Running record
UK sponsor rules changes: a running record for employers
When intent stops being a defence, the paper trail is the defence. That is the shape of the changes since March 2026: Statement of Changes HC 1691 (laid 5 March 2026) and the sponsor guidance that implemented it added a duty to hold evidence, not just to comply, but to be able to show compliance. The biggest new item is Appendix D: sponsors must now retain evidence they gave sponsored workers information about their employment rights, and it reaches workers already in post, not only new hires. This page is a running index. Statements of Changes land roughly twice a year, so each cycle gets its own dated entry below rather than a rewritten page. Verified 16 July 2026.
Last updated . Reviewed by Soteriaa team.
Changes by date
March–May 2026 cycle: Statement of Changes HC 1691 (laid 5 March 2026); sponsor guidance updated in stages (v03/26 from 6 March, v04/26 from 8 April, further update from 20 May). Covers Appendix D employment-rights records, the pay-period salary rule, and eligible role. Detailed below. Future cycles will be added above this one as new Statements of Changes land. This entry will not be rewritten.
March 2026 cycle — Appendix D: employment-rights records (the one that creates work now)
Sponsors must retain evidence that sponsored workers were given information about their employment rights: 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 limit this to workers sponsored after March 2026, so most sponsors have an unstarted backfill: producing or locating evidence for everyone already on the books, not just new starters. Full detail: Appendix D: what sponsors must hold.
March 2026 cycle — the other changes
Pay-period salary and eligible role, from 8 April 2026.
Salary tested per pay period
The required salary and going rate must now be met in each pay period, averaged over any 3-month period (or any 12-week period where pay is more frequent) rather than mainly annually.
“Eligible role” replaces “genuine vacancy”
For CoS assigned from 8 April 2026, the role must exist at assignment, match the duties and hours on the CoS, meet skill and salary requirements, and comply with NMW and Working Time rules.
The standing duty behind all of this
None of this is optional reading. Sponsor guidance has long required sponsors to read it in full and stay aware of updates, and the Spring 2026 guidance is explicit that a licence can be revoked even where a breach was unintentional. Not knowing about a change is not a defence; neither, increasingly, is having meant well without a record to show for it.
Enforcement backdrop
This sits against a documented rise in enforcement. The Home Office's own figures show 1,948 sponsor licences revoked in the year to June 2025 (more than double the 937 revoked the year before), and described by the Home Office itself as record numbers. Sector commentary has pointed to social care, hospitality, retail, and construction as areas of particular focus, with underpayment and poor record-keeping as common issues.
Where Soteriaa fits — and where it doesn't
Soteriaa holds a rights-information record per sponsored worker (when it was given, how, and any evidence attached), shows which workers have nothing on file, and includes it in the generated audit pack. It does not compute salary compliance or a going rate, does not track which guidance version applies, does not extract data from documents, and makes no compliance determination. It records what you say you did; it does not judge whether the evidence is sufficient.
Sources
Statement of Changes to the Immigration Rules: HC 1691, 5 March 2026 (gov.uk); Home Office sponsor guidance, Appendix D and Part 3 (versions 03/26, 04/26, and the update from 20 May 2026); gov.uk, “Record numbers of visa sponsor licences revoked for rule breaking”. Verified 16 July 2026. This page is general information, not legal advice, and will be updated as further changes land.
FAQ
Sponsor rules-change questions
What changed, when, and what it means for record-keeping.
What changed for sponsors in March 2026?
Statement of Changes HC 1691 (laid 5 March 2026) and the sponsor guidance that implemented it introduced: a new Appendix D duty to retain evidence that sponsored workers were given information about their employment rights; a pay-period salary rule requiring the required salary to be met in each pay period rather than mainly annually, from 8 April 2026; and “eligible role”, which replaced “genuine vacancy” as the test applied when a Certificate of Sponsorship is assigned, also from 8 April 2026.
Does the Appendix D rights-information duty apply to workers I sponsored before March 2026?
The guidance does not carve out an exemption for workers already in post. The record-keeping duty applies to sponsored workers generally, not only to those sponsored after 6 March 2026. Most professional commentary treats this as reaching the existing sponsored population, which for most sponsors means a backfill job that has not yet started. If you are unsure how this applies to your workforce, take advice from a solicitor or a regulated immigration adviser.
Can a licence be revoked for an unintentional breach?
Yes. Sponsor guidance updated in Spring 2026 states that a licence can be revoked even where a breach was not intentional or knowingly committed. This is a change in emphasis worth taking seriously: the “we didn't mean to” defence carries less weight than the evidence you can produce.
Is this the last change, or will there be more?
There will be more. The sponsor guidance implementing the March 2026 changes has already been reissued twice since: version 03/26 (from 6 March 2026), then version 04/26 (from 8 April 2026), and the guidance was updated again with effect from 20 May 2026. Statements of Changes to the Immigration Rules land roughly twice a year. This page is structured as a running index so each new cycle is added below rather than replacing what is here.
Does Soteriaa keep me compliant with these changes?
No. Soteriaa records what you tell it you did. It does not judge whether your evidence is sufficient and makes no compliance determination. For the rights-information duty specifically, it holds a record per sponsored worker (when it was given, how, and any evidence attached), shows which workers have no record on file, and includes that in the generated audit pack. It does not compute salary compliance, and it gives no legal advice.
Hold the evidence, not just the intent.
A rights-information record per worker, evidence attached, and a clear view of who has nothing on file — in the audit pack. Start free.