Record Keeping Requirements for UK Visa Sponsors

Introduction

Every licensed UK sponsor has two parallel obligations: keeping the right records, and keeping them correctly. The Home Office treats gaps in documentation as evidence of non-compliance, regardless of whether the underlying activity was lawful. With nearly 2,000 licences revoked in 2024–25 and compliance visits rising, this guide covers exactly what you must keep, how long you must keep it, and the most common record-keeping mistakes that lead to enforcement action.

1. Records Employer must keep - Appendix D requirements

Appendix D of the Home Office's Worker and Temporary Worker sponsor guidance sets out the mandatory records for every sponsored worker. There are four core categories:

Right-to-work documents

• A clear copy of the worker's current passport (photo page and any relevant visa/entry stamps).
• eVisa share code verification record, including the date checked and the checking service reference. From 31 December 2026, this replaces the BRP as the valid right-to-work document for non-UK nationals.
• For workers with time-limited permission, date of next re-verification (share codes expire every 90 days).

Certificate of Sponsorship (CoS) records

• The CoS reference number assigned to the worker.
• The job title, SOC code, salary, and start date recorded on the CoS.
• Any subsequent CoS issued if the worker changed role or employer.

Employment and payroll documents

• Signed employment contract or written terms of employment.
• Payslips or payroll records confirming salary paid each pay period  particularly important as salary is now monitored on a per-pay-period basis from April 2026.
• Records of any changes to working hours, salary, or location - and evidence that these were reported to UKVI within the 10-working-day deadline.
• Absence records for sponsored workers, including any unpaid leave that triggered a salary change reportable obligation.

Contact and personal details

• Worker's current UK address and phone number - updated whenever they move.
• Worker's emergency contact details.
• National Insurance number (once issued).

Appendix D is updated periodically. Check gov.uk/uk-visa-sponsorship-employers for the current version  do not rely on a printed copy from more than 6 months ago.

2. How long employer must keep Sponsorship Records

3. The eVisa transition and what it changes for record-keeping

From 31 December 2026, physical Biometric Residence Permits (BRPs) are no longer valid for right-to-work checks. This changes what you must record and how:

• Stop storing BRP copies as your primary right-to-work evidence. After the transition, eVisa share code verification records are the required document.
• Record the date of each eVisa check, the share code used, and the result. This is your statutory excuse if a worker's status is later questioned.
• Build a recurring 90-day re-verification schedule — eVisa share codes expire, and an out-of-date check does not provide statutory excuse.
• Ensure your document storage system can log verification records with timestamps and user details - a spreadsheet entry without a date is not sufficient evidence during an audit.

Workers who have not yet set up a UKVI online account cannot generate a share code. Make UKVI account setup part of your onboarding checklist - do not leave it until visa renewal time.

4. Sponsor record-keeping mistakes  and how to fix them

These are the failures the Home Office finds most often during compliance visits. Each one is avoidable with the right systems in place.

Mistake: Keeping BRP copies instead of eVisa verification records post-transition.

✔ Fix: Conduct a full audit of your right-to-work files before 31 December 2026. Replace any BRP copy with an eVisa share code verification record for every current sponsored worker.

Mistake: Records stored in individual email inboxes or local drives  inaccessible when that person leaves.

✔ Fix: All sponsor compliance records must be held in a shared, access-controlled cloud system. When a Level 1 User or HR manager leaves, records must remain retrievable.

Mistake: No record of the date a right-to-work check was performed -just a scan of the document.

✔ Fix: Every right-to-work check must be logged with the date it was carried out, the document(s) or share code checked, and the name of the person who performed it.

Mistake: Payslip records don’t reflect the salary on the CoS - bonuses or deductions have shifted the effective pay below the threshold.

✔ Fix: Salary compliance is now assessed per pay period. Run a monthly comparison of actual pay vs the CoS salary threshold for every sponsored worker. Flag and report discrepancies immediately.

Mistake: Worker’s address and contact details haven’t been updated since they joined  they moved 18 months ago.

✔ Fix: Add an annual contact detail re-confirmation step to your sponsored worker compliance calendar. UKVI expects you to hold current information.

Mistake: Records for workers who left are deleted once the employment ends.

✔ Fix: Retain all records for the required trailing period (sponsorship duration + 1 year minimum). Set deletion dates in your document management system  do not delete on departure.

Mistake: Shared SMS login credentials between multiple HR staff members.

✔ Fix: Every SMS user must have their own login. Shared credentials are a compliance violation. Remove access immediately when a user leaves  dormant accounts with active permissions are flagged at audit.

5. Making sponsor records audit-ready

A Home Office compliance visit  announced or unannounced  can happen at any time. The sponsors who handle them without incident are those who treat their records as live documents, not archive files.

Quarterly record-keeping checklist

• All sponsored worker files contain: current CoS reference, right-to-work verification record (eVisa, dated), signed contract, payslips for the past 12 months, and current contact details.
• eVisa share code records are dated and within the 90-day validity window.
• Payslip records for every sponsored worker confirm salary at or above the CoS threshold for each pay period.
• Absence records are current and any absence-triggered reporting has been completed in the SMS within 10 working days.
• Records for former sponsored workers are retained and accessible - not archived to personal drives or deleted.
• Document storage access is limited to current, named staff - no shared logins, no departed employee access.

If you find a gap during an internal audit, report it proactively through the SMS and document that you did so. Voluntary disclosure is treated more favourably than failures identified by the Home Office.

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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