Getting a Sponsor Licence is one thing.
Keeping it is another.
Once a business becomes a licensed sponsor, the Home Office expects it to keep certain information about its sponsored workers and the organisation itself up to date.
Some changes need to be reported.
Some do not.
Some need to be reported within 10 working days.
Others generally have a 20-working-day deadline.
And unfortunately, the Home Office does not send somebody round every Friday afternoon to ask whether anything interesting happened that week.
The responsibility sits with the sponsor.
This is one of the reasons Sponsor Licence compliance should not be treated as something that only matters when a Home Office inspection is announced. Reporting duties exist throughout the life of the licence.
Under the current Sponsor Guidance, changes affecting sponsored workers generally need to be reported within 10 working days unless a different period is specified. Relevant organisational changes generally need to be reported within 20 working days unless the guidance says otherwise.
That distinction gives us a useful starting point:
Worker changes: usually 10 working days.
Organisation changes: usually 20 working days.
But the actual reporting requirements are considerably more detailed than that.
What are Sponsor Licence reporting duties?
Sponsor Licence reporting duties are the obligations placed on licensed sponsors to tell UK Visas and Immigration about certain events affecting their sponsored workers or organisation.
Most reports are made through the Sponsor Management System, usually called the SMS.
The SMS allows sponsors to report worker circumstances, withdraw sponsorship, change organisational details and carry out other licence-management functions.
For most businesses, these reports will be handled by a Level 1 User.
However, responsibility does not begin and end with whoever has the SMS password.
The organisation needs a system that allows the relevant person to find out that something has changed in the first place.
If HR knows an employee resigned but nobody tells the Level 1 User, the SMS cannot report the resignation by itself.
That internal communication is a significant part of Sponsor Licence compliance.
What is the 10-working-day reporting rule?
For changes affecting sponsored workers, the general rule is that reportable events must be reported within 10 working days of the relevant event occurring, unless the Sponsor Guidance provides a different timeframe.
This can include events involving:
- absence;
- termination of employment;
- changes to the worker’s role;
- changes in salary;
- changes to work location;
- delayed start dates; and
- other circumstances affecting the sponsorship.
Not every employment change automatically requires the same report.
Some changes may also have immigration consequences beyond simply updating the SMS.
That distinction matters.
A report to the Home Office does not necessarily make an otherwise impermissible change permissible.
What is the 20-working-day reporting rule?
Significant changes to the sponsoring organisation generally need to be reported within 20 working days, unless another rule applies.
Current Sponsor Guidance includes changes involving matters such as the organisation’s name, address, branches, structure, regulatory status, trading position and certain key personnel details.
GOV.UK also specifically identifies significant business changes such as stopping trading, insolvency, substantial changes to the nature of the business and mergers or takeovers.
So the two deadlines should not be confused.
A sponsored employee leaving is not something to put in the diary for 20 working days later.
Likewise, the rules governing a corporate restructuring may be different from the rules governing an employee’s absence.
What happens if a sponsored worker does not start work?
A sponsor should monitor whether the worker actually starts the employment for which they were sponsored.
This sounds obvious, but it becomes particularly important where somebody has been recruited from overseas.
The business might assign a CoS in January.
The worker receives their visa.
The expected start date arrives.
Then nobody turns up.
That is an immigration compliance issue as well as an HR problem.
The Sponsor Guidance contains specific requirements concerning delayed or non-existent starts and the circumstances in which they need to be reported.
The business should therefore have a system that identifies when a sponsored worker has not started as expected.
It should not take payroll three months to notice that somebody has never actually appeared.
Do you need to report when a sponsored worker resigns?
Yes, where the business stops sponsoring the worker because their employment has ended, the relevant change needs to be reported.
The sponsor should provide the information required by the SMS and Sponsor Guidance.
Current guidance also requires sponsors reporting that they are no longer sponsoring a worker to provide the worker’s last recorded residential address, contact telephone number and any personal email address held by the sponsor.
This is one reason employee contact records need to remain current.
If a sponsored worker resigns, HR should have a process that triggers the sponsorship report.
The immigration side should not be discovered six weeks later while somebody is clearing old names from the payroll system.
What if the sponsored worker is dismissed?
The same broad principle applies.
If the worker’s employment ends and the organisation will no longer sponsor them, UKVI needs to be informed in accordance with the reporting requirements.
The reason for termination should be recorded accurately.
This could involve:
- dismissal;
- redundancy;
- resignation;
- expiry of a fixed-term arrangement;
- failure to complete probation; or
- another genuine reason for the employment ending.
Do not invent a more convenient explanation because it sounds nicer.
The sponsor’s records, employment documentation and SMS report should tell a consistent story.
Do redundancies need to be reported?
If a sponsored worker is made redundant and sponsorship ends, the sponsor needs to report that it is no longer sponsoring the worker.
Redundancy can be particularly sensitive because there may be wider employment-law issues alongside the immigration consequences.
From the sponsorship perspective, however, the basic question is straightforward:
Is the organisation still sponsoring this worker in the employment recorded under their sponsorship?
If not, the Home Office needs to know.
Where the organisation is restructuring and proposing a different role rather than ending employment completely, the position should be checked more carefully.
A change of job may have different immigration consequences from termination.
What if a sponsored worker is absent without permission?
Unauthorised absence has a specific reporting rule.
Current Sponsor Guidance requires a sponsor to report where a sponsored worker has been absent from work without permission for more than 10 consecutive working days.
The report must be made no later than 10 working days after the tenth day of absence. This applies even where the employer intends to continue sponsoring the worker.
The report should include relevant information such as when the absence started, whether the worker has returned and attempts made to contact them.
This is why attendance monitoring is a Sponsor Licence duty rather than simply an ordinary management preference.
The Home Office expects the sponsor to know whether the person it sponsored is actually attending work.
Does every sickness absence need to be reported?
No.
The fact that a sponsored worker phones in sick does not mean somebody needs to log into the SMS before lunchtime.
Sponsors need to distinguish between authorised absence, unauthorised absence and other circumstances that engage specific sponsorship rules.
There are also rules around salary reductions during certain types of absence.
Long-term sickness, maternity leave and other extended absences can therefore raise sponsorship questions depending on what happens to salary and employment arrangements.
The important point is that sponsored workers should not disappear into the ordinary HR system with nobody considering whether a particular absence has immigration implications.
Do changes to salary need to be reported?
Salary changes can be particularly important.
A sponsored worker’s salary forms part of the basis on which sponsorship and immigration permission were granted.
Some salary changes can be reported through the SMS.
Others may affect whether the worker continues to satisfy the requirements of the immigration route.
The Sponsor Guidance specifically identifies reporting worker activity, including changes to salary, as part of the Level 1 User’s role.
So if payroll decides to change a sponsored employee’s salary, the immigration consequences should be considered before the change is implemented where possible.
This is especially important with salary reductions.
A company should not assume:
“They already have the visa, so the salary threshold no longer matters.”
Sponsorship does not work that way.
What if a sponsored worker gets a pay rise?
A pay rise is usually rather more pleasant than a pay cut.
But sponsorship reporting requirements can still apply depending on the circumstances.
The correct treatment depends on why the salary has changed and whether anything else about the role has changed with it.
For example, a routine annual pay increase may be different from a substantial promotion involving a new job.
The question should therefore not simply be:
Has the salary changed?
It should also be:
Has the sponsored role changed?
That leads us to one of the more important reporting areas.
Do promotions need to be reported?
Potentially.
A promotion can range from a modest increase in responsibility within essentially the same job to an entirely different occupation.
Those two situations should not automatically be treated the same way.
Current Sponsor Guidance states that where a worker’s role changes after permission has been granted and the change does not require a change-of-employment application, the sponsor must report the change within 10 working days.
But some job changes may require a new Certificate of Sponsorship and a new immigration application before the worker can move into the new role.
That is why we would recommend checking promotions involving sponsored workers before the new role starts.
HR may see a promotion.
The Home Office may see a different occupation.
Those are not always the same thing.
What if the worker’s job title changes?
A job title changing does not necessarily mean the underlying occupation has changed.
Companies rename jobs all the time.
“Marketing Executive” becomes “Senior Marketing Executive”.
“Developer” becomes “Software Engineer”.
“Office Manager” becomes “Head of Making Sure Everything Actually Gets Done.”
The Home Office is interested in the substance of the sponsored employment, not simply how creative the company has become with job titles.
If duties, occupation code, salary or other material aspects of the role change, the sponsorship position needs to be considered.
Where the change is permitted without a new immigration application, it may still need to be reported within 10 working days.
Can you change a sponsored worker’s occupation code?
This requires particular care.
The occupation code is central to Skilled Worker sponsorship.
If the employee moves into a genuinely different occupation, simply changing the SMS record may not be sufficient.
The worker may need a new CoS and a change-of-employment application.
Current guidance also warns that where UKVI discovers a sponsored worker performing a role that does not match the occupation code or job description on their CoS, outside permitted changes, this can amount to a mandatory ground for Sponsor Licence revocation.
That is considerably more serious than an administrative oversight.
So if the duties have changed substantially, check the immigration position before deciding that it is merely an internal HR update.
Does a change of work location need to be reported?
It can.
The Sponsor Guidance contains reporting requirements for changes to a sponsored worker’s work location.
For example, where a worker moves to a different registered branch from the one recorded on their CoS, the sponsor must report the change within 10 working days.
This can become particularly relevant where businesses expand, relocate or reorganise teams.
It can also matter where the employee starts working from a different client site or branch.
The correct approach depends on the sponsorship arrangement and the nature of the new location.
Again, the HR system and sponsorship system need to speak to each other.
What about working from home?
Home and hybrid working have made work-location reporting more complicated than it once was.
A sponsored employee might have:
an office;
a regular home-working arrangement;
client locations;
and occasional travel.
Not every day spent working from the kitchen table necessarily creates a new sponsorship event.
But a significant or permanent change in the worker’s normal working arrangements can require consideration under the Sponsor Guidance.
The safest approach is to ensure the work locations and arrangements recorded for sponsorship purposes genuinely reflect how the worker is employed.
If the role was sponsored as office-based in Manchester and six months later the employee permanently works from Cornwall, that is not something the sponsor should simply ignore.
What if the company moves office?
This is an organisational change rather than simply a worker change.
The Home Office requires sponsors to report significant changes to the organisation, including changes to its address and head-office details. These are generally subject to the organisational reporting timeframe.
The practical issue is that an office move may affect both:
the organisation’s licence details
and
the work locations of sponsored employees.
So the business should consider both aspects.
Changing the address on Companies House alone does not update the Sponsor Management System.
Government databases do not politely update one another just because it would make everyone’s life easier.
Do you need to report a change of company name?
Yes, relevant changes to the sponsoring organisation’s name should be reported through the appropriate Sponsor Management System process.
UKVI may ask for supporting evidence.
This can arise following:
- rebranding;
- corporate restructuring;
- changes to the registered company name; or
- changes affecting branches included on the licence.
A simple trading-name change may not always have the same consequences as a change to the underlying legal entity.
The distinction matters.
A Sponsor Licence belongs to the licensed organisation.
If the legal entity itself changes, the issue may be considerably bigger than updating a name.
What happens if the business is sold?
This is one of the areas where employers should get advice early.
Sponsor Licences are not transferable.
The current Sponsor Guidance specifically states this in relation to mergers, takeovers and changes in ownership.
Depending on the transaction, the existing sponsor may need to report the change and the acquiring organisation may need its own Sponsor Licence.
There can also be implications for sponsored workers moving between organisations.
The guidance generally requires relevant merger and takeover changes to be reported within 20 working days.
This is therefore not something to investigate three months after the sale completes.
If a business with sponsored workers is being bought, sold, merged or restructured, sponsorship should form part of the transaction planning.
What if the company changes ownership?
A change in direct ownership can have significant Sponsor Licence consequences.
The precise outcome depends on the structure of the transaction.
For example, a share sale may need to be analysed differently from the transfer of a business to another legal entity.
The Home Office looks at who the licensed sponsor actually is and whether that organisation continues to exist in the relevant form.
Because the licence cannot simply be transferred from one organisation to another, ownership changes need careful treatment.
The safest point to consider this is before the transaction completes.
Not when somebody remembers the Sponsor Licence during the Christmas party six months later.
What if the business stops trading?
The Home Office must be informed.
GOV.UK specifically identifies stopping trading and insolvency as significant organisational changes that sponsors must report.
This makes sense.
A Sponsor Licence exists so that a genuine operating organisation can sponsor workers.
If that organisation ceases to trade, the basis on which sponsorship is being provided may disappear.
The position of the sponsored workers will also need to be considered.
What if the company becomes insolvent?
Insolvency has its own section within the Sponsor Guidance and can create complicated sponsorship consequences depending on the procedure involved.
The business should not assume that entering an insolvency process automatically produces the same outcome in every case.
But it does need to consider its reporting obligations promptly.
If insolvency is a realistic possibility and sponsored workers are employed, professional advice should be taken early because immigration, employment and insolvency issues may overlap.
Do changes to the Authorising Officer need to be reported?
Yes.
The Home Office needs current information about the key personnel responsible for the Sponsor Licence.
A Level 1 User can use the SMS to replace the Authorising Officer or Key Contact and update relevant details.
Changes involving Level 1 and Level 2 Users also need to be managed through the system.
This is why a business should never allow its only active Level 1 User to leave without considering SMS access.
If the person with access resigns on Friday and nobody thinks about the Sponsor Licence until Monday morning, things can become unnecessarily awkward.
Key personnel should form part of the company’s leaver process.
What if the Level 1 User leaves the company?
The sponsor needs to maintain appropriate access to the SMS.
The current Sponsor Guidance identifies managing Level 1 and Level 2 Users as part of the sponsorship system and specifically allows users to be added or removed as required.
If a Level 1 User leaves, their access should not simply remain active indefinitely.
The organisation should ensure it still has an eligible person capable of carrying out the necessary sponsorship functions.
This sounds basic.
It is also exactly the sort of basic administrative issue that can cause surprisingly large problems.
Do you need to report changes to business structure?
Potentially, yes.
The current guidance specifically refers to organisational changes such as additional branches or sites and new linked entities.
Some structural changes are relatively straightforward SMS updates.
Others, particularly mergers, takeovers and changes in ownership, can affect the Sponsor Licence itself.
The important thing is not to assume that every corporate change is simply a Companies House matter.
If your organisation sponsors workers, corporate restructuring has an immigration dimension too.
How are Sponsor Licence changes reported?
Most relevant changes are reported through the Sponsor Management System.
A Level 1 User can use functions within the SMS to report worker activity and request changes to licence details.
In limited circumstances, a sponsor change-of-circumstances form may be required instead.
The exact route depends on the change.
The sponsor should also retain appropriate evidence supporting what has been reported.
Do not treat the SMS entry as the entire compliance record.
If UKVI later asks why something changed, the business should be able to demonstrate what happened.
Should you keep evidence of SMS reports?
Yes.
Good compliance practice is not simply making the report.
It is being able to show later that the report was made, when it was made and why.
That can include keeping:
- copies or screenshots of relevant SMS submissions;
- employment documents;
- correspondence with the worker;
- salary records;
- absence records;
- updated job descriptions;
- internal approvals; and
- supporting corporate documents.
The exact evidence will depend on the event.
This becomes particularly valuable during a Home Office compliance visit.
Sixteen months later, nobody should have to reconstruct an important sponsorship event from somebody’s vague recollection of an email they think they sent.
Who should be responsible for Sponsor Licence reporting?
The Level 1 User usually performs the SMS activity.
But operational responsibility needs to extend beyond one person.
A sensible structure might involve:
HR identifying worker changes.
Payroll identifying salary changes.
Management identifying promotions and restructures.
Company leadership identifying ownership, trading or office changes.
The Level 1 User assessing and completing the relevant sponsorship report.
That does not need to become a bureaucratic empire.
A company with six employees does not need a Sponsor Licence Compliance Department occupying the third floor.
It simply needs a clear process.
What happens if you report something late?
Late reporting can amount to a breach of sponsor duties.
The consequences depend on the circumstances, seriousness and wider compliance history.
UKVI has powers to take action against sponsors that fail to meet their duties. The current Sponsor Guidance covers measures including downgrading, suspension and revocation.
A single late report does not mean we should automatically assume the Sponsor Licence disappears the following morning.
But repeated failures, serious breaches or evidence that the sponsor does not have proper systems can create much greater concern.
If a deadline has already been missed, ignoring the problem usually does not improve it.
The circumstances should be assessed and the appropriate corrective action considered.
Can the Home Office check your reporting history?
Yes.
The SMS creates a record of sponsorship activity.
UKVI can also carry out compliance checks and examine whether the organisation has met its sponsorship responsibilities.
This means reporting should not be treated as an exercise in filling boxes simply because the system requires them.
During a compliance check, UKVI may compare what has been reported with:
- payroll;
- employment contracts;
- attendance records;
- HR files;
- work locations;
- sponsored workers’ actual duties; and
- other business records.
If the SMS says one thing and the employment records say another, questions are likely to follow.
Reporting duties and record keeping are not the same thing
These two obligations are closely connected but distinct.
Reporting means telling the Home Office about certain events.
Record keeping means retaining the evidence and information required under the sponsorship system.
The current Appendix D sets out the record-keeping duties that apply to sponsors.
A business can therefore fail compliance in different ways.
It might have made the correct SMS report but failed to retain the required evidence.
Or it might have excellent HR records but never told the Home Office about a reportable change.
Good Sponsor Licence management requires both.
How can businesses avoid missing reporting deadlines?
The best system is usually the simplest one that actually works.
For smaller businesses, we would normally want key immigration events built into existing HR procedures.
For example, create a sponsorship check whenever:
- a sponsored worker resigns;
- employment is terminated;
- salary changes;
- job duties change;
- somebody is promoted;
- work location changes;
- prolonged absence occurs;
- the business moves;
- key personnel leave; or
- ownership or corporate structure changes.
The person managing the Sponsor Licence can then decide whether an SMS report or further immigration action is required.
This is much safer than expecting somebody to remember every Home Office reporting rule from memory.
Should every business have a Sponsor Licence compliance calendar?
It can be very useful.
The calendar does not need to be complicated.
It might include:
visa expiry dates
passport or right-to-work follow-ups where relevant
scheduled HR file checks
key personnel reviews
sponsored worker reviews
licence-detail checks
and periodic compliance audits.
Reporting duties are event-driven, so a calendar cannot catch everything.
But combining a compliance calendar with clear internal triggers creates a much stronger system.
Is professional Sponsor Licence management worthwhile?
For some businesses, yes.
An organisation can manage its own Sponsor Licence.
The question is whether it has somebody with the time and knowledge to keep up with the sponsorship requirements and recognise when ordinary business decisions have immigration consequences.
A salary reduction may look like payroll.
A promotion may look like HR.
An office move may look like facilities management.
A company acquisition may look like corporate work.
For a licensed sponsor, every one of those things can also become an immigration compliance issue.
Professional support can help the business identify what needs reporting, assess whether a proposed change is permitted and make sure sponsorship issues are considered before decisions are implemented.
That can be considerably more cost-effective than discovering a compliance problem after UKVI has already identified it.
What should you do if something has already changed?
Do not panic.
But do not ignore it either.
Establish:
- what changed;
- when it changed;
- which worker or part of the organisation is affected;
- whether the change should have been reported;
- whether the reporting deadline has passed;
- whether the underlying sponsorship remains compliant; and
- what evidence is available.
Then determine the appropriate action.
This is particularly important where the issue involves salary, occupation code, termination, ownership or a worker performing duties different from those originally sponsored.
Sometimes the solution is a straightforward SMS report.
Sometimes it is not.
Knowing the difference is the important part.
Need help managing Sponsor Licence reporting duties?
Sponsor Licence compliance does not end when the licence is granted.
If your business already holds a Sponsor Licence, we can help you understand your ongoing sponsorship responsibilities and assess changes affecting sponsored workers or the organisation.
This can include reviewing proposed salary or role changes, worker departures, changes in work location, key personnel changes and other Sponsor Management System reporting issues.
Where possible, it is better to check a significant change before it happens.
That gives the business an opportunity to understand the immigration consequences before making the decision.
And if something has already happened, dealing with it promptly is generally better than hoping the Sponsor Management System somehow forgets.
It doesn’t.
The good news is that Sponsor Licence reporting does not need to dominate the working week.
With sensible systems, clear responsibility and proper advice when something unusual happens, most reporting duties can be managed efficiently alongside the normal running of the business.