Appendix D Guide: UKVI Sponsor Record-Keeping Rules 2025

1. Introduction

Navigating the complexities of UK immigration sponsorship demands meticulous record-keeping and strict compliance with Home Office guidance. Failures in this area can result in licence suspension, revocation, and serious reputational harm. Central to maintaining compliance is Appendix D of the UKVI sponsor guidance for Worker and Temporary Worker routes — the definitive rulebook on which documents sponsors must keep.

This blog unpacks the latest version of Appendix D (04/25), effective from 9 April 2025. Whether you’re a Sponsor Licence holder, HR professional, or Compliance Officer, understanding and applying these record-keeping requirements is crucial. We’ll explore the guiding principles, examine the required evidence across categories such as right to work, recruitment, salary, and skill level, spotlight the recent updates, and share actionable best practices to help you meet your sponsor duties with confidence.

2. Understanding Appendix D

What is Appendix D?

Appendix D is a detailed segment of the UKVI sponsor guidance, specifying the exact documents sponsors must keep to fulfil their compliance duties. It ensures that sponsors can adequately evidence their compliance to UKVI upon request.

Who needs to comply with Appendix D?

All organisations holding Worker and Temporary Worker sponsor licences must comply. This includes employers sponsoring Skilled Workers, Global Business Mobility, Creative Workers, and Temporary Workers, as well as their HR and compliance teams.

Recent changes effective from April 2025 (Version 04/25) 

The guidance effective from 9 April 2025 incorporates several updates. Notably:

● Terminology has shifted, with 'Parts' now referred to as 'sections'.

● Clarifications have been made regarding record-keeping duties and right-to-work check responsibilities in varied circumstances.

● Adjustments reflect the phasing out of Biometric Residence Permits and changes for Creative Workers entering via the visa concession.

● The 'care worker recruitment requirement' for Skilled Worker sponsors has been formally integrated.

● Some restructuring occurred, moving previous paragraphs into a new section (Section 5).

3. Core Principles of Document Keeping under Appendix D

Mastering Appendix D starts with understanding its foundational principles:

◆ Document Format: 

UKVI offers flexibility; records can be kept either as physical paper copies or securely in an electronic format. The key is ensuring they are readily accessible and producible upon request by compliance officers.

◆ Retention Period (Sponsored Workers): 

For documents relating specifically to a sponsored worker, the standard rule is to retain them throughout the sponsorship period and until one year after the sponsorship ends, or until a compliance officer has reviewed and approved them if that happens sooner than the one-year mark.

◆ Sponsor Licence Application Documents: 

Information submitted as part of your initial sponsor licence application must be kept for the entire duration that you hold a valid licence.

◆ Overlap with Other Legal Requirements: 

Be aware that Appendix D duties often intersect with other legal obligations. For instance, right-to-work check documentation must also satisfy requirements under illegal working legislation, potentially necessitating longer retention periods for certain documents.

◆ Data Protection Alert: 

Sponsors must also comply with their responsibilities under the Data Protection Act 2018 and the UK General Data Protection Regulation (GDPR), especially considering the immigration exemption. Regularly reviewing these obligations is essential to ensure ongoing compliance.

In the following sections, we will deep dive into five main areas of Appendix D: Evidence of Right to Work, Evidence of Recruitment, Evidence of Salary, Evidence of Skill Level, and Additional Required Documents.

4. Section 1 Deep Dive: Evidence of Right to Work

The Dual Purpose:

Right to work checks serve two purposes: firstly, it's a fundamental sponsor duty, essential for compliance. Secondly, for workers you directly employ, correctly performed checks establish a 'statutory excuse' against potential civil penalties for illegal working.

Performing the Checks:

Checks must be completed before the worker begins employment. Sponsors should follow the process outlined in the official guidance: Right to work checks: an employer’s guide or you can check our Complete Guide to Right to Work Checks for UK Employers 2025 blog.

Handling Different Employment Scenarios:

● Direct Employees: Sponsors must conduct and retain the right to work check themselves.

● Indirect Employees: Sponsors can either carry out the check or retain a copy of the check done by the employing organisation.

● Self-Employed Workers: Sponsors must still perform and record the check, even though it does not provide a statutory excuse.

Checking Date of Entry to the UK:

Required when the worker was sponsored for entry clearance. Sponsors must confirm the worker entered during the visa’s validity period.

● Acceptable evidence includes passport stamps or alternative proof such as travel tickets or boarding passes. You don't need to retain copies of tickets/passes, just make a record of the entry date found.

Special Note: Creative Worker Concession:

Workers entering under this route must obtain a ‘leave to enter’ stamp or use the remote clearance process. Without these, they must exit and re-enter the UK through proper channels.

5. Section 2 Deep Dive: Evidence of Recruitment

The Goal:

UKVI requires sponsors to demonstrate how they recruited sponsored workers. This primarily serves to prove the role is a genuine vacancy. For certain routes, particularly older ones, it also involved proving attempts were made to recruit from the resident labour market first.

Scenario A: Formal Resident Labour Market Test (RLMT) or Similar Was Required

● Required Routes: 

Primarily applies to roles sponsored under the pre-December 2020 Tier 2 (General) route, and certain specific roles under Religious Worker, Creative Worker, and Sportsperson routes (including their Tier 2/5 predecessors).

● Documentation Required:

○ Job advert copies showing title, duties, salary, location, and closing date.

○ Screenshots of web adverts (with URL, dates, and full content).

○ Proof of publication (e.g. invoices or letters from the platform).

○ Applications shortlisted for final interview.

○ Reasons for rejecting settled applicants.

● Additional Evidence: 

Rolling programmes, milk rounds, recruitment processes for researchers, religious record searches, Creative Worker codes of practice, and governing body endorsements for Sportspersons.

Scenario B: No Formal RLMT Required / Exempt Routes

Covers most current Worker and Temporary Worker categories.

● If Advertised:

○ Retain job advert text, publication details and duration.

○ Record applicant and shortlisted numbers.

○ Summary evidence of candidate selection (e.g. interview notes, scoring criteria).

○ Do not retain personal data of unsuccessful candidates.

● If Not Advertised:

○ Provide an explanation and supporting evidence of how the candidate was identified (e.g. internal promotion, speculative application, previous employment).

● Care Worker Recruitment Requirement:

○ sponsoring a Skilled Worker subject to this requirement (see section SK4 of the Skilled Worker guidance), you must demonstrate efforts to recruit from the 'displaced worker pool' before selecting the sponsored candidate. Evidence could include elements from advertised or non-advertised processes above.

6. Section 3 Deep Dive: Evidence of Salary

You must retain clear proof that sponsored workers are paid appropriately according to the sponsorship certificate and relevant immigration rules.

Required Documentation:

● Payslips showing name, NI number, tax code, allowances, and deductions.

● Proof of payment, such as bank records showing individual transfers.

Contracts:

Employment or service contracts must include names, signatures, start/end dates, job role, hours, and salary information.

Allowances:

Any allowances must be documented with clear valuation:

● Rent: tenancy agreement or independent assessment if sponsor-owned.

● Allowances generally do not count towards salary thresholds under the Skilled Worker route.

Route-Specific Exclusions:

Salary documentation is not required for:

● Global Business Mobility – Service Supplier

● Previous International Agreement route provisions

● Global Business Mobility – Secondment Worker

Other Required Documents:

Any additional documents listed under Immigration Rules or route-specific Codes of Practice applicable at the time of the Certificate of Sponsorship assignment.

7. Section 4 Deep Dive: Evidence of Skill Level

Demonstrating that a sponsored worker possesses the necessary skills for the role is another key compliance area. You must retain:

Job Descriptions:

Sponsors must retain a detailed job description specifying the role’s duties, responsibilities, and required skills, qualifications, and experience.

Worker Qualifications/Experience:

Copies of relevant academic or professional qualifications and/or references must be kept to demonstrate the worker’s suitability.

Mandatory Qualifications:

If a qualification was listed as essential, sponsors must provide evidence the worker holds it. If waived, reasons must be documented.

Registration/Accreditation:

For roles requiring registration or professional licensing (e.g., General Medical Council for doctors), sponsors must retain confirmation of the worker’s registration.

Creative Worker Entourage:

For entourage roles under the Creative Worker route, evidence of the worker’s technical or specialist skills must be retained.

8. Section 5 Deep Dive: Additional Required Documents

Beyond the core areas of right to work, recruitment, salary, and skills, Appendix D mandates retaining several other important documents, where relevant:

National Insurance (NI) Number:

A copy showing the worker's NI number, unless they are exempt. Acceptable evidence includes an NI card, official HMRC/DWP letter, or its appearance on documents like a BRP, eVisa confirmation, payslip, P45/P60, or RTI submission confirmation. Encourage workers without an NI number (who aren't exempt) to apply for one promptly.

Worker Contact Details History:

Maintain an up-to-date history of the worker’s UK residential address, email, and phone number.

Consent for Under-18s:

If sponsoring a child under 18, keep a letter of consent from a parent or legal guardian.

DBS Checks:

Where relevant to the role, retain a copy of the worker’s Disclosure and Barring Service check.

Absence Records:

A record of the worker’s absences, manual or electronic, must be maintained.

Route-Specific Documents:

● GMB Service Supplier: Service contracts and tender or award documentation.

● GMB Secondment Worker: Contracts for goods or investment, and tender/award evidence.

● ATAS Certificate: Retain for roles where Academic Technology Approval Scheme clearance is required according to section S7 of Part 2: Sponsor a worker.

● Child Performance Licence: Required for underage Creative Workers involved in public performances.

​​● Other Specific Documents: Retain any other documents specified in the relevant sponsor guidance or codes of practice (e.g., Appendix Creative Worker Codes of Practice, Sporting code of practice).

9. Best Practices for Recording Documents Compliant with UKVI Appendix D 

Maintaining compliance with Appendix D isn't just about having the documents; it's about managing them effectively. Consider these best practices:

✔ Choosing a System: 

Decide between digital and paper systems (or a hybrid).

○ Digital: Offers searchability, space-saving, and potentially easier remote access/backup. Requires robust data security, clear organisation (file naming, folders), and reliable backup procedures.

○ Paper: May feel more tangible for some. Requires significant physical storage, robust organisation (filing systems), and protection against damage (fire, flood). Can be slower to search and retrieve.

Using a UKVI-compliant HR system like WPC HRMS can significantly ease record-keeping duties by automating storage, access, and reminders.

✔ Organisation:

Implement logical and consistent structures. Use clear naming conventions for files or folders (e.g., WorkerName_DocumentType_Date). Ensure anyone who needs access understands the system.

✔ Accessibility: 

Your system must allow for prompt retrieval of documents upon request from UKVI compliance officers. Disorganisation or inability to locate required evidence quickly reflects poorly on your compliance procedures.

✔ Regular Audits: 

Don't wait for a UKVI visit. Conduct periodic internal audits (e.g., quarterly or annually, and when sponsorship ends for a worker) to check for completeness, accuracy, and adherence to retention periods. Identify and rectify any gaps proactively.

✔ Secure Storage & GDPR: 

Protect the sensitive personal data contained within these documents. Ensure storage (physical or digital) is secure against unauthorised access. Always comply with UK GDPR and Data Protection Act 2018 principles regarding data handling, storage duration, and disposal.

10. How Long Must Sponsorship Records Be Kept?

Sponsors must retain documents for the duration of the worker’s sponsorship and for at least one additional year, or until a UKVI compliance officer has examined and approved them—whichever is sooner. Documents relating to the sponsor licence itself must be kept for the lifetime of the licence. Some records may also need to be retained longer for compliance with other legal obligations, such as the prevention of illegal working.

11. Compliance Checks by UKVI

Types of Checks:

UKVI may conduct both announced and unannounced compliance visits. These checks can occur before or after a licence is granted and during the renewal process.

Preparing for a Check:

Ensure all required records are complete, accurate, and readily accessible. Train staff involved in sponsorship management and review internal systems regularly.

Consequences of Non-Compliance:

Failure to provide documents or demonstrate compliance can lead to licence downgrading, suspension, or revocation. This may also affect sponsored workers’ immigration status and your organisation’s operations.

12. How Can WorkPermitCloud Help?

WorkPermitCloud helps UK sponsor licence holders stay compliant with immigration requirements through expert-led, end-to-end support services.

✔ Right to Work Checks

Verify documents in minutes via our RTW Check App or website. Includes secure storage, reminders, and a step-by-step YouTube guide.

✔ Cloud HR Software

Streamline HR compliance with tools for contracts, absence tracking, and performance reviews.

✔ Compliance Audit and Support

We help identify gaps and prepare for UKVI checks/visits.

✔ Expert Sponsorship Advice

Book a free consultation with our legal specialists for tailored guidance.

13. Conclusion

Meticulous record-keeping is essential to maintain your sponsor licence and avoid compliance risks. Sponsorship obligations do not end with visa approval—they continue throughout employment. If in doubt, seek expert support to ensure your processes remain audit-ready and compliant.

14. Glossary