What is rolling salary compliance?
Sponsored worker salary compliance is assessed on a rolling three-month basis, not just at the point the CoS is assigned. Across any three consecutive months, a sponsored worker's actual earnings must meet the minimum salary threshold for their SOC code and the overall Skilled Worker minimum. Short dips in any one month (for example due to sickness absence) are acceptable, but if the rolling three-month average falls below the threshold, this is a compliance breach.
How to monitor it
Use your payroll system to track each sponsored worker's gross earnings month by month. At the end of each month, check the previous three months together against the current minimum. Flag any worker whose rolling average is trending down before they fall below threshold.
What counts toward the threshold
Only guaranteed, regular contractual pay counts. Overtime, weekend uplifts, and discretionary bonuses do not count toward meeting the minimum salary. Holiday pay must be paid at the contracted rate (not the lowest applicable rate) and does count.
If a worker falls below
If a sponsored worker's rolling three-month earnings fall below the applicable minimum, contact Borderless immediately. Depending on the cause you may need to report a change of circumstance, adjust the worker's contract, or assign a new CoS at a higher salary.
Government guidance: https://www.gov.uk/guidance/sponsor-a-skilled-worker#paying-your-workers