The UK government has implemented a new form of compliance audit for Tier 2 sponsors conducted by UKVI as a telephone interview.   The new process will supplement but not replace the established activity of full compliance audits that are carried out by the Sponsor Compliance Network at sponsor premises.

Starting on June 15, the Authorizing Officer listed on the Sponsorship License may have received an email requesting participation in a telephone interview with little advance notice. The UKVI wants to assure themselves that sponsors are aware of and continue to adhere to the following key duties expected of them: the monitoring of employees’ immigration documents and their entitlement to work; that any sponsored worker(s) are undertaking the role for which they were granted permission to be in the UK; adherence to sponsorship duties as defined within the Tier 2 & 5 Sponsor Guidance document; and the obligation to retain records of relevant documents.

The interview should last from 30 – 60 minutes. If sponsors wish to nominate an alternative member of the key personnel noted on the sponsor license to carry out the interview, they may do so.

They may also request that their legal counsel partake in the interview.   

 What can Sponsors do now to prepare?

It is the right time for all employers to review legal right to work processes, company reporting, record keeping, migrant tracking and recruitment procedures to ensure on-going compliance with obligations as a Tier 2 sponsor.  We expect there to be a significant increase in this type of telephone sponsor compliance activity in the coming weeks and months, particularly in advance of the opening of the Tier 2 regime to European nationals wishing to work in the UK following the end of the current post-Brexit transition period. It is therefore vital that all sponsors have in place adequate safeguards and compliance procedures to ensure that their on-going employment and immigration obligations are met.