Further Changes to sponsor guidance

6th May 2026 | Nelli Shevchenko | Immigration, Sponsor guidance, Employment rights

The Home Office updated its sponsor guidance on 9 March 2026 (effective immediately), with further changes effective 8 April 2026. The main four changes are worth paying attention to:

• Introduction of the eligible role test. The previous “genuine vacancy” requirement has been replaced with a broader eligible role test, applying across all sponsored routes. Roles must genuinely exist and be sustainable, match the duties, responsibilities and details on the Certificate of Sponsorship (“CoS”), meet all skill, salary and regulatory requirements, and be appropriate to the organisation’s business model and financial position. Failure is a mandatory ground for licence refusal or revocation.

• Increased scrutiny on salary compliance. Sponsors must ensure salaries are genuine, not artificially inflated, and financially sustainable relative to business turnover. From 8 April 2026, sponsored workers must be paid at or above the required salary in monthly or less frequent pay periods (or as otherwise specified in their contract), and the salary must meet the going rate for the occupation code for each hour worked during each pay period. The averaging window has tightened from 12 months to any 3-month period (monthly or less frequent pay), and from 12 months to any 12-week period (more frequent than monthly). UKVI has simultaneously expanded data-sharing with HMRC and Companies House, enabling digital compliance audits (often without notice) and allowing underpayment to be identified far more quickly.

• Greater emphasis on CoS accuracy. Strict alignment is now required between the CoS and the worker’s actual role. Job description, occupation code, duration and duties must accurately reflect reality; permitted changes must be reported within 10 working days; and mismatches or reporting failures are mandatory grounds for revocation.

• New worker welfare obligations. Sponsors must actively promote and evidence worker welfare by providing information on the National Minimum Wage and working time rules, statutory leave, pay and pension auto-enrolment and opt-outs, health and safety and equality rights, and trade union rights and grievance procedures. Evidence that this information has been provided must be retained in line with record-keeping duties under Appendix D.

To find out more contact Nelli Shevchenko, or the Immigration team.