Domiciliary Care Rota Compliance: How We Brought 65 Sponsored Workers to Contract from a Rostering System That Left 37 in Shortfall

We were instructed by a domiciliary care provider operating six branches across the West Midlands and Staffordshire. They hold a sponsor licence. They employ 65 workers on Skilled Worker visas. Four are on maternity leave. Twenty-five are non-sponsored. Ninety active workers in total.

The provider had been using their rostering system for years. The rota looked full. Visits were covered. Payroll ran on time. Nobody had flagged a problem.

We exported the data and found that 37 of the 65 sponsored workers were not receiving their contracted hours. Nine of them had received zero hours for the entire week. The provider did not know.

If your rostering system cannot tell you which of your sponsored workers are in shortfall right now, you are in the same position this provider was. Our Sponsor ComplIANS Hub was built to solve exactly this problem — tracking every sponsored worker's hours against their Certificate of Sponsorship in real time.

We pulled the full visit export for one week: 5,117 visit rows, 175 columns per row. That is 895,475 individual data points from the rostering system alone. We also exported 116 employee records across 83 columns and 279 client records across 94 columns.

We cross-referenced every worker against the provider's staff list to verify immigration status, driving licence status and contracted hours from their Certificate of Sponsorship.

We classified every visit by grouping on service user name, date and time. 2,964 single calls. 2,153 double call visits. 3,212.25 worker-hours across 247 clients at six branches.

Understanding the relationship between CoS salary obligations and actual rostered hours is the foundation of every rota compliance analysis we conduct.

The rostering system does not know which workers are sponsored. It does not know what their contracted hours are. It distributes visits based on availability and proximity. Sponsored and non-sponsored workers are treated the same.

The consequences:

• 37 of 65 sponsored workers were in shortfall. Nine received nothing.
• 855 hours had been given to non-sponsored workers while sponsored workers went without.
• Nine workers were over the 48-hour Working Time Regulations limit.
• Two were working 7 days with no rest day.
• One worker did 63 hours in a single week — 18 hours over her contract.

Non-driving workers were being sent to single calls. In domiciliary care, a single call means one carer travelling alone to a client's home. If the worker cannot drive, they cannot get there. The rostering system does not check driving licence status. It assigns non-drivers to single calls the same as everyone else.

Double calls had no pairing. When two carers attend the same client, the rostering system did not link them. There was no record of who was Carer 1 and who was Carer 2.

Workers were being sent to multiple branches on the same day. No one-location-per-day rule. No compliance alerts. No shortfall reporting. No Working Time Regulations monitoring.

These are exactly the kinds of breaches that trigger the "We Have Concerns" email from the Home Office. When the compliance visit happens — and it will — the evidence needs to be there. Read our guide on how compliance visits are decided to understand what triggers them.

We obtained the month's payroll data covering 51 sponsored workers. 26 of them had been paid less than their contracted amount. The combined underpayment in a single month was over £10,000. Annualised, that exceeds £127,000.

Under paragraph S2.64 of the Sponsor Guidance, a sponsor must pay the worker at least the salary on their Certificate of Sponsorship. If the rota does not give them the hours, they cannot earn the salary. The breach is built into the schedule before the week even starts.

This is the same pattern we documented in our analysis of UKVI salary mismatch cases — and it is the single most common reason for sponsor licence action in the care sector. If you are unsure whether your payroll aligns with your CoS obligations, our guide to minimum wage compliance for sponsored workers explains the thresholds.

We took the same 5,117 visits and 3,212.25 hours. Same clients, same times, same durations. No visits added. No visits removed. We reassigned workers using a four-tier priority system:

• Tier 1: Sponsored drivers. All call types. Contracted hours filled first.
• Tier 2: Sponsored non-drivers. Carer 2 on double calls only. Always paired with a driver. Never assigned to single calls.
• Tier 3: Non-sponsored drivers. Remaining calls after all sponsored workers are at contract.
• Tier 4: Non-sponsored non-drivers. Remaining Carer 2 slots.

The allocation enforces rules the rostering system does not: maximum 6 working days, one location per day, non-driver restriction to Carer 2 doubles, travel-aware scheduling with postcode-based travel time estimates between consecutive clients, feasibility checks on day length and start times, maternity exclusion with compliance alerts, 100% double call pairing, and a sponsored overtime pass up to 48 hours before non-sponsored workers receive overtime.

• 65 of 65 sponsored workers at contract. Up from 28.
• Zero shortfalls. Every sponsored worker at or above their contracted hours.
• 385 hours redirected from non-sponsored to sponsored workers. Non-sponsored hours went from 855 to 731. No work was lost. It was redistributed to the workers who needed it for their visa compliance.
• 100% fill rate. All 5,117 visits assigned. Zero unassigned slots.
• Working Time Regulations breaches down from 9 to 1.
• All 10 non-drivers at contract through Carer 2 double call pairing. Three of them had received zero hours under the rostering system.

The data tells the story. In the care sector, 1,948 sponsor licences were revoked in recent years. Many of those revocations stemmed from exactly this kind of invisible shortfall — the rota looked fine, but the contracted hours were not being met.

A letter running to 20 sections: scope of work itemising every data extraction step, key findings with comparison tables, per-worker breakdown of all 65 sponsored workers under both systems sorted by shortfall, payroll evidence, root cause analysis identifying four causes, three resolution options with references to paragraphs S2.64 and C1.32 of the Sponsor Guidance, practical implementation guidance covering cross-location travel, non-driver transport, client continuity, staff communication, phased rollout and mileage costs.

A five-tab rota workbook: Weekly Overview with daily hours and contract status for all 90 workers, Detailed Schedules showing every visit per worker with travel time rows between 4,578 consecutive calls and 1,268 short travel gaps flagged, Single Calls tab with all 2,964 visits, Double Calls tab with all 2,153 visits and paired carer names, Location Summary across all branches. Every tab cross-linked with formulas. Filters on every header row.

A task tracker with notes against every phase of the Master Execution Plan.

A live progress page with downloadable letter and workbook.

All delivered in a single day.

This is not about the rostering system being bad software. It schedules visits. It tracks attendance. It generates invoices. It does what it was built to do.

But it was not built for sponsor licence compliance. It does not know about Certificates of Sponsorship. It does not know about contracted hours obligations. It does not prioritise sponsored workers. It does not restrict non-drivers. It does not pair double calls. It does not flag Working Time Regulations breaches. It does not produce the evidence the Home Office expects to see.

Every domiciliary care provider with sponsored workers and a standard rostering system has the same gap. The rota is full but the contracts are not met. The visits are covered but the compliance is not. The shortfalls are invisible until someone exports the data and counts.

That is what we do.

Providers across the West Midlands have seen their licences revoked for exactly these gaps. The pattern is always the same: the provider believed they were compliant because the rota was full. The Home Office looked at the contracted hours and found shortfalls. By then it was too late.

Check last week's rota against your sponsored workers' contracted hours. Count the hours each one actually received. Compare it to what their CoS says they should get.

If any sponsored worker got less than their contracted hours, you have a problem. If your rostering system cannot tell you the answer without a manual count, you have a bigger one.

We can run this analysis on any rostering system export. The process takes the raw visit data, classifies call types, verifies worker status, builds the optimised allocation and produces the evidence. If you want to know where you stand, get in touch.

If you have already received a compliance letter or are preparing for a Home Office visit, read our case studies on providers who submitted every document and were still revoked — and those who had their licence reinstated after suspension. The difference is always in the evidence.