As of 6 March 2026, sponsor licence holders are required to provide their sponsored workers with information about their employment rights.
The update to the rules was made in the government’s Sponsorship: guidance for employers and educators documents. Appendix D (the Appendix) of the guidance refers to record keeping obligations, and states that:
You must retain a copy of all of the following, to the extent that they are relevant:
- Evidence you give your sponsored workers information about their employment rights in the UK (as set out in section L2 of Part 1: Apply for a licence) – for example, copies of any written information you have provided to your workers (this could be in their contract of employment) or training or awareness courses you have provided to your workers
Which workers does the rule relate to?
The Appendix refers to workers including those sponsored on:
- The Worker routes (Skilled Worker, Global Business Mobility – Senior or Specialist Worker (i.e. this also applies to expatriates from head office), T2 Minister of Religion, International Sportsperson)
- The Temporary Worker routes (Charity Worker, Creative Worker, the Global Business Mobility routes (other than the Senior or Specialist Worker), Government Authorised Exchange, International Agreement, Religious Worker, Scale-up or Seasonal Worker)
- The predecessor routes of the above
Record-keeping requirements
Paragraph L2.7 of the government’s Workers and Temporary Workers: guidance for sponsors states that:
- You must have human resources systems or processes in place which demonstrate that you provide this information to any employees or workers you sponsor. You must retain this evidence for any workers you sponsor, in accordance with Appendix D to this guidance
Documents to be kept can include employment contracts, employee handbooks, employment policies and training records, along with evidence that the information was delivered to the employee and that they received it.
The documents can be in electronic format or paper copies, and be available for inspection by UKVI officials.
How long must the records be retained?
Records must be kept throughout the period that a worker is sponsored and until the earlier of:
- One year after the date on which sponsorship of the worker ended; or
- The date on which a compliance officer examined and approved the records, if this is less than one year after sponsorship of the worker ended
What information should be provided to workers?
Information that workers should receive includes, but is not limited to, the following:
- Their entitlement to receive the National Minimum Wage
- Details of the Working Time Regulations setting out maximum working hours and entitlement to rest breaks
- Pension auto-enrolment information and the choice to opt out
- Details of statutory leave and pay, including entitlement to holiday, sick pay, maternity and paternity pay and shared parental leave
- Health and safety rights
- Trade union membership rights
- Equality Act protections and information on the right not to be discriminated against
- Details of their right to raise a grievance
Ensuring compliance with the new rules
Employers can ensure compliance with these requirements by putting robust and comprehensive employment contracts in place. Where necessary, separate employee handbooks or policies can be compiled and provided to new workers at the start of their employment.
By keeping signed receipts, employers will be able to demonstrate that sponsored workers have received the necessary information.
Changes must be clearly notified in writing, and evidence that employees have been advised of these should be retained.
How 3CS can help
Our expert immigration and employment solicitors can advise and assist you in a full range of issues relating to obtaining and running a sponsor licence and ensuring you have compliant systems in place.
For assistance, please get in touch today.
