RWK Goodman: Preparing for Home Office pay compliance requests

The Home Office recently published the 2026 Q1 (January to March 2026) figures confirming a record level of 1,548 sponsor licences were revoked. As part of this increase in enforcement action by the Home Office, care providers are seeing a growing number of requests for further information based on concerns that sponsored care workers are not being paid at the required levels.

Change in approach

The above figures are alarming, and the care sector has been drastically impacted. As you may be aware, the Home Office is working closely with other government organisations, specifically HMRC. They are monitoring payment cycles of sponsored migrants and comparing them to salary information on their certificates of sponsorship.

Home Office requests for further information on pay

The Home Office is contacting care providers usually via email, once they have spotted issues or have doubts about payment irregularity. Sometimes these requests ask for information relating to named sponsored employees only, but often they are generic and request information relating to all the care provider’s sponsored employees.

Usually the Home Office requests the following information: employment contracts; payslips for at least the last three months; confirmation of national insurance numbers; absence records; business account bank statements for the last six months confirming payments made to employees; P60s of all sponsored employees and P45’s (where applicable); Payroll Summary or Real Time Information (RTI), confirming Gross & Net pay and NI & Tax deductions for the last 6 months.

The given timeline to respond is usually ten working days from the date of the email from the Home Office. This is a very tight timeframe to respond, so care providers need to be ready to act quickly.

What you can do now to prepare

Authorising officers, and other key personnel, must ensure their contact details are kept up to date with Home Office. They must regularly monitor their emails (including junk mails).

• Conduct internal audits to ensure all payments are in line with the COS of each sponsored migrant and the minimum salary requirements.
• Any reduction in salary or working hours due to absence must be for a permitted reason or below the permitted level, and reported on time (if required), in accordance with the sponsor guidance.
• Appropriate systems must be in place to monitor and record absences. These may need to be provided to the Home Office to justify any drop in salary due to absence.
• Whilst the Home Office request usually only asks for copies of documents, you should prepare a detailed cover letter explaining the documents and, in particular any discrepancies or issues you have identified.
• Care providers must remain informed of changes by following updated Home Office guidances for skilled worker sponsors [Sponsorship: guidance for employers and educators - GOV.UK].

Following the care provider’s response, if the Home Office is satisfied with the information provided, no further action may be taken. However, if concerns remain, the sponsor licence may be suspended while the Home Office raises further enquiries and investigates the grounds for suspension. Alternatively, if the Home Office feels the concerns are well founded, the licence may be revoked.

Key takeways

• Home Office scrutiny of sponsor licence compliance is increasing, in part due to checks on HMRC pay data.
• Requests for information from the Home Office can be both broad and time-sensitive.
• You should proactively audit your pay, hours and absence records to ensure sponsored workers are being paid correctly.

A thorough and well-prepared response to a Home Office request is the best way to reduce the risk of licence revocation.

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