Sponsor Licence Compliance for UK Construction Employers

Construction sponsors face two compliance pressures that don't apply to most other sectors: workers move between sites constantly, and pay often includes overtime, bonuses, and per-diems that complicate salary threshold compliance. Both are compounded by short-notice project changes that strain the 10-working-day reporting window.

Work location reporting

Every new site a sponsored worker operates from is a reportable change. The 10-working-day clock starts the first day the worker is at the new site. Sponsors with rotating crews need a process that flags new sites as they appear in HR/payroll data — chasing this manually at month-end is too slow.

CSCS card and HS&E test

Not an immigration requirement per se, but a frequent practical condition of site access and an indicator UKVI auditors will look for when verifying the role matches the CoS. Track expiry per worker.

Variable pay and the rolling-window rule

SW 14.3B (in force 8 April 2026) requires the salary threshold to be met in each rolling 3-month window for monthly-paid workers, not just averaged annually. Pay patterns with low base + high bonus can fail this even when annualised pay clears the threshold. Test scenarios before adjusting pay structure.

SOC mapping

Construction roles often span the line between codes (e.g. trades vs. supervisor vs. manager). The role the worker is actually doing must match the SOC on the CoS — a de-facto promotion to site supervisor is a reportable change in role.