Client-Site and Consultancy models — where a business sponsors workers who are then placed to serve its customers, can be a strategic way to deliver services, scale technical teams, or fulfil project needs. For many organisations, it’s an efficient model: they carry the sponsor licence, manage compliance, and deploy talent to third-party client sites. However, for UK Visas & Immigration (UKVI), this model must be structured carefully to ensure it represents genuine employment, not simply a labour-supply or “body-shopping” scheme. In 2025, regulatory scrutiny remains strong, and sponsors must demonstrate control, supervision, and real business need if they are to remain compliant.
Key Risks
To run a compliant client-site consultancy model, sponsors must guard against several major risks:
- Lack of supervision or direction
- If the third-party client dictates the worker’s daily duties, without input from the sponsoring employer, UKVI may decide that the worker is not genuinely employed by the sponsor.
- If UKVI finds that sponsored workers are effectively supplied as labour, the licence can be revoked.
- Inadequate documentation
- Without clear contracts or statements that define duties, reporting lines, and oversight, it will be very difficult to evidence that the worker is employed by the sponsor rather than the client.
- Sponsors need to maintain robust records, including contact details, right-to-work evidence, and confirmation of where the worker actually does their job.
- Recouping costs wrongly
- As of January 2025 (and reinforced by guidance updates), sponsors must not recoup certain costs (e.g., licence fee, CoS cost, administrative costs) from the worker.
- Attempting to recover these costs is now a ground for licence revocation.
- Poor contractual clarity
- Agreements between sponsor, worker, and client must clearly define roles, responsibilities, supervision, and salary. Poorly drafted or vague contracts raise red flags.
Demonstrating Genuine Employment: Supervision, Control, and Documentation
To satisfy UKVI that a client-site consultancy model is genuine, sponsors must proactively document and enforce control and supervision. Here’s how:
- Work Contracts / Employment Contracts
Your employment contract with the sponsored worker should:
- Declare the sponsor company as the employer, with its registered address.
- Clearly define the job title, core duties, and performance metrics, even if the worker is deployed to a client site.
- Specify reporting lines: the worker should formally report (for performance review, appraisal, etc.) to a manager at the sponsor.
- Clarify that salary and payment will be made by the sponsor company, not the client.
- State any travel or site-specific work locations, and whether time is billed to the client, but reinforce the contractual employment relationship.
2. Service/Consultancy Agreement (Sponsor–Client)
The contract between the sponsoring entity and the client company should also be robust, to show the legitimacy of the placement. Key elements include:
- Scope of services: clearly define what the worker will do at the client site, deliverables, and reporting requirements.
- Governance: outline how the sponsor retains oversight (e.g., regular status meetings, performance reviews).
- Supervision obligation: the sponsor must retain the right to evaluate work, rectify underperformance, and reassign tasks.
- Payment terms: show that the client pays the sponsor for the service, not to the individual directly.
- Termination and exit: define how and when the supplier relationship (and placement) can be ended, and how that affects any sponsored worker.
3. Evidence for Compliance Checks
UKVI may request access to records and third-party sites. According to Part 1 guidance, sponsors might be required to provide “evidence of arrangements … that ensure full co-operation” from the third party. You should therefore maintain:
- Copies of employment contracts and service contracts.
- A written statement of roles, supervision, and reporting lines.
- Payroll records showing the sponsor pays wages.
- Timesheets, if relevant, showing hours worked at the client site.
- Evidence of site visits, performance appraisals, and review meetings to show ongoing management.
- Right-to-work checks, contact details, and up-to-date employment records for each worker.
Role of a Sponsor Licence Consultancy Client Site Model
When structured properly, the consultancy / client-site model can benefit all parties:
- Sponsor gains flexibility and capacity: it can deploy talent to multiple clients under one licence.
- Worker gains a stable employer (the sponsor) with a clear contract, rights, and a UK-based salary.
- Client receives talent without themselves needing to apply for a sponsor licence.
This model is especially relevant for:
- Technology consultancies staffing projects at client sites
- Engineering firms deploying specialist engineers to customer locations
- Professional services firms (e.g., IT, risk, audit) placing consultants in client offices
But only if compliance is rigorous, control is maintained, and documentation is solid.
Common Pitfalls and How to Avoid Them?
Even with the best intentions, some sponsors fall foul of UKVI rules. Here are pitfalls and mitigation steps:
- Pitfall: Client has full control of work
- Risk: UKVI may argue that the sponsor is only providing labour supply, not genuine employment.
- Mitigation: Define clear supervisory structures. Retain decision-making power for performance appraisals, termination, and promotions.
- Pitfall: Poorly drafted contracts
- Risk: vague contracts may not satisfy UKVI.
- Mitigation: Use legally reviewed contracts. Include explicit language on employer, control, payment, and deployment.
- Pitfall: Recoupment of costs
- Risk: Charging licensed or CoS fees to workers is prohibited.
- Mitigation: Sponsors should absorb these costs. As of 31 December 2024, recouping sponsor-licence or CoS fees from workers is explicitly prohibited and can lead to revocation.
- Pitfall: Inadequate record-keeping
- Risk: During compliance visits, the inability to produce payroll, site-visit records, or supervision documentation could trigger sanctions.
- Mitigation: Maintain and update all relevant records, including timesheets, reporting lines, appraisal notes, and contact logs.
Why Choose a Sponsor Licence Consultancy Client-Site Model?
When done right, this model offers several advantages:
- Scalability: You can flexibly deploy talent to multiple clients, improving the utilisation of your sponsored workforce.
- Cost Efficiency: Rather than each client needing its own sponsor licence, you centralise sponsorship under one entity.
- Talent Retention: By employing the workers directly, you give them job security, benefits, and continuity.
- Regulatory Compliance: With proper documentation and control, you reduce the risk of non-compliance and safeguard your sponsor licence.
It also builds your reputation: clients know you’re investing in workforce compliance, not simply trading labour.
Final Thoughts: Staying Compliant in 2025
The sponsor licence consultancy client site model can be a highly effective way to sponsor workers who serve your clients — but only if it’s built on a solid foundation of control, clarity, and compliance. In 2025, UKVI’s rules are explicit: third-party placements must not be used to circumvent the immigration system, and genuine employment must be demonstrated through contracts, site oversight, and proper governance.
If you’re planning to operate such a model, make sure you:
- Create detailed employment and service contracts.
- Keep all documentation ready for compliance checks.
- Conduct regular appraisals and site visits.
- Never recoup prohibited costs from workers.
- Understand that misuse can jeopardise your licence.
At Sponsor Licence Hub, we help businesses navigate these complexities, providing guidance, due diligence, and documentation support — to ensure your sponsor licence consultancy client site arrangements are robust, compliant, and sustainable.
