Spring 2026 changes UK sponsor licence holders should be aware of

Thursday 26 March

The UK Government has announced this month several significant changes to its guidance for sponsors (effective immediately), as well as changes to the UK Immigration Rules (which take effect in early April).

We expect more clarity on some of these in the next few weeks and we have also asked UK Visas and Immigration (UKVI) for certain clarifications, which if helpful we will feed back to our clients. In the meantime, employers with a UK sponsorship licence should be aware of the following important changes and amend their practices so that they continue to be compliant with their sponsor duties.

The background to these changes is a continued rise in enforcement activity by UKVI.

You can use the form below or click here to contact us if you would like us to organise some training on these new measures and to ensure your practices are fully complaint with the most up to date sponsor guidance and Immigration Rules.

The important changes to be aware of are as follows:

Awareness of employment rights

Sponsors have a responsibility to comply with wider UK law, including UK employment law. The guidance has now been updated to specifically require sponsors to ensure their workers understand their employment rights. This includes but is not limited to:

• entitlement to National Minimum Wage
• compliance with Working Time Regulations
• pension auto-enrolment and opt-outs
• entitlement to statutory leave and pay
• health and safety
• trade union memberships
• your duties under the Equality Act
• how to raise grievances

Major change to the scope of right to work checks

The sponsor guidance has been updated to suggest that sponsors must now conduct right to work (RTW) checks where they are employing “or engaging” a worker (whether sponsored or not) – this potentially extends the scope of your duty to carry out right to work checks to all workers, not just direct employees as was the case previously. UKVI has also now stated that where you are employing or engaging a worker who does not have the right to work in the UK, your sponsor licence will normally be revoked. This is significant, because most employers will not have been carrying out right to work checks on self-employed workers and will be unaware of their status – it has not been a requirement to do so and failure to do so has no consequences under current legislation relating to illegal working.

At this stage it is unclear what the scope of this change will be, as the term “engaging” has not been defined within UKVI guidance or the rules.  We have reached out to UKVI for clarification as this places a significant burden on sponsors. Where sponsors are engaging self-employed workers, there is limited scope to protect against the loss of their licence if a self-employed worker is found not to have the right to work, with the only reprieve being that this is a discretionary ground for revocation. As such, for the time being, we would recommend carrying out RTW checks on all workers (whether employed by you or not directly employed by you, e.g. self-employed, secondees etc.) to mitigate this risk as much as possible and screen out anyone you are engaging who does not have the right to work in the UK.

We will update this page regarding any further clarification we receive from the UKVI. Please contact us if you require assistance in the meantime.

All the above changes are effective immediately.

How pay periods meet salary minimums

The Immigration Rules on payment of Skilled Workers will be updated on 8 April 2026. From this date, a worker must be paid the required salary or above for sponsorship in monthly or less frequent pay periods, or as otherwise specified in their contract. Salary must meet the going rate for the occupation code each hour worked during each pay period and the average salary must meet the required amount across any three-month period for monthly or less frequent pay periods, or in any 12-week period in more frequent pay periods (rather than over a year as was previously the case).

If the amount sponsored Skilled Workers are paid differs between pay periods, there are new rules regarding how UKVI will determine salary across a longer working pattern and also how UKVI will consider situations where a person repays their employer for certain immigration costs.

Where a worker is paid the same amount each regular pay period and the total annual amount meets the requirements, this is unlikely to be affected by the new rules.  Examples where this could require changes by sponsors are where the pay amounts or periods are irregular or longer, such as when someone is paid less often than monthly or where pay is weighted differently due to shift working or annual salary being front- or back-loaded in the year (although it is important to note that UKVI does not recognise golden handshakes, parachutes or bonuses as eligible for meeting the salary requirement).  The aim of the rule is to allow UKVI to assess whether a worker is being paid enough more quickly and so they do not need to wait to see if it averages out over a year.

If this applies to any of your sponsored workers, it may be worth taking advice from an immigration practitioner.

Increased Home Office enforcement and the importance of reporting changes

The backdrop to these changes is an increase in UKVI enforcement action. The number of UK employers losing their licence to sponsor migrant workers tripled at the end of 2025. More than 1,500 employers were stripped of their sponsor licence between October and December, up from 541 in the previous three months. A total of 3,100 revocations during 2025 was the highest since records began in 2012.

Enforcement has particularly focused on certain sectors such as social care, hospitality, retail and construction, with common issues including underpayment, poor record-keeping and worker exploitation – all issues that the above measures are targeting. However, this sharp increase is the result of the UKVI’s intensified approach to compliance.

The Home Office increasingly relies on data-sharing across government systems (including HMRC, PAYE and Companies House) to identify compliance concerns, rather than traditional site visits. As a result, minor breaches, particularly around reporting duties and salary compliance can have serious implications. Errors in pay calculations, such as allowances, deductions or working hours, can be a key trigger for enforcement action.

It is therefore essential to ensure that systems, record-keeping and reporting processes are accurate, up to date and proactively managed in order to minimise risk.

What you can do to protect yourself and how we can help

These changes introduce stricter compliance expectations around sponsorship and right to work checks. We would recommend you conduct an immediate audit of your right to work check procedures. You may also wish to move beyond “contract salary” checks and monitor actual pay across pay periods.

You may also want to review employment contracts, handbooks and documents provided to workers to ensure that they are informed of their rights as mentioned above.

If you have any concerns regarding how the above changes may impact your organisation or you would like us to provide training on adhering to sponsor duties and compliance and/or a compliance health check, please feel free to contact us.