A Skilled Worker sponsor must be able to show the Home Office – not merely assert – that every sponsored role is appropriately skilled and paid correctly, and that each sponsored worker has the correct permission to work in the UK. The safest approach is to maintain a complete, current and auditable file for each sponsored worker, supported by reliable HR, payroll and recruitment systems.

The core requirements are found in Appendix D to the Workers and Temporary Workers sponsor guidance. Records may be kept on paper or electronically, but they must be readily available if the Home Office requests them, including during a compliance visit.

The essential records for each sponsored worker

1. Right-to-work and immigration records

Keep evidence that a compliant right-to-work check was completed before employment began and repeat the check where the worker has time-limited permission. Depending on the worker’s status, the evidence may be an online Home Office right-to-work check or the documents retained following a permitted manual check.

Do not assume that holding a sponsor licence replaces the statutory right-to-work process. Sponsorship and the prevention of illegal working are related but separate compliance obligations.

2. Recruitment records

The Skilled Worker route does not usually require a formal resident labour-market test, but sponsors must still retain evidence of any recruitment activity.

There is no general requirement to keep the CVs, application forms or interview notes of unsuccessful candidates under Appendix D. However, the data that you have to retain must be handled consistently with UK GDPR and the Data Protection Act 2018.

If the role was not advertised, retain a contemporaneous note and supporting evidence explaining the recruitment route – for example, prior lawful employment with the company, a speculative application, a university recruitment exercise, references, qualification checks or an interview.

3. The role, skill and qualification evidence

The job description should match the occupation code and the information stated on the Certificate of Sponsorship (CoS). Generic descriptions copied from an occupation-code list are poor evidence if they do not reflect the work actually performed.

4. Employment, salary and payroll records

Payroll records should reconcile with the salary, weekly hours and working pattern stated on the CoS. Changes to salary, hours, duties or work location should trigger an immediate internal sponsor-compliance review before they are implemented.

5. Personal, contact, attendance and safeguarding records

This can include the examples given below. However, please note that this list is not exhaustive:

• A complete history of the worker’s UK residential address(s), personal email address and telephone number. Current details alone are not enough: preserve the history of changes;
• A record of absences, whether maintained electronically or manually, supported by an attendance and absence-reporting system;
• A copy of a DBS check, if required for the role;
• For a sponsored worker under 18, the required parental or legal-guardian consent relating to the application, travel, reception and care arrangements;
• Evidence that sponsored workers received information about their UK employment rights.

Hybrid working patterns should also be documented. A move to fully remote contractual working, a new main office or a new client site may engage separate Sponsor Management System reporting duties.

How long must the records be kept?

Unless Appendix D states otherwise, worker-specific sponsorship documents must be kept throughout the sponsorship and until the earlier of:

• one year after sponsorship of the worker ends; or
• the date a Home Office compliance officer examines and approves the records, if that occurs less than one year after the end of the sponsorship.

Documents submitted with the sponsor licence application must be retained for as long as the organisation holds the licence. Other laws may require longer retention. In particular, right-to-work, payroll, tax, employment and safeguarding records should be assessed under their own statutory and operational retention rules. The sponsor guidance period is therefore a minimum compliance rule, and it does not mean that the record must necessarily be destroyed upon reaching the end of this period.

Common mistakes that may put your sponsor licence at risk

• Keeping a current passport or eVisa record but no dated evidence of the right-to-work check;
• Deleting the job advert or recruitment-platform data once the vacancy closes;
• Keeping only the successful candidate’s CV, with no evidence of the selection process;
• Using a generic job description that does not match the worker’s actual duties;
• Failing to reconcile payroll payments, contracted hours and CoS salary information;
• Overwriting old contact details instead of preserving a history of changes;
• Recording annual leave but not sickness, unpaid leave or unauthorised absence consistently;
• Treating record keeping as an HR-only function, without coordination between HR, payroll, line management and the sponsor licence’s key personnel.

Why does this matter?

Recent sponsor licence refusals, suspensions and revocations underline the Home Office’s increasingly exacting approach to sponsor compliance, including through unannounced compliance visits and detailed scrutiny of recruitment, right-to-work and payroll records. Sasha Lal, a solicitor at

Gherson who has recently been dealing with such matters, notes that sponsors should treat record-keeping as an active licence protection measure rather than a routine administrative exercise. A defensible file should allow an independent reviewer to reconstruct the recruitment decision, right-to-work check, sponsored role, pay, attendance and every material change without relying on an oral explanation.

Practical next step

Undertake a structured internal audit of your sponsor management systems and a representative
sample of sponsored worker files. Gherson’s specialist immigration team can assist by conducting a mock sponsor compliance audit, identifying areas of risk and helping the business implement a proportionate remediation plan before a Home Office compliance visit or sponsor licence application.

Frequently asked questions

Can sponsor records be stored electronically?

Yes. Appendix D permits paper or electronic records and does not prescribe a particular storage method. The decisive requirement is that the records are complete, secure and available promptly if the Home Office requests them.

How long must we keep a sponsored worker’s records?

Unless a specific rule says otherwise, keep them throughout the period of sponsorship and until either one year after the sponsorship ends, or the date a Home Office compliance officer examines and approves them, whichever is sooner. Other legal duties may require longer retention of documents.

Must we keep records for unsuccessful candidates?

Appendix D does not generally require application forms, CVs or interview notes for unsuccessful candidates, where no formal resident-labour-market test applies. You should still retain the advert, applicant and shortlisted candidates numbers along with sufficient evidence of the selection method. Any personal data retained must comply with data-protection requirements.

What if we did not advertise the role?

Record how the worker was identified, and why the company considered them suitable. Supporting evidence may include prior performance, interview notes, references, qualification checks, a speculative application or a university recruitment exercise.

Is a copy of the worker’s eVisa enough for a right-to-work check?

No. The file must evidence the prescribed right-to-work check itself, including the dated online result or the documents retained after a permitted manual check. Merely keeping immigration-status evidence does not prove that the employer completed a compliant check.

Do we need to keep former addresses and telephone numbers?

Yes. Appendix D requires a history of the worker’s UK residential address, personal email address and telephone number, and that this information is kept up-to-date. Systems should preserve previous details rather than overwrite them.

Are payslips sufficient evidence that salary was paid?

No. Keep payslips and separate evidence showing the amount and frequency of each payment into the worker’s named bank account or permitted prepaid card. Payroll and banking records should identify the individual worker and reconcile with the salary and hours stated on the CoS.

What should we do if an audit identifies missing records?

Recover reliable contemporaneous evidence where possible and create a dated remediation note recording the gap, the evidence recovered, the corrective action and the system change adopted. Never backdate or manufacture records. Consider whether the gap also reveals an unreported change or another sponsor duty breach requiring immediate action.

How Gherson can assist

Gherson’s Immigration Team are highly experienced in advising on all UK visa and immigration matters. If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

This article was first published in 2022 and has been updated in August 2026. 

©Gherson 2026