Resource guide
Appendix D: what sponsors must now hold on employment rights
Since March 2026, Appendix D of the sponsor guidance requires sponsors to retain evidence that they gave each sponsored worker information about their employment rights in the UK: a contract, written guidance, or training records can count, but an undocumented induction that mentions rights in passing may not be enough on its own. The guidance does not exempt workers sponsored before the change, so for most sponsors this is a backfill job that has not started: evidence needed for the existing sponsored workforce, not only new hires. Verified 16 July 2026.
Last updated . Reviewed by Soteriaa team.
Short answer
Since March 2026, Appendix D requires sponsors to retain evidence that each sponsored worker was given information about their employment rights, not just to have told them, but to be able to show it. The duty is not limited to new hires: the guidance does not exempt workers already in post, so for most sponsors this is an unstarted backfill job against the existing sponsored workforce.
What counts as evidence
What Appendix D is looking for.
The common thread is a dated, specific record, not a recollection that it was mentioned.
Written contract terms
Employment-rights information set out in the contract itself.
Written guidance
A dedicated document given to the worker covering their rights.
Training or induction records
A log or record of a session that specifically covered employment rights, not just that induction happened.
A signed acknowledgement
Evidence the worker received and engaged with the information, where obtained.
Why this reaches your existing workforce, not just new hires
The guidance does not say “for workers sponsored after 6 March 2026.” It states the record-keeping duty for sponsored workers generally. Professional commentary is consistent on the practical reading: without a carve-out, the duty reaches everyone currently sponsored. That is the detail most sponsors miss, because it is easy to assume a new rule only affects new hires. Here, it doesn't.
The backfill job
What most sponsors now need to do.
Identify the gap
Work out which currently-sponsored workers have no dated evidence of being given rights information.
Issue or locate the record
For anyone missing one, provide the information now (in writing or via a documented session), and file the evidence.
Keep it current going forward
Record it for every new sponsored worker at the point they join, so the gap doesn't reopen.
Where Soteriaa fits — and where it doesn't
Soteriaa holds, per sponsored worker: when rights information was given, the method used (contract, induction, written guidance, training, or other), any evidence file attached, and notes. It shows which workers have no record on file (the gap this page describes), and includes the record in the generated audit pack. It does not extract data from uploaded documents, does not track which guidance version applies, gives no legal advice, and makes no compliance determination about whether any sponsor's evidence is sufficient.
Sources
Statement of Changes to the Immigration Rules: HC 1691, 5 March 2026 (gov.uk); Home Office sponsor guidance, Appendix D: record-keeping duties (gov.uk, version updated 20 May 2026) and Part 3: sponsor duties and compliance. Related: UK sponsor rules changes: the running record. Verified 16 July 2026. This page is general information, not legal advice. For how this applies to your organisation, take advice from a solicitor or a regulated immigration adviser.
FAQ
Appendix D questions
What the duty requires, who it reaches, and what to do about it.
What does Appendix D require sponsors to do?
Appendix D sets out the record-keeping duties sponsors must meet, including a duty (added as part of the March 2026 changes) to retain evidence that sponsored workers were given information about their employment rights in the UK. Acceptable evidence includes things like written terms in the employment contract, dedicated written guidance, or records of a training or induction session that covered rights.
Is an induction that briefly mentions rights enough?
It may not be, if there is no record of it. The requirement is to retain evidence: a verbal mention with nothing written down or filed leaves nothing to produce if asked. The safer position is a specific, dated record: a document given, a training log, or a signed acknowledgement, kept against the worker's file.
Does this apply to workers I sponsored before March 2026?
The guidance does not carve out an exemption for workers already in post. The duty applies to sponsored workers generally, not only to those sponsored after 6 March 2026. Most professional commentary reads this as reaching the existing sponsored population. In practice, that means most sponsors have a backfill job: producing or issuing the missing record for people already on the books, not just new starters. If you are unsure how this applies to your specific workforce, take advice from a solicitor or a regulated immigration adviser.
What happens if I can't find a record for a worker?
If there is no record, the practical step commentators suggest is to issue the information now (in writing, or via a documented refresher session), and keep the evidence from that point on. This page is general information, not an assessment of any sponsor's position or a substitute for advice.
Can a licence be revoked over missing rights-information records?
Sponsor guidance updated in Spring 2026 states that a licence can be revoked even where a breach was unintentional, and record-keeping failures generally are a stated area of enforcement focus. This page does not assess any individual sponsor's risk. For that, take advice.
Does Soteriaa handle this for me?
Soteriaa holds a rights-information record per sponsored worker: the date it was given, the method (contract, induction, written guidance, training, or other), any evidence file attached, and notes. It shows which workers have no record on file, and includes it in the generated audit pack. It does not extract data from documents, does not judge whether your evidence is sufficient, and makes no compliance determination.
Close the rights-information gap, worker by worker.
A dated record per sponsored worker, evidence attached, and a clear view of who is missing one — in the audit pack. Start free.