Record keeping is one of the five groups of sponsor duties. Part 3 of the sponsor guidance says you must keep certain documents for each worker you sponsor (C1.37). The list itself is in Appendix D. The version we read is 08/26, valid from 3 August 2026.
This guide summarises Appendix D. It explains the published rules and does not review any organisation's records. Speak to a regulated adviser about your circumstances.
Format
Documents can be kept on paper or electronically. Appendix D sets no prescribed storage method, but you must be able to make the documents available to the Home Office on request. If you keep them electronically, all the relevant parts of each document must be visible (C1.37).
How long to keep them
Unless Appendix D says otherwise, documents about a sponsored worker must be kept for as long as you sponsor them, and then until the earlier of:
- one year after your sponsorship of the worker ended, or
- the date a compliance officer examined and approved them, if that is sooner
You must also keep the documents you sent with your licence application for as long as you hold the licence.
Some documents may need keeping longer for other reasons. Appendix D gives illegal working law as an example. The employer's guide to right to work checks says right to work evidence is kept for the length of employment and for two years afterwards.
1. Right to work evidence
You must keep evidence that you carried out right to work checks on any worker you employ, and any worker you sponsor (Appendix D, section 1.1). Our guide to right to work checks for sponsors covers this in detail.
Where you sponsored a worker's visa application, you must also check and keep evidence of their date of entry to the UK (section 1.2). That usually means a copy of the page with their entry stamp.
2. Recruitment evidence
You must be able to show how you recruited each sponsored worker (section 2). Where a formal resident labour market test applied, section 2.1 lists the evidence. Where none applied, section 2.2 says you must still be able to explain, with evidence where appropriate, how you recruited the worker. The Home Office uses this to judge whether the role meets the definition of "eligible role".
3. Salary evidence
Section 3 lists:
- payslips showing the worker's name, National Insurance number, tax code, allowances and deductions
- evidence of each salary payment into the named worker's bank account or pre-paid card
- a copy of the contract or written statement of employment particulars, showing the parties, dates, job, hours and pay
- evidence of the value of any allowances, where the route permits them and they are not shown elsewhere
Account records that show only "wages for personnel", without identifying the worker, will not be accepted.
4. Skill level evidence
Section 4 lists:
- a detailed job description with the skills, qualifications and experience the job needs
- copies of the worker's relevant qualifications, or references showing their experience
- copies of any registration or professional accreditation the job legally requires
If your job advert said a qualification was mandatory, you must keep evidence the worker has it. If you waived it, you must keep detailed reasons why.
5. Other documents
Section 5 lists, where relevant:
- the worker's National Insurance number
- a history of their contact details, kept up to date: UK address, personal email and phone
- a parental consent letter for any worker under 18
- a DBS check where the role requires one
- a record of the worker's absences
- an ATAS certificate where the role needs one
- evidence that you give workers information about their UK employment rights
Route-specific guidance can add more. For care workers, Sponsor a Skilled Worker (SK4.35) asks sponsors to keep evidence that a worker had been working for them for at least 3 months before the CoS was assigned.
When the Home Office asks
You must give the Home Office, when asked, any documents it considers relevant to your compliance (C1.38). Its example is evidence of recruitment practices. If you do not provide them, or miss its deadline, the guidance says it will take action.
Annex C2(g) lists failing to provide an Appendix D document on request, within the time limit, as a ground on which the Home Office will normally revoke a licence. Compliance officers may inspect records during a visit (C7.15).
Data protection
Appendix D and Part 3 both remind sponsors of their duties under the Data Protection Act 2018 and UK GDPR (C1.41).
The printable sponsor compliance checklist includes the record-keeping duties.
Common questions
Can we keep records only in an HR system?
Yes. Appendix D allows paper or electronic records, with no prescribed method. They must be available to the Home Office on request.
Do we keep records after a worker leaves?
Usually, yes: until one year after sponsorship ended, or until a compliance officer approves them if that is sooner. Right to work evidence follows its own rule.
Does a pooled payroll report count as salary evidence?
Not if it does not identify the individual worker. Appendix D says the Home Office must be able to see the specific worker's pay.
Can we talk to someone about our situation?
You can tell us about your situation. We do not assess cases or help with forms.