The Sponsor Change of Circumstances Form is used by UK employers holding a sponsor licence to update or amend certain details when they do not have access to the Sponsorship Management System (SMS). A common use of the form is to appoint a new Level 1 user who will manage the licence on behalf of the organisation.
Employers must ensure their sponsor licence details on the SMS remain accurate and up to date. In particular, failing to report specific changes on time can result in penalties, such as suspension or revocation of the licence.
Section A: What is the Sponsor Change of Circumstances Form?
The Sponsor Change of Circumstances Form is an official Home Office document (available as an interactive ODT file on GOV.UK) designed for licensed sponsors in the UK who need to report specific changes but lack access to the Sponsorship Management System (SMS).
It is not a general form for all sponsor updates; most changes, such as organisational details (e.g., address, key personnel), worker absences, salary adjustments or location changes must be reported digitally via SMS within the relevant timeframe to maintain compliance and avoid penalties.
Using the form incorrectly may lead to rejection, requiring resubmission via SMS once access is restored.
For priority processing of urgent changes (e.g., adding Level 1 users), a separate £200 priority service is available via email, but this is not available for changes made using the Sponsor Licence change of circumstances form.
Section B: When to use the Sponsor Change of Circumstances Form
Under the rules of the Certificate of Sponsorship, employers and sponsored employees are under a duty to notify the UKVI of specific changes in circumstances within 10 working days.
Failure to report any changes of circumstances can result in licence downgrading, a suspended or revoked licence or a fine may be issued for failure to comply with the sponsor licence and migrant reporting duties.
The Sponsor Change of Circumstances Form is only required if you cannot make the necessary changes through the SMS. If you have SMS access, the changes should be submitted directly through the system.
Sponsors without SMS access, perhaps due to forgotten credentials or technical issues, complete and email the form to the Home Office, providing details like licence number, organisation info, and the reason for the change. It’s a fallback option, and SMS access remains the default for routine licence compliance duties.
Importantly, the form can only be used in the following scenarios:
a. Appointing a new Level 1 user (who manages day-to-day SMS tasks) when access is lost.
b. To request the surrender of your sponsor licence where SMS access is unavailable within your organisation.
c. To ask for your licence to be made dormant if no one in your organisation has access to SMS.
Requests falling outside these specific scenarios will be declined. In such cases, a Level 1 User listed on your licence must submit the request directly through SMS.
Section C: How to Use the Sponsor Change of Circumstances Form
To use the form, you will first need to download the most up to date of the Sponsor Change of Circumstances Form from the Home Office website. Complete the form, ensuring the information you provide is accurate and up-to-date and that all required fields are filled in correctly.
Key information to provide includes:
- Organisation details: Sponsor licence number, full name, registered address, and contact info (email, phone).
- Change type: Clearly state the reason (e.g., “Add Level 1 user due to lost SMS access”).
- New personnel info (for Level 1/AO): Full name, date of birth, UK address, email, phone, job title, and suitability confirmation (e.g., no unspent convictions, no immigration breaches in last 5 years).
- Declarations: AO’s name, signature (digital or printed), date, and confirmation of accuracy/compliance.
Email the completed form to sponsors@homeoffice.gov.uk.
Processing takes up to 8 weeks; include supporting docs like ID copies if requested.
Note that the Priority Change of Circumstance Service cannot be used with the Sponsor Change of Circumstances Form. The priority service is exclusively for A-rated Worker or Temporary Worker sponsor licence holders who have already submitted their change of circumstances request via the SMS.
These form submissions are processed separately via email to sponsors@homeoffice.gov.uk.
Section D: Sponsor Change of Circumstances Duties
Under the UK’s sponsor licence framework, licensed employers have ongoing duties to monitor and report significant changes to a sponsored worker’s employment circumstances, as outlined in the Home Office’s “Workers and Temporary Workers: Guidance for Sponsors – Part 3: Sponsor Duties and Compliance”. Sponsors use the SMS to report these changes.
Ini effect, sponsors are responsible for reporting any “significant changes” to a worker’s employment that could affect their visa eligibility or the original CoS. This includes alterations to job duties, title, core responsibilities, salary or work location. Reports must be submitted via SMS, or the Sponsor Change of Circumstances Form in limited circumstances. Day-to-day minor variations (e.g., occasional task shifts) do not require reporting, but substantial modifications, such as those altering the Standard Occupational Classification (SOC) 2020 code or salary thresholds, have to be notified to avoid breaching sponsor duties.
Key changes to be reported include:
a. Job Role, Title, or Core Duties: Report if the change affects the SOC code (e.g., promotion to a new occupation) or requires a new CoS application. For example, a Skilled Worker transitioning from software developer (SOC 2136) to IT manager (SOC 2135) must be reported if it impacts skill level or salary compliance.
b. Salary Reductions: Any decrease from the CoS-stated level, unless it’s an increase or meets exceptions (e.g., temporary reductions for statutory maternity leave, or adjustments for nurses/midwives completing Nursing and Midwifery Council (NMC) registration and moving to qualified pay bands).
c. Work Location Changes: Permanent shifts, such as to a new site, branch, client office or full-time remote/home-based work (if not hybrid with regular office attendance). Occasional client visits or hybrid patterns (e.g., 2-3 days remote) are exempt if the main location remains unchanged.
d. Other Employment Circumstances: Absences over 10 unauthorised days or 4 weeks unpaid/reduced pay annually (with exceptions like sickness); early contract termination; or route-specific events, e.g., Scale-up Worker start dates or offshore worker arrivals/departures in UK waters.
e. Route-Specific: For Skilled Worker, report NMC registration completion/failure for nurses (within 8 months); General Medical Council (GMC) withdrawal for doctors; or care worker prior UK employment evidence (3 months transitional).
Most worker-related changes must be reported within 10 working days of the event (e.g., salary reduction effective date or new duties start). Organisational changes (e.g., mergers impacting duties) are within 20 working days. For offshore arrivals/departures, no earlier than the event, but no later than 10 days after.
Exceptions include:
- Salary increases (unless for pre-registration professionals like nurses achieving NMC status).
- Hybrid working with partial office attendance or temporary location shifts (e.g., short-term client sites).
- Minor duty variations not altering SOC code or requiring visa updates.
- Absences for valid reasons (e.g., statutory leave, sickness) if under 4 weeks unpaid annually.
- No reporting for day-to-day operational changes without significant impact.
Non-reporting breaches sponsor duties, potentially leading to Home Office investigation that may result in reduced or zero CoS allocation, a licence downgrade to B-rating, licence suspension or revocation, civil penalties, criminal referrals or director disqualifications.
Section E: Need assistance?
We are experienced advisers to sponsor licence holders. Please contact us if you have a question about the change of circumstances duties including use of the form, or any other query relating to sponsor licence or sponsored visa management and certificates of sponsorship.
Section F: Sponsor licence change of circumstances FAQs
What is the Sponsor Change of Circumstances Form?
The form is used by sponsors who do not have access to the Sponsorship Management System (SMS) to make certain changes, such as appointing a new Level 1 user.
When should I use the sponsor change of circumstances form?
The form is typically required when changes to sponsor licence details, such as key personnel or business address, need to be made but cannot be completed through the SMS.
Section G: Glossary
| Term | Definition |
|---|---|
| Sponsor Licence | A permission granted by the Home Office allowing UK employers to sponsor migrant workers under specific visa routes. |
| Sponsorship Management System (SMS) | The online platform used by sponsors to manage their licence and report changes to sponsored workers or the organisation. |
| Authorising Officer | The person responsible for the sponsor licence and ensuring compliance with Home Office requirements. |
| Level 1 User | A nominated person with access to the SMS to carry out day-to-day sponsorship activities, including submitting forms. |
| Change of Circumstances | Any significant change relating to the sponsoring organisation or a sponsored worker that must be reported to the Home Office. |
| Sponsor Duties | Legal obligations imposed on sponsors, including reporting certain changes and maintaining accurate records. |
| Certificate of Sponsorship (CoS) | An electronic document issued by a sponsor to enable a migrant worker to apply for a relevant UK visa. |
| Worker Visa | A UK visa route that allows eligible non-UK nationals to work in the UK under a valid sponsor licence. |
| Compliance Visit | An inspection by the Home Office to assess whether a sponsor is meeting their duties and maintaining accurate records. |
| Revocation | The cancellation of a sponsor licence due to serious breaches of sponsor duties or immigration rules. |
Author
Founder and Managing Director Anne Morris is a fully qualified solicitor and trusted adviser to large corporates through to SMEs, providing strategic immigration and global mobility advice to support employers with UK operations to meet their workforce needs through corporate immigration.
She is recognised by Legal 500 and Chambers as a legal expert and delivers Board-level advice on business migration and compliance risk management as well as overseeing the firm’s development of new client propositions and delivery of cost and time efficient processing of applications.
Anne is an active public speaker, immigration commentator, and immigration policy contributor and regularly hosts training sessions for employers and HR professionals.
