Resource guide
HMRC and Home Office data sharing: what sponsors need to know
If a sponsored worker's pay dips below the level on their Certificate of Sponsorship for a single pay period, that is now a detectable event, not something averaged away over a year. Two changes from 8 April 2026 combine: the Skilled Worker sponsor guidance now states the Home Office checks salary “through compliance checks, HMRC checks, or both”, and the pay-period rule (Statement of Changes HC 1691) requires the salary to meet the required level in each pay period, averaged only across a 3-month or 12-week window. Because the Home Office matches PAYE data to the visa record, an underpaid month can surface without a compliance visit. Sources verified 16 July 2026.
Last updated . Reviewed by Soteriaa team.
Short answer
Per-pay-period salary now matters, and your payroll data is visible to the Home Office. A payslip that dips below the Certificate of Sponsorship figure for a single pay period is now a detectable event rather than something averaged away across the year, because the Home Office matches HMRC PAYE data to the visa record, and the rules now test each pay period.
What changed on 8 April 2026
Two changes, one combined effect.
The guidance names HMRC checks
The Skilled Worker sponsor guidance now states the Home Office checks salary “through compliance checks, HMRC checks, or both” (the first time this is expressly set out, though it happened in practice beforehand).
Salary is tested per pay period
Statement of Changes HC 1691 requires the required level to be met in each pay period, averaged only across a 3-month or 12-week window, not primarily over the year.
What the Home Office can see
The gov.uk publication “Sponsored Work and Family visa earnings, employment and Income Tax” describes data matching between Home Office visa records and HMRC's PAYE Real Time Information (RTI) data, with visa records linked to RTI via the National Insurance number and the Migrant Worker Scan. That is what the published source states. It describes the matching of visa records to PAYE data.
The pay-period rule in detail
Under HC 1691 (in force 8 April 2026): the salary must meet the going rate for each hour worked in each pay period, and the average must meet the required minimum across any 3-month period (for monthly or less frequent pay, at least a quarter of the required annual salary) or any 12-week period (12/52 of the annual figure) where pay is more frequent. The practical shift is from an annual view to a per-pay-period view.
What it means in practice
For a sponsor, the useful takeaways.
General guidance on how the checks work, not an assessment of any employer.
One month counts
A dip below the CoS figure in a single pay period can be seen; it is no longer averaged away over 12 months.
Keep pay aligned each period
The going rate and minimum are tested within each pay period, subject to the 3-month / 12-week averaging windows.
Be ready to evidence pay
A data anomaly can prompt a request for evidence or a visit, so keep clear, current pay and worker records.
Where Soteriaa fits — and where it doesn't
Soteriaa keeps the sponsor-side records in one place: sponsored worker records, Certificate of Sponsorship records, visa and BRP dates, evidence, deadlines and alerts, and a one-click audit pack, so the compliance picture is easy to review and produce. It does not process payroll, does not file to HMRC or the Home Office, gives no legal advice, and makes no compliance determinations.
Sources
Skilled Worker sponsor guidance (updated 8 April 2026); gov.uk, “Sponsored Work and Family visa earnings, employment and Income Tax”; Statement of Changes to the Immigration Rules HC 1691 (in force 8 April 2026). Verified 16 July 2026. This page is general information, not legal advice.
FAQ
HMRC data-sharing questions
What the guidance and gov.uk actually say about salary checks.
Does the Home Office see my payroll data?
The gov.uk publication “Sponsored Work and Family visa earnings, employment and Income Tax” describes data matching between Home Office visa records and HMRC's Pay As You Earn (PAYE) Real Time Information (RTI) data, with visa records linked to RTI via National Insurance number and the Migrant Worker Scan. The Skilled Worker sponsor guidance, updated 8 April 2026, states salary is checked “through compliance checks, HMRC checks, or both”.
When did this start?
The sponsor guidance was updated on 8 April 2026 to state HMRC checks expressly (the first time this is set out in the guidance), though the Home Office had validated pay against HMRC in practice beforehand.
What is the pay-period salary rule?
Under Statement of Changes HC 1691, in force from 8 April 2026, salary must meet the going rate for each hour worked in each pay period, and the average must meet the required minimum across any 3-month period (for monthly or less frequent pay, at least a quarter of the required annual salary) or any 12-week period (12/52 of the annual figure) where pay is more frequent. This replaces primarily-annual assessment.
What happens if a worker is underpaid in one pay period?
Because pay is now tested per pay period and payroll data is matched to the visa record, an underpaid pay period can be identified without a compliance visit. That can prompt a request for evidence, a compliance visit, or enforcement action. This is general information about how the checks work, not an assessment of any particular employer.
Does Soteriaa monitor my payroll or file to HMRC?
No. Soteriaa keeps the sponsor-side records: sponsored worker records, Certificate of Sponsorship records, visa and BRP expiry dates, evidence, deadlines, and a one-click audit pack. It does not process payroll and does not file to HMRC or the Home Office.
Is this legal advice?
No. This page is general information. For how these rules apply to your organisation, take advice from a solicitor or a regulated immigration adviser.
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