EOFY Immigration Checklist for Australian Employers: Sponsorship, Payroll and Compliance in One Guide

EOFY Immigration Checklist for Australian Employers: Sponsorship, Payroll and Compliance in One Guide 

As 30 June approaches, most Australian businesses are focused on payroll finalisation, tax planning, superannuation obligations, and closing out the financial year. 

But for employers sponsoring overseas workers, EOFY is much more than an accounting deadline. 

It is one of the highest-risk immigration compliance periods of the year. 

Every year, sponsorship issues quietly surface during EOFY reviews. 

A payroll adjustment made months earlier. A sponsored worker now operating from a different location. A role that no longer matches the original nomination. An internal restructure nobody reported. 

Individually, these issues may seem harmless. 

Collectively, however, they can expose businesses to sponsor breaches, civil penalties, nomination refusal risks, and costly scrutiny from the Department of Home Affairs. 

In 2026, those risks are even sharper. 

Salary thresholds continue to rise. Sponsor monitoring is increasingly data-driven. Payroll information is more easily cross-checked against immigration systems. Regulators are sharing information more frequently than ever before. 

For sponsors, EOFY is no longer simply an administrative exercise. 

It is a full compliance health check. 

Businesses that proactively review their sponsorship obligations before 30 June are far better positioned to avoid expensive mistakes in the new financial year. 

Why EOFY Creates Higher Sponsorship Risk 

EOFY creates the perfect environment for immigration compliance issues to surface. 

Why? 

Because this is when businesses reconcile payroll, review staffing structures, finalise financial reporting, and organise internal records. 

During the year, immigration compliance often sits separately from payroll and HR systems. 

At EOFY, those systems suddenly intersect. 

That is when inconsistencies become visible. 

The salary approved in a nomination may no longer match actual payroll. The nominated worksite may differ from where the employee now works. The approved occupation may no longer reflect the employee’s actual duties. 

Once those discrepancies appear on paper, they become difficult to ignore. 

The Department of Home Affairs expects sponsors to actively monitor their obligations throughout the sponsorship period — not only when visas are lodged. 

That includes ensuring: 

• Sponsored workers are paid correctly; 

• Salary thresholds continue to be met; 

• Employment conditions remain compliant; 

• Sponsorship records are maintained; and 

• Reportable changes are notified within required timeframes. 

EOFY is often when businesses discover they unintentionally drifted away from compliance. 

Payroll Reconciliation: Reviewing AMSR and CSIT Before 30 June 

One of the most important EOFY tasks for sponsors is conducting a payroll reconciliation against immigration salary requirements. 

This is where many otherwise compliant employers unknowingly fall into breach territory. 

Understanding AMSR and CSIT 

Sponsors generally need to ensure overseas workers receive at least: 

• The Annual Market Salary Rate (AMSR); and 

• The Core Skills Income Threshold (CSIT), where applicable. 

The AMSR reflects what an equivalent Australian worker would earn for the same role in the same location. 

The CSIT operates as the minimum salary threshold for many employer-sponsored visa programs. 

The key issue is that sponsorship compliance is ongoing. 

A worker who met salary requirements at nomination stage may no longer satisfy those requirements months later because of: 

• Reduced work hours; 

• Unpaid leave arrangements; 

• Payroll restructuring; 

• Incorrect allowances; 

• Salary sacrifice arrangements; or 

• Administrative payroll errors. 

EOFY is therefore the ideal time to compare: 

• Nomination-approved salaries; 

• Employment contracts; 

• Actual payroll records; 

• Payslips; and 

• Superannuation contributions. 

Sponsors should not focus only on what the employment contract says. 

The Department examines what employees are actually being paid. 

If payroll records fail to support approved nomination terms, sponsors may still face compliance action — even where the issue was accidental. 

The Compliance Trap Many Employers Miss 

One of the most common misunderstandings in sponsorship compliance is believing employee agreement automatically protects the business. 

It does not. 

Many sponsored workers voluntarily agree to: 

• Reduced hours; 

• Temporary salary reductions; 

• Flexible unpaid leave; or 

• Alternative payment arrangements. 

From a workplace perspective, those arrangements may appear reasonable. 

From an immigration perspective, however, they can create serious problems if salary thresholds are no longer met. 

Sponsor obligations exist independently from private agreements between employers and employees. 

EOFY provides employers with the opportunity to identify whether operational decisions throughout the year unintentionally created sponsorship breaches. 

Record-Keeping Obligations Employers Commonly Forget 

Immigration compliance is not only about salary. 

Sponsors are also legally required to maintain records and notify the Department of certain changes within prescribed timeframes. 

This is where many businesses encounter difficulties. 

Throughout the year, operational changes happen quickly. 

Employees move locations. Payroll systems change. Businesses restructure. Job duties evolve. 

But immigration notification obligations are often overlooked. 

EOFY is therefore the ideal time to conduct a sponsorship records review. 

Key records employers should review include: 

• Employment contracts; 

• Payslips and payroll summaries; 

• Superannuation records; 

• Leave records; 

• Position descriptions; 

• Recruitment records; 

• Labour market testing evidence; 

• Sponsorship approval documents; and 

• Notification correspondence with Home Affairs. 

Businesses should also assess whether any reportable events occurred during the financial year. 

This may include: 

• Changes to business ownership; 

• Internal restructures; 

• Employee resignations; 

• Salary amendments; 

• Worksite relocations; or 

• Significant changes to job duties. 

Many employers only realise at EOFY that these changes were never formally reported. 

Hybrid Work and Site-Change Risks 

One of the fastest-growing sponsorship compliance risks in Australia involves worksite changes. 

Hybrid work arrangements are now common across many industries. 

Sponsored workers may now operate: 

• From home; 

• Across multiple offices; 

• Interstate; 

• At client sites; or 

• Under flexible remote arrangements. 

Operationally, this may work perfectly well. 

Immigration-wise, however, employers must still ensure nominated work locations remain compliant. 

A substantial worksite change may trigger obligations to: 

• Update sponsorship records; 

• Notify the Department; or 

• Assess whether a new nomination is required. 

Many employers mistakenly assume workplace flexibility automatically translates into immigration flexibility. 

It does not. 

EOFY reviews should therefore confirm whether sponsored workers remain employed in locations consistent with their approved nominations. 

The 2026 Nomination Timing Strategy Employers Should Consider 

EOFY is not only about compliance. 

It is also a critical sponsorship planning period. 

This is particularly important because salary thresholds may increase again after 30 June 2026. 

For businesses planning to sponsor overseas workers in coming months, nomination timing can significantly affect: 

• Sponsorship costs; 

• Workforce planning; 

• Salary budgeting; and 

• Recruitment strategies. 

In some cases, lodging nominations before threshold increases may help businesses lock in current salary requirements. 

For regional employers and small-to-medium businesses especially, even moderate increases can materially affect recruitment budgets. 

Businesses delaying sponsorship planning until the new financial year may therefore face: 

• Higher salary obligations; 

• Increased compliance costs; and 

• Longer recruitment delays. 

EOFY is the ideal time to review pending recruitment needs before financial-year changes take effect. 

The 12-Point EOFY Immigration Checklist for Employers 

Before 30 June 2026, sponsors should consider conducting the following EOFY immigration compliance review. 

1. Review all sponsored employee salaries

Confirm employees continue meeting AMSR and CSIT requirements. 

2. Conduct a payroll reconciliation

Compare payroll records against approved nomination salaries. 

3. 3. Review guaranteed earnings

Check whether allowances and variable earnings remain compliant. 

4. Verify occupation duties

Ensure employees are still performing duties consistent with nominated occupations. 

5. Confirm work locations

Review whether sponsored employees remain at approved worksites. 

6. Assess unpaid leave arrangements

Identify whether leave or reduced hours affected salary compliance. 

7. Review sponsor notifications

Confirm reportable changes were notified within required timeframes. 

8. Organisesponsorship records 

Ensure payroll, employment, and recruitment records are complete. 

9. Check visa expiry dates

Identify upcoming workforce renewal requirements early. 

10. Reviewlabourmarket testing evidence 

Ensure recruitment records remain properly stored. 

11. Assess pending sponsorship nominations

Consider whether applications should be lodged before threshold increases. 

12. Conduct an internal immigration audit

Identify compliance gaps before regulators do. 

EOFY Should Be a Compliance Reset — Not a Panic Period 

For many employers, immigration compliance still feels administrative. 

Until an audit begins. 

Potential consequences for sponsors may include: 

• Civil penalties; 

• Sponsorship cancellation; 

• Sponsorship bar periods; 

• Nomination refusal; 

• Reputational damage; and 

• Workforce disruption. 

Importantly, many sponsorship breaches are not deliberate. 

They develop gradually through operational drift. 

A payroll adjustment here. A reporting oversight there. A role that slowly changes over time. 

EOFY is often when those issues finally become visible. 

The businesses that manage sponsorship compliance best are not necessarily the businesses with the largest HR teams. 

They are usually the businesses that treat immigration compliance as part of ordinary operations rather than a once-a-year visa exercise. 

EOFY provides employers with an opportunity to: 

• Align payroll and immigration records; 

• Strengthen internal compliance systems; 

• Identify risks early; 

• Prepare for future sponsorship changes; and 

• Improve long-term workforce planning. 

For Australian employers relying on overseas skilled workers, immigration compliance is no longer a side issue handled only when visas expire. 

It is now an ongoing operational responsibility. 

And EOFY is when that responsibility is tested most heavily. 

Disclaimer: This publication contains general information only and is not legal advice. Immigration law and workplace law obligations may change, and outcomes vary depending on individual circumstances. Readers should obtain independent legal advice tailored to their specific situation before acting on any information contained in this article.