The Home Office's April changes to the Skilled Worker sponsor guidance confirm that the stakes are now higher for sponsors regarding salary compliance. The Home Office has re-emphasised that sponsors must understand and correctly apply the rules on salary payments. Compliance action is also more likely to be taken in practice because of data cross-checking between the Home Office and HMRC. In this article, we summarise the updated requirements, outline some practical pitfalls and make some suggestions for how to minimise risk exposure. 

The Skilled Worker sponsor guidance was updated on 8 April 2026.

What does the new guidance say about salary compliance?

The updated guidance underlines that you as a sponsors must understand the rules on salary calculation, including:

• What can be included as 'salary' and what can't;
• How to pro‑rate salaries (e.g.  for part‑time arrangements); and
• How the Home Office will assess compliance in practice.

Crucially, 'salary' for this purpose means remuneration that is compliant with the Immigration Rules and guidance. This includes remuneration for self-employed sponsored workers, e.g. Partners of LLPs, barristers and dentists. Given how intricate the Rules and guidance are, mistakes in interpreting or applying them can result in an unintended breach. 

At paragraph SK7.19, the guidance confirms that the Home Office will 'regularly check' that sponsored workers are being paid at least the salary stated on their Certificate of Sponsorship (CoS) (or any subsequent salary-related report made against the CoS on the Sponsorship Management System (SMS)). These checks may be conducted:

• Through onsite or virtual compliance visits; and/or
• By cross‑checking data with HMRC. 

This shouldn't be news to sponsors, as the Home Office has been doing this in practice for a while, but the process has now been formalised in the updated guidance.

We're also aware that the Home Office is increasingly contacting sponsors querying whether sponsored workers are being paid in line with their CoS, The Working Time Regulations and National Minimum Wage, as well as whether sponsor reporting duties have been met. 

Paying a sponsored worker less than you told the Home Office you would, including where you haven't reported a permitted reduction or where a reduction is not permitted, is a mandatory ground to revoke the sponsor licence. Revocation will also normally follow if you fail to comply with any of your sponsor duties, which will include complying with wider UK laws including employment laws.

In the recent case of Southcroft Healthcare Lodge Ltd,  the High Court highlighted that each sponsor licence revocation ground is independent, and a breach of any one can justify revocation. 

Common salary compliance failures

Here are some examples of common salary compliance failures that we see in practice. Most happen through a genuine mistake or misunderstanding.

• You included immigration fees that you are recouping from a sponsored worker in the salary amount stated on their CoS:Certain deductions from salary are not permitted and will reduce the salary for immigration purposes for CoS assigned on or after 9 April 2025.
• You failed to submit reports on reduced/no pay for permitted absences: Reductions or non-payment of salary due to unpaid leave (up to a maximum of 4 weeks per calendar year according to their normal working pattern) or for a valid exception reason (e.g. statutory paternity leave) are permitted, but a failure to report this is a compliance breach. It's important to be aware that revocation action can happen solely due to a failure to report a change in salary on the SMS even if the reduction is permitted by the Immigration Rules.
• You didn't increase salary to ensure National Minimum Wage is met at all times: This is in addition to continuing to meet the salary thresholds in force at the time the worker applied for their permission under the route. 

A new issue we see on the horizon is how sponsors should comply with the new 'pay per period' Rule (Appendix Skilled Worker, paragraph SW 14.3B). It came into force for CoS assigned on or after 8 April 2026. It requires a sponsored worker to be paid the going rate for their occupation for every hour worked in each pay period, but certain aspects of it will require clarification from the Home Office. For more detail read our analysis of Spring 2026 UK Immigration Rule changes for employers under the heading 'New requirement for payment of Skilled Workers'. The updated sponsor guidance mirrors the Rule, which means there's still a lot of unknowns as to applying this Rule in practice. We are actively monitoring developments in this area – sign up to receive our updates direct to your inbox.

For further discussion of common pay‑related issues on the Skilled Worker route, see our What's happening in immigration law Q&A and Warning for sponsors: salary compliance and reporting.

Practical steps for sponsors 

The updated sponsor guidance states that the Home Office may take action if they reasonably suspect that you're failing to comply with your sponsor duties. This means they can complete an onsite or virtual audit even where they have no substantial evidence that you're failing to comply. 

Given this increased scrutiny, we would suggest that you:

• Check the salary on the CoS met the requirements at the date it was assigned;
• Make sure you have correctly reported absences and permitted salary changes for each sponsored worker;
• Review and understand how you're impacted by the 'pay per period' Rule – we expect the Home Office to provide guidance on this soon;
• Make sure your personnel records meet the Appendix D record‑keeping requirements and address any gaps now. Refer to our earlier article for a list of salary evidence currently being checked by the Home Office; and
• Consider having an external mock audit of your sponsor compliance carried out.

Need more help?

We'll be covering sponsor compliance in our upcoming online Immigration Law Academy on 6 & 7 May. Click here for further details and to sign up. 

If you need detailed advice on how the Home Office's salary compliance requirements apply to your workforce or would like tailored compliance support, please contact a member of our immigration team.