Sponsor Guidance: Key 2026 Updates for Businesses

The latest update to the sponsor guidance introduces a number of significant changes for sponsor licence holders.

In summary, the changes reflect a stronger emphasis on sponsor compliance, closer scrutiny of minimum salaries and right to work practices, and greater responsibility on sponsors to demonstrate robust internal processes.

This article highlights those changes most likely to affect your business and outlines the practical implications for organisations managing sponsored workers.

1. Enhanced record-keeping duties

Appendix D of the sponsor guidance, which deals with sponsorship recording-keeping duties, has been updated to require sponsors to retain evidence that they have provided sponsored workers with information about their employment rights in the UK.

In practice, this information may already be incorporated into employment contracts, staff handbooks and/or onboarding materials, and should cover matters such as entitlement to the National Minimum Wage, compliance with Working Time Regulations, duties under the Equality Act and the process for making a protected disclosure or raising a grievance, for example.

If this isn’t being done, sponsors must ensure that both the information itself and the evidence of communication are recorded clearly.

2. New pay period for sponsored salaries

Sponsors are now required to meet the minimum salary in each pay period, rather than relying on an annual calculation, as was previously the case.  This allows the Home Office to identify and address underpayment earlier, rather than waiting until the end of a full year. The change is intended to strengthen compliance and protect the welfare of sponsored workers.  

The rules now require pay to meet the relevant threshold over defined rolling periods (typically three months, 12 weeks or 17 weeks), depending on pay frequency and working pattern.

3. The new definition of ‘eligible role’

The Home Office has introduced a new glossary of terms, the most interesting of which is that of ‘eligible role’ and the criteria that must be satisfied when assigning a Certificate of Sponsorship (“CoS”) to a sponsored worker.

Among other things, the definition makes clear that the Home Office must be satisfied that the role is appropriate to the nature and scale of the business or organisation.

This, in turn, could give the Home Office a greater opportunity to reject CoS applications if they are not satisfied that the role is eligible. Sponsors should therefore review job design, business rationale, and role descriptions carefully before assigning a CoS.

4. Higher English language threshold for settlement

The English language requirement for settlement across a number of work routes is due to increase. As flagged in the White Paper on 12 May 2025, the required level will increase from B1 to B2 under the Common European Framework of Reference for Languages (CEFR), for applications made on or after 26 March 2027. Applicants who have already met the B1 requirement in a previous successful application may continue to rely on that evidence when applying for settlement, provided they remain on the same immigration route.

5. Digital ID

20th July 2026 Update: Andy Burnham is widely expected to scrap the digital ID scheme

The Home Office is expanding the re-use of digital identity information as part of its wider drive to modernise and streamline the immigration system. Although the change will not apply to overseas applicants, it should assist applicants already in the UK by reducing the need to attend biometric enrolment appointments. This is a practical development that may help simplify parts of the in-country application process.

More broadly, digital identity remains a live policy issue. While proposals in this area have previously attracted privacy concerns, the wider direction of travel suggests continued movement towards greater digital verification across public services. For employers, the key question will be whether future developments feed through into right to work checking or sponsorship record-keeping obligations.

6. Expanded right to work obligations

The updated guidance includes a requirement for sponsors to check any worker they wish to sponsor or any worker they otherwise wish to employ or directly engage has permission to enter/stay in the UK and can do the work in question.

Whilst ‘directly engaged’ is not defined, this has potentially significant implications for businesses engaging with contractors, sub-contractors, gig-economy workers, zero-hours contract workers, and other non-traditional arrangements.

It also reenforces the wider anticipated expansion of right to work checks which we expect to apply to all businesses later in the year.

Key takeaways and next steps:

Overall, these changes reinforce the direction of travel in sponsor compliance: greater scrutiny, broader operational obligations, and a stronger expectation that employers will be able to evidence active and well-governed compliance processes.

Sponsor licence holders, and businesses carrying out right to work checks more generally, should take this opportunity to review their HR, payroll and record-keeping arrangements to ensure they remain aligned with the latest guidance.

If you would like advice on the impact of these developments, or support with a mock audit of your organisation’s compliance arrangements, please get in touch.

We will also be hosting a webinar on 11 June 2026 to discuss the proposed right to work changes in more detail. If you would like to attend, or require more information, visit our event listing and register your interest.

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