Skilled Worker salary compliance has changed. Are you exposed?

Salary compliance under the UK Skilled Worker route is no longer assessed annually. From 8 April 2026, sponsors must meet salary thresholds in every pay period, significantly increasing compliance risk.

This change was introduced in the Statement of Changes published on 5 March 2026, inserting paragraph SW 14.3B into Appendix Skilled Worker.

What has actually changed?

Salary compliance was previously assessed against the annual salary stated on the Certificate of Sponsorship and the employment contract. This allowed for some fluctuation in pay across the year, provided the overall threshold was met.

That flexibility has now been removed.

Under the new framework, UK Visas and Immigration can assess salary compliance at any point by reviewing payroll data across defined pay periods. This includes payslips, working hours and payroll summaries. 

Since April 2026, UK Visas and Immigration (UKVI) actively monitors sponsor compliance by cross-referencing data directly with HMRC’s Real Time Information (RTI) system.

This digital link allows UKVI to instantly compare the actual salary and hours processed through your payroll against the figures declared on the worker's Certificate of Sponsorship (CoS).

Because this monitoring is ongoing and automatic, any discrepancy between your HMRC submissions and UKVI records can immediately trigger a compliance audit or licence suspension, without the need for an on-site visit or manual document request.

Salary must now meet both the overall threshold and the applicable going rate for the role on a per-hour basis during each pay period.

In practical terms, a worker can be considered underpaid even if their annual salary remains compliant if they fall below the required level during any given period.

For those on a monthly or less frequent payroll, compliance is assessed across any three-month period. Where workers are paid more frequently, this is assessed across any 12 weeks.

Why this increases risk for sponsors

UKVI no longer needs to wait until the end of the year to identify underpayment. Issues can be flagged and acted on much earlier.

This creates two challenges.

First, compliance is now continuous. Sponsors must be able to demonstrate, at any given point, that salary requirements are being met.

Second, payroll data becomes central to compliance. It is no longer enough for contracts and CoS data to be correct on paper. The actual payments made must consistently align.

Failing to meet these requirements can lead to:

• Visa refusals or delays
• Negative findings during a Home Office audit
• Sponsor licence suspension or revocation

At the same time, enforcement activity is increasing, with greater scrutiny on payroll records and data consistency.

Where sponsors are most exposed

This change will be felt most by organisations with non-standard pay structures.

This includes sectors such as healthcare, hospitality and logistics, where pay may fluctuate due to shift patterns or hours worked. It also affects businesses that rely on bonuses or irregular payments to meet salary thresholds.

A common risk scenario is where a worker’s annual salary appears compliant, but short-term reductions in hours or pay cause them to fall below the threshold within a specific period.

For example, if a sponsored employee works fewer hours over a two-month period, their pay during that time may drop below the required level. Under the new rules, this can trigger non-compliance even if their total annual earnings remain unchanged.

Additional complexity arises where working patterns or pay are uneven across periods. The Home Office has introduced rules for assessing salary across longer or irregular pay cycles, meaning sponsors must ensure compliance is maintained even where earnings fluctuate.

Common compliance gaps

Most breaches under this framework are unlikely to be intentional and are usually caused by operational gaps.

Common risks are:

• Payroll teams are not aligned with immigration salary thresholds
• Payslips and CoS data do not match exactly
• Working hours fluctuate without corresponding salary safeguards
• Record-keeping is inconsistent across HR and finance systems

Sponsors should also be aware that where a worker is required to repay certain immigration-related costs to the employer, this may be taken into account when assessing whether the minimum salary has been met.

What you should be doing now

To reduce risk, sponsors need to move from static compliance to active oversight

This includes:

• Reviewing payroll processes to ensure salary thresholds are met in every pay period
• Aligning HR, payroll and sponsorship data so that records are consistent and auditable
• Stress-testing variable pay structures against the new requirements
• Ensuring payslips and working hours data clearly evidence compliance

With irregular or variable pay, sponsors should review arrangements early, as risks may not be obvious until assessed by the Home Office.

Act early

For many organisations, the challenge is not the rule itself, but applying it across payroll, HR and sponsorship systems.

Those who act early can protect their licence and avoid disruption.

Those who do not may only uncover issues when the Home Office does.

Don’t risk non-compliance under the new Skilled Worker pay period rules. Speak to our business immigration team for specialist support with sponsor licence compliance. Contact us today at [email protected] or give us a call on +44 (0) 20 7759 5420.