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On 5 March 2026, the Home Office announced an important new record-keeping requirement for employers holding sponsor licences.
Sponsors must now hold evidence showing that they have actively provided their sponsored workers with up-to-date information about their UK employment rights.
As many sponsored workers were previously unaware of their legal protections, the Home Office introduced this new requirement to help combat exploitation and modern-day slavery.
The change reflects a wider Home Office initiative to boost sponsor accountability and ensure immigration compliance is aligned with UK employment law.
The changes implemented by the Home Office pose two new obligations for employers.
Not only do they need to proactively share employment rights information with their sponsored workers, but they also need to document the steps taken to ensure these details are understood.
This means employers cannot just issue contracts or written statements to sponsored workers. Instead, they must actively communicate the employment rights while storing evidence of their compliance.
These changes aren’t limited to hires after March 2026, as they apply retrospectively to any worker sponsored before.
Under the guidance, records should be kept for the entire duration of sponsorship and for at least one year afterwards.
While the Home Office hasn’t issued a template of workers’ rights that need to be shared with their sponsored employee, employers should consider the following:
As the Home Office hasn’t specified what format they want evidence to be kept, employers might be confused about how they can demonstrate the requirement is being met.
While the guidance lacks detail, there are some good record-keeping practices that could be adopted to avoid difficulties during a potential Home Office audit.
A distinction employers need to make is that they need to prove information was received and understood, rather than just shared.
For example, when a sponsored employee is signing their contract, employers should ask them to confirm in writing they understand their UK employment rights.
If an employee started before March 2026, employers might want to organise documented refresher sessions to bring pre-existing workers up to speed.
After contracts have been signed, induction materials given to an employee as part of their onboarding should be documented to show how their rights were further communicated.
Likewise, any relevant training records, such as attendance sheets or certificates, or email threads, should also be kept.
Keeping clear and easily retrievable records that evidence information being provided proactively can be critical in the event a business is audited by the Home Office.
Our immigration solicitors can assess whether the evidence your company holds effectively demonstrates workers have understood their employment rights.
This might take the form of mock compliance audits or retrospectively fixing gaps in understanding for those sponsored before March 2026.
We understand the prospect of a Home Office audit can be daunting, especially with compliance that is constantly changing.
By reaching out today, you can test whether the information your company holds would withstand a visit from the Home Office before one is arranged.
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