Sponsor Licence Record-Keeping Duties
Licensed sponsors must keep specified records relating to their sponsored workers and their Sponsor Licence. These records help demonstrate that the worker, role and employment arrangements remain consistent with the sponsorship, and allow the Home Office to verify compliance during a check. Appendix D sets out the record categories and retention rules — the exact evidence depends on the sponsorship route and the worker's circumstances, so use Appendix D as the primary framework rather than a generic HR checklist.
On this page
- Why keep records?
- Which document sets
- Identity & immigration
- Contact details
- Employment records
- Salary & payroll
- Absence & attendance
- Recruitment evidence
- Fixed recruitment method?
- Qualifications
- Regulated roles
- Third-party / client-site
- Application documents
- How long to keep records
- Electronic storage
- Producing records
- Data protection
- If records are missing
- File structure
- Record-keeping workflow
- Record Checker
- How ENS can assist
- FAQs
In brief
- Licensed sponsors must keep specified records for their sponsored workers and the licence (Appendix D).
- These include identity and immigration documents, contact details, employment records and pay evidence.
- Absence and attendance records must also be kept.
- Good records are what demonstrate compliance if the Home Office checks — the guide lists each document set.
Why do sponsors have to keep records?
Appendix D requires sponsors to retain specified evidence so they can demonstrate matters such as identity and immigration status; sponsored employment; pay; attendance and contact details; recruitment history where relevant; qualifications or professional registration where required; compliance with conditions attached to the sponsored role; and the evidence provided when applying for the Sponsor Licence. These records may be requested during Home Office compliance activity.
Record keeping is evidence of sponsorship in practice. The Home Office can ask to see records showing that the worker, role and employment arrangements match the sponsorship information held on its systems.
Which document sets does Appendix D cover?
Identity & immigration
Who the worker is and the basis for sponsorship.
Contact & employment
Current personal/contact details and the sponsored employment.
Recruitment evidence
How the worker was recruited or identified, where required.
Pay & employment evidence
Salary and employment arrangements.
Qualifications & route-specific
Evidence required by the occupation or route.
Sponsor Licence application records
Evidence originally supplied with the application.
What identity and immigration records should be kept?
Appendix D requires sponsors to retain specified documents relating to the sponsored worker's identity and immigration status — records connected with the passport/travel document, immigration permission, biometric/eVisa evidence where relevant to the sponsorship record, and other documents specified by Appendix D for the route.
The statutory Right to Work check procedure is outside this guidance. The prescribed-document list, follow-up checks and statutory excuse are governed by the separate Home Office employer right-to-work / illegal-working regime — check that guidance for the check procedure.
What contact details must a sponsor keep?
Appendix D requires sponsors to maintain current contact information for sponsored workers — the relevant details specified by the guidance, such as residential address, telephone number, mobile number where applicable, and other current contact information required by Appendix D. The employer should have a process for updating contact details when the worker notifies a change.
Don't rely on the contact details recorded when the worker first joined. Sponsor records should reflect the worker's current contact information where Appendix D requires this.
What employment records should be kept?
The sponsor should retain records showing the sponsored employment and its terms. Depending on the route and circumstances, Appendix D includes records connected with the employment contract or written particulars; job title; duties; working hours; salary; work location; employment start/end; and other role-specific information.
The employment record should be consistent with the sponsored role. If the actual job changes, check both the reporting duty and whether the sponsorship itself can continue. Genuine role · assigning a CoS.
What salary and payroll evidence should be retained?
Appendix D requires sponsors to keep evidence showing the amount and frequency of pay for sponsored workers — which may include payslips, payroll records, evidence of salary payments, relevant bank/payment records and contractual salary information. The evidence should support the salary information recorded for sponsorship.
The salary thresholds and going rates themselves live on the salary requirements page.
What absence and attendance records should be kept?
Sponsors are expected to have systems capable of identifying relevant worker absence and attendance events, and Appendix D requires retention of specified attendance-related evidence where applicable. These records support the sponsor's ability to know whether the worker started employment; identify relevant absences; explain reported non-attendance; and demonstrate monitoring during a compliance check.
The guidance doesn't require a Home-Office-mandated daily attendance register — it requires the evidence Appendix D specifies. → reporting duties.
What recruitment evidence must be retained?
Where there's no formal resident labour market test requirement but the sponsor carried out recruitment activity, Appendix D requires the sponsor to keep evidence of that process. Where the role was advertised, the evidence includes a copy or record of the advertisement; where it was advertised; how long for; the number of applicants; the number shortlisted; and at least one further item showing the selection process (interview notes, questions, scoring, or reasons for selection/rejection). If the role was not advertised, the sponsor must be able to explain how the worker was identified and, where practicable, retain evidence showing why that person was considered suitable.
No advertisement does not mean no recruitment evidence. If the worker was identified without advertising the role, keep a clear record of how and why that person was selected. Genuine role →
Does Appendix D require a fixed recruitment method?
No. Appendix D doesn't prescribe a universal recruitment method for roles where no formal resident labour market test applies — there's no fixed minimum number of advertisements and no single prescribed advertising method under that general evidence framework. The sponsor should retain evidence of the recruitment process it actually used, rather than creating a retrospective process designed only for the Home Office file.
Keep evidence of the real process. Record the recruitment you actually carried out — don't fabricate interview notes or advertising history.
What qualifications and professional-registration records should be kept?
Where the worker must hold a qualification, professional registration, accreditation or other route/occupation-specific evidence, the sponsor must keep the records specified in Appendix D and the relevant route guidance — for example degree/qualification evidence where required, professional registration, sector-specific authorisation, or other evidence needed for the sponsored role. Not every Skilled Worker must hold a formal qualification; keep what the route and occupation require.
What records are required for regulated roles or organisations?
Where lawful operation or a sponsored role depends on registration, licensing or professional authorisation, sponsors should retain the records required by Appendix D and relevant guidance — which may include organisational regulator details; worker professional registration; and evidence that required registration remained valid during sponsored employment.
→ supporting documents · reporting.
What records are needed for third-party or client-site work?
Where sponsorship involves a permitted service/project delivered for a third party, relevant records may include evidence of the commercial contract; the defined service/project; sponsor control over the worker's duties/functions/outcomes; work location; and salary/employment responsibility. These records may be relevant to showing the arrangement is genuine sponsor-led service delivery rather than prohibited labour supply.
The contract alone may not be enough. The sponsor may need to demonstrate how the worker is actually managed and how the arrangement operates in practice. Genuine role →
Do Sponsor Licence application documents need to be kept after approval?
Yes. Appendix D requires sponsors to keep the documents submitted with the original Sponsor Licence application for as long as the organisation holds the licence — including the evidence used to support the licence application.
Don't archive or destroy the Sponsor Licence application file after approval. Appendix D requires those records to be retained for the life of the licence. Original document framework →
How long must sponsored-worker records be kept?
Appendix D sets retention periods for sponsor records. The rule for each record category should be taken directly from the precise Appendix D provision — different categories may have different retention logic, so there's no single "keep everything for X months" rule.
| Record category | Current retention period | Source |
|---|---|---|
| Sponsor Licence application evidence | For as long as the licence is held | Appendix D |
| Worker identity / status records | Confirm against the current Appendix D provision | Appendix D |
| Recruitment evidence | Confirm against the current Appendix D provision | Appendix D |
| Pay / employment records | Confirm against the current Appendix D provision | Appendix D |
| Other route-specific evidence | Confirm against the current Appendix D provision | Appendix D |
Per-category worker retention periods aren't fixed on this page. Only the licence-application retention rule is stated ("for as long as the licence is held"); the worker-record periods vary by category and should be confirmed against the current Appendix D. Retention periods are current as at August 2026 — confirm against the latest Appendix D. Confirm on GOV.UK →
Can sponsor records be stored electronically?
Appendix D allows sponsor records to be kept in the formats permitted by the guidance, provided they remain accessible, complete and capable of being produced when requested. Where electronic storage is permitted, sponsors don't need to create unnecessary duplicate paper files merely for sponsorship purposes.
The compliance question is retrieval and reliability. Can the sponsor retrieve the required evidence promptly and demonstrate that it's complete and reliable?
How quickly must records be produced if the Home Office asks?
The Home Office can request documents and information as part of its compliance activity, and sponsors are expected to cooperate and produce requested information within the period specified by the Home Office or applicable guidance.
There's no single general record-production deadline shown here. Use the deadline stated in the Home Office request. Compliance checks →
Data protection and Sponsor Licence records
Sponsors should keep the records required by the sponsor guidance while also complying with applicable data-protection law.
Detailed UK GDPR / Data Protection Act requirements are outside this guidance. Data-protection retention and handling are governed by a separate legal framework that needs separate sourcing.
What happens if records are missing?
Failure to retain or produce required records can lead to Sponsor Licence compliance action. Depending on the circumstances, the Home Office may require remedial action, downgrade the licence, suspend it or revoke it. Missing records can also make it harder for the sponsor to demonstrate that a role, salary, recruitment process or reported event complied with the guidance. The outcome depends on the nature and seriousness of the failure — a single missing document doesn't automatically revoke the licence.
→ ratings · suspension · revocation.
Sponsor record file structure
A practical way to organise records — this is an organisational suggestion, not a Home-Office-prescribed structure:
Per sponsored worker
01 Identity & immigration · 02 Employment & CoS · 03 Recruitment · 04 Salary & payroll · 05 Attendance & leave · 06 Qualifications / registrations · 07 Reporting & SMS · 08 Changes / correspondence.
Per licence
A Sponsor Licence application · B Supporting documents · C Key Personnel · D SMS governance · E Organisation changes · F Compliance visits / correspondence.
Suggested filing structure only. The Home Office does not require this exact folder structure — it's a practical way to organise the records the sponsor guidance requires.
Eight-step record-keeping workflow
- Identify the record category — what evidence does Appendix D require for this worker/role?
- Collect it at the correct stage — avoid retrospectively reconstructing records that could have been kept contemporaneously.
- Check consistency — make sure records align with the CoS, employment, pay and work location.
- Store it securely — use an accessible filing structure.
- Update changes — replace/update records where details change, while retaining historic evidence where required.
- Link reporting evidence — keep an audit trail for Home Office reports and underlying events.
- Apply the correct retention period — use the Appendix D category rule.
- Test retrieval — the sponsor should be able to locate required evidence promptly if the Home Office asks.
This workflow organises record keeping; it does not replace Appendix D.
Sponsor Record Checker
Mark which records you hold and the checker highlights the Appendix D categories that may need attention. It doesn't confirm your records are compliant or that you'd pass an audit.
This tool identifies record categories to review. It does not determine whether your Sponsor Licence records satisfy Appendix D in full.
How ENS can assist with Sponsor Licence records
We advise and assist sponsors with identifying Appendix D record categories; reviewing sponsored-worker files; checking recruitment records; reviewing consistency between CoS, employment and payroll records; identifying missing or outdated sponsorship evidence; helping build a proportionate Sponsor Licence record system; preparing for Home Office document requests; reviewing record-keeping concerns raised during a compliance check; and advising on related reporting or compliance issues. We help you review your records against Appendix D — we can't "certify" compliance, guarantee an audit outcome or give Home Office approval.
Sponsor Licence record review
The scope depends on the number of sponsored workers, sponsorship routes and whether the review is preventive or linked to a Home Office compliance concern. We agree the scope and a fixed fee in writing before any work begins.
Discuss a Sponsor Licence record review
Frequently asked questions
What records does a Sponsor Licence holder need to keep? +
Appendix D requires sponsors to retain specified records relating to matters such as the sponsored worker's identity and immigration position, contact details, employment, pay, recruitment, qualifications or registrations where relevant, and the Sponsor Licence application itself.
Do sponsors have to keep recruitment evidence? +
Where recruitment activity was undertaken, Appendix D requires specified evidence of that process. If the role was not advertised, the sponsor must be able to explain how the worker was identified and, where practicable, retain evidence showing why they were considered suitable.
Does every sponsored job have to be advertised? +
No general blanket advertising requirement is imposed by the supplied Appendix D framework where no formal resident labour market test applies. The sponsor must instead retain evidence of any recruitment it did undertake and explain how the worker was identified if the role was not advertised.
Do Sponsor Licence application documents need to be kept? +
Yes. Appendix D requires documents supplied with the Sponsor Licence application to be retained for as long as the organisation holds the licence.
Can sponsor records be stored electronically? +
The sponsor guidance permits records to be retained in the forms allowed by Appendix D, provided required evidence remains accessible and can be produced when requested.
What happens if required sponsor records are missing? +
Failure to meet record-keeping duties can lead to Sponsor Licence compliance action. The consequence depends on the nature and seriousness of the failure and the wider circumstances.
Related guidance
Contextual: SMS · salary requirements · occupation codes · Sponsor Licence hub.
Disclaimer. This page provides general guidance on Sponsor Licence record-keeping duties using Appendix D. Retention periods can differ by record category and can change — confirm the exact rule for each category against the current Appendix D before relying on it. Sources: Home Office sponsor guidance — Appendix D, and Part 3 — confirm the current version on GOV.UK.
Source basis: the UK Immigration Rules and the Home Office sponsor guidance for Workers and Temporary Workers (sponsor a worker, and sponsor duties and compliance) published on GOV.UK. Rules and guidance change; confirm the current version on GOV.UK before relying on it.
Keep the records that show sponsorship in practice
Sponsor record keeping is the evidence base for a compliant licence. Employers should identify the Appendix D categories relevant to each worker and route, keep the evidence contemporaneously, apply the correct retention period, and be able to produce it promptly if the Home Office asks.