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Core duty themes
Prevent illegal working: Right-to-work checks and follow-ups.
Keep records: Recruitment, contact details, right-to-work evidence, and other Appendix D-style records as required.
Report changes: Worker no-shows, job changes, early endings, and organisational changes via SMS within required timeframes.
Comply with the law: Pay, working time, and wider employment law still apply.
RACI, name humans, not departments
| Theme | Accountable | Cadence |
|---|---|---|
| Right-to-work | HR / People Ops | At hire + follow-ups |
| SMS reporting | Level 1 user | Within Home Office deadlines |
| SMS sign-in | Level 1 users | Keep email, mobile number and date of birth current for sign-in codes (since 3 September 2026). Accounts not used for 12 months can be deactivated. |
| Level 2 users | Authorising Officer | Move any Level 2 users to Level 1 (if eligible) or remove them before 8 March 2027. |
| Record pack | AO + HR | Living folder; audit-ready |
| Key personnel backup | AO | Review quarterly |
| Salary / role changes | HR + hiring manager | Before the change goes live |
| Job ad sponsorship claims | TA / employer account owner | Every publish |
Cadences that prevent surprises
- 1
Weekly: Level 1 checks SMS tasks and upcoming worker changes.
- 2
Monthly: Reconcile sponsored headcount vs HRIS vs CoS records.
- 3
Quarterly: AO review: backups, address books, training, open risks.
- 4
Licence health: Review key personnel, SMS access, and records on a set cadence. Mention expiry only for UK Expansion Worker and Scale-up licences, which stay time-limited.
Visit-day / audit runbook
Assume you may be visited or asked for documents. Panic is optional if the folder already exists.
Single compliance pack: Per sponsored worker + organisational SMS evidence.
Named hosts: Who meets the officer; who pulls records.
No improvisation: If you do not know, say you will retrieve, do not invent.
Post-visit actions: Log requests, fix gaps and ask a specialist if issues come up.
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Who should own compliance?+
A named Authorising Officer with operational Level 1 support. Spreading duty across “whoever is free” is a common failure mode.