Worker and Temporary Worker sponsors must follow version 10/26 of Appendix D on record-keeping duties, valid from 8 October 2026, which covers wider right to work checks and new Religious Worker evidence.
Key facts
- Who: Worker and Temporary Worker sponsor licence holders, including Skilled Worker sponsors. Section 2.2(e) applies to Religious Worker sponsors.
- From: 8 October 2026 (version 10/26). The Right to Work Scheme extension in section 1.1 applies from 1 October 2026. The Religious Worker resident labour consideration is removed from 29 October 2026, and the section 2.2(e) duty applies where the worker applied for entry clearance or permission on or after 29 October 2026.
- Source: Workers and Temporary Workers: guidance for sponsors – Appendix D: record-keeping duties (accessible)
Version 10/26 of Appendix D lists the documents that Worker and Temporary Worker sponsors must keep. It makes three substantive changes.
Section 1.1, right to work checks. The section is redrafted to reflect the extension of the Right to Work Scheme to other working arrangements from 1 October 2026. Sponsors must keep evidence of right to work checks on any worker they employ, or are considered to employ for the purposes of the Scheme, even if they are not the worker's sponsor. They must also keep evidence for any worker they sponsor, regardless of the nature of the working arrangement. The check must be carried out before the worker starts work, in the manner set out in "Right to work checks: an employer's guide" at the time of the check.
Section 2.1, resident labour consideration. The entry for the Religious Worker route is updated to reflect the removal of the resident labour consideration for that route from 29 October 2026. The table now describes the route as in place between 11 October 2021 and 28 October 2026 (inclusive).
Section 2.2(e), new duty. This applies to a Religious Worker sponsor where the worker applied for entry clearance or permission on or after 29 October 2026. It applies where the worker meets the role eligibility requirements for the route because they performed religious duties outside the UK for at least 6 months for a faith-based organisation to which the sponsor is affiliated. In that case the sponsor must keep a copy of the letter the organisation gave the worker confirming those details.
The guidance also lists other minor housekeeping changes. A full list of changes is in the document itself.
Retention rules are set out in the introduction. Documents must be kept throughout the sponsorship, and until the earlier of one year after sponsorship ended or the date a compliance officer has examined and approved them, if that is less than one year after sponsorship ended. Records can be paper or electronic, but sponsors must be able to make them available on request.
What this means for applicants
Sponsors must keep evidence of right to work checks for every worker they sponsor, whatever the working arrangement, and for any worker they employ, or are considered to employ, under the Right to Work Scheme. Where a Religious Worker applied for entry clearance or permission on or after 29 October 2026 and meets the role eligibility requirements through at least 6 months of religious duties outside the UK for a faith-based organisation the sponsor is affiliated with, the sponsor must keep a copy of that organisation's confirmation letter. Sponsors must be able to make their records available on request.
Related guide
Sponsorship requirements: Skilled Worker
Sources
- Workers and Temporary Workers: guidance for sponsors – Appendix D: record-keeping duties (accessible), UK Visas and Immigration, version 10/26