From 6 March 2026, UKVI has introduced a significant compliance change for sponsor license holders. Employers sponsoring overseas workers must now actively inform sponsored workers of their UK employment rights – and crucially, retain evidence that they have done so.
This update to Appendix D: Record‑Keeping Duties signals a clear shift in the Home Office’s approach, placing greater responsibility on sponsors to demonstrate fair and lawful treatment of migrant workers.
What is the new sponsor duty?
For businesses relying on international talent, understanding and implementing this requirement is now essential to avoid compliance risk. Under the updated guidance, sponsors must:
- Ensure all sponsored workers are informed of their employment rights in the UK
- Keep verifiable records proving this information has been provided
- Skilled Worker visa
- Global Business Mobility (GBM) routes
- Minister of Religion
- International Sportsperson
- All Temporary Worker categories
Why has UKVI introduced this change?
The Home Office has been steadily tightening sponsor compliance obligations. This update aligns with broader enforcement priorities, including:
- Preventing exploitation of migrant workers
- Promoting fair and lawful employment practices
- Increasing transparency and accountability within the sponsorship system
- Protecting the integrity of the UK labour market
What employment rights must be communicated?
Sponsors must ensure that workers are informed of key UK employment protections, including:
- National Minimum Wage and National Living Wage
- Working time limits and rest breaks
- Protection from discrimination
- Rights relating to pay, holiday, sick leave, and family leave
- Health and safety standards
- Protection from unlawful wage deductions
- The right to join a trade union
- Access to grievance and disciplinary procedures
What evidence to sponsors need to keep?
While Appendix D does not prescribe a specific format, sponsors must be able to produce evidence on request. Examples of acceptable evidence include:
- Signed contracts of employment confirming the worker has received and reviewed information about their rights
- Induction materials such as employee handbooks, or onboarding packs containing employment rights content
- Email records, including delivery receipts, showing that appropriate information was provided
- Training records, such as attendance sheets or certificates from onboarding or rights‑awareness sessions
- Digital access evidence, including screenshots or system logs showing the worker accessed rights information via an intranet or portal
What are the risks of non compliance
Failure to meet this new duty can have serious consequences for sponsor licence holders, including:
- sponsor licence downgrade
- sponsor licence suspension
- full licence revocation
- loss of ability to sponsor migrant workers
- potential impact on current employees’ immigration status
UKVI expects sponsors to stay up to date with all guidance. Ignorance of updates is not accepted as a defence.
What this means for employers
This change represents a subtle but important shift. Sponsors are no longer just expected to comply with employment law – they must now actively ensure sponsored workers understand their rights.
For HR teams and compliance leads, this means:
- Reviewing onboarding and induction processes
- Updating employment documentation
- Implementing clear audit trails
- Training managers and internal stakeholders
