Records and evidence

Appendix D record keeping: what sponsors must actually keep

Appendix D of the sponsor guidance lists the records a sponsor must keep for each sponsored worker, grouped into Right to Work, recruitment, salary, skill level and additional route-specific evidence.

Appendix D is the part of the sponsor guidance that sponsors most often believe they have covered, right up until someone asks to see a specific document for a specific worker. The guidance is not difficult to read. The difficulty is that satisfying it requires evidence to be complete, connected, current, retained for a reason and retrievable on request — and most organisations only manage the first of those five.

What records does Appendix D require sponsors to keep?

Appendix D requires records across five areas for each sponsored worker: Right to Work, recruitment, salary, skill level, and additional evidence specific to certain routes or circumstances.

Everything else in this guide is detail underneath those five headings. If you can produce a complete, current set in each area for any worker picked at random, you are in good shape. If you can only do it for the workers hired since the current HR team arrived, you have a problem that will surface at a compliance visit.

What Right to Work evidence do you need to keep?

You need evidence of the check route you used, the date you carried it out, the outcome, and any follow-up date that arises from it.

A stored passport scan is not, on its own, a compliant Right to Work record. What establishes a statutory excuse is evidence that the correct check was performed correctly, at the right time, before employment began. That means retaining:

• The check route used — online share code check, manual document check, or Employer Checking Service verification.
• The official output of that check, retained securely and dated.
• The permission position it established, including whether it is time-limited.
• The follow-up check date where the permission is time-limited.

Getting the route wrong matters as much as missing the record. Our guide to checking a Right to Work share code covers which route applies to whom, and what evidence each one produces.

What recruitment evidence do you need to keep?

You need records that show the role was a real vacancy and that the appointment followed a defensible process.

In practice this means the job description as advertised, evidence of how and where the role was advertised, records of the recruitment and assessment process, candidate assessment notes, and a documented reason for appointing the person you appointed.

This is the evidence area that decays fastest, because recruitment happens once and then everyone moves on. Two years later the advert has gone, the interview notes were in a departed manager's inbox, and the job description on file has been quietly updated to reflect what the person actually does now. That last point is the dangerous one: it destroys the link between the role you recruited for and the role on the Certificate of Sponsorship. See the genuine vacancy test for what that link has to demonstrate.

What salary evidence do you need to keep?

You need the records that establish what the worker is actually paid, against what they were supposed to be paid.

That set includes the employment contract, payroll records and payslips, working-hours records, any salary calculations you relied on, and the relevant Certificate of Sponsorship information.

Working hours are the part sponsors underestimate. A salary that clears the threshold at 37.5 hours may not clear it at 30, and a role that quietly moved to reduced hours can drop below the requirement without anyone changing the headline salary figure. If you want to check a specific position, the Skilled Worker salary checker applies the general threshold and the occupation going rate with pro-rating for hours.

What skill-level evidence do you need to keep?

You need records supporting both the sponsored role's skill level and the worker's ability to perform it.

Typically: the job description, qualifications, any professional registrations required for the role, the role requirements themselves, occupational information and supporting employment records.

The test here is whether the evidence connects to the role rather than sitting in a folder as unrelated documents. A degree certificate proves someone has a degree. It does not, by itself, demonstrate that the sponsored role requires that qualification — which is what the record is meant to support.

Can Appendix D records be stored electronically?

Yes. Current guidance confirms electronic storage is acceptable, provided the records can be produced on request.

There is no requirement to keep paper. There is a requirement to be able to produce the right record, for the right worker, when asked — which is a retrievability obligation, not a storage-format one. A shared drive technically satisfies "electronic", and completely fails "produce on request" when the folder structure only makes sense to one person.

How long do sponsors need to keep Appendix D records?

Record keeping does not end when sponsorship ends. Records must be retained for the period set out in the guidance for the relevant document type, which for some records extends beyond the worker's departure.

The practical implication is that retention has to be tied to the worker lifecycle rather than to employment status. Two failure modes are common, and both are avoidable:

• Deleting too early — treating a leaver's file as closed and purging it, removing evidence you are still required to hold.
• Keeping everything forever — which is a data protection problem rather than a compliance solution, and makes producing a specific record harder rather than easier.

Is having the documents enough?

No. Appendix D is satisfied by evidence that is complete, connected to the right worker, current, retained for an identifiable reason and retrievable on request.

This is the distinction that separates sponsors who pass a records check from those who do not. Having twenty documents on file is not the same as having the right twenty documents. A folder containing an expired Right to Work check, a job description that no longer matches the role and a contract superseded two variations ago is a folder with twenty documents and several compliance gaps.

The questions worth asking about any worker's file:

1. Is anything missing from the five evidence areas?
2. Does each document relate to this worker and this sponsored role?
3. Is each document current, or has it been superseded?
4. Can you say which requirement each document supports?
5. Could you produce the set today, without searching?

How Sponsoro handles Appendix D

Sponsoro treats Appendix D as a completeness position rather than a document store. Each worker's evidence is filed against the requirement it supports, so the system can show which of the five areas are complete, which have gaps, and what specifically is missing — a percentage with named gaps, not a file count.

Because the evidence stays attached to the compliance decisions that used it, the audit history shows not just what conclusion was reached about a worker, but the evidence behind it. And when a request arrives, an audit pack exports the relevant set rather than sending someone into a shared drive.

See how Appendix D record keeping and the evidence vault work, score your current position with the sponsor licence health check, or read how Sponsoro covers every sponsor licence duty.