Student Sponsor Guidance UK

Section A: Overview of Student Sponsorship Guidance

Educational institutions in the UK that want to enrol non-UK nationals who require immigration permission to study must first secure a student sponsor licence. The Student Sponsor Guidance, published by the Home Office, provides the rules and framework that institutions must follow to lawfully sponsor international students under the Student and Child Student visa categories. For HR directors, familiarity with this framework is the cornerstone of immigration compliance in the education sector.

Student sponsorship refers to the legal responsibility that an education provider takes on when issuing a Confirmation of Acceptance for Studies (CAS) to an international student. When assigning a CAS, the institution is confirming to the Home Office that it is satisfied the applicant meets the relevant academic, attendance and immigration requirements, and that it will continue to discharge monitoring duties once the student has enrolled. The CAS is generated through the Sponsor Management System (SMS), and has to be issued no more than 6 months before an out-of-country application, and no more than 3 months before the start date for an in-country application.

The Student Sponsor Guidance sets out the legal obligations and operational expectations for student sponsors. It is a central point of reference for HR directors because it explains how the Home Office expects institutions to manage their sponsor licence, monitor student activity, meet reporting duties and prepare for compliance audits. An institution that fails to adhere to the guidance risks enforcement action, which may include suspension or withdrawal of its licence.

1. Types of institutions eligible for a sponsor licence

Institutions that can apply for a student sponsor licence include:

• Higher education providers registered with the Office for Students (OfS) that have established a track record of compliance.
• Independent schools inspected by Ofsted or equivalent inspectorates in Scotland, Wales and Northern Ireland, and that are also registered with the Department for Education (DfE).

Institutions must show that they are genuine, lawfully established in the UK and capable of meeting the Home Office’s compliance framework. Further education colleges no longer qualify in most cases to hold a student sponsor licence, although a limited number continue to operate as legacy sponsors with restricted sponsorship rights.

2. Distinction between Student route and Child Student route

The Student route applies to individuals aged 16 and above who are enrolling on eligible courses at licensed institutions. The Child Student route is limited to children aged 4–17 who will be studying at independent schools only. HR directors must ensure their institution is licensed for the correct route or routes and must be aware of the different monitoring obligations that apply to adult students and to minors.

Section B: Applying for a Student Sponsor Licence

Securing a student sponsor licence is the first step for institutions that want to enrol international students. The Home Office applies strict eligibility rules to ensure that only trusted and capable education providers can act as sponsors. HR directors must understand these rules clearly before starting the application process, as failing to meet the baseline requirements will lead to refusal and wasted costs.

1. Eligibility criteria

Only institutions that meet strict eligibility requirements can apply for a student sponsor licence. The Home Office restricts sponsorship to trusted providers that are capable of meeting regulatory standards and immigration control duties. Institutions must be genuine education providers, lawfully operating in the UK, and able to evidence financial and operational stability. Meeting these criteria is not a formality; the Home Office applies rigorous checks and will refuse applications where standards are not met. HR directors should ensure that the institution’s status, governance and compliance record are in good order before submitting an application.

The specific eligibility criteria vary depending on the type of institution:

• Higher education providers: Must be registered with the Office for Students (OfS) and show a track record of compliance. For providers in England, OfS registration is mandatory. In Scotland, Wales and Northern Ireland, equivalent regulatory recognition is required. The OfS status must be up to date, and any conditions on registration may trigger additional scrutiny from the Home Office.
• Independent schools: Must be registered with the Department for Education (DfE) and inspected by Ofsted, or by Education Scotland, Estyn in Wales, or the Education and Training Inspectorate in Northern Ireland. Only independent schools are eligible to apply for a Child Student licence. State schools are not eligible to act as sponsors under the immigration system.
• Further education providers: New applications from FE colleges are not accepted. A limited number retain legacy licences but cannot expand sponsorship. A limited number of colleges retain sponsor status as “legacy sponsors” but new student sponsor licences are not being issued in this category. Institutions outside HE and independent schools should consider whether alternative immigration routes are more appropriate for their students.

Beyond institutional type, the Home Office applies the “suitability test”. This assesses whether the institution and its key personnel are honest, dependable and reliable. The test includes checks for past immigration breaches, non-compliance with previous sponsor duties, poor OfS or Ofsted outcomes, and whether the organisation has sufficient resources to manage sponsorship effectively. Criminal convictions for key staff, poor financial stability, or a history of insolvency or regulatory sanctions are all grounds for refusal.

The Home Office also requires applicants to pass the “genuine education provider” test. This involves demonstrating that the institution offers credible, approved courses and has systems in place to deliver high-quality teaching and student support. Institutions that cannot show robust safeguarding arrangements, secure financial foundations and transparent governance structures will not meet this test. For independent schools, safeguarding compliance is particularly scrutinised, while for higher education providers, OfS compliance records carry significant weight.

HR directors should carry out a full internal review before beginning the application process, including checks on regulatory status, governance, finances and compliance history. Gaps identified during this review should be addressed in advance. Submitting an application without first ensuring that all eligibility criteria are met is likely to result in refusal, wasted fees and potential cooling-off periods before reapplying. Institutions should treat the eligibility stage as the foundation of the licence process, ensuring that the application is built on a platform of demonstrable compliance and credibility.

2. Application process, costs and timescales

The application for a student sponsor licence is made online through the Home Office portal. The process is document-heavy and requires careful preparation. HR directors should treat it as a formal submission that exposes the institution’s governance, financial stability and compliance arrangements to Home Office scrutiny. Once submitted, the application cannot be altered, so errors or omissions can lead directly to refusal.

The main stages of the process are as follows:

• Online application form: Completed by the institution, with details about the organisation, key personnel and types of courses offered. Application fees must be paid at this stage.
• Submission of supporting documents: Institutions must upload or send required evidence within five working days of submission. Failure to meet this deadline will result in automatic refusal.
• Home Office review: Caseworkers assess the application, verify supporting documents and may carry out further checks with regulators such as the OfS or DfE.
• Compliance visit: In some cases, the Home Office will conduct a pre-licence audit to test systems for monitoring, record-keeping and reporting before granting approval.
• Decision: A licence will be granted on a probationary basis if the institution meets the requirements. If concerns arise, the application may be refused, and the institution could face a six-month cooling-off period before reapplying.

The application fee depends on the size of the institution. At present, the fee for small sponsors (charities and small education providers) is £536, while large sponsors pay £1,476. Fees are non-refundable even if the application is refused.

The standard processing time is up to eight weeks, although delays are common where additional checks or site visits are required. A priority service is available for an additional £500, which aims to provide a decision within ten working days, but this is subject to strict daily caps and demand is consistently high.

Institutions should plan recruitment timelines with these processing times in mind. An incomplete or poorly prepared application will almost certainly delay international recruitment plans, as refusal triggers both lost fees and waiting periods before a fresh application can be made.

3. Supporting documents

The Home Office requires student sponsor licence applications to be supported with a specific set of documents. These are prescribed in Appendix A of the Immigration Rules and must be submitted within five working days of the online application. Failing to provide the correct documents, or providing them late, results in automatic refusal. HR directors should ensure that all evidence is gathered and checked before the application is submitted.

Typical supporting documents include:

• Regulatory approval: Higher education providers must provide proof of registration with the Office for Students (OfS). Independent schools must show that they are registered with the Department for Education (DfE) and inspected by Ofsted or the equivalent body in Scotland, Wales or Northern Ireland.
• Inspection reports: Independent schools must provide a recent inspection report confirming that they meet educational and safeguarding standards.
• Financial evidence: Recent audited accounts, or certified financial statements if audited accounts are not required. These must demonstrate that the institution is financially stable and capable of meeting its obligations.
• Policies and procedures: Documents showing how the institution monitors attendance and academic engagement, safeguards students, and ensures immigration compliance across HR and admissions processes.
• Corporate documents: Depending on the structure, this may include certificates of incorporation, partnership agreements, or evidence of charitable status.

The exact documents required will depend on the institution’s type and structure. The Home Office may also carry out verification checks with regulators or request additional evidence to confirm authenticity. HR directors should cross-check the list of required documents against Appendix A and maintain an indexed file ready to submit within the five-day deadline. Preparing a compliance-ready bundle in advance is one of the most effective ways to avoid refusal.

4. Key personnel roles

A student sponsor licence cannot function without designated key personnel. These individuals are named on the application and are held personally accountable by the Home Office for ensuring that sponsor duties are met. If the wrong people are appointed, compliance risks rise sharply. HR directors must therefore ensure that these roles are filled by staff with the right seniority, experience and capacity to manage the demands of sponsorship.

The roles are as follows:

• Authorising Officer (AO): The most senior person responsible for the sponsor licence. The AO has ultimate accountability for compliance and must have sufficient authority to influence institutional policies and resources.
• Key Contact: Acts as the main point of contact between the institution and the Home Office. The Key Contact must be accessible and responsive to ensure smooth communication with UKVI.
• Level 1 User: Holds full access rights to the Sponsor Management System (SMS). The Level 1 User is responsible for day-to-day administration, including assigning CAS, updating sponsor details and reporting changes. At least one Level 1 User must always be in place. At least one Level 1 User must be a settled worker, unless a published exemption applies.
• Level 2 User: Has restricted SMS access and typically deals with more limited functions, such as issuing CAS under the oversight of a Level 1 User.

The Home Office applies suitability checks to all nominated personnel, including criminal record checks and reviews of previous compliance history. If an individual has a poor immigration or compliance record, the application is likely to be refused. Institutions should therefore conduct internal due diligence before nominating staff. HR directors should also ensure that responsibilities are properly resourced and not added as a nominal duty to an already overstretched role. In practice, the AO must be senior enough to exercise real oversight, while SMS users must be sufficiently skilled and supported to manage the system accurately.

Once appointed, these roles must be kept under regular review. Any change in key personnel must be reported to the Home Office within 20 working days, and delays in updating the SMS can be treated as non-compliance. Establishing a structured framework of accountability, supported by training and oversight, is one of the most effective ways for HR directors to reduce compliance risk.

Section C: Sponsor Duties and Compliance

Securing a student sponsor licence is only the starting point. The Home Office requires institutions to demonstrate continuing compliance with sponsor duties, which are set out in detail in the Student Sponsor Guidance. These obligations exist to ensure that international students are genuine, actively engaged in their studies and meeting their visa conditions. HR directors must make sure that these duties are embedded into institutional processes, with oversight that extends beyond HR to admissions and academic departments. Institutions that cannot evidence compliance risk being placed on probation, restricted in issuing CAS, or losing their licence entirely.

1. Record-keeping duties

Institutions must keep detailed and up-to-date records for every sponsored student. These records must include:

• A clear copy of the student’s current passport and evidence of their immigration status, such as their digital eVisa status share code.
• Up-to-date UK contact details for the student, including historic records where relevant.
• Academic records showing enrolment, attendance and progression through the course.
• Evidence of English language ability where required for admission under the Student route.
• CAS allocation records, including issued, withdrawn and cancelled CAS with reasons documented.
• Financial evidence, if assessed at admission stage, such as proof of maintenance funds or tuition fee payments.

Under Appendix D, sponsors must retain records for the longer of: one year after the end of sponsorship, or until a Home Office compliance officer has examined and approved them. Institutions must also keep copies of all SMS reports and correspondence with the Home Office relating to sponsored students. Aligning record-keeping with Appendix D ensures that, if a compliance officer inspects, the institution can produce accurate evidence without delay.

2. Reporting duties

Sponsors are under strict obligations to report certain events to the Home Office using the Sponsor Management System. Reports must be accurate and submitted within set deadlines. Student-related changes must be reported within ten working days, while institutional-level changes, such as a merger or change of ownership, must be reported within twenty working days. Missing a deadline is treated as a serious compliance failure.

3. Monitoring academic engagement and progression

The Home Office requires sponsors to demonstrate that every sponsored student is engaged with their studies. Engagement is not limited to classroom attendance; it covers participation in lectures, tutorials, seminars, assessments, supervised study and online learning where relevant. For higher education providers, engagement monitoring must be robust enough to provide a clear picture of whether a student is genuinely following their course. For Child Student sponsors, the duty extends into safeguarding, requiring closer oversight of absences, pastoral checks and escalation if a child’s welfare may be at risk.

Institutions must set out in writing what constitutes engagement for each course type and how non-engagement is identified. Systems should be capable of generating data reports that highlight emerging patterns of non-attendance or disengagement. Reliance on paper registers or ad hoc monitoring is regarded as weak practice by the Home Office. Instead, sponsors are expected to use structured processes, often electronic systems, that integrate with student record platforms and HR oversight to provide real-time tracking. HR directors should insist on clear escalation routes, so that missed classes trigger alerts to academic tutors and student support teams. Where concerns persist, cases must be escalated to compliance teams and, if thresholds are met, reported to the Home Office within ten working days.

Progression monitoring is also a sponsor duty. Sponsors must evidence that students are making academic progress in line with their course of study. This includes keeping assessment records, exam results and confirmation of course completion. Students who are not progressing should be identified early, and where progression issues call into question continued sponsorship, this must be reviewed and, if necessary, reported. Poor engagement or progression data is one of the most common reasons institutions fail compliance audits, and HR directors should treat it as a high-risk area requiring continuous oversight.

4. CAS allocation duties

Assigning a Confirmation of Acceptance for Studies (CAS) is one of the highest-risk compliance functions for student sponsors. When an institution issues a CAS, it is effectively certifying to the Home Office that it has carried out all necessary checks and is satisfied the applicant meets the academic, financial and immigration requirements of the Student or Child Student route. Each CAS is tied directly to the sponsor’s credibility, and the Home Office monitors refusal rates closely. A high proportion of refusals linked to an institution’s CAS is a red flag and can cause the sponsor to fail its Basic Compliance Assessment or face an audit.

Sponsors must have clear written policies on who can authorise CAS allocation, the checks required before a CAS is issued, and how records are kept. These checks should include verifying the applicant’s academic qualifications, confirming that English language requirements are met, reviewing financial evidence where relevant, and assessing whether the course offered meets the eligibility criteria under the Immigration Rules. For Child Students, additional safeguarding and parental consent checks must be documented before a CAS is assigned. HR directors should ensure that CAS policies are consistent across departments and that any delegated authority to issue CAS is backed by training and oversight.

CAS misuse, whether intentional or careless, carries serious consequences. Sponsors must never issue CAS speculatively or as a recruitment tactic. Each CAS must be justified with evidence that can be produced at audit. Institutions should implement an internal sign-off process, such as requiring dual approval for CAS allocations, to reduce risk. A full record of each CAS decision, including copies of evidence assessed, should be stored in line with Appendix D requirements. HR directors should also monitor refusal data closely; where patterns emerge, corrective action should be taken immediately to avoid breaching compliance thresholds.

In practice, CAS allocation is not just an administrative task but a compliance judgement that can make or break an institution’s sponsor licence. Treating it as a strategic risk area, with strong systems and governance, is vital for maintaining the trust of the Home Office and protecting the licence.

5. Basic Compliance Assessment (BCA)

The Basic Compliance Assessment (BCA) is an annual requirement for all student sponsors. It is the Home Office’s mechanism for measuring whether an institution is continuing to meet the minimum standards of sponsorship. A sponsor that fails the BCA risks being placed on probation, facing restrictions on CAS allocation and, if problems persist, having its licence withdrawn altogether. For HR directors, the BCA is a compliance benchmark that should be monitored continuously, not just once a year.

The BCA measures three specific metrics for refusal, enrolment and completion. These are set out in the sponsor guidance and updated periodically:

• Visa refusal rates: The proportion of visa applications linked to the sponsor’s CAS that are refused. A high refusal rate suggests poor CAS practices or weak admissions checks.
• Enrolment rates: The percentage of students issued with a CAS who go on to enrol. Low enrolment indicates speculative or inappropriate CAS allocation.
• Course completion rates: The proportion of students who complete their course. High drop-out or non-completion figures raise concerns about student engagement and the sponsor’s monitoring systems.

To pass the BCA, sponsors must stay within the thresholds set by the Home Office across all three categories. These thresholds are not publicly negotiable and change periodically as policy evolves. Falling short on any metric can lead to the sponsor being placed on probation, which restricts their ability to assign new CAS until compliance is restored. Repeat failure often results in licence withdrawal.

HR directors should therefore track refusal rates, enrolment data and completion records in real time, rather than waiting for the annual assessment. Admissions, academic and compliance teams must share accurate data, and discrepancies between departments should be resolved quickly. Institutions should also investigate any spike in visa refusals or non-completion rates and adjust internal policies before BCA thresholds are breached. Where issues are identified, remedial plans should be documented and actioned so that the institution can evidence proactive compliance if challenged by the Home Office.

The BCA is one of the most common points of failure for institutions. A single year of poor results can damage the institution’s reputation and recruitment pipeline. HR directors should treat the BCA as an ongoing performance indicator, integrating its metrics into regular management reporting and using them to inform compliance strategy across the institution.

6. Home Office compliance visits

The Home Office has wide powers to carry out compliance visits to any student sponsor. These visits may be announced in advance or unannounced, and they can take place before a licence is granted, during the probationary period, or at any time while the licence is active. The purpose is to test whether the sponsor is meeting its obligations in practice, not just on paper. Inspectors will look for evidence that systems are working effectively and that staff across departments understand their duties. An institution that is unprepared risks serious enforcement action, including suspension or withdrawal of its licence.

During a visit, compliance officers will usually examine:

• Student records: Inspectors expect immediate access to student files, including passport copies, eVisa status evidence, contact details, attendance and engagement records, and progression data. Records must match what has been reported on the SMS.
• CAS allocation practices: The Home Office will review whether CAS are issued in line with published policies, supported by evidence, and allocated only to genuine applicants. A high visa refusal rate will prompt scrutiny of admissions checks.
• Reporting accuracy: Inspectors will test whether reportable events are being submitted on time and whether the SMS record aligns with institutional records. Late or inaccurate reporting is a common compliance failure.
• Staff awareness: Compliance officers often interview HR, admissions and academic staff to check that they understand sponsor duties and can describe the systems in place. Poor staff knowledge is treated as evidence of weak compliance culture.
• Institutional governance: Inspectors will examine how responsibilities are delegated and overseen by key personnel, particularly the Authorising Officer. Weak oversight or lack of accountability is a red flag.

Preparation for compliance visits must be ongoing. Institutions should not wait for notice of an inspection before reviewing records. HR directors should schedule internal audits, conduct mock inspections and maintain an audit-ready bundle of policies, training materials and sample student files. Training should extend to staff outside HR, so that anyone approached by an inspector can explain their role in compliance. Institutions should also have clear communication lines during an inspection, with key personnel briefed to manage requests and provide documents quickly.

Enforcement outcomes from visits can range from advisory recommendations through to probation, suspension or revocation. In serious cases, the Home Office may withdraw a licence immediately, leaving enrolled students without a sponsor and the institution unable to recruit new international students. HR directors should therefore treat audit readiness as a permanent requirement, embedding compliance culture across the organisation and ensuring that staff, systems and records are inspection-ready at all times.

Section D: Compliance Best Practices

Even when an institution understands and implements the Student Sponsor Guidance, the risk of compliance failure remains. The Home Office sets high expectations for student sponsors, and many institutions have lost their licence because of issues that could have been avoided. For HR directors, a proactive risk management approach is essential. Compliance should be treated as a shared responsibility across HR, admissions and academic departments, supported by systems that make compliance part of daily operations.

1. Common compliance failings and how to prevent them

The Home Office frequently identifies recurring weaknesses when auditing student sponsors. These include poor academic engagement monitoring, late or inaccurate reporting of changes, incomplete student records and a lack of oversight when issuing CAS. Each of these failings can result in licence downgrading, suspension or withdrawal. They are preventable through structured procedures, clear accountability and regular internal reviews. HR directors should implement scheduled compliance checks and staff training to identify and address weak areas before they attract official scrutiny.

2. Systems for monitoring student engagement

Monitoring systems should go beyond the basic requirements set by the Home Office. Effective approaches may include:

• Electronic registers or digital monitoring platforms that integrate with HR or student record systems.
• Automated alerts when students miss classes or show signs of disengagement.
• Formal escalation pathways to academic leads and student support teams for early intervention.

These layered monitoring processes allow institutions to identify problems quickly and take remedial action before non-compliance arises. HR directors should work closely with academic staff to ensure attendance and engagement data is consistently captured and acted upon.

3. Training HR staff and academic colleagues on sponsor duties

Sponsor compliance cannot rest solely with HR teams. Academic departments, admissions officers and student support staff all have roles to play in meeting sponsor duties. HR directors should design and deliver structured training programmes so that all relevant colleagues understand reporting triggers, academic engagement obligations and the importance of accurate record-keeping. Training should not be a one-off exercise. Regular refresher sessions and updates following any changes in Home Office guidance are essential to maintaining compliance awareness across the institution.

4. Preparing for Home Office audits and site visits

The Home Office can visit institutions with little or no notice. Institutions must be audit-ready at all times. HR directors should maintain compliance manuals, audit trails and policies that evidence how duties are discharged in practice. Mock audits can be invaluable, highlighting weaknesses and giving staff confidence in how to respond to Home Office inspectors. All records, particularly relating to CAS allocation, student monitoring and reporting, must be accurate and immediately accessible. Institutions that cannot provide requested evidence on the spot face a high risk of enforcement action.

Institutions that fail the annual Basic Compliance Assessment (BCA) or are found to be non-compliant during an inspection can be placed on probationary status. This restricts their ability to assign new CAS until compliance improves. In serious cases, licences can be revoked altogether. HR directors should treat BCA results as a compliance barometer and act quickly where any risk indicators are identified.

Section E: Summary

Student sponsorship gives UK educational institutions the opportunity to welcome international students, but it also carries significant compliance obligations. A sponsor licence is not just an administrative step to enable recruitment. It is a legal framework that requires institutions to prove their integrity, maintain high operational standards and submit to Home Office scrutiny at all times. For HR directors, the responsibility is broad, spanning licence applications, key personnel management, ongoing monitoring, reporting obligations and readiness for audits. The consequences of falling short can be severe, from probationary status and restrictions on issuing CAS to full licence revocation, which disrupts both the institution and the students who rely on it.

Institutions must build systems that align with the Student Sponsor Guidance and apply them consistently across HR, admissions and academic teams. Monitoring student engagement, reporting changes accurately and on time, and keeping well-organised records are not optional tasks but fundamental sponsor duties. Annual Basic Compliance Assessments now act as a continuing test of compliance, and with licences continuing indefinitely, the focus is on long-term vigilance rather than renewal deadlines. Risk management should be part of daily operations, with training, internal audits and data-led monitoring embedded across the institution.

International students contribute to diversity, academic growth and financial sustainability, but the ability to enrol them rests on robust sponsorship compliance. For HR leaders, the task is to implement systems that are resilient under Home Office inspection, safeguard the sponsor licence and support the institution’s long-term capacity to attract and retain international students.

Section F:  Need Assistance?

Maintaining a student sponsor licence is demanding, and the risks of getting it wrong are significant. HR directors and leadership teams should not wait until problems arise before acting. If your institution is applying for a licence, preparing for a Basic Compliance Assessment or seeking to strengthen internal systems, professional support can make the difference between compliance and enforcement action. Specialist advice ensures that your policies, monitoring processes and reporting practices meet Home Office standards and that your institution remains audit-ready at all times. By acting now, you protect your ability to recruit and retain international students and safeguard the long-term future of your sponsor licence.

Section G: Student Sponsor Guidance FAQs

What is the difference between an A-rated and a probationary sponsor licence?

All new student sponsor licences are issued on a probationary basis. During this stage, the institution is subject to close monitoring and restrictions on its use of CAS. Once the institution demonstrates consistent compliance, the licence can be upgraded to an A-rating, which allows full sponsorship privileges. Loss of an A-rating is serious and usually follows evidence of non-compliance.

What happens if our institution fails a Home Office compliance audit?

If the Home Office identifies significant breaches, the licence may be downgraded, suspended or revoked. Downgrading can restrict recruitment, suspension halts the ability to issue CAS, and revocation removes the licence entirely. In cases of serious or systematic failings, revocation can be immediate. HR directors should treat audit outcomes as urgent compliance priorities, taking remedial action without delay and seeking expert input where needed.

Can international students switch to another visa category from the Student route?

Yes, students may be able to switch into another visa category, such as the Skilled Worker route, provided they meet the eligibility criteria. Switching is subject to Home Office rules in force at the time, and not all categories permit an in-country switch. Institutions remain responsible for sponsor duties until the student completes their course or formally changes immigration status. Reporting obligations must be met as soon as a change occurs.

How often should HR review compliance policies for sponsored students?

Compliance policies should be reviewed at least annually and more frequently if there are updates to Home Office guidance. Reviews should also follow any compliance audit, reported breach or internal incident. Regular reviews not only help identify risks but also demonstrate strong governance and a commitment to maintaining sponsor duties.

Section H: Glossary

Section I: Additional Resources and Links