Appendix D: sponsor licence record keeping duties

This guide is for UK employers who hold a sponsor licence and for the immigration advisers who help them. The Home Office published version 10/26 of Appendix D on 8 October 2026, replacing version 08/26, so older summaries are out of date. We build Filyst, case software for immigration firms. Its deadline tracking counts calendar days on an immigration case; it does not track sponsor reporting duties, so this guide describes the rules, not a product feature. The sections cover what Appendix D is, who it binds, the retention period, the documents, the reporting deadlines, the sanctions and who may advise.

What is Appendix D?

Appendix D is the Home Office document that tells a sponsor licence holder which documents it must keep to meet its record-keeping duties. Its GOV.UK page is titled “keeping records for sponsorship”. It forms part of the collection “Workers and Temporary Workers: guidance for sponsors”.

The current version is Appendix D version 10/26, valid from 8 October 2026. Documents can be kept as paper copies or in an electronic format. Appendix D prescribes no storage method, but the sponsor must be able to make the documents available to the Home Office on request.

The duty itself sits in Part 3 of the sponsor guidance: sponsor duties and compliance (version 08/26, valid from 28 August 2026). Paragraph C1.37 of Part 3 says a sponsor must keep certain documents for each worker it sponsors, and that Appendix D lists them.

Who do the record keeping duties apply to?

The duties apply to every organisation that holds a sponsor licence on the Worker or Temporary Worker routes. A sponsor licence is the Home Office permission that lets an employer sponsor overseas workers. Part 3 paragraph C1.1 applies its duties to all Worker and Temporary Worker sponsors.

Appendix D counts as a “sponsored worker” anyone sponsored on the Worker routes (Skilled Worker, Global Business Mobility Senior or Specialist Worker, T2 Minister of Religion, International Sportsperson), the Temporary Worker routes, or their predecessor routes such as Tier 2 and Tier 5.

A sponsor’s responsibility for a worker starts on the date it assigns that worker a Certificate of Sponsorship (CoS), the electronic record a worker uses to apply for a visa (Part 3, C1.10). One record reaches further: section 1.1 of Appendix D requires right to work evidence for any worker the sponsor employs, even one it does not sponsor.

How long must sponsors keep worker documents?

Sponsors keep all documents relating to a sponsored worker throughout the period of sponsorship and until the earlier of two dates: one year after the sponsorship ended, or the date a compliance officer examined and approved the documents. A compliance officer is the Home Office official who checks a sponsor’s records.

The rule opens with “unless otherwise stated in this guidance”, and Appendix D states three other periods:

• Documents sent with the sponsor licence application are kept for as long as the organisation holds the licence.
• Sports governing body endorsement letters, and the documents submitted to obtain them, are kept for 2 years after the endorsement expires (section 2.1, paragraph l).
• Documents needed for other purposes can have longer periods. Appendix D gives legislation on preventing illegal working as its example, and says the sponsor must meet any other legal record-keeping requirement set by the Home Office or another government department.

Appendix D also reminds sponsors of their responsibilities under the Data Protection Act 2018 and the UK General Data Protection Regulation, which apply to worker records held for any of these periods.

Which documents must sponsors keep?

Appendix D groups the documents into five numbered sections. The table gives the main documents in each; the appendix holds the full wording.

Recruitment evidence is required on all routes. Section 2.2 says a sponsor on a route with no formal resident labour market test must still retain evidence of any recruitment activity, and must be able to explain how it recruited the worker if it did not advertise. Sponsors need not keep application forms, CVs or interview notes of unsuccessful candidates under section 2.2.

Salary evidence must identify the worker. Appendix D says the Home Office will not accept accounts that show only “wages for personnel” without naming the sponsored worker or giving another unique identifier. Section 3 exempts some Global Business Mobility arrangements from the payment evidence.

What does section 5 of Appendix D add?

Section 5 requires a copy of each of these, to the extent it is relevant to the worker:

1. The worker’s National Insurance number, unless the worker is exempt from needing one.
2. A history of the worker’s contact details: UK residential address, personal email address and telephone number, always kept up to date.
3. A consent letter from the parents or legal guardian of a child aged under 18.
4. The worker’s Disclosure and Barring Service (DBS) check, where the role requires one.
5. A record of the worker’s absences, kept electronically or manually.
6. Any other document set out in the route-specific sponsor guidance, the Creative Worker codes of practice or the sporting code of practice.
7. For Global Business Mobility Service Supplier sponsors: the service contract, with the tender document or evidence of how it was awarded.
8. For Global Business Mobility Secondment Worker sponsors: the contract for goods or investment, with evidence of how it was awarded.
9. An Academic Technology Approval Scheme (ATAS) certificate, where the role requires one.
10. Evidence of a child performance licence, for a Creative Worker below school-leaving age in paid performances or modelling.
11. For Government Authorised Exchange sponsors who used the trial “Sponsor UK” service: a record of the information given to the worker about the role.
12. Evidence that the sponsor gives its sponsored workers information about their employment rights in the UK.

What changed in Appendix D version 10/26?

Version 10/26 replaced version 08/26 (published on 3 August 2026) on 8 October 2026. Appendix D lists three changes, plus minor housekeeping:

• Section 1.1was redrafted because the Right to Work Scheme applies to working arrangements beyond traditional employment from 1 October 2026. A sponsor must hold right to work evidence for any worker it sponsors, “regardless of the nature of the working arrangement”.
• Section 2.1 reflects the removal of the resident labour consideration for the Religious Worker route from 29 October 2026.
• Section 2.2(e)is a new duty. A sponsor of a Religious Worker who applied on or after 29 October 2026, and who qualifies through at least 6 months of religious duties for an affiliated faith-based organisation overseas, must retain a copy of that organisation’s letter to the worker.

What must sponsors report, and by when?

Sponsors must report listed changes to a sponsored worker’s circumstances within 10 working daysof the event, and changes to the organisation within 20 working days (Part 3, C1.13). Reports go through the Sponsorship Management System (SMS), the Home Office online account for licence holders, using its “Report migrant activity” function (C1.16).

Paragraph C1.15 of Part 3 lists nine worker changes. The records in Appendix D are what tell a sponsor that one has happened.

A job change outside the same occupation code is not a report. Paragraph C1.15 covers only changes “other than those which require a change of employment application”. The occupation code is the job classification stated on the worker’s CoS.

Work location has its own detail. A sponsor does not report a move to hybrid working or day-to-day changes of site, but must report a worker who will work entirely remotely (C1.23 to C1.25).

Two duties have no fixed number of days. A sponsor must tell the Home Office “as soon as reasonably practicable” if it knows or suspects a sponsored worker has breached their conditions of stay, and must give the police any information suggesting a sponsored worker is engaged in terrorism or criminal activity (C1.14).

Organisation changes run on a different clock. A sponsor must report them no later than 20 working days after the date it became aware of the change, except when replacing its Authorising Officer or Key Contact (C2.3). The changes include a new name or address, a change of structure, ceasing to trade, an insolvency procedure, a merger or takeover, and a relevant conviction; Part 3 paragraph C2.4 holds the full list. Supporting documents must reach the Home Office within 5 working days of the request (C2.19).

What happens when a sponsor misses a duty?

The Home Office can apply any of five sanctions when it reasonably suspects a sponsor is failing its duties (Part 3, C1.12): reducing the CoS allocation or setting it to zero, downgrading the licence rating, suspending the licence during an investigation, revoking the licence, and reporting the sponsor to the police or other authorities.

Records are tested on request. Paragraph C1.38 says that if a sponsor fails to provide documents when asked, or within the timeframe given, the Home Office “will take action”.

A relatively minor breach that the sponsor is willing and able to correct leads, in most cases, to a B-rating (C7.25). A B-rating is a transitional licence rating below the normal A-rating. A B-rated sponsor:

• must comply with an action plan, for which it must pay a fee within 10 working days (C8.3, C8.14);
• follows a plan set for a fixed period of 3 months (C8.17);
• cannot assign a CoS to any new worker until its A-rating is restored (C8.11);
• has its licence revoked if it does not comply with the plan or make the improvements in time (C8.3);
• can be B-rated only twice in any rolling 4-year period, after which the licence is revoked (C8.22, C8.24).

Revocation ends sponsorship on every route the licence covers, and the Home Office will normally cancel the permission of the sponsored workers (C10.2). There is no right of appeal. The sponsor cannot apply again for at least 12 months, or 24 months after a second revocation (C10.3).

Who can advise a sponsor on these duties?

Only a “qualified person” may give immigration advice or services in the UK. The Immigration Advice Authority lists four ways to qualify in its registration guidance.

They are registration with the IAA; authorisation by a Designated Professional Body; authorisation by a Designated Qualifying Regulator; or acting under the supervision of a person who meets one of those three.

Solicitors qualify through their own regulator. The IAA says firms regulated by the Solicitors Regulation Authority (SRA) do not need IAA registration. Licensed sponsors have a separate, limited exemption under the Licensed Sponsors Order 2022 (SI 2022/235). It lets a sponsor give advice up to IAA Level 1 without registration, on three conditions: the advice is free, it goes only to people the organisation directly sponsors and their immediate family, and it relates to applications under a sponsored work or study route.

Sponsor duties sit beside the adviser’s own. An IAA-registered adviser who helps a sponsor is bound by the IAA Code of Standards, which our IAA Code of Standards 2024 guideexplains Principle by Principle. The adviser’s client file follows that Code, not Appendix D, so its retention period differs: how long UK immigration advisers must keep client records sets it out.

One thing we learnt building Filyst is that the two kinds of deadline are counted differently. Filyst tracks deadlines on each immigration case, such as a biometrics appointment or a submission date, and reminds the firm 30, 14, 7 and 1 days before, in calendar days. Sponsor reporting clocks run in working days from an event at the employer. Filyst does not track sponsor reporting duties or working-day deadlines. Software for immigration firms describes what it does track.

Frequently asked questions

Sources

1. Home Office, Sponsor guidance Appendix D: record-keeping duties (version 10/26, accessible)
2. Home Office, Sponsor guidance Part 3: sponsor duties and compliance (version 08/26)
3. IAA, IAA registration explained