Published 20/05/2026
🔍 WHAT HAS CHANGED?
✅ 1. Right to Work Checks Clarified
The Home Office has provided clearer guidance on when sponsors must carry out right to work checks.
Affected Documents:
• Part 1
• Part 2
• Part 3
• Appendix D
👉 Employers should review their onboarding and compliance procedures to ensure they remain compliant.
🏢 2. New Definition of “Operating or Trading”
A formal definition of “operating or trading” has now been added.
Affected Documents:
• Glossary
• Part 1
👉 Sponsors may need to provide stronger evidence that their business is genuinely active and trading.
🚫 3. New Licence Refusal & Revocation Ground
The Home Office can now refuse or revoke a sponsor licence if it believes a business has been established primarily to facilitate the entry or residence of a foreign worker.
Affected Documents:
• Part 1
• Part 3
⚠️ This represents a significant compliance risk for sponsors and reinforces the need for genuine business operations and recruitment practices.
💻 4. Continued Roll-Out of eVisas
Guidance has been updated to reflect the ongoing transition to eVisas.
Affected Documents:
• Part 2
• Appendix D
👉 Employers should ensure HR teams understand how to verify immigration status using digital records.
🎯 WHAT SPONSORS SHOULD DO NOW
✔️ Review updated sponsor guidance documents
✔️ Audit right to work check procedures
✔️ Ensure evidence of genuine trading activity is readily available
✔️ Familiarise HR teams with eVisa processes
✔️ Review sponsor compliance systems and record-keeping practices
🚨 COMPLIANCE WARNING
Failure to comply with sponsor duties can lead to:
❌ Sponsor licence suspension
❌ Sponsor licence revocation
❌ Loss of ability to sponsor overseas workers
❌ Increased Home Office scrutiny
📢 KEY MESSAGE The Home Office is strengthening compliance expectations for sponsors. Now is the time to review your systems, documentation, and right to work processes to ensure your organisation remains fully compliant.