UK visa sponsors in 2026, requiring data management and compliance officers to maintain comprehensive, accessible digital records for workers and organizations. By leveraging HRIS, automating compliance, and preparing for audits and full eVisa operations, teams can ensure adherence to UKVI rules and avoid penalties. Strategic record management supports seamless sponsorship and global talent mobility.

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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