A UKVI compliance audit is a visit (announced or unannounced, in-person or remote) to assess whether a UK sponsor licence holder is meeting their compliance duties. The visit examines HR records, SMS data, sponsored worker files, the Authorising Officer''s knowledge, and the genuineness of sponsored roles. Findings range from advisory notes to immediate licence revocation.

UKVI has stepped up audit frequency and severity since 2023. Sponsors who haven''t had an audit recently should expect one in the next 24 months. Sponsors who fail audits typically lose the licence.

Types of audit

Pre-licence audit

Conducted before granting a new sponsor licence. Tests whether the applicant has the systems to meet sponsor duties. Usually announced; on-site visit at the registered office.

Post-licence audit

Conducted at any point during the 4-year licence term. Can be:

• Routine: random selection.
• Triggered: by intelligence, complaints, suspicious activity, or pattern flags from SMS data.
• Pre-renewal: in the 6-12 months before licence renewal.

Can be announced (with 48-72 hours notice) or unannounced. Either in-person at the workplace or remote (video call with document upload).

What UKVI checks

The audit examines five areas:

1. HR records for every sponsored worker

For each sponsored worker, the file must contain:

• Original CV / qualifications.
• Right-to-Work check evidence (online check screenshots, or manual document copies).
• Contract of employment.
• Job description matching the CoS.
• Recent payslips (typically last 6 months).
• Bank statements showing salary actually paid.
• Attendance and absence records.
• Performance review documentation (if applicable).
• Any record of role / salary changes with SMS reports.

UKVI inspects a sample of files (typically 3-5 for smaller sponsors; more for larger).

2. SMS data and reporting log

• Every CoS assigned matches a real role, real worker, real start.
• Every reportable change made within 10 working days.
• SMS salary matches payroll.
• SMS work location matches reality.
• SOC code matches actual duties.

UKVI has read-only audit access to SMS — they see every record.

3. Right-to-Work check evidence

• Every sponsored worker has a valid check completed before their first day.
• Follow-up checks completed before time-limited permissions expire.
• Records retained for at least 2 years post-employment.

4. Authorising Officer interview

A 30-60 minute interview with the Authorising Officer testing their understanding of:

• The sponsor licence and its conditions.
• Reporting duties on SMS.
• The genuineness of vacancies sponsored.
• How HR systems support compliance.
• The size and structure of the business.
• The Authorising Officer''s own role.

An AO who can''t articulate the system in their own words is a significant audit red flag.

5. Genuine vacancy

UKVI tests whether the sponsored role is real or constructed. They examine:

• Does the role description match the SOC code?
• Are the duties at the right skill level?
• Is the salary commercially reasonable for the role?
• Was the role advertised before being filled?
• Is the business activity consistent with the role''s claimed duties?

For new and small sponsors particularly, "non-genuine vacancy" is a frequent finding.

Common audit findings

In order of frequency:

Missing or late reports

Reportable changes (salary, role, location, absence) not reported on SMS within 10 working days. The most common finding.

CoS-payslip mismatch

Worker''s actual salary differs from the CoS salary. Even small differences are flagged.

Right-to-Work check gaps

Missing checks, late checks (done after the first day), or check documents that don''t comply with current rules (e.g. manual checks on BRPs, which haven''t been valid since 2022).

Inadequate HR records

Missing payslips, no contract of employment on file, no job description, no evidence of duties matching the SOC code.

Authorising Officer not credible

Cannot explain the system. Hasn''t reviewed SMS reports. Doesn''t know which workers are currently sponsored.

Non-genuine vacancy

Role doesn''t exist as described. Worker doing different duties from the CoS. Salary clearly reverse-engineered to meet the threshold.

Outcomes

After the audit, UKVI issues a decision:

A-rated (compliant)

Sponsor remains in good standing. Audit findings may include minor advisory notes.

B-rated

The licence is downgraded. The sponsor must complete an action plan within 3 months and pay a fee (£1,476 in 2026). Cannot assign new CoS until upgraded back to A-rated.

Suspension

The licence is suspended pending further investigation. Cannot assign new CoS. Existing workers can continue. Often a precursor to revocation.

Revocation

The licence is revoked. All sponsored workers have their visas curtailed (typically to 60 days). The sponsor enters a cooling-off period (typically 12 months) before re-applying.

The right of appeal is limited. Most licence decisions can only be challenged by judicial review — expensive and rarely successful.

How to prepare

Build the compliance system before the audit

Don''t scramble. The system you operate every day is what passes or fails.

Run a mock audit

Quarterly or twice a year, have someone (HR lead, immigration consultant) audit your records as if they were UKVI. Find the gaps. Fix them.

Keep a real-time compliance log

A spreadsheet (or property management system) showing every sponsored worker with: CoS reference, salary, SOC code, work location, hours, RTW check date, expected visa expiry, recent reports made.

Train the Authorising Officer

The AO must be able to talk confidently about: the workers, the licence, the duties, recent reports. Brief them ahead of any audit visit.

Keep SMS clean and current

Build it into the HR workflow. Every change triggers an SMS check.

If the audit goes badly

If you receive a notice of suspension or revocation:

• Immediately engage a specialist immigration lawyer. Generalist commercial lawyers don''t do this work.
• Don''t panic-respond. You typically have 20 working days to respond formally.
• Provide additional evidence if there are factual errors in UKVI''s findings.
• Consider judicial review only if there are clear legal errors in the decision — it''s expensive (£15-£50K) and the success rate is low.

For most sponsors, the better strategy is preventing the bad outcome through prepared compliance, not fighting it after the fact.

What to do this month

• Run a mock audit against the five areas above.
• For each sponsored worker, verify: CoS matches payroll, RTW check is on file, contract is current, SOC code matches duties.
• Brief the Authorising Officer on the licence and current workers.
• Schedule a quarterly mini-audit going forward.