How should we respond when UKVI says our payroll does not match the CoS?

Start with a worker-by-worker, pay-period reconciliation. Compare the salary and hours on each CoS with the contract, gross pay, paid hours, deductions, payslip and payment evidence. Record every variance and its explanation. Then answer the UKVI allegation directly, cross-reference the evidence and address any separate salary-change reporting duty within the stated deadline.

Preserve the UKVI request and deadline

Record the sender, reference, date, response channel, workers and periods in scope, and deadline stated in the email. Preserve the original message and attachments.

Sponsor Guidance Part 3, paragraph C7.16 allows the Home Office to ask for evidence by telephone, video conference or letter as part of a compliance check. Use the request itself to define the response scope.

Build one calculation for each worker and period

For each pay period, record the CoS salary, contracted hours, paid hours, gross pay, relevant deductions, expected figure and difference. Link each figure to the source record.

Sponsor a Skilled Worker, paragraphs SK7.19 to SK7.24 explain UKVI's checks against the CoS, use of HMRC information and the pay-period and hourly-rate assessment. Do not rely on an annual total where the concern relates to specific periods.

Test deductions separately

Skilled Worker guidance, paragraph SK7.25 says specified deductions and loan repayments connected to business, immigration or investment costs are subtracted from salary in the period in which they are made.

List each deduction, why it was made, who benefited and whether it changes the sponsorship calculation. Worker consent does not by itself determine the sponsor-rule treatment.

Reconcile the document set

Appendix D, version 08/26, sections 3(a) to 3(c) require payslips, salary-payment evidence and a contract or written particulars showing the job, hours and pay.

Check that the CoS, contract, payslip, payroll report, bank or payment record and HMRC information describe the same worker, period and figure. Record missing evidence rather than filling the gap with narrative.

Explain every variance

Separate data-entry errors, timing differences, authorised unpaid absence, relevant deductions, changed hours, changed salary and unexplained shortfalls. Apply the current rule to each explanation.

Sponsor Guidance Part 3, paragraph C7.20 explains that discrepancies found during checks may be investigated. State the difference, evidence, applicable rule, correction and preventive control plainly.

Decide whether a salary report was required

Part 3, paragraphs C1.13 and C1.15 contain the general worker-change reporting period and include specified salary or pay reductions. Record the trigger date, deadline, decision, SMS submission and confirmation.

A payroll correction and an SMS report are separate controls. Complete both where the facts and current guidance require them.

Write to the allegation, not around it

Use a response schedule with one row per worker and period. State the UKVI concern, calculation, answer, evidence references, discrepancy explanation, remediation and reporting position.

Keep the final representations, evidence index, source documents, calculations and submission proof. Obtain advice where the response may admit a serious breach or the legal position is disputed.

This article provides general information, not legal advice.

Related questions

Can UKVI compare our payroll with HMRC data?

Yes. Skilled Worker guidance paragraph SK7.19 says UKVI will regularly use compliance checks, HMRC checks or both to compare pay with the CoS or a reported change.

What period should the salary calculation cover?

Use the workers and periods in the UKVI request, then apply the pay-period and hourly-rate rules in SK7.20 to SK7.24.

Do deductions matter when checking CoS salary?

Some do. SK7.25 requires specified business, immigration or investment-related deductions and loan repayments to be subtracted in the period made.

Is a back-payment enough to answer UKVI?

No. Record the back-payment, but also address the original pay periods, the applicable rule, any reporting duty and the control that failed.

Which records should we include?

Use the CoS, contract, payslips, payroll, paid hours, payment evidence, deduction details, calculation and relevant SMS reporting records.