Guide
We think we're compliant. Could we prove it tomorrow?
By Sponsor ComplIANS · 12 November 2026 · 6 min read
Most care providers believe their records are in order. A compliance officer asks a different question: show me. Pick two or three sponsored workers at random and try to answer ten questions for them, with the evidence, today, and with someone other than the usual person answering. Wherever you cannot find or explain something, record the gap and give it an owner. It is not a pass or fail test; it shows where your evidence is, where it is missing, and who will fix it.
What can a compliance check look at?
Checks can happen at any time, before or after a licence is granted, announced or unannounced (Part 3, C7.9). They can involve document requests, on-site visits, remote video checks, phone calls and checks with other government bodies. An officer can examine your records and systems, including Appendix D; interview sponsored workers, past workers and recruitment staff; and check for illegal working among other staff (C7.15). Pay can be checked by visit, HMRC data or both. The officer will not give their assessment during the check, and not co-operating or delaying is a normal revocation ground (Annex C2(e)).
What are the ten questions?
| # | Question |
|---|---|
| 1 | Worker files: can you produce any sponsored worker's right to work check today, and explain how it was done? |
| 2 | Checks: do you know when each worker's next right to work follow-up check is due, and who will do it? |
| 3 | Pay: for the last three months, can you show each worker's pay against their contract and the salary on their CoS? |
| 4 | Hours: can you show each worker's contracted, planned and worked hours, and explain any gap? |
| 5 | Absence: can you show every absence for each worker, and whether it was permitted? |
| 6 | Reporting: for each change in the last year, can you show the reporting decision, the deadline and any SMS reference? |
| 7 | Job and location: is each worker doing the job, hours and location on their CoS, or has any change been assessed? |
| 8 | Records: are contact details, contracts and payslips current and on file for every worker? |
| 9 | Responsibilities: does every sponsor duty have a named owner and a deputy who know it is theirs? |
| 10 | Resilience: if your usual person were away, could someone else find and explain all of this? |
How do we run the check?
- Pick at randomTwo or three sponsored workers. Answer for them, not in general.
- Find the evidenceFor each question, the evidence and where it is kept.
- Record the gapsAnything you cannot find or explain, with an owner.
- Choose three actionsThe three most urgent, with owners and dates.
- Repeat in three monthsWith different workers and someone else answering.
A fictional result
The team answered 7 of the 10 questions with evidence for all three workers. The gaps: no record of whether two absences were permitted; one worker moved to a new area without an assessment; and nobody but the HR manager could open the payroll system. The three actions: HR to review and record both absences that week; HR to assess the location change against the reporting rules; and payroll access for a deputy by Friday.
The action plan completely changed how we approach sponsor compliance. It gave us clarity, accountability and a roadmap. We feel prepared instead of exposed.
Where do we go from here?
Each question has a Working Pack with the worksheet behind it: pay, absence, right to work, reporting, hours, worker files, roles and the one-worker monthly review. Bring anything you could not answer to Sponsor ComplIANS Live, or take it to your adviser.
This article gives general information, not legal advice. Guidance checked on 11 November 2026. Check the current guidance and your own circumstances before acting.
Free Working Pack 10: "Could we prove it tomorrow?" readiness check
A four-page check that tests whether your team can find and explain the evidence for any sponsored worker, without warning. It covers:
- How to pick workers and run the check.
- The ten questions, with space for evidence, gaps and owners.
- The three most urgent actions.
- Questions to bring to Sponsor ComplIANS Live or your adviser.
- A fictional result.
Sponsor ComplIANS Live, 26 November 2026
Sponsor ComplIANS Live is a practical day for payroll, HR, coordinators and managers in care providers that sponsor workers. It covers why care providers are losing sponsor licences, who does what across HR, payroll, recruitment and coordinators, and a full demonstration of the Hub.
- When: Thursday 26 November 2026, 9am to 5pm
- Where: Leicester Marriott Hotel
- Paid by 11:59pm UK time on Thursday 19 November: £699 + VAT for the first attendee and £300 + VAT for each additional attendee booked together
- After that: £999 + VAT and £600 + VAT
Attending does not guarantee compliance or any outcome with the Home Office.
In the Sponsor ComplIANS Hub, Salary compliance compares pay with the required pay each period, each reporting duty has one owner and one deadline with the proof kept, and on Core each worker's record shows their full position on one page. The Hub supports your checks; it does not replace them or guarantee compliance. See the Compliance Hub
Related questions
Will the Home Office tell us before a compliance visit?
Not necessarily. Checks can be announced or unannounced, and can happen before or after a licence is granted.
Is this readiness check a certificate of compliance?
No. It shows where your evidence is and where it is missing. It is not a pass or fail test and does not guarantee compliance.
What happens if we cannot answer some of the questions?
Record the gap, give it an owner and choose the three most urgent actions. Take advice where the rules or your circumstances are unclear.