United Kingdom: Additional Compliance Obligations Introduced in Updated Sponsor Guidance

Communicating employment rights to sponsored workers. 

Existing guidance already reminded sponsors of their responsibility to comply with UK employment law. As of March 6, 2026, sponsors must now ensure their sponsored workers are informed and understand their employment rights including (but not limited to): 

• Minimum salary entitlements  

• Maximum working hours  

• Pension auto-enrolment and opt-outs  

• Statutory leave and pay  

• Health and safety protections  

• Trade union membership and activity  

• Rules regarding discrimination 

• Access to grievance procedures 

All sponsor licence holders must have a process to retain evidence demonstrating that they provide the above information to employees and must retain this evidence for any workers they sponsor. 

• Employers will need to review employment contracts, and other associated documentation that contain particulars of employment or any other documentation that contains information on workers’ rights to ensure they capture the requisite information from a sponsor obligation perspective and to ensure this information is being retained.  

• Employers should consider organising accessible locations in which to store such evidence to enable quick production in the event of a UK Home Office compliance check.  

Requirement for sponsors to read sponsor guidance. Effective March 6, 2026, sponsor licence holders and prospective sponsors are now expressly required to have read all relevant parts of the sponsor guidance and must remain aware of any changes made to the content. 

• Sponsors should ensure that they are familiar with the relevant portions of the sponsor guidance that apply to the routes they are licensed to sponsor.  

• Sponsors should consider identifying an individual who will be responsible for reviewing relevant guidance and tracking any changes. The guidance does not prescribe who from the licenced entity must have read the guidance and organisations have flexibility in how this is met. It does not necessarily need to be met by the Authorising Officer (who is usually a senior member of the licenced organization).  

Pay period threshold changes. The Immigration Rules have been amended to tighten salary compliance under the Skilled Worker route by requiring sponsors to meet the minimum salary in each pay period, rather than relying on an annual calculation.  

This allows the Home Office to identify and address underpayment earlier, rather than waiting until the end of a full year.  

The rules now require pay to meet the relevant threshold over defined rolling periods (typically three months, 12 weeks or 17 weeks, depending on pay frequency and working pattern). The change is intended to strengthen compliance oversight and protect worker welfare.  

This requirement is effective in relation to workers assigned Certificates of Sponsorship from April 8, 2026.  

The salary in every pay period must also equal or exceed the hourly threshold for that period.  

• Sponsors should consider reviewing contractual pay periods and payroll arrangements for roles they wish to sponsor to ensure that salary thresholds will be met for the defined payment periods. 

• The scope to average pay across different time frames is limited to prescribed periods and reduces flexibility for the frequency of payments to sponsored workers. The impact and need for adjustment is likely to be greater in sectors where pay frequency is linked to irregular work patterns and aligned pay cycles.