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Skilled Worker salary compliance has fundamentally changed from April 2026, with sponsors now required to meet salary thresholds across defined pay periods rather than on an annual basis. This introduces a more technical framework, particularly where working hours or pay vary, and increases the risk of non-compliance if not properly structured. We support sponsors in understanding and navigating these requirements under SW 14.3B, whether by designing a clear, compliant pay structure or by providing ongoing support where flexibility in working patterns is maintained.

Skilled Worker Salary Compliance (UK) 

From 8 April 2026, Skilled Worker salary compliance is no longer assessed on an annual basis. Instead, sponsors must ensure that salary thresholds are met across defined pay periods, including 3-month, 12-week and 17-week assessments.

 

This shift significantly increases the compliance burden for employers, particularly where working hours and pay vary.

 

We support sponsors through two distinct approaches, depending on their business model and operational needs.

 

Our Approach

 

There is no single solution to salary compliance under SW 14.3B.

 

For some employers, the priority is to design a structure that avoids complexity altogether. For others, particularly those operating with variable or zero-hours arrangements, the focus is on actively managing compliance over time.

 

We offer both.

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1. Salary Compliance Structuring (One-Off Setup)

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For most sponsors, the most effective approach is to establish a clear and compliant pay and working model from the outset.

 

This reduces the need for ongoing monitoring and avoids the risks associated with fluctuating working patterns.

 

We carry out a structured review of your current arrangements and provide practical, legally grounded guidance on how to align with the requirements of SW 14.3B.

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This includes:

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  • Assessing which provision applies: b(i), b(ii), or c

  • Advising on appropriate pay frequency and weekly working hours

  • Identifying risk areas, including:

     

    • Uneven weekly hours

    • Periods of reduced pay

     

  • Providing a clear, compliant structure across your workforce

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The objective is to ensure that salary compliance is built into your operating model, rather than managed retrospectively.

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2. Ongoing Compliance Support (Variable / Zero-Hours Workforce)

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Where employers choose to retain zero-hours or variable working arrangements, compliance becomes significantly more complex.

 

In these cases, salary must be assessed across continuous pay periods, and risk can arise depending on how hours and pay align over time.

 

We work closely with HR and payroll teams to support compliance on an ongoing basis.

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This includes:

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  • Regular (typically weekly) review of hours worked and pay

  • Assessment of compliance across relevant pay periods

  • Identification of potential risks before they arise

  • Ongoing guidance to maintain compliance across all sponsored workers

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This approach is designed for employers who require operational flexibility but recognise the increased compliance burden and risk exposure.

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Which Approach Is Right for You?

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The appropriate approach depends on your workforce structure and appetite for ongoing compliance management.

 

  • Employers with fixed or consistent hours will typically benefit from a one-off structuring exercise

  • Employers operating with variable or zero-hours arrangements will generally require ongoing support

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We can advise on the most suitable approach based on your current model.

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Why This Matters

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Under the updated rules, compliance is no longer about total annual salary alone.

 

Sponsors must ensure that salary thresholds are met within each relevant pay period, taking into account how and when salary is paid.

 

This creates risk in areas such as:

 

  • Uneven working patterns

  • Reduced pay during certain periods

  • Misalignment between hours worked and pay received

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A failure to meet the requirements can result in non-compliance with sponsor duties, with potential consequences for your licence.

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Contact Us

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We provide both one-off structuring advice and ongoing compliance support, depending on your operational needs.

 

If you would like to:

 

  • Review your current salary arrangements

  • Minimise the risk of non-compliance

  • Or implement a compliant structure across your workforce

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Contact us to discuss your current arrangements or planned recruitment on 0115 998 7326 or complete our enquiry form.

Image by Mike Kononov

For A More Detailed Breakdown Of How These New Rules Work In Practice, Read Our Article

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