Faith-based organisations play a significant role in the UK’s migration system, regularly sponsoring overseas workers to fill specialist religious roles. Although sector-specific data is not published by the UKVI, it is widely understood that many of the UK’s 140,000 sponsor licence holders are prominent faith-based organisations.
However, it is a challenging time to be a sponsor licence holder. In response to a tougher enforcement stance by the government and a shifting public mood, the UKVI has recently become focused on tackling the exploitation of workers and misuse of the sponsorship system.
Statistics published in February 2026 show a rise in compliance action. In the last quarter of 2025, just over 1,500 of sponsors had their licences revoked.
There has been a notable increase in the UKVI’s scrutiny of sponsorship activity undertaken by faith-based organisations, and many have been subject to compliance visits. There have also been significant changes to UKVI guidance that will impact sponsor licence holders.
Below is a summary of recent changes to UKVI and trends impacting faith-based organisations.
Changes to UKVI guidance
The UKVI sponsor guidance was updated on 6 March 2026 to include the following changes:
Requirement to have read the UKVI guidance for key personnel
The guidance contains a new explicit requirement for all sponsor licence holders and prospective sponsors to have read all relevant parts of the sponsor guidance and remain aware of any changes or updates. The guidance appears to indicate that this applies to anyone falling within the definition of ‘you’, which includes all key personnel and any owner, director, person with significant control, or person involved in the organisation’s day to day running. This new requirement demonstrates the more stringent approach being taken by the UKVI in relation to sponsorship, in emphasising that sponsorship is a privilege, not a right. Sponsors should ensure that all key personnel and as far as is practicable, all owners and managers, have read and are familiar with the guidance and implement systems to keep up to date with changes and updates to the guidance.
Employment law obligations
The updated guidance contains a new requirement for sponsors to ensure workers understand their employment rights and retain evidence that sponsored workers have been informed of this. Sponsors are now required to “ensure and promote the workplace-related welfare of workers they sponsor and ensure workers understand their employment rights“. The Guidance gives the following non-exhaustive list of examples:
- entitlement to National Minimum Wage;
- compliance with the Working Time Regulations;
- pension auto-enrolment and opt-outs;
- entitlement to statutory leave and pay;
- health and safety;
- trade union membership, participation in union activities and the rights of trade union representatives (insofar as this role is otherwise compatible with this guidance and role a worker is being sponsored for);
- your duties under the Equality Act;
- how to raise grievances.
UKVI have said this requirement clarifies a pre-existing requirement in wider UK law for employers (and therefore sponsors) to inform workers of their employment rights. The requirement is now explicitly mentioned in the sponsor guidance and places an obligation on sponsors to retain evidence.
Although non-exhaustive, Appendix D of the Sponsor Guidance provides examples of evidence that must be retained:
- copies of any written information provided to sponsored workers (this could be in their contract of employment);
- training or awareness courses provided to sponsored workers.
It is important that sponsors are aware of these changes to the guidance and ensure they are compliant. We have written an article on this separately here. Sponsors who do not comply could have their sponsor licence suspended or revoked.
Recent trends
Certificate of Sponsorship (CoS) allocation requests and further information requests
As part of routine CoS requests, sponsors are frequently being asked to provide a range of documents from full payroll information and bank statements covering a 6-month period, full staff list and an explanation of why the CoS is required. For faith-based organisations, there is particular scrutiny on whether a role is pastoral or not. Such further information requests can be intrusive and burdensome especially as a sponsor is given a 5 working day deadline to send the full list of documents to the UKVI.
Compliance checks have become common practice, and UKVI have expanded their enforcement team. Recent UKVI guidance indicates that compliance checks may be carried based on ‘reasonable suspicion’ rather than proven breach, thereby broadening the scope.
Digital audits
Salary discrepancies and underpayments have become a significant focus point for the UKVI due to media scrutiny and publicity about ‘rogue employers’ and labour exploitation, and UKVI have indicated that they will revoke sponsor licence where such discrepancies are found.
UKVI has adopted a more proactive and data-driven approach to identifying breaches of sponsor licence duties. Investigations now rely heavily on digital audits and cross-agency collaboration. For example, UKVI are undertaking digital checks by requesting data from HMRC to see if a sponsor is paying a migrant less than what is listed on the CoS for the migrant and if an appropriate report has been submitted to the UKVI clarifying the reason for the change.
Another action which can lead to UKVI compliance action is failing to notify UKVI about a change in migrant’s circumstances, for example, if they go on long term sick leave, or failing to notify UKVI of changes to an organisation’s structure, i.e. if the organisation has been taken over, acquired a new organisation / employee or merged. As changes to an organisation can be easily found on Companies House and via HMRC, UKVI are taking compliance action if a sponsor has not reported a change.
Physical audits
UKVI have increased unannounced visits on organisations that hold a sponsor licence. During these visits, UKVI are interviewing Authorising Officers, checking if sponsors are meeting their reporting and record keeping duties and interviewing sponsored workers about their roles.
How to remain compliant
It is clear that UKVI has adopted a strict approach to sponsor licence compliance and management, and sponsors can be penalised for not managing their sponsor licence adequately. We recommend that sponsors carry out the following key steps:
- refresh your knowledge of reporting and record-keeping duties, so you are aware of what needs to be reported and the timelines involved. The UKVI guidance is regularly updated, and it is important to be aware of any changes;
- ensure your right to work checks remain compliant with the legislation;
- have sufficient processes in place to manage a sponsor licence, including ensuring that the monthly checks are being completed by the Authorising Officer;
- implement systems to report significant changes in a sponsored worker or the organisation’s circumstances promptly.
If you would like to discuss anything outlined in this article, please get in touch.
The material in this article is provided for guidance and general information only and is not intended to constitute legal or other professional advice upon which you should rely. In particular, the information should not be used as a substitute for a full and proper consultation with a suitably qualified professional. Please do contact the Bates Wells team if you require further advice.