Important Updates
Important Updates
February 18, 2026 | United StatesUnited States: Quota for First of Three Supplemental H-2B Visa Allocations Is Reached for FY 2026
February 18, 2026 | Saudi ArabiaArabian Gulf Business Insight: Saudi Business Visa Rejections Rise as Scrutiny Tightens
February 18, 2026 | CanadaCanada: Biometrics Waived for Certain FIFA-Invited Visitors for 2026 World Cup
February 18, 2026 | Australia, New ZealandDoyle’s Guide 2026: Fragomen Leaders Recognized as Leading Immigration Lawyers
February 18, 2026 | Slovak RepublicSlovakia: New Digital Immigration Platform
February 18, 2026 | United StatesUnited States: Quota for First of Three Supplemental H-2B Visa Allocations Is Reached for FY 2026
February 18, 2026 | Saudi ArabiaArabian Gulf Business Insight: Saudi Business Visa Rejections Rise as Scrutiny Tightens
February 18, 2026 | CanadaCanada: Biometrics Waived for Certain FIFA-Invited Visitors for 2026 World Cup
February 18, 2026 | Australia, New ZealandDoyle’s Guide 2026: Fragomen Leaders Recognized as Leading Immigration Lawyers
February 18, 2026 | Slovak RepublicSlovakia: New Digital Immigration Platform
February 18, 2026 | United StatesUnited States: Quota for First of Three Supplemental H-2B Visa Allocations Is Reached for FY 2026
Subscribe
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Navigating Immigration Under the Second Trump AdministrationFragomen Consulting EuropeImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Navigating Immigration Under the Second Trump Administration
  • Fragomen Consulting Europe
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • Vietnamese Immigration
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
  • Insights

Is it time to make immigration compliance a priority agenda item for UK businesses?

September 12, 2022

London city main header

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Naomi Goldshtein

As the last two years have proven, continuity planning is a key agenda item for any business, with the ability to maintain an agile global workforce being paramount. For those businesses which hold UK a sponsor licence, this must include compliance with sponsor duties. 

The scenario

We were recently approached by a medium-sized business whose global mobility team was struggling to get buy-in from senior leadership when it came to providing resourcing and budget. Immigration compliance was a key concern for the team. When asked the question, “What impact would the loss of their sponsored workforce have on the business?” the response was, “Catastrophic.” Through more focussed discussions, specific concerns were raised regarding the business’ lack of investment into its immigration compliance obligations and failure to appreciate the risk to business continuity of possible consequential compliance breaches.  

Sponsorship compliance should not be taken lightly

Like many immigration regimes, the UK places a responsibility on its employers to know the identity of their UK workforce, whilst satisfying themselves that their UK employees have the right to work. For those familiar with the UK sponsorship system, a regime that keeps many sponsors on their toes, responsibilities for sponsor licence holders go much further than this.

In line with the UK Government’s Sponsorship Roadmap, published in August 2021, the updates made to the sponsor guidance on 22 August 2022 show the UK immigration system evolving further to digital processes. As digitisation plays a key part in the Sponsorship Roadmap, sponsors should be prepared for data to be shared between government departments more easily. Although we have seen the practice of data sharing as far back as 2008, especially in the identification of illegal working, the frequency and expansion into other uses is evident with these latest changes.

Compliance checks are now defined in two ways – an in-person “compliance visit” and a virtual “digital inspection.” The latter is expected to continue checking PAYE data against declared sponsored migrant salaries and publicly available documents from organisations such as Companies House, as previously, as well as other Governmental data which may be shared with UK Visas and Immigration (“UKVI”).

Reporting duties

An ongoing compliance obligation placed on UK sponsors is to track and monitor their sponsored workforce. Where there are changes in specific elements of an individual’s sponsored employment (work location, working hours, job title) these must be reported through the UKVI’s Sponsor Management System within 10 working days. Where there is deemed to be a significant change in the role, this may even result in a new Certificate of Sponsorship (“CoS”) being required, which means the employee must reapply for their status again before they can begin the new role.

Reporting is not just limited to changes in circumstances linked to the sponsored employee. Although linked entities by common ownership or control can also be listed on a licence, it is changes to the licence holding entity which the UKVI will keep an eye on. Changes in ownership, company status, and trading address must all be reported. With expectations that M&A activity is likely to increase, sponsors should also note the importance of assessing such activity against the ownership structure and implications for sponsor licences.

Similar to the sponsorship of an individual, where there are deemed significant changes to a sponsor’s ownership, a new licence may be required. While a sponsor is going through the steps of reapplying for a licence it is important for leadership to know that this could restrict sponsoring anyone new.   

Where there is a lack of reporting, identification of non-compliance by the UKVI was formerly a manual process. But as government departments sync and allow for data sharing, changes in sponsoring entity and employee work arrangements will be flagged more easily. No matter the size of the business, it is evident that this places pressure on sponsors to keep on top of their reporting duties and maintain robust in-house processes.

One size does not fit all

How a sponsor manages its compliance, in our experience, often depends on the size of the organisation, its internal network and the knowledge of those responsible for the licence. Where we have been approached by startups and SMEs experiencing compliance action from the UKVI, responsibilities linked to sponsorship compliance are commonly more centralised. Non-compliance often arises where there is a lack of understanding of general compliance requirements or due to loss of knowledge upon a change in personnel.

By comparison, larger sponsors often have sophisticated, established compliance processes where   key personnel possess detailed knowledge and have regular training. Nevertheless, when put under the microscope, lack of communication between departments or a lack of budget allocation can inadvertently result in oversights.

What are we seeing?

On 25 June 2020, we saw the Corporate Insolvency and Governance Act (the “Act”) receive Royal Assent. Experts across a wide range of practice areas welcomed this legislation, noting that both short- and long-term provisions within the Act made the UK an attractive restructuring hub.

Whether a direct correlation or not, we have supported unprecedented volumes of licence updates over the last two-year period and continue to witness trends in corporate restructuring that have a direct impact on sponsor licence holders. Sadly, not all are captured and reported within the required 20 working day time period as the impact of restructuring and the implications on a sponsor licence are often overlooked by senior leadership.

The UKVI will become aware of such changes in a licence holder’s structure through its increased use of digital resources. It is expected that the synchronisation of government departments will accelerate that identification, forcing sponsors to up their reporting game.

Whilst in-person UKVI compliance checks continue and are expected to remain the principle means of reviewing a sponsor’s compliance processes for the time being, the UKVI is transitioning into digital methods of compliance inspections, which will include virtual interviews and expansion of data-sharing in the detection of non-compliance.

What does this mean for sponsors?

We strongly encourage all sponsors to consider internal policies and whether any ‘house-keeping’ is required. This could be as simple as opening lines of communication amongst senior leadership to ensure proactive steps are taken and the sponsor licence and sponsored workforce remain secure.

Need to know more?

For further information and advice on this topic, please contact Director Naomi Goldshtein at [email protected] and Senior Associate Victoria Welsh at [email protected]. This blog was published on 12 September 2022, and due to the circumstances, there are frequent changes.

To keep up to date with all the latest updates on global immigration, please visit our dedicated COVID-19 site, subscribe to our alerts and follow us on LinkedIn, Twitter, Facebook and Instagram. 

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Media mentions

Arabian Gulf Business Insight: Saudi Business Visa Rejections Rise as Scrutiny Tightens

Partner Abeer Al Husseini discusses increased scrutiny of Saudi business visas in AGBI, highlighting stricter review of short-term entry used for operational work and the implications for regional employers.

Learn more

Awards

Doyle’s Guide 2026: Fragomen Leaders Recognized as Leading Immigration Lawyers

Australia and New Zealand Managing Partner  Teresa Liu, Partner Charles Johanes, Practice Leaders Hedvika and Leader Ben Lear and Senior Associate Hannah Scanlan are recognized in the 2026 edition of Doyle’s Guide as leading immigration practitioners in Australia.

Learn more

Awards

Fragomen Ranked Band 1 in the Chambers Global 2026 Guide

Fragomen is ranked Band 1 for Immigration: Business in the Chambers Global 2026 Guide, marking two decades of recognition since 2006. The firm is also the only firm ranked Band 1 in the Global: Multi-Jurisdictional Immigration category and receives additional individual recognitions in the USA: Business Immigration rankings.

Learn more

Fragomen news

Fragomen Strengthens Canadian Practice with Partner and Counsel Hires in MontréalLearn more

Media mentions

Buffalo Toronto Public Media: IRCC faces processing hurdles as FIFA World Cup draws near

Partner Rick Lamanna provides insight to Buffalo Toronto Public Media on potential IRCC processing challenges as Canada prepares for increased visa demand ahead of the 2026 FIFA World Cup.

Learn more

Blog post

Time to Act: Three Key Questions for Employers Ahead of March 1 Remuneration Increases for Employment Permits in Ireland

Immigration Director Deirdre Murray explores the impact of upcoming employment permit changes on employers and workforce planning in Ireland. 

Learn more

Video

Global Entry | #MobilityMinute

Director David Iannella discusses how Global Entry can help frequent business travelers navigate US entry more predictably and access TSA PreCheck.

Learn more

Video

London Fashion Week 2026

Manager Russell Hodges and Associate Gurpreet Phalora explain key UK immigration considerations for London Fashion Week 2026.

Learn more

Advisory services

The EU Blue Card Recast Through the Employer Lens

Senior Counsel Jo Antoons and Immigration Supervisor Elisabeth Kamm explore the EU Blue Card recast and its impact for employers, highlighting how hiring, retention and mobility decisions are affected. 

Learn more

Media mentions

Times of India: The 2027 H-1B Season: Revised Strategies for Sponsoring Employers and Implications for Aspirants

Partner James Pack on US H‑1B updates and what employers should know for the upcoming lottery.

Learn more

Immigration analysis

Applying for Swiss Citizenship: When Timing and Eligibility Matter

Manager Konstantin Schmid provides a practical overview of Swiss citizenship routes, eligibility rules and common reasons applications are delayed or refused. 

Learn more

Media mentions

CNN: These Americans Are Clinging to Hope for Italian Citizenship

Manager Pierangelo D’Errico discusses how recent changes to Italy’s citizenship rules are affecting applicants with Italian ancestry.

Learn more

Media mentions

Arabian Gulf Business Insight: Saudi Business Visa Rejections Rise as Scrutiny Tightens

Partner Abeer Al Husseini discusses increased scrutiny of Saudi business visas in AGBI, highlighting stricter review of short-term entry used for operational work and the implications for regional employers.

Learn more

Awards

Doyle’s Guide 2026: Fragomen Leaders Recognized as Leading Immigration Lawyers

Australia and New Zealand Managing Partner  Teresa Liu, Partner Charles Johanes, Practice Leaders Hedvika and Leader Ben Lear and Senior Associate Hannah Scanlan are recognized in the 2026 edition of Doyle’s Guide as leading immigration practitioners in Australia.

Learn more

Awards

Fragomen Ranked Band 1 in the Chambers Global 2026 Guide

Fragomen is ranked Band 1 for Immigration: Business in the Chambers Global 2026 Guide, marking two decades of recognition since 2006. The firm is also the only firm ranked Band 1 in the Global: Multi-Jurisdictional Immigration category and receives additional individual recognitions in the USA: Business Immigration rankings.

Learn more

Fragomen news

Fragomen Strengthens Canadian Practice with Partner and Counsel Hires in MontréalLearn more

Media mentions

Buffalo Toronto Public Media: IRCC faces processing hurdles as FIFA World Cup draws near

Partner Rick Lamanna provides insight to Buffalo Toronto Public Media on potential IRCC processing challenges as Canada prepares for increased visa demand ahead of the 2026 FIFA World Cup.

Learn more

Blog post

Time to Act: Three Key Questions for Employers Ahead of March 1 Remuneration Increases for Employment Permits in Ireland

Immigration Director Deirdre Murray explores the impact of upcoming employment permit changes on employers and workforce planning in Ireland. 

Learn more

Video

Global Entry | #MobilityMinute

Director David Iannella discusses how Global Entry can help frequent business travelers navigate US entry more predictably and access TSA PreCheck.

Learn more

Video

London Fashion Week 2026

Manager Russell Hodges and Associate Gurpreet Phalora explain key UK immigration considerations for London Fashion Week 2026.

Learn more

Advisory services

The EU Blue Card Recast Through the Employer Lens

Senior Counsel Jo Antoons and Immigration Supervisor Elisabeth Kamm explore the EU Blue Card recast and its impact for employers, highlighting how hiring, retention and mobility decisions are affected. 

Learn more

Media mentions

Times of India: The 2027 H-1B Season: Revised Strategies for Sponsoring Employers and Implications for Aspirants

Partner James Pack on US H‑1B updates and what employers should know for the upcoming lottery.

Learn more

Immigration analysis

Applying for Swiss Citizenship: When Timing and Eligibility Matter

Manager Konstantin Schmid provides a practical overview of Swiss citizenship routes, eligibility rules and common reasons applications are delayed or refused. 

Learn more

Media mentions

CNN: These Americans Are Clinging to Hope for Italian Citizenship

Manager Pierangelo D’Errico discusses how recent changes to Italy’s citizenship rules are affecting applicants with Italian ancestry.

Learn more

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.