Appendix D Record-Keeping Checklist for UK Sponsors

What this checklist covers

Appendix D of the Home Office sponsor guidance lists the documents and records a sponsor licence holder must keep for each sponsored worker. This page is a working checklist of those records, the retention periods and the gaps the Home Office most often finds. Missing records can lead to a licence being downgraded, suspended or revoked.

Mandatory Records You Must Keep

Under Appendix D, you must maintain the following for each sponsored worker:

• Copy of passport (current and any previous)
• eVisa / digital immigration status (replacing BRP)
• National Insurance number evidence
• Contact details including UK residential address
• Employment contract with job title matching CoS
• Certificate of Sponsorship (CoS) reference and details
• Evidence of Right to Work check (with dates)
• Attendance and absence records
• Record of any changes reported to UKVI
• DBS check certificate (where applicable)

Record Retention Periods

Appendix D says the documents for each sponsored worker must be kept throughout the period you sponsor them, and then until the earlier of one year after your sponsorship of the worker ended, or the date a compliance officer has examined and approved them. Some documents have their own rules, so check Appendix D for each one. Right to Work check copies are kept for the duration of employment and for two years afterwards (Home Office employer's guide to right to work checks). Digital copies are acceptable if they are clear, legible and stored securely, and they must be easy to produce if the Home Office asks for them.

Common Appendix D Compliance Failures

Based on Home Office enforcement actions, these are the most frequently cited failures:

1. 1

   Missing or incomplete Right to Work check records — failing to record the date a check was performed or not keeping a clear copy of the document.

2. 2

   Job title mismatch between employment records and the Certificate of Sponsorship, particularly after internal promotions or role changes.

3. 3

   Failure to maintain up-to-date contact details, including not updating records when a worker changes their UK address.

4. 4

   Inadequate attendance monitoring — not tracking absences or failing to report 10+ consecutive days of unauthorised absence.

5. 5

   Not reporting changes to UKVI within the required 10 working days, such as salary reductions or changes to job duties.

How LuwaSuite Helps You Keep These Records

Each employee profile in LuwaSuite holds the worker's documents with expiry dates and reminders, and Right to Work checks can be completed with Home Office share codes, with the proof kept on the record. LuwaScore™ scores each sponsored worker's file from 0 to 100% across six areas, including documents and change reporting, so gaps show up before an audit. Guided workflows prepare Sponsorship Management System reports for your staff to check and submit, and the audit trail records each compliance action with a timestamp.

Best Practices for Staying Compliant

Follow these practices to maintain strong Appendix D compliance:

• Conduct a quarterly internal compliance audit of all sponsored worker records
• Set up automated alerts for document expirations at 90, 60, and 30 days
• Keep a centralised digital record system rather than paper files
• Train all HR staff on Appendix D requirements annually
• Maintain an audit trail of all document verifications and changes
• Review and update employee contact details at least quarterly