A compliance officer can arrive unannounced, ask for a sponsored worker's file and read it on the spot. If the degree certificate that proves the worker's skill level is in Polish, Portuguese or Arabic, and nobody at the sponsor can explain what it says, the record exists but proves nothing.
The rules on paper are thin on this point. Appendix D, version 10/26, valid from 8 October 2026, tells sponsors what to keep and for how long, but not what language it must be in. The consequences are not thin: failing to provide a specified document when asked is on the Home Office's list of reasons it will normally revoke a licence.
Below: what Appendix D requires, which records arrive in other languages, the translation rule for licence applications, compliance checks, and the mistakes behind B-ratings, as of October 2026.
What records must a sponsor keep under Appendix D?
Five groups of documents for every sponsored worker, kept "throughout the period that you sponsor them" and then until the earlier of one year after sponsorship ends or the date a compliance officer has examined and approved them. Documents from your licence application must be kept for as long as you hold the licence. Records can be paper or electronic, but "you must be able to make them available to us on request."
| Appendix D section | What you must keep | Often in another language? |
|---|---|---|
| 1. Right to work and date of entry | Evidence of the right to work check; for workers you sponsored for entry clearance, a copy of the entry stamp, or a record of the entry date from tickets or a boarding pass | Rarely: UK checks and travel records |
| 2. Recruitment | Adverts, numbers of applicants and shortlisted candidates, and at least one item showing how the worker was chosen; more for routes with a resident labour market test | Sometimes: overseas applications and CVs |
| 3. Salary | Payslips, proof of each payment into the worker's account, the contract or written statement, evidence of allowances | No: UK payroll records |
| 4. Skill level | A detailed job description; "copies of any relevant qualifications the worker holds to confirm skill level"; references from previous employers; registration documents, such as GMC registration for a doctor | Yes: foreign degrees, transcripts and references |
| 5. Additional evidence | National Insurance number, contact history, a DBS check where required, absence records, an ATAS certificate where needed, and route-specific documents | Yes: parental consent letters, overseas contracts, faith organisation letters |
Section 4 has a sharp edge. If your advert said a qualification was mandatory, "you must retain evidence that the worker you are sponsoring for the role has that qualification", or detailed reasons for waiving it. That evidence is the foreign certificate, and it only works if someone can read it.
Which sponsor records usually need translating?
The ones that come from abroad. With no translation rule in Appendix D, these are the records a compliance officer cannot assess without one:
- Degree certificates, diplomas and transcripts filed to confirm skill level or a mandatory qualification.
- References and employment certificates from overseas employers, showing experience.
- Professional licences held abroad, where you rely on them as evidence of skills or experience.
- Consent letters for workers under 18, from the parents or legal guardian, covering the application, travel, reception and care arrangements.
- Global Business Mobility contracts. Service Supplier sponsors keep the contract and its tender document, or evidence of how it was awarded; Secondment Worker sponsors keep the agreement with the overseas business and evidence of how it was awarded.
- Religious Worker letters. A new duty in version 10/26: for workers applying on or after 29 October 2026 who qualify through at least 6 months' religious duties abroad for an affiliated faith-based organisation, keep that organisation's letter confirming the details.
Keep each translation with its original, so a compliance officer can read one against the other.
For grading scales and course titles, see academic transcript translation. Appendix D does not ask for a UK ENIC statement of comparability; if you want one for your records, see UK ENIC step by step.
What translation does UKVI require with a sponsor licence application?
A certified translation of every supporting document not in English or Welsh. Section 6.6 of Appendix A (version 04/26, valid from 8 April 2026) says the translator or translation company "must confirm in writing on the translation":
- "that it's a 'true and accurate translation of the original document'"
- "the date of the translation"
- "the full name and contact details of the translator or a representative of the translation company"
GOV.UK's licence pages repeat it: "If your documents are not in English or Welsh, you must include a certified translation." Supporting documents go by email within 5 working days of the online application, and a mandatory document that arrives late, "incomplete or in the incorrect format" makes the application invalid. The translation rule sits in the same section on the format of documents.
Overseas businesses carry the heaviest load. A UK Expansion Worker application needs proof of the overseas business's trading presence: 12 months of bank statements, 3 years of certified accounts, its registration, articles and memorandum of association, and contracts or advertising. Appendix A says "You must ensure any documents not in English or Welsh are accompanied by a certified translation", with one concession: bank statement translations need not cover "every transaction", but must include "all transactions relevant to your application". For parent company records, see opening a UK branch or subsidiary.
What happens at a sponsor compliance check?
UKVI checks sponsors before and after a licence is granted, and Part 3 of the sponsor guidance (version 08/26) says a visit or interview "can be on an announced or an unannounced basis". A check can involve:
- Requests for documents or information, by email, letter, telephone or video.
- Verification of documents with the issuing body, in the UK or overseas.
- An on-site visit to any place sponsored workers work, including a client's premises, or a digital check by video conference.
- Interviews with sponsored workers and the staff who recruited them.
- Inspection of records against Appendix D, plus checks with HMRC on pay.
Part 3 is direct about records: "You must give us, when asked, any documents relating to your sponsored workers or the running of your organisation that we consider relevant", and if you do not do so "within the timeframe we specify, we will take action against you." Where UKVI "cannot verify statements made or documents given", it will "take the appropriate action".
What happens if records are missing or unusable?
The outcome depends on how serious the gap is:
| Outcome | When | Effect |
|---|---|---|
| B-rating and action plan | Relatively minor breaches that can be put right | £1,579 action plan fee, a fixed 3-month plan, no new certificates of sponsorship; at most twice in any rolling 4 years |
| Suspension | Serious breaches while UKVI investigates | No new certificates of sponsorship; current workers unaffected unless revocation follows |
| Revocation | Among others, failing to provide an Appendix D document when asked and within the time limit | Sponsored workers' permission normally cut to 60 days; no new licence for at least 12 months |
For scale: since 8 April 2026 a licence costs £611 for small or charitable sponsors and £1,682 for medium and large ones, plus £525 for each Skilled Worker certificate of sponsorship.
Common mistakes in sponsor files
- A foreign degree certificate with no translation, filed to prove a qualification the advert called mandatory.
- A translated summary instead of a full translation, missing grades, dates or the awarding body.
- The translation kept, the original lost, so nothing can be compared or verified.
- Undated translations with no translator's name or contact details, below the Appendix A standard.
- An under-18 worker's parental consent letter in a language nobody at the sponsor reads.
- Global Business Mobility contracts kept untranslated and unreadable at a visit.
- Right to work copies destroyed after one year, when the employer's guide requires the whole employment plus two years.
The worker's own visa application is separate and follows paragraph 39B(f) of the Immigration Rules; see Skilled Worker visa documents and, for checks on every employee, right to work checks with foreign documents.
Checklist: a sponsored worker's file
Questions people ask
Do sponsor licence records have to be in English?
Appendix D does not say so, and records can be paper or electronic. But UKVI can ask for any of them and must be able to verify what they show, so a foreign degree certificate or reference without a translation may not prove the skill level it is filed for.
What translation does UKVI accept with a sponsor licence application?
A certified translation for every document not in English or Welsh, with the translator's or company's written confirmation that it is a true and accurate translation, the date, and the translator's or representative's full name and contact details. Appendix A sets this out in section 6.6.
How long do sponsors have to keep records?
Throughout the sponsorship, then until one year after it ends or until a compliance officer has examined and approved the records, whichever is earlier. Licence application documents are kept for as long as you hold the licence, and right to work copies for the whole employment plus two years.
Can our HR team translate documents for the file?
Appendix D sets no rule on who translates records kept on file, but an independent professional translation carrying the Appendix A elements is easier to rely on at a compliance check. For the worker's own visa, the Skilled Worker caseworker guidance asks for "a fully certified translation from a professional translator or translation company".
What does a sponsor compliance visit check?
Compliance officers can verify your licence application, interview sponsored workers and recruiting staff, inspect records against Appendix D and check other workers' right to work. Visits can be announced or unannounced, and some checks happen by video conference.
What happens if we cannot produce a document UKVI asks for?
For relatively minor breaches, UKVI usually downgrades the licence to a B-rating with a 3-month action plan costing £1,579. Failing to provide an Appendix D document when requested and within the time limit is among the circumstances in which UKVI will normally revoke a licence.
Do we need to translate an overseas parent company's documents?
For a UK Expansion Worker licence, yes: Appendix A requires certified translations of any documents not in English or Welsh, including the overseas business's accounts, registration and constitutional documents. Bank statement translations may leave out transactions that are not relevant to the application.
How much does a certified translation cost, and how fast is it?
Official Translations charges £29.95 per page, a page being up to 300 words of the original. Most single-page documents, such as a degree certificate, arrive as a signed PDF by email within 24 hours, and longer documents take 1 to 3 business days.
