SMS System

Sponsor Licence Compliance for Hospitality Employers

Hospitality is among the sectors UKVI targets most heavily for compliance visits. High turnover, variable hours, and role-mixed kitchens make reporting and salary tracking harder than in steadier sectors — but the duties are the same.

Why hospitality is high-risk

  • High turnover — every starter and leaver is a reportable event on a 10/20-working-day clock. Miss a few and a UKVI visit will surface them.
  • Variable hours — the SW 14.3B rolling-window salary rule (in force 8 April 2026) is directly relevant; quiet trading and seasonal patterns can pull annualised pay below threshold.
  • Multi-site moves — workers shifted between venues create work-location changes that must be reported within 10 working days.

Food hygiene and allergen training

  • Food hygiene — retained EU Reg 852/2004 requires role-proportionate training. Level 2 for handlers, Level 3 for supervisors is the practical standard.
  • Allergen training — a separate requirement under UK food law. Track it independently of hygiene.

How SMS System helps

  • Variable-hours salary monitor — rolling 12-month pay tracked against threshold for every sponsored worker.
  • Food hygiene and allergen tracking — per-worker training records with expiry alerts.
  • High-turnover reporting — starter and leaver events open the reporting clock automatically.

Primary sources

Frequently asked questions

›Why is hospitality a high-risk sector for sponsor licence compliance?

High staff turnover means more reportable events (starters, leavers, role changes, location moves) — each on a 10 or 20-working-day clock. Variable hours also make the SW 14.3B rolling-window salary rule especially exposed.

›What food hygiene training does the law actually require?

Retained EU Regulation 852/2004 requires food handlers to receive training proportionate to their role — the law mandates training, not a specific certificate. Level 2 is the practical standard for handlers; Level 3 for supervisors. Allergen training (Natasha's Law context) is a separate requirement.

›How does the SW 14.3B rolling-window rule affect hospitality?

Hospitality workers often have variable hours and seasonal patterns. SW 14.3B (in force 8 April 2026) requires the salary threshold to be maintained on a rolling 12-month basis — quiet months and unpaid leave both count, so the calculation must be done continuously, not just at CoS assignment.

›Is allergen training a CQC-style legal requirement?

It is a food law requirement under Natasha's Law and FSA guidance, not CQC. Sponsors should track it alongside food hygiene to evidence the role-appropriate training UKVI may ask about during a compliance visit.

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SMS System monitors CoS expiry, salary thresholds and the 10-working-day reporting clock so nothing slips.

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