ENTITY Sponsor Licence EF

Section E. Sponsor Management System

The Sponsor Management System (SMS) is the Home Office online system used by licensed sponsors to manage their sponsor licence and carry out sponsorship activity.

Once a sponsor licence has been granted, authorised users access the SMS to perform functions such as assigning Certificates of Sponsorship, reporting specified changes relating to sponsored workers and updating certain information about the sponsoring organisation.

The SMS is therefore the principal administrative interface between a licensed sponsor and the Home Office.

1. What is the Sponsor Management System?

The SMS is the online platform through which sponsors administer their licence.

Depending on the sponsor’s licence, routes and user permissions, the system is used for activities including:

• assigning Certificates of Sponsorship;
• reporting specified changes concerning sponsored workers;
• reporting relevant changes to the organisation;
• managing certain licence information;
• managing SMS users;
• requesting certain changes to the licence; and
• carrying out other sponsorship functions.

The SMS should not be viewed simply as an administrative portal. Actions taken through the system form part of the sponsor’s regulatory record.

2. Who can access the SMS?

Access to the SMS is restricted to authorised users.

The principal operational role is the Level 1 User.

Level 1 Users have broad access to sponsor management functions and can undertake significant actions on behalf of the organisation.

Sponsors can also appoint Level 2 Users where appropriate. Level 2 Users have more restricted permissions than Level 1 Users and can perform only specified functions within the system.

The organisation should ensure that individuals given SMS access satisfy the applicable Home Office requirements.

3. What can a Level 1 User do?

Level 1 Users carry out much of the day-to-day administration of the sponsor licence.

Their functions can include:

• assigning Certificates of Sponsorship;
• reporting worker changes;
• reporting certain organisational changes;
• requesting changes to sponsor details;
• managing certain users;
• viewing sponsorship information; and
• undertaking other functions available through the SMS.

The exact functions available depend on the sponsor’s circumstances and the permissions provided by the system.

Because these actions can have immigration and compliance consequences, Level 1 User access should be limited to appropriate individuals.

4. What is a Level 2 User?

A Level 2 User is an SMS user with more limited permissions.

Level 2 access can be useful where an organisation wants an individual to undertake specified sponsorship functions without providing the wider access available to a Level 1 User.

The sponsor should determine what level of access an individual actually requires rather than providing broader permissions as a matter of convenience.

5. SMS security

SMS access should be treated as sensitive regulatory access.

Each authorised user should use their own credentials.

Login details should not be shared between colleagues or used as a general departmental account.

The organisation should maintain oversight of:

• who has SMS access;
• which level of access they hold;
• whether that access remains necessary;
• whether the user remains eligible; and
• whether access needs to be removed or changed.

Where an SMS user leaves the organisation or changes responsibilities, their access should be addressed promptly in accordance with the applicable requirements.

6. Assigning Certificates of Sponsorship through the SMS

One of the most important SMS functions is the assignment of Certificates of Sponsorship.

Before assigning a CoS, the sponsor should ensure that the proposed sponsorship satisfies the requirements of the relevant immigration route.

The process should not be treated as simply entering information into the SMS.

A suitable internal process can be:

Sponsorship request

↓

Role and worker assessed

↓

Relevant route identified

↓

CoS information checked

↓

Internal approval obtained

↓

Authorised user assigns CoS

The sponsor remains responsible for the accuracy of the information provided through the SMS.

7. Reporting worker changes through the SMS

Sponsors are required to report specified changes and events relating to sponsored workers.

Depending on the circumstances, reportable matters can include changes concerning:

• employment;
• job role;
• salary;
• work location;
• absence;
• termination of employment; and
• other matters specified by the sponsor guidance.

Not every employment change is dealt with in the same way. Some changes can be reportable through the SMS, while others can have wider sponsorship or immigration consequences.

The organisation should therefore assess the immigration implications of a proposed change rather than assuming that making an SMS report is always sufficient.

8. Reporting organisational changes

The SMS is also used to notify the Home Office of specified changes relating to the sponsor itself.

These can include relevant changes concerning matters such as:

• organisation details;
• addresses;
• key personnel;
• ownership or corporate circumstances; and
• other licence information.

Corporate changes can have consequences beyond a routine SMS update.

For example, some changes involving ownership, legal entities, mergers or business transfers can affect whether an existing licence can continue to be used.

9. Reporting deadlines

Sponsor reporting duties are subject to Home Office deadlines.

The applicable timeframe depends on the type of change or event.

Sponsors should therefore have internal systems that allow reportable events to reach the appropriate SMS user promptly.

The practical compliance chain is:

Business or worker event

↓

Relevant employee identifies change

↓

Sponsor team notified

↓

Immigration consequence assessed

↓

SMS action taken within applicable deadline

The practical compliance chain is:

A technically capable Level 1 User cannot protect the organisation from late reporting if relevant information does not reach them in time.

10. Accuracy of SMS information

Information submitted through the SMS should be accurate.

This applies both to Certificates of Sponsorship and to reports or requests made after the licence has been granted.

Sponsors should take care when entering information concerning matters such as:

• job titles;
• occupation codes;
• salaries;
• working hours;
• work locations;
• employment dates; and
• worker details.

Errors should be addressed in accordance with the applicable sponsor guidance.

Repeated or material inaccuracies can create compliance concerns.

11. SMS and internal records

The SMS should not be the organisation’s only source of sponsorship information.

The sponsor should maintain its own appropriate records of:

• CoS assignments;
• sponsored workers;
• immigration permission;
• employment details;
• reports made to the Home Office;
• relevant changes; and
• internal approvals where appropriate.

This allows the organisation to reconcile its own records against the information held within the sponsorship system.

12. Maintaining an audit trail

For significant sponsorship actions, the organisation should be able to establish:

The practical compliance chain is:

What happened?

When did it happen?

Who identified it?

What immigration assessment was made?

What SMS action was taken?

When was it taken?

Maintaining an internal audit trail can help the sponsor demonstrate how it manages its compliance responsibilities.

It can also make internal audits and responses to Home Office enquiries more effective.

13. SMS and Home Office compliance

UKVI can examine SMS activity when assessing sponsor compliance.

The Home Office can compare information recorded through the sponsorship system with:

• worker files;
• employment contracts;
• payroll;
• actual job duties;
• work locations;
• attendance records; and
• other organisational information.

The sponsor should therefore ensure that the information it provides through the SMS reflects the reality of the sponsored employment.

14. Common SMS compliance risks

Problems can arise where:

• reports are made late;
• required reports are not made;
• incorrect information is entered;
• CoS are assigned without appropriate checks;
• former employees retain SMS access;
• credentials are shared;
• organisational changes are not reflected in the licence; or
• HR information does not reach the sponsor team.

These are governance problems as much as technical SMS problems.

15. Managing SMS access

Sponsors should periodically review SMS users.

A practical review can ask:

Who currently has access?

Are they still employed or otherwise appropriately authorised?

Do they remain eligible?

Do they require their current level of access?

Is there sufficient Level 1 User coverage?

Should any access be removed?

This is particularly important following staff departures or internal restructuring.

16. The SMS does not replace sponsor compliance systems

The SMS records and communicates sponsorship activity, but it does not identify every compliance issue automatically.

The organisation still needs systems capable of identifying events that require action.

For example:

Line manager changes worker’s duties

↓

HR identifies sponsorship implications

↓

Sponsor team assesses the change

↓

Required SMS or immigration action is taken

The weakness often occurs before the SMS stage.

Effective sponsor management therefore depends on connecting the SMS with the organisation’s wider HR and management processes.

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Section F. Certificates of Sponsorship

A Certificate of Sponsorship (CoS) is an electronic record assigned by a licensed sponsor to a worker it intends to sponsor under an eligible immigration route.

Despite its name, a CoS is not a physical or paper certificate. It is created and assigned electronically through the Sponsor Management System and has a unique reference number that the worker uses when making the relevant immigration application.

Assigning a CoS is a significant sponsor action. Before assignment, the organisation should be satisfied that the worker and proposed role meet the applicable sponsorship requirements and that the information recorded on the CoS is accurate.

1. What is a Certificate of Sponsorship?

A Certificate of Sponsorship links three important elements of the sponsorship process:

Sponsor → Worker → Sponsored role

The CoS contains information relevant to the worker’s immigration application, which can include:

• details of the sponsor;
• information about the worker;
• job title;
• occupation code;
• salary;
• working hours;
• work location;
• employment dates; and
• other information required for the relevant route.

The Home Office uses this information when considering the worker’s immigration application.

2. Does a Certificate of Sponsorship grant a visa?

No.

A CoS does not grant immigration permission and does not itself establish a right to work in the UK.

The worker uses the CoS reference when applying under the relevant sponsored immigration route.

The sequence is:

Licensed Sponsor

↓

Certificate of Sponsorship

↓

Worker Immigration Application

↓

Home Office Decision

↓

Immigration Permission, if granted

The worker must independently satisfy the requirements of the relevant immigration route.

3. Defined and Undefined Certificates of Sponsorship

Under the Skilled Worker route, Certificates of Sponsorship are divided into Defined and Undefined CoS.

The correct type depends principally on the nature of the worker’s application.

Sponsors need to identify the correct CoS before assignment because the processes for obtaining and using Defined and Undefined CoS differ.

4. What is a Defined Certificate of Sponsorship?

A Defined CoS is generally required when sponsoring a Skilled Worker who is applying for entry clearance from outside the UK.

The sponsor requests the Defined CoS through the Sponsor Management System.

The Home Office considers the request before the CoS becomes available for assignment.

The sponsor must provide the required information about the proposed role when making the request.

Once the Defined CoS has been granted to the sponsor, it can be assigned to the relevant worker.

5. What is an Undefined Certificate of Sponsorship?

Undefined CoS are used for Skilled Worker applications where a Defined CoS is not required, including relevant in-country applications, and for other routes where the Undefined CoS system applies.

Sponsors can have an annual allocation of Undefined CoS.

Where the organisation does not have sufficient CoS available, it may need to request an increase or otherwise obtain the required allocation through the Sponsor Management System.

Sponsors should therefore monitor their CoS requirements as part of workforce planning.

6. CoS allocation and availability

Holding a sponsor licence does not necessarily mean that the organisation has an unlimited number of Certificates of Sponsorship available.

The sponsor needs to manage its CoS position through the SMS.

Depending on the type of CoS, this can involve:

• requesting a Defined CoS;
• using an existing Undefined CoS allocation; or
• requesting an increase to the available allocation.

Organisations planning substantial international recruitment should consider CoS availability before committing to immigration-dependent start dates.

7. What should be checked before assigning a CoS?

Before assignment, the sponsor should confirm that the proposed sponsorship satisfies the relevant requirements.

A pre-assignment check can include:

Worker

Is the individual eligible for the proposed sponsored route?

↓

Role

Is there a genuine role that meets the applicable sponsorship requirements?

↓

Occupation code

Has the appropriate occupation code been identified?

↓

Duties

Do the actual duties correspond with the occupation being sponsored?

↓

Salary

Does the proposed remuneration satisfy the applicable requirements?

↓

Hours

Are the working hours correctly recorded and compatible with the salary assessment?

↓

Location

Is the work location accurately stated?

↓

Dates

Are the proposed employment and sponsorship dates accurate?

↓

CoS type

Is the correct type of CoS being used?

Only after these matters have been checked should the CoS be assigned.

8. Occupation codes

For sponsored routes where occupation eligibility is relevant, the sponsor needs to identify the appropriate occupation code for the role.

The code should be based on the actual duties of the position rather than selected simply because its title appears convenient.

Job titles alone are not determinative.

Two employers can use the same job title for materially different roles, while two differently titled roles can potentially involve substantially similar duties.

The sponsor should therefore consider the substance of the job.

9. Salary information

The salary recorded on the CoS should accurately reflect the sponsored employment and satisfy the requirements of the relevant immigration route.

For Skilled Worker sponsorship, salary eligibility can depend on several factors under the Immigration Rules.

The sponsor should therefore assess the applicable salary requirement for the individual sponsorship rather than relying on a single universal Skilled Worker salary figure.

Salary information should also be consistent with the worker’s employment arrangements.

10. Working hours

Working hours can be relevant to sponsorship eligibility and salary calculations.

The sponsor should accurately record the working arrangements required by the CoS and ensure that the employment documentation and payroll arrangements correspond with the sponsorship information.

Where hours or salary subsequently change, the sponsor should assess whether this creates a reporting requirement or a more significant immigration consequence.

11. Work location

The CoS should accurately reflect the worker’s work location or locations as required.

Changes to where a sponsored worker performs their role can have sponsor reporting implications.

Employers operating hybrid, remote or multi-site working arrangements should therefore ensure that sponsorship records remain consistent with the worker’s actual working arrangements and current Home Office requirements.

12. Accuracy of CoS information

The sponsor is responsible for the information it provides when assigning a Certificate of Sponsorship.

The organisation should therefore check the CoS carefully before assignment.

Particular attention should be given to:

• worker identity;
• job title;
• occupation code;
• duties;
• salary;
• hours;
• work location;
• start and end dates; and
• any route-specific information.

Errors can affect the worker’s immigration application and can also create sponsor compliance issues.

13. Can a Certificate of Sponsorship be corrected?

The appropriate action depends on the nature of the error and when it is identified.

Some matters can potentially be addressed through the mechanisms available within the sponsorship system, while more significant errors can require different action.

Sponsors should therefore not assume that every mistake can simply be corrected by adding a note after assignment.

The current sponsor guidance should be followed for the particular error.

14. How long is a CoS valid?

A Certificate of Sponsorship must be used for the worker’s immigration application within the validity period specified by the Immigration Rules and sponsor guidance.

Sponsors should check the applicable timeframe when assigning the CoS.

A CoS should not be assigned substantially in advance without considering when the worker will actually be able to make the relevant application.

15. Certificate of Sponsorship fees

A fee is generally payable when a sponsor assigns a Certificate of Sponsorship.

The applicable amount depends on the sponsorship route and current Home Office fee structure.

This is separate from:

• the sponsor licence application fee;
• the Immigration Skills Charge, where applicable;
• the worker’s immigration application fee; and
• the Immigration Health Surcharge, where applicable.

16. Immigration Skills Charge

The Immigration Skills Charge (ISC) applies to specified sponsorship under the Skilled Worker and Senior or Specialist Worker routes, subject to the applicable rules and exemptions.

Where payable, it is a sponsor-side charge associated with the sponsorship of the worker.

The amount can depend on matters including the size or status of the sponsor and the duration of sponsorship.

The sponsor must not pass the Immigration Skills Charge on to the sponsored worker.

17. Recovering sponsorship costs from workers

Sponsors should be careful when seeking to recover sponsorship-related costs from workers.

Home Office requirements restrict the passing of specified sponsorship costs to sponsored workers.

Employers should therefore distinguish between:

Sponsor-side costs

and

Worker-side immigration costs

before using contractual repayment or clawback provisions.

A general contractual provision stating that an employee must repay all immigration costs does not override restrictions imposed by the sponsor regime.

18. CoS assignment and internal governance

For organisations sponsoring workers regularly, CoS assignment should be subject to an internal approval process.

For example:

Recruitment identifies sponsorship requirement

↓

HR confirms employment details

↓

Immigration eligibility checked

↓

Occupation code and salary reviewed

↓

CoS information prepared

↓

Authorised approval

↓

Level 1 User assigns CoS

This helps prevent certificates from being assigned solely as an administrative response to a recruitment request.

19. Certificates of Sponsorship and compliance

UKVI can compare information recorded on the CoS with the worker’s actual employment.

For example:

CoS job duties ↔ Actual duties

CoS salary ↔ Payroll

CoS hours ↔ Working arrangements

CoS location ↔ Actual work location

Material discrepancies can create sponsor compliance concerns.

The CoS should therefore reflect the genuine employment arrangement at the point of sponsorship, with subsequent changes dealt with in accordance with the applicable sponsor requirements.

20. Certificates of Sponsorship are not transferable

A CoS is assigned by a particular sponsor to a particular worker for the relevant sponsored employment.

It cannot simply be transferred between employers.

Where a sponsored worker changes employer in circumstances requiring new sponsorship, the new employer will generally need to hold the appropriate sponsor licence and assign a new CoS, with the worker taking any required immigration action.

21. CoS audit

Sponsors should periodically reconcile CoS records against actual sponsored employment.

A practical review can examine:

CoS

↓

Worker

↓

Immigration permission

↓

Job

↓

Occupation code

↓

Salary

↓

Hours

↓

Location

↓

Current employment position

This can identify discrepancies before they develop into wider compliance problems.

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