Home Office publishes revised sponsor guidance clarifying right to work obligations for STEM employers

Regulatory Update | UK Immigration Sponsorship Compliance for STEM Sector Employers

In brief: On 20 April 2026, the Home Office published revised sponsor guidance clarifying that right to work checks are required for workers a sponsor employs or sponsors and removing earlier wording that had extended the apparent scope to certain unsponsored workers. For STEM employers, including technology businesses, engineering firms, life sciences companies, research institutions and universities, the change is particularly relevant where workforce models rely on sponsored talent, contingent specialists, project-based consultants and collaborative delivery arrangements. Sponsors should consider whether internal guidance, training and compliance processes require updating in light of the change.

As we noted in our earlier updates on the March and April 2026 sponsor guidance changes, the introduction of “direct engagement” significantly widened the perceived scope of right to work obligations. In STEM settings, this created particular uncertainty for organisations using agency technicians, externally funded researchers, independent consultants on product builds, and contractor resource embedded into fast-moving delivery teams. The latest revision appears to roll back that position and restore greater clarity for sponsors.

For sponsors in the STEM sector, the revision is significant because it affects the interpretation of compliance obligations, takes immediate effect and may require a review of internal policies, onboarding workflows, procurement arrangements, contingent labour processes and training materials.

What has changed

The current version supersedes version 04/26, which was published on 8 April 2026. According to the published guidance, the principal amendments include clarification that sponsors are required to carry out right to work checks on any worker whom they sponsor or otherwise employ:

• S1.40. You must check that any worker you wish to sponsor (including a worker who is not your direct employee), or any worker you otherwise wish to employ (whether sponsored or not), has the appropriate immigration permission to work in the UK and do the work in question before they start working for you. This applies even if the worker is, or appears to be, a British citizen or other settled worker. If you fail to carry out a right to work check, or any necessary follow-up checks, you will be in breach of your sponsor duties and may be liable for a civil penalty under illegal working legislation. If you are issued with a civil penalty, or otherwise fail to carry out the correct checks, we will normally revoke your licence. For guidance on how to carry out the relevant checks, and the evidence you must keep, see:

Right to work checks: an employer’s guide

Appendix D to the sponsor guidance

Why this matters

The versions published on 6 March 2026, and 8 April 2026 suggested that sponsors were required to carry out right to work checks on unsponsored workers who were directly engaged, even where those individuals were not employed by the sponsor. That wording has now been removed following feedback from users. For STEM employers, this is important because projects often involve mixed teams of sponsored employees, visiting researchers, agency workers, outsourced developers, grant-funded specialists and consultancy support. The revised position makes clear that those earlier references to unsponsored workers who were ‘engaged’ or ‘directly engaged’ by the sponsor should no longer be relied upon.

Practical impact for sponsors

Narrower scope of right to work checks: STEM sponsors are no longer expected to carry out right to work checks on individuals they merely “directly engage” where there is no employment or sponsorship relationship. This is particularly helpful for businesses and institutions working with external coders, specialist engineers, lab service providers, field researchers, outsourced project teams or agency-supplied technical personnel.

Reduced compliance uncertainty: The removal of “direct engagement” wording provides greater clarity for STEM employers using non-standard engagement models, including university spin-outs, R&D collaborations, innovation hubs, engineering consultancies and life sciences businesses operating with flexible resourcing structures.

Re-focus on core obligations: The guidance confirms that right to work checks must be carried out on workers a sponsor employs or sponsors, allowing STEM organisations to align hiring, mobility and compliance processes with established illegal working legislation without overextending checks to every external contributor involved in a research, development or product-delivery environment.

Review of internal processes still required: Despite the clarification, STEM sponsors should revisit any changes made in response to the March/April updates, for example extended checks for agency technicians, project-based developers, visiting academics, research collaborators or bank staff, and ensure policies now reflect the corrected position.

Training and communication updates: HR, mobility, compliance, procurement, faculty operations, research administration and technical line managers may need updated guidance to avoid over‑checking, creating unnecessary administrative burden or applying inconsistent practices across labs, campuses, engineering sites and product teams.

Audit readiness remains critical: STEM sponsors should maintain clear, documented processes for who is subject to right to work checks and why, particularly where personnel move between funded projects, client engagements, campuses, laboratories or cross-functional delivery teams, ensuring a defensible position in the event of a Home Office audit.

How we can help

If you would like support reviewing your right to work processes or assessing the impact of the updated guidance on your STEM organisation, please get in touch with our immigration team. We can carry out a targeted review, update your policies and provide tailored training for technology, engineering, life sciences, research and higher education employers to ensure your approach is compliant, practical and audit‑ready.

Further details here: Workers and Temporary Workers: guidance for sponsors part 2: sponsor a worker (accessible) – GOV.UK