In brief: On 20 April 2026, the Home Office has 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. Sponsors should consider whether internal guidance, training and compliance processes require updating in light of the change.
The Home Office has reissued the principal sponsor guidance documents, together with the glossary and Appendix D, in a further update to sponsor compliance guidance. The publication appears to reverse a material change introduced in March and amended again in April following user feedback.
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. The latest revision appears to roll back that position and restore greater clarity for sponsors.
For sponsors, the revision is significant because it affects the interpretation of compliance obligations, takes immediate effect and may require a review of internal policies, procedures and training materials.
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:
Right to work checks: an employer’s guide
Appendix D to the sponsor guidance
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. 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.
Narrower scope of right to work checks: 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 reduces the reach of the earlier March/April position.
Reduced compliance uncertainty: The removal of “direct engagement” wording provides greater clarity for employers, particularly those using contractors, agency workers or non‑standard engagement models.
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 organisations to align processes with established illegal working legislation.
Review of internal processes still required: Despite the clarification, sponsors should revisit any changes made in response to the March/April updates (e.g. extended checks for contractors or bank staff) and ensure policies now reflect the corrected position.
Training and communication updates: HR, compliance and operational teams may need updated guidance to avoid over‑checking (creating unnecessary administrative burden) or inconsistent practices.
Audit readiness remains critical: Sponsors should maintain clear, documented processes for who is subject to right to work checks and why, ensuring a defensible position in the event of a Home Office audit.
If you would like support reviewing your right to work processes or assessing the impact of the updated guidance on your organisation, please get in touch with our immigration team. We can carry out a targeted review, update your policies and provide tailored training 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
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