Most sponsor licence failures do not start with an audit. They start six months earlier, in payroll.

The Home Office does not need to visit your premises to identify salary compliance failures. Through data-sharing with HMRC, it can identify discrepancies between the salary declared on a Certificate of Sponsorship and the wages actually paid, without prior notice and without a compliance visit.

This is how the majority of the 3,100 sponsor licence revocations in 2025 were triggered. Not by inspections. By data.

The April 2026 per-pay-period salary compliance rules make this more, not less, significant. The salary must now be met in each pay period, not averaged across the year. A single month where a sponsored worker’s pay falls short of their CoS declaration, because of variable hours, a deduction or an irregular payroll run, can now constitute a compliance breach.

The businesses most at risk are not those who are deliberately non-compliant. They are the ones where:

• HR and payroll operate in separate systems with no cross-check against CoS records
• Sponsored workers move between roles, sites or hours without the SMS being updated
• SMS users were trained two or three years ago and are working from outdated knowledge
• No one in the business has formally reviewed compliance since the April 2026 rule change

SMS Level 1 and Level 2 User Training addresses the compliance framework within which the system operates, the reporting obligations that attach to every sponsored worker and the record-keeping requirements the Home Office will test in a compliance visit. If your SMS users are working from knowledge that pre-dates the March 2026 guidance update and the April 2026 salary compliance changes, they are managing your licence on incomplete information.

Davenport Solicitors delivers updated SMS training for sponsors across all sectors. Contact us on 020 7903 6888 or email contact@davenportsolicitors.com