Getting the Sponsor Licence approved feels like the finish line.
For the business, it is usually anything but.
The licence allows the organisation to sponsor eligible workers, but in return the employer accepts a series of ongoing responsibilities to the Home Office. These are generally referred to as sponsor duties or Sponsor Licence compliance duties.
And they continue for as long as the organisation holds the licence.
This is the part of sponsorship that can sometimes get overlooked.
There is usually plenty of attention when the licence is first needed. Documents are collected. HR systems are checked. Key personnel are appointed. Everyone suddenly becomes very interested in Companies House records and employer’s liability insurance.
The licence is granted.
The worker gets their visa.
Then everybody goes back to running the business.
That is perfectly understandable.
The problem arises when nobody remembers that the Sponsor Licence is still sitting quietly in the background with ongoing responsibilities attached to it.
For most well-run businesses, Sponsor Licence compliance does not need to become an enormous administrative burden.
But it does need to become part of normal business operations.
This guide explains the main duties, how they work in practice, what businesses should have in place and what can happen when sponsorship compliance goes wrong.
What are Sponsor Licence duties?
A licensed sponsor has responsibilities to the Home Office before, during and after sponsoring a worker.
These broadly cover areas such as:
- monitoring sponsored workers;
- keeping required records;
- reporting specified changes;
- complying with UK immigration law;
- complying with wider UK law; and
- not behaving in a way that is considered contrary to the public good.
The detailed requirements are contained in the Home Office’s sponsor guidance.
Home Office guidance on sponsor duties and compliance
The important thing for employers to understand is that these are ongoing duties.
They do not only apply when assigning a Certificate of Sponsorship.
An organisation can sponsor a worker perfectly correctly at the beginning and still develop compliance problems later if it fails to manage the licence properly.
When do Sponsor Licence duties start?
Sponsor duties generally begin from the date the Sponsor Licence is granted.
Some responsibilities naturally become more relevant once sponsored workers are employed, but the organisation’s responsibilities as a licensed sponsor begin with the licence itself.
This means the period between:
licence granted
and
first worker sponsored
should not be treated as an administrative vacuum.
It is a useful time to make sure the organisation knows:
who is responsible for sponsorship;
who has access to the Sponsor Management System;
where sponsorship records will be stored;
how relevant employee changes will be escalated;
and who will check whether something needs reporting.
Ideally, these systems should already have been considered during the Sponsor Licence application.
What does the Home Office expect from a licensed sponsor?
At its simplest, the Home Office expects sponsors to know who they are sponsoring and to maintain appropriate oversight of the employment.
That means the organisation should be capable of answering fairly basic questions about its sponsored workers.
- Does the person work for you?
- What job do they do?
- Where do they work?
- What are they paid?
- Are they actually carrying out the role for which they were sponsored?
- Do you hold the records you are required to retain?
If something significant changes, does somebody within the business recognise that there may be a sponsorship issue?
These questions sound obvious.
That is partly the point.
Sponsor compliance is often less about creating extraordinary immigration procedures and more about making sure ordinary HR procedures actually work.
Monitoring sponsored workers
One of the core Sponsor Licence duties concerns monitoring sponsored workers.
The organisation needs appropriate systems for keeping track of matters relevant to their sponsorship.
That includes monitoring attendance and absences in accordance with the Sponsor Guidance.
For a business with established HR software, this may already be relatively straightforward.
Employees book annual leave through the system.
Managers record sickness.
HR knows when somebody is absent.
Payroll knows when somebody leaves.
The sponsorship task is then to make sure relevant information reaches whoever is responsible for immigration compliance.
A small business may use a much simpler system.
That is not necessarily a problem.
The Home Office does not require every company to purchase an expensive multinational HR platform before it can sponsor somebody.
A spreadsheet, calendar and properly maintained personnel records may be perfectly capable of supporting a small organisation.
What matters is whether the system actually works.
Do sponsors need to monitor attendance?
Yes.
Sponsors must have appropriate arrangements to monitor the attendance of sponsored workers.
The practical method will depend on the organisation and the nature of the employment.
A construction company, restaurant, office-based consultancy and fully remote technology business will naturally monitor attendance differently.
There is no reason to pretend otherwise.
The system should make sense for the business.
For example, evidence of attendance or engagement might arise through:
timesheets;
shift records;
office attendance;
HR systems;
work schedules;
manager oversight;
remote working systems;
or other appropriate records.
The important thing is that the employer knows whether the sponsored worker is actually working as expected.
What about remote and hybrid workers?
Remote working has made this more important.
A sponsored employee does not necessarily need to sit at the same desk in the same office five days a week simply because they hold a Skilled Worker visa.
Many legitimate businesses operate hybrid or remote arrangements.
The sponsorship question is whether the working arrangement remains consistent with the sponsored employment and whether the sponsor continues to exercise genuine oversight.
If a worker is supposedly employed full-time by a company in London but nobody within the organisation has spoken to them for six months and nobody is entirely sure which country they are currently in, that is rather more difficult to describe as effective monitoring.
Remote does not mean invisible.
Keeping sponsored worker contact details
Sponsors are required to maintain certain information about sponsored workers.
This includes keeping relevant contact information up to date.
The organisation should therefore have a process for recording changes to details such as a worker’s residential address and contact information where required.
Most employers already collect this information for ordinary HR purposes.
The compliance issue is making sure records remain current.
A policy saying:
“Employees must notify HR if their address changes”
is useful.
A policy that nobody follows and HR never checks is less useful.
Sponsor compliance is ultimately judged by what happens in practice, not by how impressive the policy document looks.
Sponsor Licence record-keeping duties
Sponsors must retain specified records relating to sponsored workers.
The detailed record-keeping requirements are set out in Appendix D of the Sponsor Guidance.
Home Office Appendix D record-keeping guidance
Depending on the circumstances, records can include evidence relating to:
- right-to-work checks;
- the worker’s immigration status;
- contact information;
- recruitment;
- employment;
- salary;
- qualifications where relevant;
- professional registration where required; and
- other evidence connected with the sponsorship.
Employers should work through Appendix D rather than rely on a generic online folder labelled:
“Visa stuff.”
The Home Office specifies what sponsors are expected to retain.
How long do Sponsor Licence records need to be kept?
The required retention period depends on the particular record and the Sponsor Guidance.
As a general sponsorship principle, many relevant documents must be retained for the duration of sponsorship and for a specified period afterwards, while other legal requirements can impose their own longer retention periods.
This is an area where the current Appendix D should be checked rather than relying on memory.
The important operational point is simple:
Do not destroy sponsorship records merely because the worker’s visa application has been approved.
The evidence may be required later during a Home Office compliance check.
Do sponsors need to keep copies of passports?
The rules around right-to-work evidence and immigration documents have evolved significantly with the introduction of eVisas and online immigration-status checking.
Employers should therefore follow the current right-to-work and Sponsor Guidance rather than using an old checklist built around physical BRPs.
Where an online right-to-work check is required, the employer should retain the appropriate evidence of that check.
GOV.UK employer right-to-work checks guidance
The wider lesson is important.
Sponsor compliance procedures need occasional updating.
A policy written in 2020 and never looked at again may refer to documents and processes that no longer operate in the same way.
Right-to-work checks and Sponsor Licence compliance
Having sponsored somebody does not remove the employer’s responsibility to conduct the appropriate right-to-work checks.
These are related but distinct obligations.
The business should ensure that the required check is completed correctly and at the appropriate time.
For many sponsored workers, this will involve the Home Office online right-to-work service.
The employer should retain evidence demonstrating that the prescribed check was undertaken.
This matters both for sponsorship compliance and the employer’s wider responsibilities concerning illegal working.
A Certificate of Sponsorship is not a substitute for a right-to-work check.
Reporting duties for Sponsor Licence holders
Licensed sponsors are required to report specified changes to the Home Office.
These can concern:
the sponsored worker
or
the sponsor organisation itself.
Many reports are made through the Sponsor Management System.
Examples involving workers can include circumstances where employment does not begin as expected, ends early or relevant sponsored employment circumstances change.
Examples involving the organisation can include certain changes to its details, structure, ownership or key personnel.
The exact reporting requirement depends on what has happened.
This is why employers should avoid trying to memorise a single list and assuming it covers every future situation.
The better internal rule is:
If something significant changes involving a sponsored employee or the organisation, check whether it has sponsorship consequences.
What is the 10-working-day Sponsor Licence reporting rule?
Many reportable changes involving sponsored workers need to be reported within 10 working days.
This is an important deadline.
But it is not a universal rule applying identically to every possible sponsor event.
Certain changes concerning the organisation are subject to different requirements and timescales, including events which generally need to be reported within 20 working days.
The current Sponsor Guidance should therefore be checked for the specific event.
The practical challenge is often not completing the SMS report.
It is getting the information to the Level 1 User quickly enough.
What happens when a sponsored employee resigns?
A sponsored employee can resign like any other employee.
The employer then needs to deal with both:
employment matters
and
sponsorship matters.
From an employment perspective, this might include notice, holiday pay, final salary and returning company equipment.
From a sponsorship perspective, the organisation will generally need to report the end of sponsorship through the appropriate Home Office process.
The sponsor should maintain a record of what happened and when the relevant report was made.
The company does not decide what happens to the worker’s immigration permission afterwards.
That is a matter for the Home Office and the worker.
The employer’s responsibility is to deal properly with its own sponsorship obligations.
What if a sponsored worker is dismissed?
Broadly, the same principle applies.
Sponsorship does not prevent an employer from taking legitimate employment action.
A sponsored worker is still an employee and UK employment law continues to apply.
If employment ends, however, the sponsor needs to consider the Home Office reporting requirements.
This is why we generally recommend that employers consider immigration implications alongside significant employment decisions involving sponsored workers.
Not several weeks later when somebody remembers the employee had a visa.
Do salary changes need to be reported?
Salary changes can have sponsorship implications.
The answer depends on what is changing and why.
An increase in salary will obviously raise different issues from a reduction.
Changes to hours can also affect the effective salary position.
For a Skilled Worker, salary forms part of the immigration requirements underpinning the sponsorship.
An employer should therefore be particularly careful before reducing:
salary;
contracted hours;
or other elements relevant to the sponsored remuneration.
Some changes may be reportable.
Some circumstances can affect whether the worker continues to satisfy the immigration requirements.
More substantial changes may require a different immigration approach.
This is one of the areas where checking before making the contractual change can save considerable difficulty afterwards.
What if the sponsored worker changes job?
It depends on what “changes job” actually means.
A minor adjustment to duties is not necessarily the same as moving the employee into an entirely different occupation.
The Home Office will be interested in whether the worker remains in the employment for which they were sponsored.
If the new role falls under a different occupation code or otherwise represents a significant change to the sponsored employment, further immigration action may be required.
Changing somebody’s internal job title does not automatically mean a new visa is needed.
Likewise, keeping the same job title does not magically make completely different duties compliant.
The reality of the job matters.
What if the worker is promoted?
Promotions are perfectly normal.
Sponsored employees are allowed to have careers.
The sponsorship implications depend on what changes with the promotion.
If the employee remains within the appropriate sponsored occupation and the changes are compatible with their existing permission, the position may be relatively straightforward.
If the promotion fundamentally changes the role, occupation code, salary structure or other sponsored circumstances, further consideration may be required.
The safest approach is to check the immigration implications before finalising a significant promotion.
That allows the business to structure the change properly rather than trying to reverse-engineer compliance afterwards.
What about changes to working hours?
Working hours can matter because salary requirements are frequently connected to hours and annual pay.
Suppose a sponsored worker wants to reduce from 40 hours per week to 25.
From an HR perspective, the request may appear straightforward.
From a sponsorship perspective, we also need to ask:
What happens to their salary?
Do they continue meeting the applicable Skilled Worker salary requirements?
Does the change require reporting?
Does anything else need to happen before the new arrangement begins?
This is a good example of an ordinary HR decision acquiring an immigration dimension because the employee is sponsored.
What if the employee goes on maternity, paternity or other family leave?
Sponsored workers have employment rights like other workers.
Authorised absences such as statutory family leave need to be considered under the relevant sponsorship rules.
There are circumstances in which a sponsored worker’s pay may legitimately reduce during particular types of absence without automatically creating the same issues as an ordinary salary reduction.
The employer should nevertheless maintain appropriate records and check the current sponsorship rules where pay or working arrangements change.
Sponsorship should not be used as a reason to deny workers employment rights to which they are legally entitled.
What about long-term sickness?
Again, context matters.
The sponsor should record absence properly and understand whether any reporting or sponsorship issues arise.
Long periods of unpaid absence can potentially engage specific sponsorship rules and exceptions.
This is not something we would advise handling through a blanket policy such as:
“Sponsored workers cannot be off for more than four weeks.”
There are exceptions and different categories of authorised absence.
The correct response depends on why the worker is absent and the applicable rules.
Unpaid leave and the four-week rule
Sponsors need to be particularly aware of the rules concerning unpaid absence.
As a general principle, sponsorship cannot normally continue where a sponsored worker is absent from work without pay for more than four weeks in total in a calendar year, subject to specified exceptions.
Those exceptions are important.
They can cover circumstances such as particular statutory or legally protected absences.
So the rule should not be applied mechanically without checking why the absence has occurred.
This is an area where HR and immigration compliance need to communicate.
Do sponsors need to report unauthorised absence?
The Sponsor Guidance contains reporting requirements relating to sponsored workers who are absent from work without permission.
Employers should have a system capable of identifying such absences and escalating them appropriately.
The business does not need somebody from HR standing at the office door with binoculars.
It does need to know when an employee has stopped attending work unexpectedly.
That is ordinary management.
For sponsored workers, it can also become a Home Office reporting issue.
What happens if a sponsored worker never starts work?
This must not simply be forgotten.
If a sponsored worker does not start their employment as expected, the sponsor needs to consider its reporting obligations.
There can be legitimate reasons for delayed start dates, and the Sponsor Guidance contains provisions dealing with when a sponsored worker may begin later than the date stated on their CoS.
But the employer should not leave the situation unexplained indefinitely.
If the worker is due to start and does not appear, somebody should notice.
Again, that sounds painfully obvious.
Compliance failures are often painfully obvious in hindsight.
What organisational changes need reporting?
Sponsor duties do not only concern workers.
The organisation itself can change.
Potentially relevant events include:
- changes to business addresses;
- changes to key personnel;
- changes in ownership;
- mergers;
- takeovers;
- restructuring;
- changes affecting branches;
- insolvency-related events; and
- other significant organisational developments.
Some are straightforward SMS updates.
Others can have much more fundamental consequences for the Sponsor Licence.
Corporate transactions deserve particular care because a Sponsor Licence is attached to the licensed organisation.
It is not simply a transferable certificate that follows the employees wherever the business assets happen to go.
Sponsor Licences and business takeovers
Suppose Company A has a Sponsor Licence and employs several Skilled Workers.
Company B buys the business.
What happens to the sponsored employees?
That question should ideally be considered before completion.
Depending on the structure of the transaction and what happens to the employing entity, there can be significant sponsorship consequences.
TUPE, corporate ownership and immigration sponsorship are related issues but they are not identical.
The employment lawyers may be perfectly happy with the transfer.
That does not automatically answer the Sponsor Licence question.
If a business with sponsored employees is being sold, merged or restructured, immigration should be on the due-diligence list.
What happens if your office address changes?
An office move may seem like routine administration.
For a licensed sponsor, it can also create reporting requirements.
The company should therefore include Sponsor Licence considerations in its change-of-address checklist.
- Companies House.
- Bank.
- Insurer.
- HMRC where relevant.
- Website.
- Stationery.
- And yes, the Sponsor Licence.
This is exactly the kind of small administrative event that gets missed because nobody thinks of it as an immigration matter.
What happens if the Authorising Officer leaves?
If the Authorising Officer or another key person leaves, the sponsor needs to update its arrangements appropriately.
The same applies to SMS users.
Former employees should not retain unnecessary access to the Sponsor Management System.
The organisation should also make sure there remains somebody appropriately responsible for the licence.
This is why key personnel should be included in employee offboarding procedures.
When somebody senior leaves, ask whether they hold any Sponsor Licence role.
It takes about ten seconds.
Those ten seconds can prevent a lot of unnecessary inconvenience.
Preventing illegal working
Sponsors must comply with UK immigration law, including their responsibilities concerning illegal working.
Right-to-work checking therefore remains important throughout sponsorship.
The employer should understand when follow-up checks are required and maintain appropriate evidence.
This duty extends beyond sponsored workers.
A licensed sponsor is expected to operate responsibly as an employer generally.
A company cannot reasonably say:
“Our sponsored worker records are immaculate”
while employing other people unlawfully.
Sponsor compliance looks at the organisation more broadly.
Complying with wider UK law
Sponsor Licence compliance is not limited to immigration rules.
Sponsors are expected to comply with relevant UK law.
That can include areas such as:
employment law;
National Minimum Wage requirements;
working-time requirements;
and regulatory obligations applicable to the business.
This is particularly important because the Home Office can obtain information from other government departments and regulatory bodies.
Sponsorship does not exist in a sealed immigration bubble.
How the business actually operates matters.
Can the Home Office carry out a compliance visit?
Yes.
UKVI can carry out compliance checks on sponsors.
This may happen before a licence is granted or after an organisation has become a licensed sponsor.
A compliance visit can involve reviewing systems, records and sponsored workers and speaking with relevant people within the organisation.
The Home Office may want to establish whether the sponsor is genuinely complying with its duties rather than merely having policies saying that it does.
This is why the best preparation for a compliance visit is not a frantic tidy-up the evening before.
It is having sensible systems all year round.
What will the Home Office check?
The exact scope depends on the circumstances.
Areas may include:
- HR systems;
- right-to-work records;
- sponsored worker files;
- attendance monitoring;
- contact details;
- salary and payroll information;
- the jobs workers actually perform;
- reporting history;
- key personnel;
- and whether the organisation understands its sponsorship responsibilities.
The Home Office can also compare information.
For example, the salary stated on the CoS should make sense when compared with payroll records.
The job described for sponsorship should resemble the job the worker actually performs.
The work location should make sense.
Consistency matters.
Can the Home Office speak to sponsored employees?
Potentially, yes.
Compliance officers may speak with sponsored workers and relevant staff as part of their checks.
This is one reason why creating a fictional role description purely to obtain sponsorship is a particularly poor strategy.
If the CoS says the employee spends their week managing international marketing campaigns and the employee says:
“I mainly make tea and answer the phone,”
the paperwork is not going to rescue the situation.
The sponsored role should be genuine from the beginning.
What happens if a sponsor breaches its duties?
The consequences depend on the nature and seriousness of the breach.
Home Office action can potentially include:
- further investigation;
- requests for information;
- licence downgrading;
- an action plan;
- suspension; or
- revocation.
The current Sponsor Guidance sets out circumstances in which action may or must be taken.
A minor administrative error is not automatically equivalent to deliberate abuse of the sponsorship system.
But repeated failures, serious breaches or evidence that the organisation is not properly fulfilling its responsibilities can create significant problems.
What does Sponsor Licence suspension mean?
Suspension is serious.
If the Home Office believes there may be grounds for action against a sponsor, it can suspend the licence while the matter is considered.
The organisation will normally be informed of the concerns and given an opportunity to respond in accordance with the applicable process.
A suspension can have substantial operational consequences, particularly for a business that relies heavily on sponsored workers.
This is why compliance should not begin when a suspension letter arrives.
By then, we are dealing with a problem rather than preventing one.
What happens if a Sponsor Licence is revoked?
Revocation is one of the most serious outcomes.
The organisation loses its ability to sponsor workers, and this can have consequences for people already sponsored under the licence.
It can also affect the organisation’s ability to obtain another Sponsor Licence for a period of time, depending on the circumstances.
For a company employing several sponsored workers, revocation can become a major business problem very quickly.
Recruitment planning, ongoing employment and business operations can all be affected.
This is why the commercial value of Sponsor Licence compliance extends well beyond immigration administration.
Does every mistake put the licence at risk?
No.
It is important not to turn Sponsor Licence compliance into unnecessary panic.
Businesses make administrative mistakes.
People mistype dates.
Emails get missed.
Records occasionally need correcting.
The Home Office guidance distinguishes between different breaches and different levels of seriousness.
What matters is the nature of the problem, why it happened, whether it is isolated or systemic, and what action the sponsor takes.
A business that discovers an issue should investigate it properly.
- What happened?
- Does it need reporting?
- Can it be corrected?
- Are other workers affected?
- Why did the system fail?
- Does the procedure need changing?
That is a much more useful response than either panicking or pretending nothing happened.
Who should be responsible for Sponsor Licence compliance?
Ultimately, sponsorship needs ownership within the organisation.
The Authorising Officer has overall responsibility, while Level 1 Users may carry out much of the practical SMS activity.
But effective compliance often involves several departments.
For example:
Managers may know about attendance and job duties.
HR may know about contracts, absences and employee changes.
Payroll knows what people are actually being paid.
Directors know about corporate changes.
The Level 1 User knows what may need reporting to UKVI.
These people need to communicate.
You do not necessarily need a “Sponsor Licence Department”.
You need a process.
Creating a Sponsor Licence compliance system
For many small and medium-sized businesses, a basic compliance structure can be surprisingly simple.
There should be clear responsibility for:
- right-to-work checks;
- sponsored worker records;
- attendance and absence;
- contact details;
- salary and employment changes;
- SMS reporting;
- CoS assignment;
- key personnel;
- organisational changes; and
- periodic compliance reviews.
The business should also know where its records are stored.
Not:
“I think Karen has them.”
Especially if Karen left in 2024.
A central electronic sponsorship folder with controlled access can work perfectly well for many businesses.
Should you carry out Sponsor Licence compliance audits?
Periodic internal reviews are sensible.
The frequency should reflect the size and complexity of the organisation.
A company sponsoring one employee may not need the same audit programme as a national employer sponsoring 300 workers.
But even a small sponsor can periodically check:
- Is the worker still doing the sponsored job?
- Is the salary correct?
- Are contact details current?
- Are required records present?
- Were relevant changes reported?
- Are SMS users current?
- Are key personnel still appropriate?
- Has the company itself changed?
These are basic questions.
Finding a problem during your own review is generally preferable to discovering it when UKVI asks.
How often should you audit your Sponsor Licence?
There is no single audit frequency that suits every organisation.
For an active sponsor, an annual full review can be a sensible baseline, supplemented by checks when significant events occur.
Businesses sponsoring larger numbers of workers may want more frequent reviews.
The important thing is not to turn the audit into a ritual where somebody ticks ten boxes every December without checking anything.
A useful audit tests whether the records match reality.
Pick a sponsored worker.
- Check their CoS.
- Check their contract.
- Check payroll.
- Check their role.
- Check the records.
- Check whether anything changed.
That tells you considerably more than asking:
“Do we have a compliance policy?”
Can you manage Sponsor Licence compliance yourself?
Yes.
A business can manage its own sponsorship compliance, and many employers successfully do so.
But that should not be confused with doing nothing.
The employer needs somebody who understands the duties, keeps up with relevant changes and knows when an employment or business decision creates an immigration issue.
For larger sponsors, that expertise may sit internally.
For smaller employers, maintaining specialist sponsorship knowledge for one or two sponsored employees can be less practical.
That is where ongoing professional support can make commercial sense.
You continue running the business.
We help make sure the immigration side of significant decisions is considered before they become problems.
Is professional compliance support worth it?
The calculation is fairly simple.
Compare the cost of occasionally checking a sponsorship issue with the potential cost of:
- a delayed worker application;
- an incorrectly assigned CoS;
- a compliance investigation;
- a licence suspension;
- or losing the ability to sponsor employees.
The objective is not to involve an adviser every time a sponsored employee books annual leave.
That would be excessive.
Professional input is most valuable where something has changed or the business is unsure of the sponsorship consequence.
For example:
- Can we reduce these hours?
- Can we move this employee into another role?
- Do we need to report this absence?
- Our Level 1 User has left. What do we do?
- We are selling the company. What happens to the sponsored workers?
- UKVI has contacted us. How should we respond?
Those are exactly the points where checking first can be far cheaper than repairing things afterwards.
Sponsor Licence compliance should become ordinary business administration
The best sign that a business has developed a mature sponsorship system is that compliance stops feeling unusual.
A new employee joins?
Right-to-work and sponsorship checks happen.
A sponsored worker changes address?
HR updates the record.
Salary changes?
Somebody checks the sponsorship implications.
Employee resigns?
SMS reporting is considered as part of offboarding.
Company moves office?
Sponsor Licence details appear on the change-of-address checklist.
Director proposes a restructuring?
Someone remembers that there are sponsored workers.
Nothing dramatic.
Just good administration.
That is ultimately what most Sponsor Licence compliance is.
Need help managing your Sponsor Licence?
We help businesses not only with obtaining Sponsor Licences, but also with the practical sponsorship issues that arise afterwards.
That can include reviewing Sponsor Licence compliance, checking sponsored worker files, considering reporting obligations, reviewing proposed changes to employment, assisting with CoS matters and helping employers understand what needs to be done when circumstances change.
If you are unsure whether something needs to be reported or whether a proposed employment change affects sponsorship, it is usually better to check before making the change.
The Home Office does not expect businesses never to change.
- Employees leave.
- People get promoted.
- Companies move.
- Businesses restructure.
The important thing is making sure the Sponsor Licence moves with the reality of the business rather than being left several years behind it.
FAQs
1. What are the main Sponsor Licence compliance duties?
Licensed sponsors must monitor sponsored workers, keep required records, carry out appropriate right-to-work checks, report specified worker and organisational changes, comply with immigration law and continue meeting wider legal obligations. These duties continue after the licence is granted and form part of the ongoing responsibility of remaining a trusted sponsor.
2. How long do Sponsor Licence duties continue?
Sponsor duties continue for as long as the organisation holds the licence and, where relevant, throughout the period it sponsors workers. Some record-keeping obligations can continue beyond the end of an individual worker’s sponsorship. Employers should therefore treat compliance as an ongoing business function rather than something that ends once a worker receives their visa.
3. What changes must be reported to the Home Office?
Sponsors may need to report changes involving sponsored workers, key personnel or the organisation itself. Examples can include employment ending, certain changes to role or salary, changes in work location, relevant absences, ownership changes and changes to Sponsor Licence personnel. The exact requirement depends on the event and current Sponsor Guidance.
4. How quickly must a Sponsor Licence change be reported?
Many reportable sponsored-worker changes must generally be reported within 10 working days, while certain organisational changes are subject to a 20-working-day timeframe. However, not every event follows the same deadline. Sponsors should identify the specific reporting rule that applies rather than treating 10 working days as a universal rule for every change.
5. What records must a Sponsor Licence holder keep?
Appendix D sets out the Home Office record-keeping requirements for sponsors. Depending on the worker and route, records may include right-to-work evidence, contact details, employment information, salary records, recruitment evidence, qualifications and professional registrations. Sponsors should maintain organised records throughout sponsorship rather than trying to reconstruct them when UKVI carries out a compliance check.
6. What happens if a sponsored worker resigns?
The employer should deal with the normal employment arrangements and also consider its Sponsor Licence reporting duties. The end of sponsorship will generally need to be reported through the appropriate Home Office process within the relevant timeframe. The sponsor should retain a clear internal record showing when the employment ended and when the report was made.
7. Can I change a sponsored employee’s salary or hours?
Potentially, but the sponsorship implications should be checked first. Salary and working hours can affect whether a Skilled Worker continues to meet the relevant requirements. Some changes may simply need reporting, while others can require a different immigration approach. Employers should avoid implementing substantial contractual changes before confirming that the sponsorship remains compliant.
8. Can the Home Office inspect a Sponsor Licence holder?
Yes. UKVI can conduct compliance checks before or after a Sponsor Licence is granted. Officers may review HR systems, sponsored worker files, payroll, right-to-work records, reporting history and whether employees actually perform the roles for which they were sponsored. Having workable systems throughout the year is better preparation than trying to repair records shortly before a visit.
9. What happens if a sponsor breaches its duties?
The consequences depend on the nature and seriousness of the breach. UKVI can investigate, request further information and potentially downgrade, suspend or revoke a Sponsor Licence. An isolated administrative mistake is not necessarily treated in the same way as serious or repeated non-compliance, but employers should investigate errors promptly and take appropriate corrective action.
10. Should a business carry out Sponsor Licence compliance audits?
Periodic internal reviews are sensible, particularly for employers actively sponsoring workers. An audit can check whether sponsored roles, salaries, records, reporting history and key personnel remain accurate. The frequency should reflect the size and complexity of the organisation. The aim is to identify weaknesses internally before they become a problem during a Home Office compliance check.