The 2026 National Minimum Wage Checklist for Sponsors

The minimum wage rules just changed. Here’s the checklist.

The Fair Work Agency launched on 7 April. HMRC and the Home Office now share payroll data. For UK businesses sponsoring overseas workers, minimum wage is no longer just a payroll question; it’s a sponsor licence question. This checklist runs you through the eight things to check first.

• Fair Work Agency live. Single enforcement body for minimum wage and broader workers’ rights, in effect since 7 April 2026.
• HMRC and Home Office payroll data link. Sponsor licence compliance checks now run against live payroll, not the figures self-reported on a CoS.
• New pay-period rule. From 8 April 2026, monthly-paid sponsored workers are checked across a rolling three-month window, not annually averaged.

Download the checklist

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What’s inside the checklist

Eight risk areas, written as questions you can answer in an afternoon, not a textbook chapter. Each one shows where HMRC tends to focus, and where the consequence stretches into sponsor licence territory.

1. Uniform and PPE deductions
2. Travel time between appointments
3. Sleep-in shifts
4. Salary sacrifice and benefit schemes
5. Training and induction time
6. Premium and enhanced rates
7. Accommodation deductions
8. Rate-band birthdays

Plus the two sponsor-specific rules that came in on 8 April 2026, a one-page self-audit summary, and the 2026 rates you’ll want to hand.

What changed in April 2026

Three rule changes landed in the same fortnight.

The Fair Work Agency launched on 7 April. It replaces a fragmented enforcement model with a single body, covering both the National Minimum Wage and broader workers’ rights.

HMRC and the Home Office now share payroll data. Sponsor licence compliance checks against the Sponsorship Management System run against live figures, not the figures self-reported on a Certificate of Sponsorship.

A new pay-period rule applies to sponsored workers from 8 April. Monthly hourly rate compliance is assessed across a rolling three-month window, not averaged annually.

Taken together, the National Minimum Wage isn’t a payroll line anymore. It’s a sponsor licence line too. The two systems are now joined up, and getting one right means getting the other right at the same time.

There’s just too much at stake to find that out the hard way.

Built for the people who need it

If you hold a sponsor licence, or you’re about to apply for one, this checklist is for you. It’s written for HR and People Operations leads, compliance and finance teams, and the founders or authorising officers who carry personal responsibility for sponsor licence compliance.

It works across every sector that sponsors, from care providers and nurseries to fintechs, hospitality, construction, and professional services. The risk areas are the same; the worked examples flex to where you are.

Most National Minimum Wage problems aren’t bad-faith underpayment. They’re routine pay structures that stopped working when the rules changed. The eight risks in this checklist are the ones that catch employers out most often, and the ones easiest to fix once you can see them.

About Borderless

Borderless is the UK platform for sponsor licence holders. We run Certificates of Sponsorship, visa applications, right to work checks, and ongoing compliance in one place, for over 500 employers and more than 13,000 sponsored workers across every sector that sponsors.

We built the platform because the old way was paper, partners, and waiting. Sponsor licence rules change too often, and the cost of getting it wrong is too high to leave it to spreadsheets and quarterly check-ins.

Related downloads

• Home Office Audit Checklist
• Sponsor Licence Application Guide and Document Checklist
• Right to Work Check Checklist
• Sponsor Licence Duties and Guidance for Authorising Officers

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