Home Office Compliance Visit: What UKVI Checks and How to Prepare
Most employers meet their sponsor duties in good faith. The problem is that "good faith" is not the test. What the Home Office tests is whether your records, your systems and your people can withstand an inspection, and it can run that inspection at any time, with no warning at all.
Last reviewed 11 October 2026 · 10 min read
Licence audits and compliance visits
Mock audits and getting ready for a Home Office visit.
Find out moreIf a compliance officer arrives tomorrow morning, could your HR team produce a right to work check for every sponsored worker, dated before their employment started, within the hour? If the answer is “probably”, this article is for you.
This is a practical guide for employers, not a legal textbook. We define the jargon as we go, quote the Home Office guidance by paragraph number so you can check it yourself, and set out exactly what happens after a visit, including the point at which a fixable problem becomes a lost licence.
Where this comes from. Everything below is drawn from Workers and Temporary Workers: guidance for sponsors, Part 3: sponsor duties and compliance (version 08/26, published 28 August 2026, page last updated 2 September 2026), checked on 11 October 2026. Sponsor guidance changes frequently. Confirm the version in force before you rely on any point here. This is general information, not legal advice.
What is a Home Office compliance visit?
A compliance check is UKVI’s process for testing whether you are meeting your sponsor duties. A compliance visit is the version where an officer physically attends your premises. There is also a digital compliance check, which is the same interview conducted over remote video conferencing (C7.14).
A compliance check can involve any of the following (C7.6):
- asking you for additional documents or information
- verifying documents and information you have already provided
- visiting you on-site
- conducting a digital compliance check by remote video conferencing
- making checks with other government departments, agencies or local authorities
- considering other information that comes to light, including allegations from members of the public
Two points employers routinely miss.
First, UKVI makes regular checks with HMRC to confirm you are actually paying your sponsored workers what you said you would (C7.7). Your payroll data and your Certificate of Sponsorship must tell the same story. They compare.
Second, a check can be triggered by a reasonable suspicion that you have breached your duties, and that suspicion can be based on a poor compliance record with other government departments, not just the Home Office (C7.4).
Announced or unannounced, and before you even hold a licence
“We may check sponsors at any time, including before we make a decision on your licence application or after your licence has been granted. If we conduct a compliance check which involves visiting or interviewing you, this can be on an announced or an unannounced basis.” — C7.9
There is no notice period you are entitled to, and no option to ask them to come back when your HR manager is in.
The third-party premises trap
If your sponsored workers carry out their duties at a client’s or contractor’s site, you must make that third party aware that UKVI may turn up unannounced at their premises, and you must secure their cooperation. If the third party is uncooperative, UKVI takes action against you (C7.10), not against them.
This is a live risk for consultancies, staffing businesses, care providers delivering in other settings, and any employer with workers embedded at client sites. If you have never had that conversation with your clients, you are carrying an exposure you have not priced.
What a UKVI compliance officer actually does on the day
The officer may (C7.15):
| What they do | What it really tests |
|---|---|
| Verify information from your licence application, including photographing your premises | Are you genuinely trading from where you said you were? |
| Verify information given in support of any worker’s visa application | Does the CoS match reality? |
| Check you are complying with all sponsor duties | Systems, not intentions |
| Speak to sponsored workers, including ones you sponsored in the past | Does the worker describe the job on the CoS? |
| Speak to employees involved in recruitment | Was the vacancy genuine? |
| Inspect records and systems against Appendix D | Can you produce documents on demand? |
| Check other (non-sponsored) workers for illegal working | Right to work compliance across the whole workforce |
| Run criminal record and civil penalty checks on directors, Key Personnel and others associated with you | Suitability |
Three practical points:
They may interview your workers separately. The most common way a licence unravels is not a missing document. It is a sponsored worker describing duties, hours, location or pay that do not match the Certificate of Sponsorship. Brief your workers on what their CoS says; that is not coaching, it is making sure the record is accurate
They will not tell you how it went. “The compliance officer will not give an indication of their assessment or your ability to comply with sponsor duties during the compliance check” (C7.18). Silence on the day means nothing. The decision comes later, in writing (C7.23).
Verify the officer’s identity. Any officer, or third party acting for the Home Office, will carry official Home Office identification. If you doubt they are genuine, call 0300 123 4699 (C7.19).
You must also allow full access to any premises under your control on demand (C7.10), and abusive, intimidating or threatening behaviour towards officers will not be tolerated (C7.11). Refusing entry is not a strategy; it is itself a breach.
What happens after a Home Office compliance visit: the four outcomes
This is the part employers understand least, and it is where the money is. After the check, UKVI decides what action to take and notifies you in writing (C7.23).
Outcome 1: no action
You continue as an A-rated sponsor.
Outcome 2: sponsor licence B-rating plus an action plan
Where the breach is “a relatively minor issue and you are willing and able to correct it”, UKVI will in most cases downgrade you to a B-rating and issue a time-limited action plan (C7.25).
A B-rating is not a slap on the wrist. What it actually costs you:
| Consequence | Detail | Source |
|---|---|---|
| You cannot sponsor anyone new | No new CoS until you sign up to the action plan, pay the fee, and have your A-rating restored | C8.11 |
| The fee | £1,579 for an action plan | GOV.UK, Your licence rating |
| The deadline | Pay within 10 working days of the decision letter, via SMS. Do nothing, and your licence is revoked | C8.14 |
| The duration | Fixed at 3 months. Not negotiable | C8.17 |
| No new branches or routes | Frozen for the action plan period | C8.15 |
| Existing workers | You may still assign a CoS to a worker you already sponsored who needs to extend | C8.15 |
Before downgrading, UKVI writes to you with the proposed action and reasons, and gives you 20 working days to respond in writing. There is no oral hearing (C8.6–C8.7).
At the end of the three months there are three possible outcomes (C8.18):
You have not met the plan → licence revoked.
New areas of non-compliance emerge → a second action plan, and a second fee.
You have met everything and there are no other concerns → A-rating restored.
The hard limit most employers do not know: you can be B-rated twice in any rolling 4-year period, measured from the date your licence was first granted. If you meet the downgrade criteria a third time, UKVI will revoke (C8.22–C8.24). And if you use a CoS to sponsor a new worker while B-rated, your licence is revoked (C8.21).
Outcome 3: suspension
UKVI may suspend your licence while it makes further enquiries (C9.1). Suspension is where the damage starts to show outside your business:
- You cannot assign any Certificate of Sponsorship while the licence is suspended, and you must keep meeting every sponsor duty (C9.2).
- Your entry is removed from the public register of sponsors for the suspension period (C9.3). Clients, candidates and competitors can see that you have gone.
- Workers you already sponsor who hold valid permission are not affected unless and until the licence is revoked (C9.4). But UKVI will not decide applications made on a CoS you assigned before the suspension, or settlement applications you support, until the reason for the suspension is resolved (C9.20).
- You have 20 working days from the letter to respond in writing, setting out which grounds you think are wrong and why, with evidence. There is no oral hearing (C9.11). More time is given only in exceptional circumstances (C9.12). If you do not respond, UKVI goes ahead without you (C9.15).
- UKVI will normally decide within 20 working days of your response, unless the case is exceptionally complex (C9.17). The result can be reinstatement with an A-rating, reinstatement with a B-rating and an action plan, a bar on assigning new or unused CoS, or revocation (C9.16).
Outcome 4: revocation
Revocation ends your licence on every route you hold. You cannot sponsor anyone else, UKVI will normally cancel the permission of the workers you sponsor, and your details are removed from the register (C10.2). Any CoS you have assigned becomes invalid (C10.12), and entry clearance for workers who have not yet travelled is cancelled (C10.13).
Workers who were not involved in the reasons for revocation will normally have their permission cut to 60 calendar days, to find another sponsor or leave. A worker who was complicit loses all of their remaining permission (C10.10). UKVI tells your workers about the revocation, but not why (C10.15).
There is no right of appeal. You cannot apply for a new licence until at least 12 months after revocation, or 24 months if your licence has been revoked more than once (C10.3), and the wait can be longer where the revocation followed certain civil penalties or criminal convictions (C10.16). When you do apply again, you must show the reasons for the revocation no longer apply (L9.21). The only way to challenge a revocation is judicial review, which asks whether the decision was lawful, not whether it was harsh. A claim must be made promptly, and in any event within 3 months, and needs the court’s permission to proceed (Civil Procedure Rules 54.4 and 54.5).
Prevention is not the cheaper option. It is the only real option.
The grounds that end a licence
Annex C1 of the guidance lists “mandatory” grounds. If one of them arises, UKVI can revoke your licence immediately and without warning (C10.5). Two of them catch employers who never meant to break a rule:
- The job does not match the CoS. The role a sponsored worker actually does doesn’t match the occupation code or the job description on their Certificate of Sponsorship (Annex C1 s).
- You pay less than the CoS says. You pay a sponsored worker less than you said you would, without telling UKVI, and the reduction is not otherwise allowed (Annex C1 aa).
Annex C2 lists grounds on which UKVI will normally revoke. They include employing someone without permission to work after failing to do the right to work checks, failing to co-operate with a compliance check, and failing to provide documents when asked and within the time allowed (Annex C2 d, e and g). Recouping the licence fee, CoS fee or Immigration Skills Charge from a worker will also normally lead to revocation (L6.17).
Right to work: where the two regimes meet
Right to work checks are a separate legal duty from your sponsor duties, and they apply to your whole workforce, not just sponsored workers. To have a “statutory excuse” against a civil penalty, you must do one of the prescribed checks before the person starts work, and a follow-up check, on or before the date their permission ends, for anyone with time-limited permission. Since 1 October 2026 the scheme also covers many people on worker’s contracts, individual sub-contractors and online matching services, for arrangements starting on or after that date.
The civil penalty is £45,000 per illegal worker for a first breach and £60,000 for a repeat breach within 3 years, before any reductions. For a sponsor, the penalty is rarely the end of it: if you are issued with a civil penalty, UKVI is likely to revoke your licence, and you will not be eligible for a new one until at least 12 months after you have paid the penalty in full (C7.30).
Keep two clocks separate. The initial check must be done and dated before the first day of work: a check done in week two is not a defence. The follow-up check must be diarised for every worker with time-limited permission. That second clock is where employers most often slip.
What to do the moment an officer arrives
- Have a named person greet the officer, and call your adviser straight away.
- Check and note the officer’s Home Office identification. If in doubt, call 0300 123 4699 (C7.19).
- Give full access to your premises and make personnel files and SMS access available without delay (C7.10). Don’t make access depend on your adviser arriving.
- Answer what you know. If you don’t know, say you will confirm in writing, rather than guessing.
- Keep a written note of what was asked, what was inspected and who was interviewed. If a letter follows, that note is the foundation of your 20-working-day response.
Where employers get caught
- Salary drift. A change in pay, role or location nobody reported. Many changes to a sponsored worker’s circumstances must be reported within 10 working days (C1.15), and payroll is checked against the CoS through HMRC (C7.7).
- The forgotten follow-up check. The first right to work check was perfect; the follow-up was never done.
- Key personnel who left. The Authorising Officer resigned months ago and the licence still names them.
- Records that exist but cannot be found. “On demand” means on demand.
- A role that quietly stopped being eligible after the July 2025 salary and skill-level changes. See our guide to Skilled Worker sponsorship after July 2025.
Our scope. We can review your compliance before a visit and help you prepare. If you receive a suspension or revocation letter, the written representations and any judicial review are work for a solicitor or a higher-level adviser, and we will refer you promptly, because the 20-working-day clock is already running.
You’ve reached the end. Want us to look at your own situation against the current rules?
Book a consultationThis article is general information, current at the date shown. It is not legal advice on your case.
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