If UK Visas and Immigration (UKVI) asked to see your sponsored worker records tomorrow, could you confidently provide everything required?
Assigning a Certificate of Sponsorship (CoS) and reporting changes are important sponsor responsibilities. But the records you keep throughout sponsorship are just as important.
Appendix D of the Home Office’s sponsor guidance sets out the documents sponsors must retain. Missing or incomplete records can lead to compliance action, potentially affecting your sponsor licence and your ability to employ sponsored workers.
For HR teams, the priority is having a clear, consistent process that keeps records accurate, accessible and up to date.
What is Appendix D?
Appendix D explains the record keeping duties for sponsors on Worker and Temporary Worker routes, including Skilled Worker. It covers the documents sponsors must hold and how long they must retain them.
The requirements span several areas, from right to work checks and recruitment evidence to salary payments and professional qualifications. The documents needed will depend on the worker’s route and circumstances.
For Skilled Worker sponsors, these records help demonstrate that the role meets the relevant requirements, the individual is suitable for it and the organisation is meeting its ongoing sponsor duties.
Why does sponsor record keeping matter?
During a compliance visit, UKVI may ask you to produce evidence of the checks you have completed and the arrangements in place for sponsored workers.
Having carried out the right checks is only part of the picture. You also need records that demonstrate what you checked, when you checked it and what the outcome was.
For example, a right to work check may have been completed correctly, but if the result cannot be located, your organisation may struggle to demonstrate compliance.
Paper and electronic records are both permitted, provided you can make them available to UKVI on request. The practical question is whether your team can retrieve a complete file promptly, including when the person who normally manages sponsorship is unavailable. Read more about understanding your wider sponsor licence duties.
What records must Skilled Worker sponsors keep?
The following areas provide a useful starting point. They should be checked against the current guidance and any requirements specific to your sponsored workforce.
- Right to work checks
Sponsors must retain evidence of compliant right to work checks completed before work begins, together with any follow-up checks required.
For online checks, use the official “Check a job applicant’s right to work: use their share code” service. Checking immigration status through a different Home Office service does not fulfil the same requirement.
Your process should make clear who completes checks, where the evidence is stored and how follow-up dates are monitored.
- Date of entry checks
Where you sponsored a worker’s entry clearance application, you must check that they entered the UK within their visa’s validity period.
The evidence required depends on their circumstances. Where there is an entry stamp, retain the relevant copy. Where there is no stamp, check travel evidence and record the entry date; Appendix D does not generally require you to retain the travel evidence itself.
This date of entry check does not apply to in-country extensions or switches, although right to work checks remain necessary.
- Recruitment evidence
The removal of the Resident Labour Market Test for Skilled Workers does not remove the need to explain how you recruited the individual.
Where you advertised, retain the advert details, applicant and shortlist numbers, and evidence of your selection process. Where you did not advertise, you must be able to explain how you identified the worker as suitable.
Keeping this information at the point of recruitment is much easier than reconstructing a decision months later.
- Salary and payment records
Your records must demonstrate what the worker is paid and support compliance with the relevant sponsorship requirements.
This includes payslips, evidence of salary payments and the relevant employment contract or written particulars.
HR and payroll should work together to ensure records are consistent. Changes to pay, hours or working arrangements should also prompt consideration of any wider sponsorship implications.
- Evidence of the role and the worker’s suitability
Sponsors should hold a detailed job description setting out the role’s duties, responsibilities and required skills, qualifications and experience.
Relevant qualifications, references and professional registrations may also be required.
These records should support the role described when sponsorship was assigned. As a practical safeguard, review the immigration implications before making significant changes to a sponsored worker’s duties.
- Other supporting records
Depending on the circumstances, additional records include:
- Evidence of the worker’s National Insurance number.
- An up-to-date history of their contact details.
- Absence records.
- A DBS check where required for the role.
- Evidence that you have provided information about UK employment rights.
- Any further documents required by the relevant route guidance.
An onboarding checklist is helpful, but it needs to be supported by a process for maintaining records throughout sponsorship.
How long must sponsorship records be kept?
Unless a different requirement applies, Appendix D requires records to be retained throughout sponsorship and then until the earlier of:
- One year after sponsorship ends.
- The date a compliance officer examines and approves the documents, where this falls within that year.
Documents supporting your sponsor licence application must be kept for the duration of the licence.
Separate legal requirements may require longer retention. Your retention policy should therefore account for right to work, employment, tax and data protection obligations before records are deleted.
Three checks to strengthen your approach
A practical review can help identify gaps before they become harder to resolve.
- Are your files complete?
Review a sample of sponsored worker files against the current requirements. Check that the evidence is present, readable and relevant to the individual. - Do your records tell a consistent story?
Compare recruitment documents, job descriptions, contracts and payroll information. Investigate discrepancies and consider whether changes require immigration advice or reporting. - Can your team keep the process running?
Assign clear responsibilities, train the people involved and provide cover for absence or staff changes. Secure central storage and scheduled reviews can help prevent records becoming fragmented across inboxes and departments.
