At First Law Solicitors, we provide strategic, ongoing legal support for UK businesses that hold a Sponsor Licence under the Points-Based Immigration System.
Holding a Sponsor Licence is both a privilege and a responsibility. The Home Office expects continuous, real-time compliance not simply one-time approval. Our solicitors ensure that your business remains inspection-ready at all times, safeguarding your ability to employ skilled international talent while protecting your organisation from suspension, revocation, or civil penalties.
Based in Manchester and regulated by the Solicitors Regulation Authority (SRA ID No 665823), we advise employers across the United Kingdom and internationally, combining legal precision with commercial pragmatism.
The sponsor compliance regime has evolved dramatically since the Home Office reforms of 2025.
Sponsor licences now remain valid indefinitely, removing the need for four-year renewals. In return, the Home Office has intensified its enforcement powers, introducing Digital Compliance Evidence Reviews (DCER) and unannounced inspections to verify that licence holders meet their duties.
These reviews assess every aspect of your organisation’s sponsor management from record keeping and reporting accuracy to right-to-work verification and the treatment of sponsored staff.
We act as your compliance partner, conducting proactive internal audits and training your staff to meet the evolving standards set out in Appendix Sponsor and the Home Office’s sponsor guidance.
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Sponsor licence holders are legally obliged to monitor, record, and report a wide range of employee and business data. The key compliance areas include:
Record Keeping and HR Systems
Every sponsored worker’s file must contain specific documents such as their passport, visa record, and right-to-work evidence. Employers must also maintain accurate contact details, role descriptions, and salary information.
Reporting Duties
Changes to an employee’s job title, work location, salary, or immigration status must be reported through the Sponsor Management System (SMS) within ten working days.
Right to Work Checks
Employers must carry out compliant right-to-work checks before employment begins and maintain evidence in the prescribed Home Office format.
Genuine Vacancy and Salary Compliance
Every sponsored role must continue to meet the criteria of a genuine vacancy under the Skilled Worker route. The salary must remain at or above the required threshold currently £41,700 per year or £17.13 per hour, whichever is higher.
Failure to meet any of these obligations can trigger immediate enforcement action, including licence suspension or revocation.
Introduced in 2025, the Digital Compliance Evidence Review represents the Home Office’s transition from traditional site visits to data-driven, remote inspections.
Through the DCER system, the Home Office cross-references real-time payroll submissions, HMRC data, and sponsor reports to detect inconsistencies. If discrepancies are found, a formal audit or licence downgrade may follow.
Our solicitors help clients prepare for DCERs by reviewing all employee records, verifying digital submissions, and ensuring that the business’s HR systems can withstand Home Office scrutiny.
Since December 2024, the Home Office has applied a strict zero-tolerance policy to certain breaches. Sponsors found to be reclaiming the cost of sponsorship from workers, failing to report key changes, or employing individuals outside their approved job code face automatic licence revocation.
We help businesses audit their internal cost recovery policies, employment contracts, and HR systems to ensure compliance with this enforcement model.
The roles of Authorising Officer, Key Contact, and Level 1 User are central to sponsor compliance. If these individuals fail to perform their duties or leave the business, the Home Office can suspend or revoke the licence.
We provide ongoing legal supervision and training to ensure that Key Personnel understand their reporting obligations and act promptly on compliance events. Our solicitors can also step in as your external Level 1 User, managing the SMS on your behalf to ensure uninterrupted compliance.
The Home Office may conduct announced or unannounced compliance inspections at any time.
We prepare your business for inspection by:
If the Home Office identifies potential non-compliance, we act immediately to mitigate risk, negotiate downgrades rather than revocations, and demonstrate that remedial measures have been implemented.
If your licence has been suspended or downgraded, we guide you through the recovery process.
This includes:
Our proactive approach often prevents licence revocation, protecting your business’s ability to retain and sponsor international employees.
All compliance processes at First Law Solicitors are conducted under the Data Use and Access Act 2025, which governs digital identity verification, data storage, and access controls.
We use secure digital portals and encrypted communication systems to manage all documentation, ensuring confidentiality and full alignment with UK GDPR as amended by the 2025 Act.
This approach not only protects sensitive corporate and employee data but also ensures seamless integration with the Home Office’s digital immigration systems.
Proactive Strategy: We prevent problems before they arise through continuous legal oversight and early intervention.
Digital Mastery: Our systems are fully aligned with the Home Office’s DCER platform and the 2026 compliance framework.
Expert Leadership: Every client benefits from the direct involvement of a senior solicitor with more than 20 years of experience in business immigration and regulatory law.
Long-Term Partnership: We remain your ongoing compliance partner, ensuring your business stays protected through legislative changes and Home Office updates.
At First Law Solicitors, we do not simply help you comply. We create resilient compliance systems that allow your business to thrive with confidence.
For professional advice on sponsor licence management, compliance audits, or licence defence, contact First Law Solicitors today.
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