Gurjit Pall

As part of UK government measures introduced last month (March 2026), employers must make sure that sponsored staff understand their full employment rights. 

And they must be able to evidence that these rights - including those around the national minimum wage levels, working hours and statutory leave - have been fully explained to workers.

It is also now a mandatory requirement for all licensed sponsors to read all parts of the sponsor guidance and to remain aware of its content, including any changes made to it.

Immigration lawyer Gurjit Pall, a partner at Lindsays, is advising employers navigating the latest changes and said: “This is a significant undertaking. Employers should expect increasing levels of scrutiny around complying with the terms of their licence.

“The latest guidance makes clear that job descriptions detailed on certificates of sponsorship must reflect the role recruited to. These roles must also remain relevant to sponsors’ businesses.”

On practical steps to be taken, Mr Pall added: “HR and induction processes must be maintained to show both how information is communicated to sponsored workers - and to demonstrate it has been done.

“The terms of licence also require sponsors to stay up-to-date with legislative changes, which can be a challenge. Anyone in any doubt would be wise seeking legal support.”

For the year 2025, 3,299 licences allowing companies to bring in migrant workers were revoked across the UK – more than double the number in the previous 12 months (1,620). 

Employers who seek to employ international workers must first obtain a sponsor licence from the Home Office, which allows them to legally sponsor overseas staff through legally defined “eligible roles”.

Without a licence, sponsors cannot issue a Certificate of Sponsorship, which is required for workers to apply for a UK work visa.

The definition of eligible role criteria has been added to in the latest guidance.

Mr Pall, a Glasgow-based lawyer who advises businesses, charities and other organisations across Scotland, said: “Employers holding sponsor licences cannot afford to put them at risk because their procedures are not up-to-date.

“Failure to comply could ultimately lead to a sponsor licence being revoked.”

Employment lawyers at Lindsays are urging employers with sponsor licences to urgently review the latest guidance, share employment rights with all sponsored workers and log when and how that advice was given.

Businesses are also encouraged to regularly check that sponsored roles meet the most current eligibility criteria.