• 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

Fragomen in 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

Fragomen in 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

Fragomen in 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

Fragomen in 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

Fragomen in 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

Fragomen in 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

Hong Kong Business Magazine: Employers Seek Broader Immigration Reforms

In this Hong Kong Business article, Managing Director Magdalene Tennant discusses Hong Kong’s recent decision to allow employment and dependent visa renewal applications to be filed up to three months before expiry, a change intended to reduce the risk of work disruptions and provide employers with greater flexibility in managing foreign talent.

Learn more

Media mentions

Professional Engineering: How to Access International Engineering Talent in a Changing Immigration System

In this article published by Professional Engineering, Senior Manager Nadine Barnole examines how UK engineering employers can continue to access international talent amid growing skills shortages and a rapidly evolving immigration landscape.

Learn more

Media mentions

Times Brasil CNBC: How Technology is Reshaping Identity Verification Systems

In this Times Brasil CNBC Real Tech interview, Partner Diana Quintas discusses Brazil’s recent visa exemption for Chinese nationals, what it signals for Brazil-China mobility and how technology is helping support more efficient cross-border movement.

Learn more

Podcast

World Refugee Day 2026

In this episode of The Immigration Conversation, Business Immigration Manager Ayana Ibrahimi is joined by Lara Dyer, Chief Solutions Officer (Americas) at Talent Beyond Boundaries; Stuart Szabo, CEO and Co-founder of Beacon; and Jessica Turner, Co-founder and CEO of ThriveON, to discuss refugee labour mobility and employment-based pathways for displaced talent.

Learn more

Video

Business Travel to China | #MobilityMinute

In this Mobility Minute, Manager Maja Sugui provides an overview of key visa and compliance considerations for business travelers planning trips to China.

Learn more

Media mentions

Michigan Law’s Law Quadrangle: Christopher Wendt, ’98: At the Intersection of Immigration and Health Care Workers

In this profile published in Michigan Law’s Law Quadrangle, Counsel Christopher Wendt discusses the role of immigration in supporting the US healthcare workforce and expanding access to civil legal aid in Minnesota.

Learn more

Media mentions

WealthBriefing: The End of the Golden Visa?

Director Isobel Neilson discusses how investment migration programs are evolving amid political scrutiny, regulatory reform and shifting priorities, with governments moving toward pathways that emphasise economic contribution, talent and stronger ties to host countries.

Learn more

Fragomen news

Fragomen Welcomes Christopher Wendt as Counsel

Fragomen welcomes Counsel Christopher Wendt in Minnesota, bringing nearly three decades of immigration law experience, including more than 20 years supporting workforce immigration programs for Mayo Clinic.

Learn more

Media mentions

The ABC: Switzerland is Set to Vote on a Population Cap. Here's Why it's Divided the Nation

Senior Counsel Dr. Anna Boucher discusses Switzerland’s rejected population cap referendum and the role of immigration in supporting workforce and economic stability.

Learn more

Awards

Fragomen Featured in Global Mobility Lawyer’s 2026 GML Elite

Fragomen has been featured in the 2026 GML Elite, Global Mobility Lawyer’s inaugural guide to leading global mobility teams, highlighting the firm’s global immigration capabilities, international footprint and work supporting multinational clients.

Learn more

Media mentions

Deutscher AnwaltSpiegel: Die Blaue Karte EU 2026

Partner Marius Tollenaere outlines the key 2026 EU Blue Card changes employers must understand to stay compliant and competitive.

Learn more

Media mentions

STV News: What Can Scots Fans Do if Their US Travel Permits Have Been Revoked?

Partner Charlotte Slocombe explained options available to Scotland fans whose US ESTAs have been denied or revoked ahead of the FIFA World Cup.

Learn more

Media mentions

Hong Kong Business Magazine: Employers Seek Broader Immigration Reforms

In this Hong Kong Business article, Managing Director Magdalene Tennant discusses Hong Kong’s recent decision to allow employment and dependent visa renewal applications to be filed up to three months before expiry, a change intended to reduce the risk of work disruptions and provide employers with greater flexibility in managing foreign talent.

Learn more

Media mentions

Professional Engineering: How to Access International Engineering Talent in a Changing Immigration System

In this article published by Professional Engineering, Senior Manager Nadine Barnole examines how UK engineering employers can continue to access international talent amid growing skills shortages and a rapidly evolving immigration landscape.

Learn more

Media mentions

Times Brasil CNBC: How Technology is Reshaping Identity Verification Systems

In this Times Brasil CNBC Real Tech interview, Partner Diana Quintas discusses Brazil’s recent visa exemption for Chinese nationals, what it signals for Brazil-China mobility and how technology is helping support more efficient cross-border movement.

Learn more

Podcast

World Refugee Day 2026

In this episode of The Immigration Conversation, Business Immigration Manager Ayana Ibrahimi is joined by Lara Dyer, Chief Solutions Officer (Americas) at Talent Beyond Boundaries; Stuart Szabo, CEO and Co-founder of Beacon; and Jessica Turner, Co-founder and CEO of ThriveON, to discuss refugee labour mobility and employment-based pathways for displaced talent.

Learn more

Video

Business Travel to China | #MobilityMinute

In this Mobility Minute, Manager Maja Sugui provides an overview of key visa and compliance considerations for business travelers planning trips to China.

Learn more

Media mentions

Michigan Law’s Law Quadrangle: Christopher Wendt, ’98: At the Intersection of Immigration and Health Care Workers

In this profile published in Michigan Law’s Law Quadrangle, Counsel Christopher Wendt discusses the role of immigration in supporting the US healthcare workforce and expanding access to civil legal aid in Minnesota.

Learn more

Media mentions

WealthBriefing: The End of the Golden Visa?

Director Isobel Neilson discusses how investment migration programs are evolving amid political scrutiny, regulatory reform and shifting priorities, with governments moving toward pathways that emphasise economic contribution, talent and stronger ties to host countries.

Learn more

Fragomen news

Fragomen Welcomes Christopher Wendt as Counsel

Fragomen welcomes Counsel Christopher Wendt in Minnesota, bringing nearly three decades of immigration law experience, including more than 20 years supporting workforce immigration programs for Mayo Clinic.

Learn more

Media mentions

The ABC: Switzerland is Set to Vote on a Population Cap. Here's Why it's Divided the Nation

Senior Counsel Dr. Anna Boucher discusses Switzerland’s rejected population cap referendum and the role of immigration in supporting workforce and economic stability.

Learn more

Awards

Fragomen Featured in Global Mobility Lawyer’s 2026 GML Elite

Fragomen has been featured in the 2026 GML Elite, Global Mobility Lawyer’s inaugural guide to leading global mobility teams, highlighting the firm’s global immigration capabilities, international footprint and work supporting multinational clients.

Learn more

Media mentions

Deutscher AnwaltSpiegel: Die Blaue Karte EU 2026

Partner Marius Tollenaere outlines the key 2026 EU Blue Card changes employers must understand to stay compliant and competitive.

Learn more

Media mentions

STV News: What Can Scots Fans Do if Their US Travel Permits Have Been Revoked?

Partner Charlotte Slocombe explained options available to Scotland fans whose US ESTAs have been denied or revoked ahead of the FIFA World Cup.

Learn more
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
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration 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

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • 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
Important Updates
Important Updates
June 18, 2026 | United KingdomProfessional Engineering: How to Access International Engineering Talent in a Changing Immigration System
June 19, 2026 | KuwaitKuwait: Commercial Visit Visa Issuance Temporarily Suspended
June 19, 2026 | 🌐Minimum Salary Changes Announced
June 18, 2026 | ChinaHong Kong Business Magazine: Employers Seek Broader Immigration Reforms
June 18, 2026 | IndonesiaIndonesia: Processing Delays Following Ongoing Anti-Corruption Investigations
June 18, 2026 | United KingdomProfessional Engineering: How to Access International Engineering Talent in a Changing Immigration System
June 19, 2026 | KuwaitKuwait: Commercial Visit Visa Issuance Temporarily Suspended
June 19, 2026 | 🌐Minimum Salary Changes Announced
June 18, 2026 | ChinaHong Kong Business Magazine: Employers Seek Broader Immigration Reforms
June 18, 2026 | IndonesiaIndonesia: Processing Delays Following Ongoing Anti-Corruption Investigations
June 18, 2026 | United KingdomProfessional Engineering: How to Access International Engineering Talent in a Changing Immigration System
Subscribe

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
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

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

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • 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.