Manage Your Sponsor Licence

Managing a sponsor licence is an ongoing responsibility. Once a licence has been granted, the organisation has to maintain accurate licence information, control access to the Sponsor Management System (SMS), manage Certificates of Sponsorship, monitor sponsored workers, keep prescribed records and report relevant changes to UKVI.

Effective licence management therefore extends beyond using the SMS. Employers need clear internal ownership of sponsorship, reliable HR processes and communication between the people responsible for recruitment, HR, payroll, management and immigration compliance.

Failures can arise from relatively ordinary business events. A sponsored worker may change role or work location. A Level 1 User may leave the organisation. The business may move premises, restructure or change ownership. Salary or working arrangements may change. Unless the immigration implications are identified and dealt with correctly, routine operational decisions can create sponsor compliance problems.

For employers using sponsorship as part of their workforce strategy, the objective should be to make sponsor licence management part of normal business governance rather than treating it as an administrative exercise carried out only when a worker needs a visa.

What this article is about

This guide explains how UK employers should manage their sponsor licence after it has been granted. It looks at the people responsible for the licence, the role of the Sponsor Management System, Certificates of Sponsorship, sponsored worker management, reporting obligations, record keeping, changes to the organisation and the internal controls needed to maintain effective oversight of sponsorship.

It also explains where particular aspects of licence management require more detailed consideration, with links to specialist guidance on key personnel, the SMS, Certificates of Sponsorship, reporting, record keeping and sponsor compliance.

 

Section A: After Your Sponsor Licence Is Granted

 

Approval of a sponsor licence marks the beginning of the organisation's responsibilities as a licensed sponsor rather than the end of the application process.

The employer can now use the sponsorship system for the routes covered by its licence, subject to the requirements applying to the relevant route and the availability or approval of the appropriate Certificate of Sponsorship.

The organisation also becomes subject to ongoing sponsor duties. UKVI expects sponsors to maintain appropriate oversight of sponsored workers, keep relevant information and records, report specified events and ensure that the information held about the organisation remains accurate.

For this reason, the period immediately after approval should be used to establish how the licence will operate internally.

 

1. Check the sponsor licence details

 

The organisation should first check that the information associated with the licence is accurate.

This includes confirming the organisation's details, the routes for which it has been licensed and the key personnel connected with the licence.

Any apparent errors or changes that have occurred since the application was submitted should be identified promptly. Sponsor licence information should not simply be assumed to remain correct because the licence has recently been approved.

The same principle applies throughout the life of the licence. Business information changes, people leave organisations and corporate structures evolve. Employers need a process for identifying when these developments affect the information held by UKVI.

 

2. Understand the sponsor licence rating

 

A newly approved sponsor will generally be granted an A-rated licence.

An A-rating allows the organisation to carry out the normal sponsorship activities permitted under its licence, including assigning Certificates of Sponsorship where the relevant requirements are met.

A B-rating restricts the sponsor's ability to assign new Certificates of Sponsorship, subject to limited exceptions under the applicable sponsor guidance. A sponsor may also be required to comply with an action plan as part of the process for regaining an A-rating.

The rating should not be treated as a permanent indication that UKVI is satisfied with the organisation's compliance.

UKVI can take action against a sponsor where it identifies failures in the way the licence or sponsored workforce is being managed. Depending on the circumstances and the applicable sponsor guidance, this can include downgrading, suspension or revocation of the licence.

Maintaining the licence therefore requires continuing compliance after approval.

 

3. Establish access to the Sponsor Management System

 

The Sponsor Management System is the principal online system through which an organisation administers its sponsor licence.

The SMS is used for functions including managing licence information, dealing with key personnel and users, requesting or managing Certificates of Sponsorship and reporting relevant changes.

Access should be treated as a controlled business permission.

Employers should know who has SMS access, what level of access each person has and why that access is required. Login credentials should not be shared between users, and access arrangements should be reviewed when responsibilities change or individuals leave the organisation.

The organisation should also avoid allowing knowledge of the SMS to sit entirely with one employee. Dependence on a single individual can create operational problems if that person is absent, leaves the business or becomes unavailable when a time-sensitive sponsorship action is required.

Key personnel and SMS users also have to satisfy the applicable Home Office eligibility and suitability requirements. Employers should not assume that any member of staff or external adviser can automatically be appointed to every sponsorship role.

Our Sponsor Management System guide explains the SMS, user permissions and the principal functions available to sponsors in more detail.

 

4. Confirm responsibility for the licence

 

Every sponsor should be able to answer a simple question:

Who is responsible for our sponsor licence?

The formal sponsorship structure includes the Authorising Officer, Key Contact and Level 1 and, where used, Level 2 Users. These roles perform different functions within the sponsorship system and are subject to specific Home Office requirements.

Formal appointments alone are not enough.

The organisation also needs to determine who is responsible operationally for identifying sponsor-related events, checking information before it is submitted through the SMS, maintaining records and escalating issues that may require action.

Responsibility may need to extend beyond the immigration or HR function.

Recruitment teams may identify new sponsorship requirements. Payroll may become aware of salary changes. Line managers may know about absence or changes in duties. Corporate teams may be involved in restructuring or acquisitions. Senior management may make decisions affecting business ownership or operating locations.

If these parts of the organisation do not communicate with whoever manages the sponsor licence, relevant information may never reach the people responsible for deciding whether UKVI action is required.

 

5. Create a sponsor licence management process

 

Employers should establish a defined process for managing sponsorship rather than relying on individual knowledge or informal working practices.

At a minimum, the organisation should know:

• who owns overall responsibility for sponsorship;
• who has access to the SMS;
• who can request and assign Certificates of Sponsorship;
• how sponsored workers are identified within HR systems;
• how changes involving sponsored workers are escalated;
• how organisational changes are assessed for sponsorship implications;
• where sponsor records are retained;
• who checks whether UKVI reporting is required;
• how reporting deadlines are monitored; and
• how sponsor compliance is reviewed internally.

 

The appropriate level of formality will depend on the organisation.

A business sponsoring a small number of workers may operate effectively with a relatively simple process. A large employer with multiple sites, business units and sponsored workers may require documented procedures, designated responsibilities, central reporting mechanisms and periodic compliance reviews.

The underlying requirement is the same: information relevant to sponsorship has to reach the right person in sufficient time for the organisation to act.

 

6. Move from application readiness to ongoing management

 

During the sponsor licence application process, an employer is principally concerned with demonstrating that it is eligible and capable of meeting the requirements of sponsorship.

After approval, the focus changes.

The organisation now has to demonstrate through its actual conduct that its systems work in practice.

That means maintaining oversight of the licence, managing Certificates of Sponsorship correctly, monitoring the sponsored workforce, retaining required records and responding appropriately when circumstances change.

UKVI can examine these arrangements during the life of the licence. Employers should therefore operate on the basis that their sponsor management systems and records may need to withstand Home Office scrutiny.

The most effective approach is to embed sponsorship into ordinary workforce governance from the outset.

The next issue is determining who should manage the sponsor licence and how responsibility should be divided between the Authorising Officer, Key Contact and SMS users.

 

 

↑ Back to top

 

Section B: Who Should Manage the Sponsor Licence?

 

A sponsor licence has named personnel attached to it, but effective management should not depend on one individual.

UKVI requires sponsors to nominate key personnel to undertake specific roles within the sponsorship system. These include the Authorising Officer, Key Contact and Level 1 User. Organisations can also appoint additional Level 1 Users and, where appropriate, Level 2 Users.

Each role has a different purpose. Together, they provide the formal structure through which the organisation controls its sponsor licence and communicates with UKVI.

Employers should distinguish between these formal sponsorship roles and the wider internal responsibility for sponsor compliance. A person may be responsible for operating the Sponsor Management System, for example, without having authority to make wider decisions about recruitment, salary, organisational restructuring or workforce policy.

The management structure should ensure that relevant information reaches the people responsible for the licence before a reporting deadline or compliance issue arises.

 

1. Authorising Officer

 

The Authorising Officer is the senior person responsible for the organisation's sponsor licence and for overseeing the activities of the people who use the Sponsor Management System.

The role should therefore be treated as a position of organisational responsibility rather than simply a name required for the sponsor licence.

The Authorising Officer will generally need sufficient seniority and authority within the organisation to oversee sponsorship arrangements and ensure that appropriate systems are in place.

In practice, the Authorising Officer does not necessarily carry out every administrative sponsorship task personally. Day-to-day SMS work may be undertaken by Level 1 Users, while HR teams, recruitment personnel and managers may carry out other parts of the organisation's sponsorship processes.

The Authorising Officer should nevertheless have sufficient oversight to understand how the licence is being managed.

Employers should consider whether the Authorising Officer:

• understands the organisation's sponsorship activities;
• has appropriate oversight of those operating the SMS;
• can ensure that sponsor responsibilities are allocated appropriately;
• is informed of significant sponsorship or compliance issues;
• has sufficient authority to require corrective action where necessary; and
• remains suitable and available to perform the role.

 

The individual appointed must also satisfy the applicable Home Office requirements for key personnel. Appointment should not be treated purely as an internal management decision.

Problems can arise where the Authorising Officer exists only on paper and has little practical involvement in sponsorship governance.

The organisation should also have a process for dealing with changes to the role. If the Authorising Officer leaves, changes position or is no longer appropriate to act, the sponsor should identify what action is required rather than leaving outdated personnel information attached to the licence.

Our Authorising Officer guide examines the eligibility requirements, responsibilities and practical considerations involved in appointing and changing an Authorising Officer.

 

2. Key Contact

 

The Key Contact acts as the main point of contact between the sponsoring organisation and UKVI.

Depending on how the organisation structures its sponsorship arrangements, the Key Contact may also hold another key personnel role.

Employers should ensure that the contact details associated with the role remain current and that communications relating to the sponsor licence are dealt with appropriately.

The practical risk is straightforward: important correspondence should not be dependent on an email account that is no longer monitored or an individual who has left the organisation.

Where responsibilities change, the organisation should consider the implications for its sponsor licence as part of the handover process.

The Key Contact must also satisfy the relevant Home Office requirements applying to key personnel. In some circumstances, an appropriately qualified UK-based legal representative can act as the Key Contact.

Our Sponsor Licence Key Contact guide explains the role and requirements in more detail.

 

3. Level 1 Users

 

Level 1 Users carry out much of the practical administration of a sponsor licence through the Sponsor Management System.

Their permissions can allow them to perform a wide range of sponsorship functions, depending on the licence and circumstances.

This makes the Level 1 User role particularly important from an operational and control perspective.

The employer should have sufficient Level 1 User coverage to manage the licence effectively while avoiding unnecessary access.

Relying on only one person can create continuity problems. If the sole Level 1 User is absent, leaves unexpectedly or becomes unavailable, the organisation may find it difficult to carry out time-sensitive sponsorship activity.

Conversely, providing Level 1 access to numerous individuals without a clear business need can weaken control over the licence.

Employers should therefore treat SMS access in the same way as other significant business permissions: grant it deliberately, understand who has it and review it periodically.

The individuals appointed as Level 1 Users must satisfy the applicable Home Office eligibility requirements. At least one Level 1 User will generally need to meet the Home Office requirements relating to their connection with the sponsoring organisation, subject to the relevant exceptions.

Internal controls should also address who is authorised to carry out particular actions.

Technical permission within the SMS does not necessarily mean an employee should be able to assign a Certificate of Sponsorship or submit significant information to UKVI without internal approval.

For example, an organisation may require a second person to verify information relating to a worker's occupation, salary and work location before a CoS is assigned.

Our Level 1 User guide considers eligibility, permissions, responsibilities and management of Level 1 access.

 

4. Level 2 Users

 

Level 2 Users can be appointed where an organisation wants an individual to have more limited access to the Sponsor Management System.

Their permissions are narrower than those available to Level 1 Users.

The role can therefore be useful where particular members of staff need to perform specified sponsorship functions without being given wider control over the licence.

As with Level 1 Users, the decision to appoint a Level 2 User should reflect an identified operational requirement and the individual must satisfy the applicable Home Office requirements.

Access should not simply accumulate over time.

Sponsors should periodically review who has SMS access, whether that access remains necessary and whether the level of permission remains appropriate to the person's role.

Our Level 2 User guide provides further detail on the functions and restrictions associated with the role.

 

5. Can external representatives manage the sponsor licence?

 

Sponsors can use external professional advisers in connection with aspects of licence management, subject to the Home Office rules governing key personnel and SMS access.

An appropriately qualified UK-based legal representative can, in permitted circumstances, act as Key Contact and can also be appointed as a Level 1 or Level 2 User once the sponsor licence has been granted.

Certain third-party HR providers may also be able to provide personnel who act as additional Level 1 or Level 2 Users where the relevant Home Office requirements are met.

External support can be particularly useful where an organisation does not have significant internal sponsorship expertise or where the volume or complexity of sponsorship activity warrants specialist assistance.

Professional support can also provide an additional layer of checking for matters such as CoS assignments, reporting decisions and organisational changes.

The employer should not, however, regard outsourcing as transferring responsibility for the sponsor licence away from the organisation.

The sponsor remains responsible for complying with its duties.

For this reason, even where external advisers are involved, the employer still needs internal processes capable of identifying relevant events and communicating them promptly.

An immigration adviser cannot report a change they have not been told about.

 

6. Build responsibility beyond the key personnel

 

One of the most important distinctions in sponsor licence management is between formal responsibility and operational awareness.

The people formally named on the licence cannot manage information they never receive.

Consider a sponsored employee whose line manager agrees to a change in duties.

The line manager may not know whether the change affects sponsorship.

Similarly:

• payroll may implement a salary change;
• HR may approve a period of absence;
• a facilities team may relocate employees to another site;
• a corporate team may implement a restructuring;
• recruitment may alter the requirements of a sponsored vacancy; or
• a manager may accept a sponsored worker's resignation.

 

Each event may need to be considered from a sponsorship perspective.

The objective is not to turn every manager into an immigration specialist. It is to establish an internal escalation process under which potentially relevant events are referred to the person or team capable of assessing them.

A simple rule can often be effective:

If something changes involving a sponsored worker, their employment or the sponsoring organisation, consider the sponsor licence implications before assuming no action is required.

 

7. Avoid single-person dependency

 

Sponsor licence management can become vulnerable where knowledge and access are concentrated in one employee.

The problem may not become apparent until that person goes on long-term absence, leaves the organisation or is unavailable when an urgent action is required.

Employers should consider business continuity as part of their sponsor management arrangements.

Depending on the size and sponsorship activity of the organisation, this may involve:

• more than one appropriately authorised SMS user;
• documented internal procedures;
• central records of sponsored workers;
• clear escalation routes;
• handover procedures when key personnel change;
• periodic access reviews; and
• senior oversight of sponsorship activity.

 

The aim is not to create unnecessary administration. It is to prevent the sponsor licence becoming dependent on undocumented knowledge held by one person.

 

8. Create a clear sponsor management structure

 

There is no single internal management model suitable for every sponsor.

A smaller employer may have an Authorising Officer who maintains close oversight while a Level 1 User handles routine administration.

A larger organisation may have a central immigration or global mobility team supported by HR, recruitment, payroll and business managers across several locations.

Whatever the structure, responsibility should be identifiable.

A workable model should establish:

Executive accountability
Who has senior responsibility for sponsorship?

Operational ownership
Who manages sponsorship activity on a day-to-day basis?

SMS control
Who is permitted to access and make changes through the Sponsor Management System?

Information ownership
Which departments hold information relevant to sponsored workers?

Escalation
How are potentially reportable events brought to the attention of the sponsor team?

Verification
Who checks significant sponsorship information before it is submitted?

Continuity
What happens when a key member of the sponsor team is unavailable or leaves?

The formal key personnel structure provides the foundation. Internal governance determines whether that structure works in practice.

Once responsibility has been allocated, the next requirement is understanding the principal system through which the licence is administered: the Sponsor Management System.

 
 

↑ Back to top

 
 

Section C: Using the Sponsor Management System (SMS)

 

The Sponsor Management System (SMS) is the online system used by licensed sponsors to administer their sponsor licence and carry out many of their sponsorship responsibilities.

For most employers, the SMS is where the administrative consequences of sponsorship decisions are recorded. It is used to manage key personnel and users, work with Certificates of Sponsorship, report certain changes and maintain information relating to the sponsor licence.

The system should not, however, be confused with the organisation's wider sponsor compliance arrangements.

The SMS records and communicates information. The employer's internal systems have to identify that information in the first place.

A well-managed sponsor therefore needs both: appropriate control of the SMS and reliable internal processes that ensure relevant workforce and organisational information reaches the people responsible for using it.

 

1. What is the Sponsor Management System?

 

The SMS provides the interface between a licensed sponsor and UKVI for administering the licence.

Depending on the sponsor's licence, sponsorship routes and user permissions, functions available through the system can include:

• managing sponsor and licence information;
• maintaining details of key personnel and SMS users;
• requesting Certificates of Sponsorship or allocations;
• creating and assigning Certificates of Sponsorship;
• reporting certain changes involving sponsored workers;
• reporting certain changes involving the sponsoring organisation; and
• carrying out other administrative actions connected with sponsorship.

 

Employers using sponsorship regularly are therefore likely to depend on the SMS throughout the lifecycle of a sponsored worker.

It is not something used only when the organisation first obtains its licence.

Our Sponsor Management System guide provides detailed guidance on accessing and using the SMS and its principal functions.

 

2. Control access to the SMS

 

SMS access gives users the ability to carry out actions that can affect the organisation's sponsor licence and sponsored workers.

Access should therefore be controlled.

Employers should know:

• who currently has access;
• whether they are a Level 1 or Level 2 User;
• why each individual requires access;
• what sponsorship functions they are expected to perform; and
• whether their access remains appropriate.

 

Access should not remain in place simply because it was granted historically.

A person may change role, move department or cease to have any involvement in sponsorship. Someone may also leave the organisation altogether.

These events should trigger consideration of their SMS access and, where relevant, the organisation's key personnel arrangements.

Periodic user reviews can help identify accounts or permissions that are no longer required.

 

3. Do not share SMS login details

 

Each SMS user should use their own permitted access rather than sharing another person's login credentials.

Shared access weakens accountability and makes it harder for the organisation to maintain proper control over sponsorship activity.

It can also create practical difficulties in establishing who carried out a particular action.

Employers should ensure that individuals given SMS responsibilities understand that access is personal and should be protected accordingly.

Internal procedures should address the security of login details and what should happen where access may have been compromised.

 

4. Decide who is authorised to perform different SMS actions

 

Having technical permission to carry out an action through the SMS does not necessarily mean the user should have unrestricted internal authority to do so.

Employers should distinguish between system permission and organisational approval.

Assigning a Certificate of Sponsorship is a good example.

A Level 1 User may be able to assign a CoS through the system, but the organisation may require the underlying information to be checked or approved before assignment.

Relevant checks might include:

• the worker's identity;
• the proposed occupation;
• the applicable occupation code;
• salary and working hours;
• work location;
• sponsorship route;
• proposed employment dates; and
• whether the role and worker satisfy the relevant sponsorship and immigration requirements.

 

Before assigning a Certificate of Sponsorship, the sponsor should satisfy itself that the proposed sponsorship meets the requirements of the relevant route and that the worker can meet the applicable immigration requirements based on the information available to the sponsor.

The SMS user should not be expected to resolve every underlying legal, HR or recruitment issue simply because they are responsible for entering the information.

A defined approval process can reduce the risk of inaccurate information being submitted.

 

5. Build the SMS into HR processes

 

The SMS does not automatically know when something changes within the organisation.

A manager may approve a new work location. Payroll may change a sponsored worker's salary. HR may record an extended absence. A corporate restructuring may change the organisation itself.

Unless the information reaches the sponsor team, no SMS action will follow.

Employers should therefore connect sponsorship administration with the systems and people that generate relevant information.

Recruitment

The sponsor team may need information about the proposed role, salary, working arrangements and intended worker before a CoS can be assigned.

HR

Changes to employment, absence, job details and personal information may need to be assessed for sponsorship implications.

Payroll

Salary and working arrangements recorded through payroll should remain consistent with the basis on which the worker is sponsored, subject to permitted changes.

Line management

Managers may be the first people to know about changes in duties, work location, absence or employment status.

Corporate management

Changes involving ownership, structure, trading arrangements or business locations may have implications for the sponsor licence.

The objective is to ensure that relevant business events trigger a sponsorship review where necessary.

 

6. Keep SMS information accurate

 

Information associated with the sponsor licence should be kept under review.

Employers should not assume that information entered when the licence was first obtained will remain accurate indefinitely.

Changes may affect:

• organisation details;
• addresses;
• key personnel;
• SMS users;
• sponsored workers;
• employment information;
• sponsorship routes; and
• other information associated with the licence.

 

Different changes can involve different processes, reporting requirements and deadlines.

Changes to a sponsored worker's work location or working arrangements should be assessed against the current sponsor reporting requirements, including the rules applying to remote and hybrid working. Employers should not assume that every instance of homeworking or hybrid working is independently reportable, but material changes should be considered against the applicable guidance.

The important management principle is that discrepancies should be identified rather than allowed to accumulate.

An internal sponsor review should therefore include comparison between the information held within the organisation and the information maintained for sponsorship purposes.

 

7. Keep an internal record of significant SMS activity

 

For organisations with regular sponsorship activity, it can be useful to maintain an internal record of significant actions carried out through the SMS.

The appropriate approach will depend on the scale of sponsorship.

Records might identify:

• the action taken;
• the sponsored worker or licence issue involved;
• when the action was completed;
• who completed it;
• the reason for the action;
• any internal approval obtained; and
• supporting documentation.

 

The purpose is not to duplicate the SMS unnecessarily.

An internal record can provide an audit trail showing how the organisation identified and dealt with sponsorship events, particularly where several departments or individuals are involved.

It can also assist with handovers, internal audits and responses to questions raised during a Home Office compliance visit.

 

8. Plan for staff absence and departure

 

Employers should consider what would happen if the person who normally operates the SMS became unavailable.

Sponsorship activity can be time-sensitive. A report may need to be made, a CoS may need to be assigned or an organisational change may require action.

A sponsor that depends entirely on one person's access or knowledge may struggle to respond.

Business continuity arrangements can include:

• maintaining sufficient appropriate SMS user coverage;
• documenting key sponsorship procedures;
• keeping sponsored worker information centrally accessible to authorised staff;
• maintaining an escalation route for urgent matters; and
• ensuring that departures from the sponsor team trigger an immediate review of access and key personnel arrangements.

 

The appropriate solution will depend on the organisation's size and level of sponsorship activity.

The aim is to avoid a situation where the licence cannot be managed effectively because one individual is unavailable.

 

9. Review SMS management periodically

 

SMS governance should form part of the organisation's wider sponsor compliance review.

A periodic review can ask:

Users
Does everyone with access still need it?

Key personnel
Are the individuals attached to the licence still current, eligible and appropriate?

Licence information
Does UKVI hold accurate information about the organisation?

Sponsored workers
Does sponsorship information correspond with current HR and employment records?

Reporting
Have relevant changes been identified and dealt with within the applicable requirements?

Certificates of Sponsorship
Are CoS processes controlled, appropriately approved and documented?

Access and continuity
Could the organisation continue to manage the licence if a principal SMS user became unavailable?

These reviews can help identify administrative weaknesses before they develop into wider sponsor compliance issues.

The SMS is ultimately the mechanism through which much of the licence is administered. The quality of the information entered into it depends on the systems operating behind it.

One of the most important functions performed through the SMS is the management and assignment of Certificates of Sponsorship, which form the next stage of the licence management process.

 
 

 
 

↑ Back to top

 
 

Section D: Managing Certificates of Sponsorship

 

Certificates of Sponsorship are central to the operation of a sponsor licence.

A Certificate of Sponsorship, or CoS, is an electronic sponsorship record assigned by a licensed sponsor to an individual worker. It is not a paper certificate and it does not itself grant immigration permission.

The worker uses the CoS reference when making the relevant immigration application.

For the employer, assigning a CoS is a significant sponsorship action. The information entered should accurately reflect the worker, the role being sponsored and the employment being offered.

CoS management should therefore operate as a controlled process rather than a routine data-entry exercise.

 

1. Use the correct type of Certificate of Sponsorship

 

Employers first need to identify the correct type of CoS for the proposed worker and immigration route.

For the Skilled Worker route, a Defined Certificate of Sponsorship is required where the worker will apply for entry clearance from outside the UK.

An Undefined Certificate of Sponsorship is used for Skilled Workers making eligible applications from within the UK and for workers being sponsored under other routes where an Undefined CoS is required, subject to the rules of the relevant route.

Using the wrong type of CoS can have serious consequences. In particular, an Undefined CoS should not be assigned to a Skilled Worker who requires a Defined CoS for an entry clearance application.

The employer should therefore establish the worker's circumstances and intended immigration application before proceeding with assignment.

Our Defined and Undefined Certificates of Sponsorship guide explains the distinction and the circumstances in which each type is used.

 

2. Manage Undefined CoS availability

 

Sponsors using Undefined Certificates of Sponsorship should monitor their ability to assign the certificates required for planned recruitment.

The organisation should not wait until a worker is ready to make an immigration application before discovering that the required CoS is unavailable.

Workforce planning should therefore consider:

• the number of workers the organisation expects to sponsor;
• the routes under which sponsorship will be required;
• the organisation's available Undefined CoS allocation where applicable;
• Certificates already assigned or expected to be assigned;
• anticipated recruitment activity; and
• whether an additional allocation request may be required.

 

Where additional Undefined Certificates of Sponsorship are required, sponsors can request an increase through the SMS in accordance with the applicable Home Office process.

The request should be planned sufficiently early to accommodate the relevant Home Office processing arrangements rather than being treated as an emergency recruitment step.

Our Undefined CoS Allocation guide considers allocation management and requests for additional Certificates in more detail.

 

3. Request Defined Certificates of Sponsorship

 

Defined Certificates of Sponsorship are requested through the Sponsor Management System.

The sponsor will need to provide information about the proposed sponsorship as part of the request.

Approval of a Defined CoS request does not remove the sponsor's responsibility for ensuring that the proposed sponsorship is compliant.

The employer remains responsible for the accuracy of the information used when the certificate is subsequently assigned and for ensuring that the role and worker meet the applicable requirements.

Defined CoS requests should therefore be incorporated into the recruitment timetable.

A practical recruitment process should identify the need for a Defined CoS early enough for the employer to obtain it before the worker needs to make the immigration application.

Our Defined Certificate of Sponsorship guide explains the request and assignment process in detail.

 

4. Check the role before assigning a CoS

 

A Certificate of Sponsorship should not be assigned simply because the organisation has identified a candidate it wants to employ.

The proposed sponsorship needs to be assessed against the requirements of the relevant immigration route.

Depending on the route and circumstances, the employer may need to consider:

• whether the organisation is authorised to sponsor under the relevant route;
• whether the role is eligible for sponsorship;
• the appropriate occupation code;
• the applicable salary requirements;
• any relevant going rate;
• the worker's proposed working hours;
• the work location;
• the proposed employment dates;
• whether the role is genuine; and
• other route-specific requirements applying to the proposed sponsorship.

 

For Skilled Worker sponsorship, the sponsor should satisfy itself before assigning the CoS that the proposed role meets the sponsorship requirements and that, based on the information available to the sponsor, the worker can meet the relevant immigration requirements.

Responsibility for the assessment should be clear internally.

A Level 1 User should not be expected to determine whether a role is legally eligible simply because they have technical permission to assign the CoS through the SMS.

 

5. Verify the information before assignment

 

Information entered on the Certificate of Sponsorship should correspond with the employment the organisation actually intends to provide.

Before assignment, employers should verify the CoS against the underlying recruitment and employment information.

A checking process might compare:

Job description
Do the stated duties reflect the actual role?

Occupation code
Does the selected code properly correspond with the work the individual will perform?

Salary
Does the salary entered on the CoS correspond with the agreed remuneration and satisfy the relevant immigration requirements?

Working hours
Are the hours accurate and consistent with the salary assessment?

Work location
Does the CoS accurately identify the relevant working arrangements and locations required under the applicable sponsorship rules?

Employment dates
Are the proposed start and end dates accurate?

Worker information
Has the organisation checked that the certificate is being assigned to the correct individual using accurate personal information?

For higher-volume sponsors, a maker-checker process can provide useful control.

One person prepares the sponsorship information and another appropriately authorised person verifies the material details before assignment.

The level of control should be proportionate to the organisation's sponsorship activity, but assignment should not become an unchecked administrative action.

 

6. Assign the CoS to the correct worker

 

A Certificate of Sponsorship is assigned to a specific worker.

The sponsor should therefore confirm the identity and relevant details of the individual before completing the assignment.

Employers should also distinguish between three separate stages:

Sponsor approval
The organisation decides that it is prepared and able to sponsor the worker.

CoS assignment
The sponsor assigns the electronic sponsorship record through the SMS.

Immigration permission
The worker uses the CoS to make the relevant immigration application and must obtain the required permission.

Assigning a CoS does not mean that the worker has been granted a visa or permission to work.

The employer must still complete the appropriate right to work process before employment begins and comply with any continuing right to work requirements that apply.

 

7. Monitor CoS validity and recruitment timing

 

Certificates of Sponsorship operate within prescribed timeframes.

Once a CoS has been assigned, the worker generally needs to use it to make the relevant visa or immigration application within three months of the date of assignment.

For routes to which the rule applies, the worker must also ensure that the timing of the application is consistent with the employment start date stated on the CoS, including the restriction on applying more than three months before that start date.

Employers should therefore coordinate CoS assignment with the worker's intended immigration application rather than assigning certificates significantly earlier than required.

Recruitment teams should understand that delays between selection, sponsorship and the immigration application can affect the usefulness of an assigned CoS.

A practical recruitment sequence may be:

Role approved

↓

Sponsorship requirements checked

↓

Correct CoS type identified

↓

Defined CoS obtained or Undefined CoS availability confirmed

↓

CoS checked and assigned

↓

Worker makes immigration application within the applicable timeframe

↓

Immigration decision

↓

Right to work established

↓

Employment starts

 

8. Deal with CoS errors correctly

 

Errors can be discovered before or after a Certificate of Sponsorship has been assigned.

The appropriate response depends on the nature of the error and the stage reached.

An employer should not assume that every mistake can simply be corrected by changing another record or adding an explanation.

Where an error is identified, the sponsor should establish:

• what information is incorrect;
• how significant the error is;
• whether the CoS has already been assigned;
• whether the worker has already submitted an immigration application;
• whether the error affects eligibility or the basis of sponsorship;
• what action is permitted under the applicable Home Office process; and
• whether specialist advice is required.

 

The organisation should retain an appropriate record of the error, its assessment and the action taken.

It should also consider why the error occurred.

If incorrect information was taken from an outdated job description or salary record, correcting the individual certificate will not resolve the weakness in the underlying process.

Our Certificate of Sponsorship Errors guide examines common CoS mistakes and the options available to sponsors.

 

9. Withdraw or cancel sponsorship where appropriate

 

Recruitment plans can change after sponsorship activity has started.

A worker may decide not to proceed, the role may be withdrawn or employment plans may change.

The organisation should determine what action is required in relation to the Certificate of Sponsorship and any associated SMS or reporting obligations.

The correct action depends on the stage reached and the circumstances.

Sponsors should avoid leaving obsolete sponsorship records unmanaged simply because a recruitment process has ended.

Where sponsorship is no longer proceeding, the internal recruitment record and sponsorship position should be brought into alignment.

 

10. Keep an audit trail of CoS decisions

 

Employers should be able to explain why a Certificate of Sponsorship was assigned.

Depending on the organisation's process, the internal record may include:

• the worker being sponsored;
• the role;
• the applicable sponsorship route;
• the occupation code assessment;
• salary and working hours;
• work location;
• evidence supporting eligibility;
• internal approval;
• the date of assignment; and
• supporting recruitment or employment documentation.

 

The purpose is not to create unnecessary paperwork.

An audit trail allows the organisation to demonstrate that sponsorship decisions were considered and controlled rather than made without verification.

It can also assist if the worker's circumstances later change or UKVI asks the sponsor to explain the basis on which sponsorship was provided.

 

11. Reconcile CoS activity with the sponsored workforce

 

Organisations sponsoring multiple workers should periodically reconcile Certificate of Sponsorship activity with their HR and sponsorship records.

The review can compare:

• current sponsored workers;
• Certificates assigned;
• the role attached to each worker;
• salary;
• working hours;
• work location;
• current immigration status;
• employment status; and
• any subsequent changes.

 

This can identify inconsistencies such as a worker who has left but remains on an active sponsorship register, a salary that no longer corresponds with sponsorship records or a role that has materially changed since the CoS was assigned.

Reconciliation is particularly useful before an internal sponsor compliance review or where the organisation has experienced rapid recruitment, restructuring or changes in HR personnel.

 

12. Build CoS management into the recruitment process

 

The strongest control is to make sponsorship assessment part of recruitment rather than adding it at the end.

A structured process can operate as follows:

Recruitment identifies sponsorship requirement

↓

Role and worker assessed

↓

Correct sponsorship route and CoS type identified

↓

Defined CoS requested or Undefined CoS availability confirmed

↓

CoS information prepared

↓

Eligibility and material information checked

↓

CoS approved internally

↓

CoS assigned

↓

Assignment and supporting evidence recorded

↓

Worker makes immigration application within the applicable timeframe

↓

Immigration permission and right to work confirmed

↓

Worker enters ongoing sponsor monitoring

This creates continuity between recruitment, immigration and employment.

The employer's responsibilities do not end when the Certificate of Sponsorship has been assigned or when the worker's immigration application succeeds.

Once the individual enters sponsored employment, the organisation has to maintain appropriate oversight of their role, salary, working arrangements, location, attendance and other relevant circumstances.

The next stage is therefore managing sponsored workers throughout the employment lifecycle.

 
 

↑ Back to top

 
 

Section E: Managing Sponsored Workers

 

Sponsor licence management does not end when a Certificate of Sponsorship has been assigned or when the worker's immigration application has been approved.

Once sponsored employment begins, the employer has continuing responsibilities in relation to the worker. Relevant information has to be maintained, certain changes have to be identified and reported, and the organisation needs sufficient oversight to know whether the worker continues to be employed in accordance with the basis of their sponsorship.

For employers, this means connecting immigration compliance with ordinary workforce management.

HR, payroll, line managers and the sponsor team may each hold information relevant to sponsorship. Effective management depends on those parts of the organisation communicating when something changes.

 

1. Maintain an accurate sponsored worker population

 

An employer should be able to identify its sponsored workers accurately.

For each sponsored worker, the organisation should have access to the information needed to understand the basis on which they are sponsored and their current employment position.

Depending on the circumstances, this can include:

• identity and contact information;
• immigration status and relevant permission dates;
• Certificate of Sponsorship details;
• sponsored route;
• job title and occupation code;
• salary and working hours;
• work location;
• employment start date;
• relevant absence information; and
• subsequent changes affecting the employment or sponsorship.

 

For organisations sponsoring larger numbers of workers, a central sponsor register can provide a practical means of maintaining oversight.

The register does not replace the underlying HR records or information held within the SMS. Its purpose is to give the sponsor team a reliable view of the sponsored workforce and help identify matters requiring action.

 

2. Monitor the role the worker is performing

 

A sponsored worker has been sponsored on the basis of a particular role.

Employers therefore need to remain aware of changes to the worker's duties and responsibilities.

Roles naturally develop. Employees may take on additional responsibilities, move between teams or progress within an organisation.

The sponsorship implications of a change should be considered before assuming that it can simply be implemented as an ordinary HR matter.

Relevant questions can include:

• Has the worker's job title changed?
• Have their substantive duties changed?
• Does the existing occupation code remain appropriate?
• Is the worker moving into a different role?
• Does the change affect the basis on which the worker was sponsored?
• Is a report required?
• Is new sponsorship required?
• Does the worker need to make a new immigration application?

 

Not every adjustment to an employee's duties will have the same immigration consequence.

The important control is that material changes involving a sponsored worker are identified and assessed against the current sponsor guidance before they are treated as routine employment changes.

 

3. Monitor salary and working arrangements

 

Salary is frequently central to eligibility for sponsored work.

Changes to pay should therefore be considered from both an employment and immigration perspective.

A salary change may arise through:

• promotion;
• annual pay review;
• changes in hours;
• changes in working patterns;
• absence;
• family leave;
• sick leave;
• temporary reductions;
• changes in duties; or
• organisational restructuring.

 

An increase in salary may appear straightforward, but it can accompany a wider change in role that requires consideration.

A reduction can create more immediate sponsorship concerns where the worker's pay falls below a requirement applying to their immigration route or sponsored role, unless the circumstances fall within a provision permitted by the applicable sponsor guidance.

The Home Office guidance contains specific rules and exceptions for certain types of absence and permitted reductions in salary. Employers should therefore avoid assuming that every temporary reduction or period of leave has the same sponsorship consequence.

Payroll and HR teams should know when salary changes involving sponsored workers need to be referred for immigration review.

The sponsor team should not discover a material salary change only when carrying out a later audit.

 

4. Keep work locations under review

 

Employers should maintain appropriate information about where sponsored workers are working.

Changes in work location can arise for many reasons.

An employee may:

• move to another office;
• transfer between sites;
• begin working at an additional location;
• work at a client site;
• change their normal workplace;
• move into a hybrid working arrangement; or
• work remotely under different arrangements.

 

The sponsorship implications depend on the nature of the change and the applicable Home Office requirements.

Employers should not assume that every individual day of homeworking or every hybrid arrangement must be reported separately. The relevant question is whether there has been a change to the worker's normal work location or working arrangements that needs to be dealt with under the current sponsor guidance.

For employers with multiple locations or mobile workforces, this can require particularly careful management.

Line managers and operational teams may regard moving an employee between locations as routine. The sponsor team may nevertheless need to know that the move has taken place.

Processes for sponsored workers should therefore include escalation of relevant workplace changes.

 

5. Monitor attendance and absence

 

Sponsors are expected to maintain appropriate oversight of sponsored workers' attendance and absences.

The organisation should have systems capable of identifying relevant non-attendance and absence and escalating matters where sponsorship action may be required.

The appropriate system will depend on the workplace.

An office-based employer may use electronic attendance, HR absence records and line management reporting. An organisation operating across multiple sites may require different controls. Employers with remote or hybrid workers need arrangements appropriate to those working patterns.

The objective is not necessarily to create a separate attendance system solely for sponsored workers.

Existing HR processes can often be used, provided they allow the employer to identify and deal with matters relevant to sponsorship.

Particular attention should be given to unexplained absence and other absences that may engage the sponsor reporting or salary rules.

The Home Office guidance contains specific provisions governing absence and permitted periods away from work. Employers should assess the particular circumstances rather than assuming that an extended absence automatically amounts to a breach or must always be dealt with in the same way.

Managers should know where concerns need to be escalated rather than allowing unexplained non-attendance to remain solely a local management issue.

 

6. Keep worker contact information current

 

Sponsors need processes for maintaining prescribed contact information for sponsored workers.

Employees should be required to tell the organisation when relevant personal details change.

The employer should also ensure that changes reach the system or team responsible for maintaining sponsor records.

This sounds administrative, but it illustrates a recurring sponsorship problem: information can exist somewhere within an organisation without reaching the people responsible for compliance.

A worker may tell their line manager about a change, for example, without the HR record being updated.

Clear procedures help avoid these gaps.

 

7. Manage promotions and internal moves carefully

 

Promotions and internal transfers are normal parts of workforce management but can have immigration consequences for sponsored workers.

Before implementing the change, the employer should consider whether the existing sponsorship remains appropriate.

A promotion may involve:

• a new job title;
• increased salary;
• substantially different duties;
• a different occupation code;
• a different work location; or
• movement to another part of the organisation.

 

The immigration implications should be considered as part of the approval process rather than after the worker has already moved into the new position.

A useful internal control is to flag sponsored status within promotion and internal-transfer workflows.

Where HR sees that an employee is sponsored, the proposed change can then be referred for immigration review before implementation.

Depending on the nature of the change, the employer may need to determine whether a report is required, whether the existing sponsorship can continue or whether a new Certificate of Sponsorship and immigration application are required.

 

8. Deal with changes in working patterns

 

Modern working arrangements can change considerably during employment.

Workers may move between full-time and part-time arrangements, adopt hybrid working, change contractual hours or request other flexible working arrangements.

For a sponsored worker, these changes should not be assessed solely under normal HR procedures.

The organisation should also consider whether the proposed arrangement remains compatible with the worker's sponsorship and whether any reporting or other immigration action is required.

Remote and hybrid working should be assessed against the current Home Office reporting rules. Employers should distinguish between ordinary flexible working arrangements and changes to the worker's normal work location or sponsored employment that may require specific action.

Again, this does not mean every request creates a sponsorship problem.

It means sponsored status should form part of the decision-making process.

 

9. Manage absence alongside sponsorship requirements

 

Periods of absence can arise through sickness, family leave, unpaid leave and other circumstances.

Employers should understand when an absence can affect sponsorship and when action may be required.

HR procedures should therefore distinguish between recording the absence for ordinary employment purposes and considering its immigration implications.

Where a sponsored worker proposes an extended period away from work, sponsorship should be considered early enough for the organisation to determine the appropriate course of action.

The applicable sponsor guidance contains specific rules and exceptions for certain types of leave and absence, including circumstances in which a worker may be absent or receive reduced pay without sponsorship necessarily having to end.

The correct position therefore depends on the nature of the absence, its duration, the worker's pay arrangements and the sponsorship route.

Employers should avoid allowing extended absence to continue without anyone responsible for the sponsor licence being aware of it.

 

10. Manage resignations and termination of employment

 

When sponsored employment ends, the sponsor needs to identify and complete any action required under the sponsorship system.

Employment can end because of:

• resignation;
• dismissal;
• redundancy;
• expiry of a fixed-term arrangement;
• mutual agreement;
• the worker moving to another employer; or
• another event bringing the sponsored employment to an end.

 

The HR offboarding process should therefore include a sponsorship check.

The sponsor team should be told promptly that employment is ending, together with the information needed to determine what should be reported and within what timeframe.

Ending employment can also have consequences for the worker's immigration position, but the sponsor should focus on completing its own obligations accurately and within the applicable requirements.

 

11. Connect line managers to sponsor compliance

 

Line managers can be one of the most important sources of sponsor information.

They are often the first to know that:

• a worker is repeatedly absent;
• duties have changed;
• a promotion is proposed;
• the employee has moved location;
• working arrangements have changed; or
• the worker intends to leave.

 

Yet line managers may have little knowledge of sponsor licence requirements.

The solution is not necessarily extensive immigration training for every manager.

Employers can instead establish clear escalation triggers.

For example:

Tell HR or the sponsor team before changing the role, salary, hours or normal work location of a sponsored worker, and tell them promptly if the worker stops attending or is leaving employment.

Simple operational instructions can be more effective than expecting managers to determine the immigration consequences themselves.

 

12. Integrate sponsorship into the employee lifecycle

 

The strongest management model is to incorporate sponsorship controls into the normal employee lifecycle.

For example:

Recruitment
Identify whether sponsorship is required and assess the role.

↓

Offer
Confirm the employment terms on which sponsorship will be based.

↓

CoS
Check and assign the appropriate Certificate of Sponsorship.

↓

Onboarding
Confirm immigration permission, complete the appropriate right to work check and retain required records.

↓

Employment
Monitor relevant role, salary, location, working arrangements and attendance information.

↓

Change
Assess promotions, transfers, salary changes, work location changes, absence and other material developments.

↓

Offboarding
Identify sponsorship reporting requirements when employment ends.

This approach reduces dependence on individuals remembering to involve the immigration team.

Instead, sponsorship becomes a defined part of the employer's existing HR processes.

 

13. Periodically reconcile sponsorship and HR records

 

Employers should periodically compare sponsorship information against current workforce records.

A review may consider whether:

• all sponsored workers can be identified;
• immigration and right to work information remains current;
• job information corresponds with the sponsored role;
• salary and working hours are accurate;
• work locations are current;
• relevant absences have been considered;
• employment changes have been assessed;
• required reports have been made; and
• leavers have been dealt with appropriately.

 

Discrepancies should be investigated rather than simply corrected administratively.

If the records do not match, the organisation needs to understand why and whether any sponsor action should previously have been taken.

Managing sponsored workers effectively therefore depends on the employer being able to detect change.

The next question is what happens once a relevant change has been identified: when and how the sponsor needs to report it to UKVI.

 
 

↑ Back to top

 
 

Section F: Reporting Changes to UKVI

 

Licensed sponsors have ongoing responsibilities to report certain changes to UKVI. These can involve individual sponsored workers, the organisation itself or the people responsible for managing the sponsor licence.

Reporting is therefore not a standalone administrative task. It depends on the organisation first identifying that something has changed, determining whether the change is reportable and ensuring that the required action is taken within the applicable timeframe.

For many employers, the main risk is not an inability to use the Sponsor Management System. It is that the person responsible for the licence never learns about the event that should have triggered a report.

Effective reporting therefore starts with internal communication.

 

1. Understand what changes may need to be reported

 

Sponsor reporting requirements cover a range of events.

Broadly, these can be divided into two categories:

Changes involving sponsored workers

These concern the individual, their sponsored employment or circumstances relevant to their sponsorship.

Changes involving the sponsoring organisation

These concern the business or organisation holding the sponsor licence, including certain changes to its details, structure or personnel.

Different events can involve different reporting requirements, procedures and deadlines.

Many worker-related changes are subject to prescribed reporting deadlines, while changes to the sponsoring organisation may operate under different timescales and procedures. Employers should identify the specific requirement applying to the event rather than relying on a single general reporting deadline.

Potentially relevant events should therefore be referred to the person responsible for sponsorship so that the applicable requirement can be checked.

Our Sponsor Licence Reporting Duties guide provides detailed guidance on reportable events, applicable deadlines and the reporting process.

 

2. Report relevant changes involving sponsored workers

 

Events involving a sponsored worker can arise throughout the employment relationship.

Potentially relevant changes can include matters relating to:

• employment starting or not starting as expected;
• prolonged or unexplained absence;
• changes to the worker's role;
• changes to duties;
• salary or working arrangements;
• work location;
• employment ending earlier than expected; and
• other developments affecting the circumstances in which the worker is sponsored.

 

Whether a particular event is reportable depends on the applicable sponsorship rules and the facts.

The sponsor should therefore assess the change rather than assume that every alteration to employment requires the same response.

The practical challenge is ensuring that the sponsor team becomes aware of the event.

A Level 1 User cannot report a change to a worker's role if the line manager who approved the change never tells HR or the sponsor team.

 

3. Identify when a sponsored worker does not start employment

 

Recruitment plans do not always proceed as expected.

A worker may obtain immigration permission but subsequently decide not to join the organisation. Their proposed start date may change, or another event may affect commencement of employment.

Sponsors need processes capable of identifying when a sponsored worker does not start as anticipated and determining whether reporting action is required.

Recruitment and onboarding teams should therefore have a mechanism for escalating sponsored-worker no-shows or changes to intended start arrangements.

The sponsor team should not discover months later that a worker for whom a CoS was assigned never joined the organisation.

 

4. Report relevant absence and non-attendance

 

Absence information may become relevant to the sponsor's reporting responsibilities.

The employer's attendance or absence systems should allow potentially reportable events to be identified.

Particular attention should be given to unexplained non-attendance and to absences that may engage specific sponsor reporting or salary rules.

The Home Office guidance contains provisions and exceptions for certain types of leave and absence, so employers should assess the circumstances rather than assume that every extended absence automatically requires the same response.

Line managers are often the first people to know that a worker has stopped attending work, while HR or the sponsor team may be responsible for determining the sponsorship consequences.

The internal process should therefore answer:

Who identifies the absence?

Who decides whether it is reportable?

Who makes any required report?

Who records the action taken?

Without that chain, an employer can have perfectly adequate absence records but still fail to meet its sponsorship responsibilities.

 

5. Consider reporting before changing a sponsored role

 

Changes to a sponsored worker's employment should be assessed before implementation wherever possible.

A promotion, internal transfer or restructuring of duties may alter the job the worker is performing.

The employer should determine whether the proposed change:

• can take place under the worker's existing sponsorship;
• needs to be reported;
• changes the occupation code;
• requires new sponsorship; or
• affects the worker's immigration position in another way.

 

The answer will depend on the circumstances and the route under which the worker is sponsored.

Building immigration review into promotion and transfer procedures allows the organisation to identify these issues before the employee begins performing a materially different role.

 

6. Consider salary and working pattern changes

 

Salary and working arrangements can be particularly important for sponsored workers because eligibility under work routes can depend on remuneration and other characteristics of the employment.

Changes should therefore be escalated for sponsorship consideration.

This can include proposed:

• salary increases or reductions;
• changes to contractual hours;
• changes between full-time and part-time arrangements;
• temporary changes in pay;
• changes arising from absence; and
• other alterations affecting the worker's remuneration or working arrangements.

 

The sponsorship implications should be assessed against the requirements applying to the worker.

The sponsor guidance contains specific provisions and exceptions for certain forms of leave, absence and permitted salary reduction. Employers should therefore avoid treating all reductions or temporary changes as having the same consequence.

Payroll changes can otherwise be implemented without the sponsor team knowing that the basis of the sponsored employment has changed.

 

7. Report changes to work location and working arrangements where required

 

Changes to where a sponsored worker normally works may need to be considered under the sponsor reporting requirements.

This can include movement between offices or sites, changes to a normal work location and changes in working arrangements.

Remote and hybrid working should be assessed against the current Home Office sponsor guidance.

Employers should not assume that every individual period of homeworking or every hybrid working arrangement is separately reportable. The relevant question is whether there has been a change to the worker's normal work location or working arrangements that engages a reporting requirement.

For employers operating across multiple sites or using flexible working models, the sponsor team should have sufficient visibility of changes to assess whether action is required.

 

8. Report the end of sponsored employment

 

Where sponsored employment ends, the organisation should determine what needs to be reported to UKVI.

This can arise following:

• resignation;
• dismissal;
• redundancy;
• termination by agreement;
• the end of a fixed-term arrangement;
• the worker moving to another employer; or
• another event ending the sponsored employment.

 

Sponsorship should therefore form part of the organisation's leaver process.

When HR is notified that a sponsored worker is leaving, the sponsor team should receive the information needed to complete any required reporting within the applicable timeframe.

The employer should also retain an appropriate record of the employment ending and the sponsorship action taken.

 

9. Report relevant changes to the sponsoring organisation

 

Reporting responsibilities are not limited to workers.

Changes to the sponsoring organisation itself can also require action.

Potentially relevant events can include changes involving:

• organisation details;
• addresses or operating locations;
• key personnel;
• business ownership;
• corporate structure;
• mergers and acquisitions;
• restructuring;
• insolvency;
• trading circumstances; and
• other matters affecting the organisation holding the licence.

 

Some corporate events can have consequences extending beyond a straightforward SMS update.

For example, a transaction involving ownership or corporate restructuring may affect whether the existing sponsor licence can continue to be used and what action the organisations involved need to take.

Sponsor licence implications should therefore form part of transaction and restructuring planning rather than being considered only after the corporate event has completed.

Specialist advice may be appropriate where ownership or structural changes are proposed.

 

10. Keep key personnel information current

 

Changes involving the Authorising Officer, Key Contact and SMS users should be dealt with as part of licence management.

Personnel changes are inevitable.

People:

• resign;
• move roles;
• take extended absence;
• change responsibilities; or
• cease to be appropriate for a sponsorship role.

 

The organisation should have a process for identifying when one of its sponsor licence personnel is affected.

This is particularly important where HR offboarding processes would otherwise remove the employee from internal systems without anyone considering the sponsor licence.

A leaver checklist for employees with sponsorship responsibilities can help prevent outdated key personnel or access arrangements remaining in place.

 

11. Know the applicable reporting deadline

 

Sponsor reporting requirements are time-sensitive.

The applicable deadline depends on the type of event and the relevant sponsor requirement.

Employers should therefore check the specific timeframe rather than relying on a general assumption about how long they have to make a report.

Internal escalation should happen sooner than the external deadline.

If the organisation waits until the reporting deadline before information reaches the sponsor team, there may be insufficient time to establish the facts, obtain advice or complete the required action.

A stronger model is:

Event occurs

↓

Internal notification

↓

Sponsor assessment

↓

Supporting information obtained

↓

Reporting requirement confirmed

↓

SMS or other required action completed

↓

Evidence retained

The internal process should create enough time for these steps to happen properly.

 

12. Keep evidence of reports made

 

Employers should retain an appropriate record of significant reporting activity.

Depending on the event, this may include:

• what happened;
• when the event occurred;
• when the organisation became aware of it;
• whether reporting was considered necessary;
• what action was taken;
• when the report was made;
• who completed it;
• information submitted to UKVI; and
• supporting records.

 

This provides an audit trail.

It can also help where UKVI subsequently asks the sponsor to explain how it dealt with a particular event.

Where the organisation determines that an unusual or potentially significant change does not require reporting, it may also be sensible to retain a record of the assessment and the basis for the decision.

 

13. Create internal reporting triggers

 

The people closest to an event will not necessarily understand sponsor guidance.

Internal procedures should therefore focus on triggers, rather than expecting managers to decide whether something is legally reportable.

For example:

Tell the sponsor team if a sponsored worker:

• does not start work as expected;
• stops attending;
• changes job;
• is promoted or transferred;
• changes salary or contractual hours;
• changes normal work location;
• moves into materially different remote or hybrid working arrangements;
• takes an unusual or extended period of absence; or
• leaves employment.

 

And:

Tell the sponsor team if the organisation:

• changes address;
• changes key personnel;
• opens, closes or changes relevant operating locations;
• changes ownership;
• restructures;
• acquires or disposes of a business;
• merges with another organisation; or
• enters insolvency or another significant corporate process.

 

The sponsor team can then determine whether UKVI action is required.

This approach is usually more reliable than distributing detailed immigration rules throughout the business.

 

14. Connect reporting to organisational change procedures

 

Significant business changes can create some of the highest sponsor licence risks because immigration considerations may not naturally form part of corporate decision-making.

Legal, finance and senior management teams may be working on a transaction without considering the sponsor licence until late in the process.

Employers that rely on sponsored workers should therefore incorporate sponsor licence review into relevant corporate change procedures.

A useful trigger can be:

Will this change affect the identity, ownership, structure, location or operation of the entity holding the sponsor licence?

If the answer may be yes, the sponsor implications should be assessed before completion.

This is particularly important in mergers, acquisitions and restructurings, where the consequences can affect both the sponsor licence and the immigration position of sponsored workers.

 

15. Review reporting compliance periodically

 

Periodic sponsor reviews should examine whether reportable events are being identified and dealt with correctly.

A review might sample:

• recent starters;
• leavers;
• promotions;
• salary changes;
• work location changes;
• changes to remote or hybrid working arrangements;
• periods of absence;
• changes to key personnel; and
• organisational developments.

 

These can then be compared against SMS activity and internal sponsorship records.

The purpose is not merely to identify missed reports.

Patterns can expose weaknesses in the underlying process.

If several promotions were never referred to the sponsor team, for example, the problem may be the HR workflow rather than the individual SMS user.

Correcting the process reduces the likelihood of the same failure recurring.

Reporting to UKVI is therefore the end of an internal information chain. The organisation first has to know what has changed, understand its significance and retain sufficient information to demonstrate how the matter was handled.

That connects reporting directly to another core sponsor management responsibility: maintaining accurate and accessible sponsor records.

 
 

↑ Back to top

 
 

Section G: Sponsor Licence Record Keeping

 

Record keeping is a core part of sponsor licence management. Employers need to retain specified documents and information relating to sponsored workers and make records available to UKVI where required.

For employers, the practical requirement goes beyond storing documents. Records need to be accurate, accessible and connected to the organisation's wider sponsorship processes.

A sponsor should be able to establish who it sponsors, the basis of each sponsorship, the employment being undertaken and how relevant changes have been managed.

Poor record keeping can make it difficult to demonstrate compliance even where the organisation believes that appropriate procedures have been followed.

 

1. Understand the sponsor record-keeping requirements

 

The documents and information sponsors are required to retain are principally set out in the Home Office sponsor guidance, including Workers and Temporary Workers: guidance for sponsors – Appendix D: record-keeping duties.

The precise records required can depend on the worker, sponsorship route and circumstances.

They can include records relating to:

• the worker's identity and immigration status;
• right to work checks;
• contact details;
• recruitment and the sponsored role;
• salary and employment;
• attendance and absence;
• the Certificate of Sponsorship;
• relevant changes during employment; and
• sponsorship actions taken by the employer.

 

Employers should use the current Home Office requirements when determining what must be retained rather than relying solely on historic internal checklists.

Our Sponsor Licence Record Keeping guide provides detailed guidance on the documents sponsors should retain and how the requirements apply in practice.

 

2. Keep immigration and right to work records

 

Immigration records form an important part of the sponsored worker file.

The employer should retain the evidence required to demonstrate that the worker has the necessary permission to undertake their employment and that the appropriate right to work process has been completed.

Right to work compliance and sponsor compliance are related but distinct obligations.

Holding a sponsor licence does not remove the employer's responsibility to carry out compliant right to work checks.

Likewise, completing a right to work check does not satisfy all of the record-keeping requirements arising from sponsorship.

Employers should therefore ensure their processes address both.

Where a worker's immigration status is time-limited, the organisation should also have a system capable of identifying when follow-up action may be required.

 

3. Maintain current contact details

 

Sponsors need to retain prescribed contact information for sponsored workers.

The organisation should have a process for collecting the required information and keeping it current.

This can be incorporated into ordinary HR procedures.

Employees can, for example, be required to notify HR when their personal contact details change, with the HR system providing the central record.

The sponsor should nevertheless check that the information being retained meets the applicable sponsorship requirements.

A common operational weakness is fragmentation.

A worker may update one part of the organisation without the central HR or sponsorship record being changed.

Clear ownership of worker data helps reduce this risk.

 

4. Keep records of the sponsored role

 

The employer should retain sufficient documentation relating to the employment for which the worker has been sponsored.

Depending on the circumstances, relevant records can include information about:

• job title;
• job description and duties;
• occupation code or SOC code;
• salary;
• working hours;
• work location;
• employment dates; and
• contractual terms.

 

These records provide evidence of the role underlying the sponsorship.

They also provide a baseline against which later changes can be assessed.

If a worker's duties, salary or location subsequently change, the employer needs to understand both the original sponsored position and the current employment arrangements.

This is one reason why CoS information should be reconciled with HR records rather than treated as a separate immigration record.

 

5. Maintain salary and payroll evidence

 

Sponsors should be able to evidence the remuneration paid to sponsored workers where required.

Payroll records can therefore form an important part of the sponsor's compliance evidence.

The information held across the organisation should also be consistent.

For example, the salary recorded in:

the Certificate of Sponsorship

↓

the employment documentation

↓

the HR system

↓

payroll records

should make sense when considered together, allowing for legitimate and properly managed changes.

A discrepancy does not necessarily mean there has been a compliance breach, but unexplained inconsistencies can create questions.

Periodic reconciliation between sponsorship and payroll information can help identify errors or changes that have not reached the sponsor team.

 

6. Retain recruitment records where required

 

Depending on the route and circumstances, sponsors may need to retain evidence relating to recruitment and how the sponsored worker came to be appointed.

The sponsorship system no longer operates on the basis of a general resident labour market test for Skilled Workers, but this does not mean recruitment records are irrelevant.

UKVI can scrutinise whether a sponsored role is genuine and whether the worker is actually undertaking the employment described.

Employers should therefore retain the recruitment records required under the applicable sponsor guidance and maintain sufficient evidence to explain the recruitment where necessary.

Relevant documentation may include material such as:

• vacancy information;
• applications;
• interview or selection records;
• job descriptions;
• recruitment communications; and
• evidence explaining how the worker was selected,

 

where required or appropriate to the circumstances.

The exact records should be determined by reference to the current requirements rather than adopting a blanket assumption that every recruitment requires identical documentation.

 

7. Keep attendance and absence records

 

The organisation should maintain the attendance or absence information required for sponsored workers.

In many cases, existing HR systems can perform this function.

The important issue is whether those systems allow the employer to identify relevant absence and respond where sponsorship action may be required.

The records should support the organisation's ability to explain what happened.

Where a sponsored worker has a significant period of absence, for example, the employer may need to establish:

• the dates of absence;
• the reason;
• whether the absence was authorised;
• how it was treated for employment purposes;
• whether salary was affected; and
• whether any sponsorship action was considered or taken.

 

The record therefore supports both workforce management and sponsor compliance.

The Home Office guidance contains specific rules and exceptions relating to certain categories of absence and salary reduction. The records should therefore allow the employer to demonstrate why the absence was treated in the way it was.

 

8. Record changes affecting sponsored workers

 

Where a sponsored worker's employment changes, the employer should retain appropriate evidence of the change.

This can include changes involving:

• duties;
• job title;
• salary;
• working hours;
• work location;
• remote or hybrid working arrangements;
• absence;
• employment status; or
• termination of employment.

 

The record should allow the organisation to understand when the change occurred and how it was handled from a sponsorship perspective.

Where a report was made to UKVI, evidence of that action should be retained appropriately.

Where a significant change was considered but did not require reporting, maintaining a record of the assessment can also be useful, particularly where the circumstances are unusual.

 

9. Keep sponsorship records organised and accessible

 

Records are of limited practical value if they cannot be located when needed.

UKVI may request information or documents as part of its compliance activity. Sponsors should therefore be capable of retrieving relevant records without extensive reconstruction.

The appropriate filing structure will depend on the organisation.

Some employers maintain a dedicated electronic sponsorship file for each worker. Others use an HR system combined with a central sponsor register and controlled document storage.

There is no benefit in duplicating records unnecessarily if the required information can be reliably retrieved from existing systems.

The important questions are:

Where is the record?

Who owns it?

Who can access it?

Is it current?

Can it be produced when required?

Large organisations should pay particular attention to records held across different sites, business units or systems.

 

10. Control access to sponsor records

 

Sponsor records can contain personal, employment and immigration information.

Access should therefore be managed appropriately.

The fact that a document relates to sponsorship does not mean every SMS user or manager necessarily needs access to every item of personal information.

Employers should align sponsor record keeping with their wider information governance and data protection arrangements.

This involves balancing two requirements:

Compliance availability
Required records need to be accessible to authorised personnel when needed.

Information control
Access to personal and confidential information should be appropriately restricted.

Clear ownership and structured storage can help achieve both.

 

11. Know how long records need to be retained

 

Sponsor records are subject to retention requirements.

The applicable period can depend on the type of document and the relevant sponsorship requirements.

Employers should therefore maintain a retention framework based on the current Home Office guidance and any other legal obligations applying to the records.

Records should not automatically be deleted simply because a worker has left employment.

Equally, indefinite retention of every sponsorship document is not necessarily appropriate.

The sponsor's retention approach should specify what is held, where it is held and when it can be securely deleted.

 

12. Build record keeping into HR processes

 

The strongest approach is to generate and maintain sponsor records through ordinary workforce processes wherever possible.

For example:

Recruitment
Create and retain relevant recruitment and role information.

↓

Sponsorship
Record CoS information and sponsorship approval.

↓

Onboarding
Complete immigration and right to work checks and collect required worker information.

↓

Employment
Maintain salary, attendance, contact and employment records.

↓

Change
Document changes and any sponsorship assessment or reporting.

↓

Offboarding
Record the end of employment and complete required sponsorship action.

↓

Retention
Maintain the required records for the applicable period.

This reduces the need to reconstruct a sponsor file shortly before a compliance visit.

The evidence develops naturally as the worker progresses through the organisation.

 

13. Audit sponsor records periodically

 

Periodic file audits can help identify missing or inconsistent information.

An audit might sample sponsored worker files and ask:

• Can the worker's immigration status be evidenced?
• Is the right to work record complete?
• Are required contact details held?
• Can the organisation evidence the sponsored role?
• Does salary information correspond with payroll?
• Is the current work location recorded?
• Are relevant attendance and absence records available?
• Have employment changes been documented?
• Can any required UKVI reports be evidenced?
• Is the Certificate of Sponsorship information available and consistent with current records?

 

The purpose should be to test whether the organisation's system works, not merely whether a checklist can be completed.

Patterns are particularly important.

One missing document may be an isolated filing error. The same document missing across numerous sponsored worker files may indicate a weakness in the onboarding process.

 

14. Be able to produce records under Home Office scrutiny

 

Record keeping becomes particularly important when UKVI examines the sponsor's compliance.

A compliance officer may want to compare information held by the Home Office with the employer's actual workforce records and working practices.

The organisation should therefore be able to move from:

Sponsored worker

→

Certificate of Sponsorship

→

Employment records

→

Payroll

→

Attendance

→

Changes

→

Reports made

without substantial gaps or unexplained inconsistencies.

Good record keeping does not guarantee that every sponsorship decision was correct.

It does, however, allow the employer to demonstrate what happened, what information it held and how it responded.

For that reason, sponsor records should be treated as part of the organisation's compliance evidence rather than merely an archive of immigration documents.

Maintaining worker records is only one side of keeping the licence accurate. The sponsor also needs to ensure that the licence itself continues to reflect the organisation, its activities and the sponsorship routes it requires.

 

 

 
 

↑ Back to top

 
 

Section H: Keeping Your Sponsor Licence Up to Date

 

A sponsor licence needs to continue to reflect the organisation that holds it.

Businesses change over time. They move premises, appoint new personnel, expand into different activities, reorganise operations, add locations and change corporate structures. Their sponsorship requirements can also develop as recruitment needs change.

Employers need processes for identifying when these developments affect the sponsor licence and determining what action is required.

Some matters can be dealt with through routine licence administration. Others can have more significant consequences for the organisation's ability to continue sponsoring workers.

The safest approach is to consider the sponsor licence before implementing significant organisational changes rather than attempting to correct the position afterwards.

 

1. Keep organisation details accurate

 

The information associated with the sponsor licence should remain consistent with the organisation that is actually operating.

Employers should monitor changes to relevant organisational details and determine whether they need to be reported or updated.

Changes can arise through ordinary business activity, including:

• changes to business or trading details;
• changes of address;
• changes to operating locations;
• changes involving branches or sites;
• changes to contact information;
• changes to key personnel;
• changes to the organisation's activities; and
• changes to its corporate circumstances.

 

Not every alteration will have the same sponsorship consequence.

The important management requirement is that significant organisational developments are referred to the person responsible for the licence rather than being treated solely as general business administration.

 

2. Manage changes of address and operating location

 

Businesses move and working locations change.

A sponsor may relocate its principal office, open or close locations, reorganise operations between sites or change where particular teams are based.

These developments should trigger consideration of the sponsor licence.

The organisation should establish:

• what has changed;
• which legal entity holds the sponsor licence;
• whether the licence information needs to be updated;
• whether sponsored workers are affected;
• whether their normal work locations or working arrangements have changed; and
• whether any separate reporting action is required.

 

A premises change can therefore involve both an organisational issue and a sponsored worker issue.

Facilities, property or operational teams may manage the physical move, but the sponsor team needs to be included where the change has immigration implications.

Where sponsored workers move location or their working arrangements change, the employer should assess the position against the current Home Office reporting requirements, including the rules applying to remote and hybrid working. Employers should not assume that every individual instance of homeworking is independently reportable.

 

3. Keep key personnel current

 

The sponsor's key personnel arrangements should reflect the people who are actually responsible for the licence.

Employers should review the position when an Authorising Officer, Key Contact, Level 1 User or Level 2 User:

• leaves the organisation;
• changes role;
• changes responsibilities;
• takes extended absence;
• no longer requires SMS access; or
• is otherwise no longer appropriate to perform the sponsorship role.

 

The licence should not accumulate historic users and personnel simply because nobody has reviewed the position.

Staff departure procedures are particularly important.

Where someone connected with the sponsor licence leaves, the offboarding process should trigger consideration of both their formal sponsorship role and any SMS access.

Replacement arrangements may also need to be made promptly to ensure continuity of licence management.

Any replacement key personnel or SMS users must satisfy the applicable Home Office eligibility and suitability requirements for the role concerned.

 

4. Review SMS users as the organisation changes

 

The number and identity of SMS users may need to develop alongside the organisation.

A growing sponsor may require additional authorised users to manage increased sponsorship activity.

A business that centralises its immigration function may need fewer users.

Following restructuring, employees may move into different teams and no longer require access.

Employers should therefore periodically reconcile SMS permissions against current responsibilities.

A simple access review can ask:

Does this person still work for the organisation?

Do they still perform a sponsorship function?

Do they continue to satisfy the requirements applying to their role?

Is their current level of access appropriate?

Does the organisation have sufficient alternative access if they become unavailable?

The aim is controlled access with adequate operational resilience.

 

5. Keep the licence aligned with sponsorship requirements

 

An organisation's recruitment strategy may change after its sponsor licence has been granted.

It may begin recruiting workers under a sponsorship route not previously required or develop activities that create different immigration needs.

The employer should establish whether its existing licence permits the intended sponsorship and whether any change or application is required before recruitment proceeds.

Recruitment teams should not assume that holding a sponsor licence means the organisation can automatically sponsor any worker under any sponsored work route.

The scope of the licence matters.

The employer also needs to satisfy the requirements applying to the particular route and proposed sponsorship.

Immigration planning should therefore form part of workforce planning where the organisation expects to recruit internationally.

 

6. Add sponsorship routes where required

 

Where an organisation needs to sponsor workers under an additional route, it may need to apply to add that route to its existing sponsor licence.

The employer should consider the requirements before committing to a recruitment timetable.

Questions can include:

• Which sponsorship route does the organisation need?
• Does the existing licence already cover it?
• Is the organisation eligible to sponsor workers under the additional route?
• What information or evidence will be required?
• What Home Office process applies?
• How long is the process likely to take?
• What additional sponsorship arrangements may be required?
• Can the intended recruitment proceed before the route has been added?

 

The underlying business need should be identified clearly.

Adding a route should form part of planned workforce strategy rather than being discovered as a requirement after a candidate has already been selected.

Our Adding Routes to a Sponsor Licence guide explains the process and requirements in more detail.

 

7. Consider the sponsor licence before corporate restructuring

 

Corporate restructuring can have significant sponsorship implications.

An organisation may:

• reorganise its group structure;
• transfer activities between entities;
• move employees between companies;
• create a new employing entity;
• consolidate operations;
• separate a business division; or
• change ownership arrangements.

 

From a commercial perspective, these may be ordinary corporate transactions.

From a sponsorship perspective, the identity of the licensed sponsor and the employing entity can be highly significant.

A sponsor licence is granted to the specific organisation that applied for it. It cannot simply be transferred to another legal entity as though it were an ordinary commercial asset forming part of a corporate transaction.

The organisation should therefore identify:

Which legal entity currently holds the sponsor licence?

Which entity employs the sponsored workers?

What will happen to that entity after the restructuring?

Will sponsored workers transfer to another entity?

Does the receiving entity hold the required sponsor licence?

Will a new sponsor licence application or other sponsorship action be required?

What reporting requirements and deadlines apply?

These questions should be addressed while the restructuring is being planned.

Attempting to resolve the immigration position after employees have already transferred can materially increase sponsor compliance and workforce continuity risks.

 

8. Assess sponsor licence implications in mergers and acquisitions

 

Mergers and acquisitions require particular attention because sponsor licences do not automatically pass between organisations as part of a transaction.

A transaction involving a licensed sponsor can affect both the licence and the sponsored workers attached to it.

The precise consequences depend on the legal structure of the transaction and the circumstances of the organisations involved.

Immigration due diligence should therefore identify:

• which legal entities hold sponsor licences;
• the sponsorship routes covered by those licences;
• the sponsored worker population;
• the status and rating of the licences;
• any outstanding sponsor compliance issues;
• the proposed treatment of the licensed entities;
• whether sponsored workers will transfer;
• whether the acquiring or receiving entity holds an appropriate sponsor licence; and
• what Home Office reporting, application or other sponsorship action may be required.

 

Timing can be important.

The parties should understand the sponsorship steps before completion so that required applications, notifications and workforce arrangements can be coordinated with the transaction.

Where a transaction changes ownership or the identity of the employing organisation, employers should not assume that updating the SMS will necessarily be sufficient. Some changes can affect the continued validity or use of the existing licence and may require further Home Office action or a new sponsor licence application.

Our specialist guidance on Sponsor Licences in Mergers, Acquisitions and TUPE Transfers considers these issues in detail.

 

9. Consider sponsorship during TUPE transfers

 

A TUPE transfer can involve sponsored workers moving between employers.

Employment law may provide for the transfer of the employment relationship, but that does not remove the need to consider the immigration and sponsorship position.

The parties should establish whether the receiving employer has the appropriate sponsor licence and what action is required in relation to the transferring workers.

This should form part of the wider transfer planning.

Relevant information about sponsored workers should be identified during due diligence rather than emerging after the transfer has taken place.

The immigration workstream should therefore operate alongside the employment, payroll and HR workstreams.

Where the circumstances fall within the Home Office provisions dealing with changes of ownership or TUPE-type transfers, the organisations involved should identify the specific reporting, licence and worker-related requirements applying to the transaction.

 

10. Address changes in ownership

 

Changes in ownership can have significant consequences for a sponsor licence.

The impact depends on the legal and transactional structure of the change.

Employers should avoid assuming that because the business continues trading under the same name, from the same premises or with the same workforce, the sponsor position is unaffected.

The relevant questions include what has happened to the legal entity holding the licence, whether ownership or control has changed and what has happened to the employment of sponsored workers.

Where ownership changes are proposed, the organisation should establish the sponsorship consequences before the transaction is implemented.

The required response may involve more than a routine update to licence information.

This is particularly important where continued employment of sponsored workers is operationally important to the business.

 

11. Consider insolvency and major business change

 

Financial distress, insolvency processes and significant changes in trading activity can also affect sponsorship arrangements.

These situations can develop quickly and may involve changes to:

• ownership;
• control;
• employing entities;
• workplaces;
• employee numbers;
• roles;
• salary arrangements; and
• continued employment.

 

Where sponsored workers are involved, immigration considerations should form part of the organisation's response.

Insolvency practitioners, directors, HR teams and advisers should identify the sponsored workforce early and establish what sponsor licence action may be required.

The same principle applies to other major business changes that alter the circumstances in which the organisation operates or employs sponsored workers.

Where the legal entity holding the sponsor licence ceases trading or undergoes a fundamental change, employers should not assume that sponsorship can simply continue under another group company or successor business without assessing the Home Office requirements.

 

12. Build sponsor review into change management

 

The most reliable approach is to make sponsorship a standard consideration whenever significant organisational change is proposed.

A simple internal trigger can be:

Could this change affect the organisation holding the sponsor licence, the people managing it or any sponsored workers?

If yes, the sponsor implications should be assessed.

Relevant internal processes might include:

New premises
→ Sponsor licence review

Corporate transaction
→ Sponsor licence review

Restructuring
→ Sponsor licence review

Change of employing entity
→ Sponsor licence review

New international recruitment route
→ Sponsor licence review

Key personnel departure
→ Sponsor licence review

Business closure or insolvency
→ Sponsor licence review

This is more effective than expecting senior management or corporate teams to know the detailed sponsorship rules themselves.

The relevant team only needs to recognise that a sponsor review is required before the change proceeds.

 

13. Maintain a sponsor licence change log

 

For organisations experiencing regular change, a central change log can help maintain oversight.

The log could record:

• the proposed or actual change;
• the date it was identified;
• the part of the organisation affected;
• sponsored workers affected;
• the sponsorship assessment;
• any approval or advice obtained;
• action required;
• the applicable deadline;
• SMS or other Home Office action completed; and
• supporting evidence.

 

The level of detail should be proportionate to the organisation.

The value lies in creating visibility.

A sponsor can then demonstrate not only that information was updated, but that it has a process for identifying and managing organisational changes affecting its licence.

 

14. Review the licence against the organisation periodically

 

Employers should periodically compare the sponsor licence position with the organisation as it exists today.

A review can ask:

Organisation
Are the sponsor's details still accurate?

Locations
Are relevant addresses and operating locations current?

Personnel
Are the correct eligible and suitable people attached to the licence?

Access
Are SMS permissions appropriate?

Routes
Does the licence cover the sponsorship the organisation currently needs?

Corporate structure
Have ownership or structural changes been assessed?

Sponsored workforce
Do sponsorship records correspond with the people actually employed?

Outstanding changes
Is there anything the business has changed that has not yet been considered from a sponsorship perspective?

The frequency and scope of review should reflect the organisation's sponsorship activity and rate of business change.

A relatively stable organisation with few sponsored workers may require a simpler review process than a large group undergoing frequent recruitment, restructuring or acquisition activity.

The principle remains the same: the sponsor licence should reflect the organisation that actually exists, not the organisation that existed when the licence was first granted.

Keeping information current is part of effective licence administration. The wider question is how the employer brings its people, systems, controls and oversight together into a sustainable model of internal sponsor licence governance.

 
 

↑ Back to top

 
 

Section I: Internal Sponsor Licence Governance

 

Effective sponsor licence management depends on governance as much as administration.

The Sponsor Management System provides the mechanism for administering the licence, but it cannot determine how information moves through the organisation, who approves sponsorship decisions, whether HR records remain accurate or whether significant business changes are identified before they affect the licence.

Employers therefore need an internal framework that connects sponsorship with recruitment, HR, payroll, line management and corporate decision-making.

The objective is proportionate control. A sponsor should be able to identify who owns the licence, who is permitted to act, how relevant information is escalated and how the organisation checks that its sponsorship arrangements continue to work.

A useful governance model can be built around six principles:

OWN → CONTROL → MONITOR → REPORT → RECORD → REVIEW

 

1. Own: establish clear accountability

 

Someone within the organisation needs overall accountability for sponsorship.

The Authorising Officer has an important formal role, but the employer should also define how sponsorship responsibility operates in practice.

There should be clarity over:

• who has senior oversight of the licence;
• who manages sponsorship operationally;
• who makes or approves significant sponsorship decisions;
• who deals with potential compliance concerns; and
• who can require corrective action where weaknesses are identified.

 

The structure will depend on the organisation.

In a smaller business, responsibility may sit with a small number of senior and HR personnel.

A larger sponsor may have a dedicated immigration, global mobility or compliance function, with responsibilities distributed across different business units.

What matters is that accountability can be identified.

Where responsibility is unclear, sponsorship tasks can fall between departments because everyone assumes somebody else is dealing with them.

 

2. Control: manage access and decision-making

 

Sponsor licence governance should distinguish between the ability to carry out an action and the authority to approve it.

SMS users may have technical permission to perform important sponsorship functions. Internal controls should determine when those permissions can be exercised.

Employers can consider controls around:

• SMS user access;
• CoS assignment;
• CoS allocation requests;
• changes to key personnel;
• reports to UKVI;
• changes to sponsored roles;
• changes to salary or working arrangements; and
• significant organisational changes.

 

Higher-risk actions may justify additional approval or verification.

For example, the organisation may require CoS information to be checked before assignment or require specialist review before implementing a substantial change to a sponsored worker's role.

Internal controls should also ensure that individuals appointed to key personnel or SMS roles continue to satisfy the applicable Home Office eligibility and suitability requirements.

Controls should be proportionate rather than bureaucratic.

The purpose is to reduce avoidable errors while allowing sponsorship activity to operate efficiently.

 

3. Monitor: know what is happening within the sponsored workforce

 

A sponsor cannot manage risks it cannot see.

Employers should have sufficient oversight to understand their sponsored workforce and identify developments that may require action.

Monitoring can include:

• sponsored worker numbers;
• immigration permission dates;
• current roles;
• salary and working hours;
• normal work locations and relevant working arrangements;
• attendance and relevant absence;
• proposed employment changes;
• upcoming terminations; and
• changes affecting the sponsoring organisation.

 

This information may already exist within HR, payroll and management systems.

The governance challenge is ensuring that relevant information can be identified and brought together for sponsorship purposes.

A central sponsor register or dashboard can be useful, particularly for organisations sponsoring larger numbers of workers.

The dashboard does not need to duplicate every HR record. It should provide sufficient visibility for the sponsor team to know where attention is required.

 

4. Report: establish escalation routes

 

Internal reporting is the mechanism that connects business events with sponsor action.

The organisation should define which events need to be escalated to the sponsor team.

Managers do not need to decide whether an event is reportable to UKVI. They need to recognise that the event may have sponsorship implications and refer it appropriately.

Typical escalation triggers can include:

Sponsored worker events

• proposed promotion or transfer;
• change of duties;
• salary or hours change;
• change to the worker's normal work location or relevant working arrangements;
• extended or unusual absence;
• unexplained non-attendance;
• resignation or termination; and
• another significant change to employment.

 

Organisational events

• change of address;
• opening or closing relevant locations;
• change of key personnel;
• restructuring;
• merger or acquisition;
• change in ownership;
• transfer of employees between entities; and
• insolvency or significant business change.

 

The sponsor team can then assess whether any action is required and identify the applicable Home Office process and deadline.

This creates a practical division of responsibility:

Business identifies the change → sponsor team assesses it → authorised personnel take the required action.

 

5. Record: maintain evidence of sponsorship activity

 

Governance should ensure that important sponsorship decisions and actions can be evidenced.

The organisation should be able to reconstruct what happened without depending on the memory of the person who dealt with the matter.

Depending on the circumstances, internal records may show:

• why sponsorship was approved;
• how a role was assessed;
• who approved a CoS;
• what information was checked;
• when a worker's circumstances changed;
• how the change was assessed;
• whether UKVI reporting was required;
• when action was completed; and
• what supporting documents were retained.

 

Records required under the sponsor regime should be maintained in accordance with the current Home Office guidance, including Workers and Temporary Workers: guidance for sponsors – Appendix D: record-keeping duties.

An audit trail becomes increasingly important as sponsorship activity grows.

Where several people or departments participate in the process, records allow the organisation to establish who did what and why.

They also support continuity when personnel change.

 

6. Review: test whether the system actually works

 

A sponsor governance framework should include periodic review.

The purpose is not simply to confirm that policies exist.

The organisation should test whether its processes are operating in practice.

A review might examine a sample of sponsored workers and trace their journey through the sponsorship system.

For example:

CoS
Was the certificate correctly prepared, checked and approved?

↓

Onboarding
Were immigration, right to work and sponsor records completed?

↓

Employment
Do HR and payroll records correspond with the sponsored role?

↓

Changes
Were promotions, salary changes, absences, location changes or relevant changes to working arrangements identified?

↓

Reporting
Was required UKVI action completed within the applicable timeframe?

↓

Records
Can the organisation produce the relevant evidence?

Testing actual cases can expose weaknesses that are not visible from reviewing written procedures alone.

 

7. Define responsibilities across departments

 

Sponsor compliance often fails at the boundaries between functions.

A useful governance framework should therefore identify the sponsorship responsibilities of relevant teams.

For example:

Recruitment

Identify candidates who require sponsorship and ensure proposed roles are referred for assessment.

HR

Maintain worker information and escalate relevant employment changes.

Payroll

Ensure salary information is accurate and flag relevant changes involving sponsored workers.

Line managers

Escalate changes to duties, normal work location, relevant working arrangements, attendance and employment arrangements.

Sponsor team

Assess immigration implications and complete required sponsorship actions.

Corporate or legal teams

Refer transactions, restructuring, changes of ownership and changes affecting employing entities for sponsor review.

Senior management

Provide oversight and ensure weaknesses are addressed.

This does not require every department to become expert in immigration law.

Each function needs to understand the point at which it should involve the sponsor team.

 

8. Use a responsibility matrix

 

Larger sponsors may benefit from documenting responsibilities through a simple matrix.

For example:

Event	Identifies	Reviews	Approves	SMS/UKVI Action
New sponsored hire	Recruitment	Sponsor team	Authorised approver	Level 1 User
Salary change	HR/Payroll	Sponsor team	HR/Management	Authorised SMS user if required
Promotion	Manager/HR	Sponsor team	Management	Authorised SMS user if required
Worker leaves	HR	Sponsor team	As applicable	Authorised SMS user where reporting is required
Address change	Operations	Sponsor team	Management	Authorised user as required
Acquisition or restructuring	Corporate team	Sponsor team/immigration adviser	Senior management	Depends on the transaction and applicable Home Office requirements

 

The precise allocation will vary.

The value of the matrix is that it removes ambiguity about who should initiate and complete each stage.

 

9. Build sponsorship into existing governance

 

Employers do not necessarily need to create an entirely separate compliance infrastructure for sponsorship.

Existing business controls can often be adapted.

For example:

Recruitment approval
Add a sponsorship assessment where required.

New starter checklist
Add immigration and sponsor record requirements.

Promotion workflow
Flag sponsored workers for immigration review.

Payroll change process
Escalate relevant sponsored worker changes.

Flexible, remote or hybrid working process
Flag relevant changes involving sponsored workers for assessment against current sponsor reporting requirements.

Leaver checklist
Include sponsor reporting.

Change of address process
Include sponsor licence review.

M&A due diligence
Identify sponsor licences and sponsored workers.

Internal audit
Include sponsor compliance testing.

Integrating sponsorship into existing processes is generally more sustainable than operating a parallel system that employees have to remember separately.

 

10. Train people according to their responsibilities

 

Training should reflect what an individual actually needs to know.

An Authorising Officer may need to understand governance, sponsor duties and organisational risk.

A Level 1 User may require detailed knowledge of SMS processes and reporting.

Recruitment personnel need to recognise sponsorship requirements during hiring.

HR and payroll teams need to understand which workforce changes should be escalated.

Line managers may only need a concise set of sponsorship triggers.

Role-based training can therefore be more effective than giving everyone the same broad immigration presentation.

The question should be:

What does this person need to recognise, decide or do for the sponsor management system to work?

Training should then address that requirement.

Training should also be refreshed where the Home Office requirements change materially or where an internal review identifies that employees are not following the organisation's sponsorship procedures.

 

11. Plan for personnel changes and business continuity

 

Sponsor governance should continue to operate when individuals change.

Employers should consider what happens if:

• the Authorising Officer leaves;
• the principal Level 1 User resigns;
• an immigration or HR manager is absent;
• responsibility moves between departments;
• the organisation restructures its HR function; or
• an external adviser relationship ends.

 

Important knowledge should not exist solely in one person's inbox or memory.

Documented processes, appropriate alternative SMS access and centralised sponsorship records can reduce this dependency.

Handover procedures should specifically address sponsor licence responsibilities where relevant personnel leave or change role.

The organisation should also ensure that replacement key personnel and SMS users satisfy the applicable Home Office requirements before or when appointments are made as required.

 

12. Use management information to identify risk

 

Larger sponsors can use management information to identify areas requiring attention.

A sponsor dashboard might track:

• number of sponsored workers;
• visa or immigration permission expiry dates;
• CoS assignments;
• upcoming recruitment requirements;
• changes awaiting sponsorship assessment;
• reports made to UKVI;
• outstanding reporting actions;
• sponsored worker leavers;
• key personnel changes;
• internal audit findings; and
• corrective actions.

 

The purpose is not to generate data for its own sake.

Management information should help the organisation answer:

Where are our sponsorship risks today?

A dashboard can also help senior management maintain oversight without becoming involved in every individual sponsorship transaction.

 

13. Escalate potential breaches promptly

 

Internal governance should include a process for dealing with suspected sponsor compliance failures.

Examples could include discovering that:

• a required report may have been missed;
• a worker's duties have materially changed;
• salary information does not match sponsorship records;
• a former employee still has inappropriate SMS access;
• required documents cannot be located; or
• an organisational change occurred without sponsor review.

 

The organisation should establish the facts promptly and determine what corrective, reporting or other action may be required.

Potential breaches should not simply be concealed by changing the underlying record so that the current information appears consistent.

The employer needs to understand what happened, whether the issue created a sponsor compliance failure and what action is appropriate under the current Home Office requirements.

An appropriate internal record should be maintained of the issue, the assessment undertaken and any corrective action.

Repeated errors should also trigger examination of the underlying process.

If several worker changes have not been reported internally, for example, the solution may require redesigning the HR workflow rather than simply reminding one Level 1 User about reporting.

 

14. Carry out periodic sponsor licence health checks

 

A structured sponsor licence health check can bring the governance framework together.

The review can examine:

OWN
Are accountability and responsibilities clear?

CONTROL
Are SMS access and sponsorship decisions appropriately controlled?

MONITOR
Can the organisation identify its sponsored workers and relevant changes?

REPORT
Are internal escalation and UKVI reporting processes working within the applicable requirements?

RECORD
Are required documents complete, current and accessible?

REVIEW
Are weaknesses identified, corrected and followed through?

The scope and frequency should be proportionate to the organisation's circumstances.

Sponsors with large sponsored populations, multiple locations or frequent organisational change may need more regular review than employers with limited sponsorship activity.

A health check can also be appropriate before anticipated Home Office scrutiny, although employers should not wait for a compliance visit before examining whether their systems work.

 

15. Treat sponsor governance as business governance

 

Sponsor licence management works best when it is embedded into the way the organisation already manages workforce and corporate risk.

Sponsorship intersects with recruitment, employment, payroll, operations, corporate transactions and senior management decisions.

The licence therefore should not sit in isolation with one HR administrator or SMS user.

A strong governance model creates a clear chain:

OWN

Someone is accountable.

↓

CONTROL

Access and important decisions are managed.

↓

MONITOR

The organisation knows what is happening.

↓

REPORT

Relevant information reaches the right people and UKVI where required.

↓

RECORD

The organisation can evidence what it has done.

↓

REVIEW

The system is tested and improved.

This provides the operational framework for managing a sponsor licence on an ongoing basis.

Even well-managed sponsors can encounter problems. Missed reports, inaccurate records, incorrect CoS assignments or organisational changes can expose weaknesses and, in more serious cases, lead to Home Office action.

The final part of the management journey is therefore understanding the common problems that arise and when an issue needs to move from routine licence management into sponsor compliance and enforcement response.

 
 

↑ Back to top

 
 

Section J: Common Sponsor Licence Management Problems

 

Sponsor licence problems often develop from relatively ordinary events: a member of staff leaves, a worker is promoted, payroll changes a salary, a report is missed or records are not updated.

Individually, these can appear to be administrative issues. Collectively, they can indicate that the organisation is not exercising effective control over its sponsor licence.

UKVI can examine the systems and processes behind sponsorship as well as individual records. Employers should therefore treat recurring errors as evidence of a possible weakness in the underlying compliance framework.

Early identification matters. A management problem that is investigated and corrected promptly may be easier to address than one that remains undetected until a Home Office compliance visit.

 

1. Outdated sponsor licence information

 

One of the most basic management problems is allowing information connected with the sponsor licence to become outdated.

This can involve:

• old organisation details;
• incorrect addresses;
• outdated operating locations;
• former employees remaining as key personnel;
• unnecessary SMS users;
• incorrect contact information; or
• organisational changes that have not been assessed.

 

These issues can develop gradually.

The organisation may still be managing its sponsored workers properly while the administrative structure surrounding the licence becomes increasingly disconnected from the business.

Periodic reconciliation of the licence against current organisational information can identify these discrepancies.

Where an error or omission is discovered, the sponsor should establish whether a reporting or other Home Office requirement has been missed and determine the appropriate corrective action rather than merely updating information without considering the history.

 

2. Too much reliance on one Level 1 User

 

Many sponsors become dependent on one person who understands the SMS.

This may work while that individual remains available.

Problems can arise if they:

• leave unexpectedly;
• take extended absence;
• change role;
• lose access;
• become overwhelmed by other responsibilities; or
• hold sponsorship knowledge that has never been documented.

 

The organisation can then struggle to assign Certificates of Sponsorship, make reports or understand previous sponsorship decisions.

Employers should maintain sufficient continuity arrangements for their circumstances.

This may involve additional appropriately authorised SMS users, documented procedures, centralised records and formal handover arrangements.

Any person appointed to an SMS or key personnel role should satisfy the applicable Home Office requirements.

 

3. Shared or poorly controlled SMS access

 

SMS access should be treated as controlled access to the organisation's sponsor licence.

Shared login credentials undermine accountability and can make it difficult to establish who performed a particular action.

Other access weaknesses can include:

• too many users;
• former employees retaining inappropriate access;
• users having permissions they no longer require;
• inadequate handover when responsibilities change; or
• SMS actions being performed without internal approval.

 

Periodic user reviews should compare system access with current employment and sponsorship responsibilities.

The organisation should be able to identify who is authorised to perform important sponsorship actions and why they require that access.

 

4. Incorrect Certificates of Sponsorship

 

CoS errors can affect the worker's immigration application and expose weaknesses in the sponsor's recruitment or checking processes.

Common problems can involve:

• using the wrong type of CoS;
• incorrect occupation codes;
• inaccurate salary information;
• incorrect working hours;
• incorrect work locations;
• inaccurate employment dates;
• incorrect worker information; or
• assigning a CoS before the role and worker have been properly assessed.

 

For Skilled Worker sponsorship, a Defined CoS is required where the worker is applying for entry clearance from outside the UK. An Undefined CoS is used for eligible Skilled Worker applications from within the UK and in other circumstances where the applicable route requires an Undefined CoS.

Assigning an Undefined CoS where a Defined CoS is required is not a minor distinction. Current Home Office guidance warns sponsors against using an Undefined CoS for a Skilled Worker entry clearance application and indicates that misuse can result in serious compliance action.

Before assigning a CoS, the sponsor should satisfy itself that the role meets the applicable sponsorship requirements and, based on the information available, that the worker can meet the relevant immigration requirements.

A checking and approval process before assignment can prevent many errors.

Where an error has already occurred, the employer should assess the nature of the mistake, the stage reached in the immigration process and the corrective options permitted under the applicable rules.

 

5. Assigning CoS without sufficient internal control

 

A Level 1 User may have technical permission to assign Certificates of Sponsorship, but that does not mean they should make every underlying recruitment and immigration decision alone.

The organisation should determine who is responsible for approving sponsorship.

Before assignment, there may need to be confirmation of:

• the business need for the role;
• the appropriate immigration route;
• role eligibility;
• the occupation code;
• salary and working hours;
• worker eligibility;
• work location;
• the correct CoS type; and
• internal recruitment approval.

 

The CoS can then be prepared and assigned on the basis of an approved sponsorship decision.

This separation becomes particularly valuable where the organisation sponsors workers frequently or has several SMS users.

 

6. Problems caused by a B-rated sponsor licence

 

A sponsor that is downgraded from an A-rating to a B-rating faces restrictions and increased Home Office scrutiny.

A B-rated sponsor will generally be unable to assign Certificates of Sponsorship to new workers while the B-rating applies, subject to limited exceptions under the sponsor guidance.

The organisation may also be required to comply with a Home Office action plan intended to address identified weaknesses.

A downgrade therefore changes the way the licence can be operated and should not be treated as an ordinary administrative status.

Where a licence has been downgraded, senior management should understand:

• why UKVI identified the deficiencies;
• what the action plan requires;
• what restrictions currently apply to sponsorship activity;
• which workers or recruitment plans are affected;
• who is responsible for corrective work; and
• how compliance with the action plan will be evidenced.

 

Detailed treatment of downgrading and action plans belongs within the Sponsor Licence Problems & Enforcement territory, but employers managing a licence need to understand that a B-rating materially affects normal sponsorship operations.

 

7. Missing reporting deadlines

 

A reporting failure can occur even where the underlying employment change was legitimate.

The organisation may have promoted a worker, changed a work arrangement or processed a leaver correctly from an HR perspective but failed to consider the sponsor reporting requirement.

Common causes include:

• line managers not notifying HR;
• HR not notifying the sponsor team;
• uncertainty over who owns reporting;
• staff absence;
• incorrect assumptions about reporting deadlines;
• events being recorded but not escalated; or
• organisational changes taking place without immigration review.

 

Where a missed report is discovered, the employer should establish the facts, determine the applicable Home Office requirement and assess what corrective action should now be taken.

The organisation should also examine why the reporting process failed.

Correcting one late report without addressing the underlying communication problem leaves the same risk in place.

 

8. HR records and SMS information do not match

 

Discrepancies between sponsorship records and the actual employment position can create significant compliance concerns.

For example:

SMS
Worker sponsored at one salary.

Payroll
Worker receiving another salary.

Or:

CoS
Worker sponsored for one role.

HR records
Worker has subsequently moved into another role.

Or:

Sponsor records
Worker based at one normal work location.

Operational reality
Worker is now normally working elsewhere under changed arrangements.

There may be a legitimate explanation for the difference.

The problem is where the organisation cannot explain it or has failed to assess whether sponsorship action was required.

Periodic reconciliation between SMS information, HR records and payroll can identify these discrepancies before they become established.

 

9. Missing or incomplete sponsor records

 

A sponsor may believe it is compliant but be unable to produce the records required to demonstrate that position.

Common record-keeping weaknesses can include:

• missing right to work evidence;
• incomplete contact information;
• missing recruitment evidence where required;
• outdated job descriptions;
• missing salary records;
• poor absence records;
• no evidence of changes reported to UKVI; or
• documents spread across systems with no clear ownership.

 

The applicable record-keeping requirements are set out principally in the Home Office sponsor guidance, including Workers and Temporary Workers: guidance for sponsors – Appendix D: record-keeping duties.

Employers should audit records against the current requirements rather than assuming that a historic sponsor checklist remains complete.

Where documents are missing, the organisation should establish whether the issue is isolated or evidence of a wider process failure.

 

10. Failure to identify relevant worker changes

 

Some sponsor problems arise because the organisation has no mechanism for identifying changes to sponsored employment.

A sponsored worker may be:

• promoted;
• transferred;
• given substantially different duties;
• moved to another normal work location;
• placed on different working arrangements;
• given different hours;
• subject to a salary change; or
• absent for a significant period.

 

Each event may be properly recorded somewhere within the business, but nobody considers the immigration implications.

This is primarily a governance problem.

The solution is to build sponsorship triggers into the relevant HR and management processes so that changes involving sponsored workers are referred for assessment.

Remote and hybrid working should be considered under the current Home Office requirements rather than assuming that every instance of homeworking is reportable.

Similarly, absence and salary reductions should be assessed against the specific provisions and exceptions in the sponsor guidance rather than treated automatically as breaches.

 

11. Changes are implemented before immigration review

 

Timing can turn a manageable sponsorship issue into a more difficult problem.

HR may approve a promotion on Monday and tell the sponsor team after the employee has already started the new role.

A business may complete a corporate restructuring before anyone checks what happens to its sponsor licence.

Payroll may reduce hours before considering whether the new salary remains compatible with the worker's sponsorship.

A stronger control is:

PROPOSE CHANGE

↓

CHECK SPONSORED STATUS

↓

ASSESS IMMIGRATION IMPLICATIONS

↓

COMPLETE REQUIRED SPONSORSHIP ACTION

↓

IMPLEMENT CHANGE

Not every change requires Home Office action.

The benefit of pre-implementation review is that the organisation establishes the position before committing itself to an arrangement that may be incompatible with the existing sponsorship.

 

12. Corporate changes are not referred to the sponsor team

 

Corporate transactions create particular risk because they are often managed outside HR.

Senior management, finance teams, corporate lawyers or external advisers may complete a transaction without recognising that the organisation holds a sponsor licence.

Potentially significant events include:

• changes in ownership;
• mergers;
• acquisitions;
• business transfers;
• TUPE transfers;
• group reorganisations;
• changes of employing entity;
• business disposals; and
• insolvency events.

 

A sponsor licence is granted to the specific organisation that applied for it and cannot simply be transferred to another legal entity as part of a corporate transaction.

Employers should therefore assess the sponsor position before completing relevant structural changes.

Where sponsored workers are transferring between organisations, the implications for both the sponsor licence and the workers' sponsorship should be addressed as part of transaction planning.

 

13. Treating right to work and sponsor compliance as the same thing

 

Right to work compliance and sponsor compliance overlap, but they are not interchangeable.

An employer may have completed a valid right to work check but still have sponsor compliance problems relating to the worker's role, salary, records or reporting.

Equally, maintaining accurate sponsor records does not remove the requirement to carry out the appropriate right to work checks.

Employers should therefore maintain separate but connected controls for:

Right to work
Is the individual legally permitted to undertake the employment, and has the employer completed the prescribed check?

Sponsorship
Is the organisation complying with the requirements arising from sponsoring that worker?

Connecting the processes without confusing them provides stronger workforce compliance.

 

14. Assuming external advisers carry the sponsor's responsibility

 

External immigration advisers can assist employers with sponsor licence administration and compliance.

Subject to the applicable Home Office requirements, appropriately qualified UK-based legal representatives can perform permitted sponsor roles, and certain third-party HR provider personnel may be permitted to act as additional Level 1 or Level 2 Users in specified circumstances.

External support does not transfer the sponsor's underlying responsibility to the adviser.

The organisation still needs internal visibility of:

• who it sponsors;
• what roles workers perform;
• what they are paid;
• where and under what relevant arrangements they work;
• whether circumstances have changed;
• whether required information has been provided to the adviser; and
• whether required actions have been completed.

 

An adviser cannot report an employment change they have never been told about.

Employers using external support should therefore define the relationship between internal ownership and external administration clearly.

 

15. Failing to investigate repeated errors

 

Repeated sponsorship mistakes are often more significant than a single isolated error because they can indicate a systemic weakness.

Examples might include:

• several late reports;
• repeated CoS inaccuracies;
• missing records across multiple worker files;
• frequent salary discrepancies;
• multiple undocumented role changes; or
• recurring failures to remove former SMS users.

 

The organisation should ask why the same type of error continues to occur.

A useful approach is:

Identify the error

↓

Correct the immediate issue where possible and appropriate

↓

Determine the cause

↓

Change the underlying process

↓

Test whether the correction works

For example, repeated late reporting of promotions may indicate that the promotion workflow does not identify sponsored workers.

The long-term solution is therefore to change the workflow, not simply to remind the SMS user about deadlines.

 

16. Ignoring historical sponsor compliance problems

 

Employers sometimes identify historic errors during an internal review.

The fact that the event occurred months ago does not mean it should automatically be ignored.

The organisation should establish:

• what happened;
• when it happened;
• which workers were affected;
• what the applicable sponsor requirement was;
• whether a report or other action should have been taken;
• whether the issue continues;
• whether corrective action is available or required; and
• whether the problem indicates a wider compliance weakness.

 

Historical issues can require careful handling, particularly where several workers are affected or the problem may amount to a significant sponsor breach.

Employers should avoid attempting to conceal the history by altering records without preserving an accurate audit trail.

Where the potential breach is material, specialist advice may be appropriate before the organisation determines its response.

 

17. Waiting for UKVI to identify the problem

 

A sponsor licence should not be managed on the assumption that compliance only matters when UKVI announces a visit.

Home Office scrutiny can expose issues involving:

• the sponsored workforce;
• Certificates of Sponsorship;
• roles and occupation codes;
• salary;
• work locations;
• attendance;
• record keeping;
• reporting;
• key personnel;
• SMS management; and
• the organisation's wider compliance systems.

 

An employer that reviews these areas routinely is better placed to identify weaknesses before they become enforcement issues.

Internal sponsor health checks should therefore form part of ongoing licence management rather than being undertaken solely in response to Home Office scrutiny.

 

18. Know when a management problem becomes an enforcement problem

 

Not every sponsor licence mistake results in formal Home Office action.

The seriousness of an issue can depend on factors including the nature of the breach, its extent, whether it is isolated or systemic, the sponsor's wider compliance position and the applicable Home Office policy.

Potential consequences of sponsor compliance failures can include:

• additional scrutiny;
• a compliance visit;
• downgrading of the sponsor licence;
• a sponsor action plan;
• suspension;
• revocation; and
• consequences for the organisation's sponsored workforce.

 

These outcomes belong principally within the separate Sponsor Licence Problems & Enforcement territory.

The management priority is recognising when an issue is no longer a routine administrative correction.

Warning signs can include:

• multiple workers being affected;
• systemic reporting failures;
• significant discrepancies between sponsored roles and actual employment;
• serious record-keeping deficiencies;
• incorrect sponsorship affecting worker eligibility;
• corporate changes affecting the validity or use of the licence;
• Home Office contact concerning potential non-compliance; or
• notification of a compliance visit, downgrade, suspension or other formal action.

 

At that stage, the organisation should establish the facts, preserve relevant records, control communications and determine the appropriate response.

Our specialist guides on Sponsor Compliance Visits, Sponsor Licence Downgrading, Sponsor Licence Suspension and Sponsor Licence Revocation deal with these issues in detail.

 

19. Use problems to strengthen the sponsor management system

 

A strong sponsor management system is not one in which no employee ever makes a mistake.

It is one in which the organisation can identify problems, understand their significance, take appropriate action and reduce the likelihood of recurrence.

A practical response model is:

DETECT

Identify the potential problem.

↓

ASSESS

Establish the facts and applicable sponsor requirement.

↓

CORRECT

Take appropriate remedial or reporting action where available and required.

↓

DOCUMENT

Maintain an accurate record of the issue and response.

↓

IMPROVE

Address the underlying process weakness.

↓

REVIEW

Check that the corrective measures are operating effectively.

Applied consistently, this approach turns sponsor licence management from a series of isolated immigration tasks into an ongoing system of workforce control.

Employers can then move from reacting to sponsorship events to maintaining a licence that is actively monitored, accurately administered and supported by reliable internal processes.

 

 

Sponsor Licence Management Checklist

 

Managing a sponsor licence involves a combination of people, systems, workforce information and ongoing oversight. Employers should periodically check that the arrangements established when the licence was granted continue to operate effectively.

The following checklist provides a practical framework for reviewing the management of a sponsor licence.

 

1. Key personnel and responsibility

 

Check that:

• the Authorising Officer remains appropriate and has sufficient oversight of sponsorship;
• the Key Contact details are current;
• Level 1 Users remain appropriate and require their existing access;
• Level 2 Users, where appointed, continue to require their permissions;
• all key personnel and SMS users continue to satisfy the applicable Home Office eligibility and suitability requirements;
• former employees no longer have inappropriate access or responsibilities;
• there is clear operational ownership of the sponsor licence;
• responsibility does not depend entirely on one individual; and
• appropriate handover and continuity arrangements exist.

 

2. Sponsor Management System

 

Check that:

• the organisation can access and administer the SMS effectively;
• SMS users use their own permitted access;
• login credentials are not shared;
• access is restricted to people with a genuine business requirement;
• user permissions are reviewed periodically;
• significant SMS actions are subject to appropriate internal controls;
• the organisation has sufficient alternative access if a principal user is unavailable; and
• relevant SMS activity can be evidenced where required.

 

3. Certificates of Sponsorship

 

Check that:

• the correct type of CoS is used;
• Defined CoS are used where required for Skilled Worker entry clearance applications from outside the UK;
• Undefined CoS availability is monitored where relevant;
• Defined CoS requests are properly prepared;
• roles are assessed before sponsorship;
• occupation codes are checked;
• salary and working hours are verified;
• work locations are accurate;
• CoS information reflects the employment actually being offered;
• the sponsor has satisfied itself that the relevant sponsorship requirements are met before assignment;
• appropriate internal approval is obtained before assignment;
• CoS validity and application timing are monitored;
• CoS errors are identified and dealt with appropriately; and
• CoS activity can be reconciled against the sponsored workforce.

 

4. Sponsored workers

 

Check that:

• the organisation can identify all current sponsored workers;
• current immigration information is held;
• sponsored roles correspond with actual employment;
• salary and working hours remain accurate;
• normal work locations are known;
• relevant remote or hybrid working arrangements have been considered against current sponsor guidance;
• relevant attendance and absence information is available;
• promotions and transfers trigger sponsorship consideration;
• changes to duties are escalated;
• changes to salary and working arrangements are assessed;
• leavers trigger sponsor action; and
• sponsorship information is incorporated into the employee lifecycle.

 

5. Reporting

 

Check that the organisation has processes for identifying and assessing:

• workers who do not start employment as expected;
• unexplained non-attendance;
• relevant periods of absence;
• changes to roles or duties;
• salary and working pattern changes;
• changes to normal work location;
• relevant changes to remote or hybrid working arrangements;
• resignations and terminations;
• key personnel changes;
• changes of address;
• organisational restructuring;
• mergers and acquisitions;
• ownership changes;
• transfers between employing entities; and
• other significant organisational developments.

 

Internal escalation should occur early enough for the sponsor team to determine whether UKVI reporting or other action is required within the applicable timeframe.

The organisation should not rely on one general reporting deadline. Different events can be subject to different Home Office procedures and timescales.

 

6. Sponsor records

 

Check that required records are:

• being collected;
• accurate;
• current;
• stored appropriately;
• accessible to authorised personnel; and
• retained for the required period.

 

The organisation should review its records against the current Home Office requirements, including Workers and Temporary Workers: guidance for sponsors – Appendix D: record-keeping duties.

The sponsor should be able to move from the worker's sponsorship information to the relevant employment, payroll, attendance, right to work and reporting records without unexplained gaps.

 

7. Licence information

 

Check that:

• organisation details remain accurate;
• relevant addresses are current;
• key personnel information is up to date;
• SMS users reflect current responsibilities;
• the licence covers the sponsorship routes the organisation requires;
• relevant business changes have been considered;
• new locations have been assessed;
• changes in ownership or corporate structure have been reviewed;
• mergers, acquisitions and TUPE transfers have been assessed for sponsorship implications;
• changes of employing entity have been considered; and
• outstanding licence changes have been identified and dealt with.

 

8. Internal governance

 

Check that there is clear responsibility for:

OWN
Senior accountability for the sponsor licence.

CONTROL
SMS access and significant sponsorship decisions.

MONITOR
Sponsored workers and relevant employment information.

REPORT
Internal escalation and required UKVI action.

RECORD
Sponsor documents and evidence of decisions.

REVIEW
Periodic testing of the sponsorship system.

A checklist should not be treated as evidence of compliance in itself. The purpose is to test whether the organisation's actual practices, records and workforce arrangements correspond with its sponsorship responsibilities.

Where weaknesses are identified, employers should determine both the immediate action required and why the underlying process failed.

 

FAQs

 

1. How do you manage a sponsor licence?

 

A sponsor licence is managed through a combination of the Sponsor Management System and the employer's internal HR and compliance processes.

The organisation needs appropriate key personnel, controlled SMS access, processes for assigning Certificates of Sponsorship, systems for maintaining sponsored worker information, reporting arrangements, record keeping and procedures for dealing with organisational change.

Effective management also requires periodic review to ensure these arrangements continue to work.

 

2. Who is responsible for managing a sponsor licence?

 

The formal key personnel structure includes the Authorising Officer, Key Contact and Level 1 User, with additional Level 1 and Level 2 Users potentially appointed where appropriate.

These individuals must satisfy the applicable Home Office requirements for their respective roles.

The wider organisation also has a role.

HR, recruitment, payroll, line managers and corporate teams may hold information relevant to sponsorship. Employers therefore need internal procedures that ensure relevant information reaches those responsible for the licence.

 

3. What is the Sponsor Management System?

 

The Sponsor Management System, or SMS, is the Home Office online system through which licensed sponsors administer many aspects of their sponsor licence.

It is used for functions including managing licence information and users, dealing with Certificates of Sponsorship and reporting certain changes.

SMS administration is only one part of sponsor management. Employers also need internal systems capable of identifying the information that needs to be entered or reported through the system.

 

4. Who should be a Level 1 User?

 

A Level 1 User should be an appropriate person who satisfies the applicable Home Office requirements and needs the relevant SMS permissions to perform sponsorship functions for the organisation.

Employers should consider the person's responsibilities, suitability and operational need for access.

At least one Level 1 User will generally need to satisfy the Home Office requirements relating to their connection with the sponsoring organisation, subject to the relevant exceptions.

Access should be reviewed when responsibilities change.

 

5. Can more than one person manage a sponsor licence?

 

Yes. Organisations can have multiple appropriate users within the sponsorship framework, subject to the applicable Home Office requirements.

Having sufficient appropriately authorised personnel can also reduce dependency on one person.

Employers should balance business continuity against the need to control SMS access.

 

6. Can an external adviser manage a sponsor licence?

 

External advisers can assist with sponsor licence management, subject to the Home Office rules governing key personnel and SMS access.

An appropriately qualified UK-based legal representative can, in permitted circumstances, act as Key Contact and can also be appointed as a Level 1 or Level 2 User once the sponsor licence has been granted.

Certain third-party HR providers may also be able to provide additional Level 1 or Level 2 Users where the relevant requirements are met.

Using an external adviser does not transfer the sponsor's underlying responsibility for complying with its sponsor duties.

 

7. What changes have to be reported to UKVI?

 

Reporting requirements can apply to changes involving sponsored workers and changes involving the sponsoring organisation.

Potentially relevant worker events include certain changes to employment, role, salary, working arrangements, normal work location, absence and termination.

Organisational events can include changes to key personnel, addresses, ownership, corporate structure and other business circumstances.

The precise reporting requirement depends on the event and the applicable sponsor guidance.

 

8. How quickly do sponsor licence changes have to be reported?

 

Reporting deadlines vary according to the type of change.

Many worker-related and organisational changes are subject to prescribed timescales, but employers should check the requirement applying to the particular event rather than relying on a single general reporting period.

Internal reporting should occur well before the external deadline so that the sponsor team has time to establish the facts and take the appropriate action.

 

9. How should employers manage Certificates of Sponsorship?

 

CoS assignment should operate as a controlled process.

Before assignment, the organisation should verify the sponsorship route, correct CoS type, role, occupation code, salary, working hours, work location, employment dates and other relevant information.

The sponsor should also satisfy itself that the proposed sponsorship meets the relevant requirements and that, based on the information available, the worker can meet the applicable immigration requirements.

Employers should control who can approve and assign Certificates of Sponsorship and maintain an appropriate audit trail.

 

10. How long does a worker have to use a Certificate of Sponsorship?

 

Once a Certificate of Sponsorship has been assigned, the worker generally needs to use it to make the relevant immigration application within three months of the date of assignment.

The application timing also needs to be consistent with the employment start date stated on the CoS, including any applicable restriction on applying more than three months before the proposed start date.

Employers should therefore coordinate CoS assignment with recruitment and immigration application timing.

 

11. What records should a sponsor keep?

 

Sponsors are required to retain specified records relating to their sponsored workers and sponsorship activity.

Depending on the applicable requirements, these can include immigration and right to work evidence, contact information, employment and salary records, recruitment documentation, attendance information and evidence relating to relevant changes and reports.

The principal record-keeping requirements are set out in the Home Office sponsor guidance, including Workers and Temporary Workers: guidance for sponsors – Appendix D: record-keeping duties.

 

12. What happens if a Level 1 User leaves?

 

The organisation should review the individual's SMS access immediately and determine whether replacement or alternative arrangements are required.

Where the departure also affects the organisation's key personnel arrangements, the sponsor should identify the relevant Home Office action required.

Any replacement user should satisfy the applicable requirements for the role.

Employers should avoid becoming dependent on a single Level 1 User without appropriate continuity arrangements.

 

13. Can you change the Authorising Officer?

 

Yes. The Authorising Officer can be changed where required, subject to the applicable Home Office requirements and process.

The organisation should ensure the replacement is eligible and suitable for the role and that the licence information is updated appropriately.

A change should also trigger consideration of the wider sponsorship handover and governance arrangements.

 

14. What happens if a sponsored worker changes job?

 

The employer should assess the proposed change before it is implemented wherever possible.

The sponsorship consequences depend on matters including the new duties, occupation code, salary, work location and other characteristics of the role.

The change may require reporting, further sponsorship action or a new immigration application depending on the circumstances.

 

15. What happens if a sponsored worker's salary changes?

 

The employer should consider the sponsorship implications of the proposed salary change before implementation.

A salary reduction can affect whether the worker continues to satisfy the requirements of the sponsored route, while an increase may accompany a wider change in role that also requires assessment.

The sponsor guidance contains specific provisions and exceptions for certain types of leave, absence and permitted salary reduction. Employers should therefore assess the individual circumstances rather than assume that every salary change has the same consequence.

 

16. Does hybrid or remote working have to be reported?

 

Not every individual period of homeworking or hybrid working is automatically reportable.

Employers should assess whether there has been a change to the sponsored worker's normal work location or working arrangements that engages the current Home Office reporting requirements.

Where working arrangements change materially, the sponsor team should review the position rather than relying on a general assumption that remote working either always or never needs to be reported.

 

17. What happens when a sponsored worker leaves?

 

The employer should identify any sponsor reporting action required and update its internal records.

Sponsorship should therefore be included within the organisation's employee offboarding procedure so that the sponsor team is notified promptly when sponsored employment ends.

The organisation should retain an appropriate record of the end of employment and the sponsorship action taken.

 

18. Does a sponsor licence need to be renewed?

 

Most Worker and Temporary Worker sponsor licences no longer require periodic renewal.

From 6 April 2024, licences that would previously have required renewal generally remain valid without the sponsor having to submit a renewal application, unless the licence is revoked, surrendered or otherwise ceases to be valid under the applicable rules.

The removal of routine renewal does not remove the sponsor's continuing duties.

Employers still need to maintain accurate licence information, manage sponsored workers correctly and remain compliant with the Home Office sponsorship requirements.

 

19. What does a B-rated sponsor licence mean?

 

A B-rated sponsor licence indicates that UKVI has identified compliance weaknesses.

A B-rated sponsor is generally restricted from assigning new Certificates of Sponsorship, subject to limited exceptions under the sponsor guidance, and may be required to comply with a Home Office action plan.

A B-rating should therefore be treated as a significant compliance issue rather than routine licence administration.

Detailed guidance is available within our Sponsor Licence Downgrading resources.

 

20. Can UKVI inspect an employer after the sponsor licence has been granted?

 

Yes. UKVI can undertake compliance activity during the life of a sponsor licence.

Employers may be required to demonstrate how they manage sponsored workers, use the Sponsor Management System, maintain records and comply with their sponsor duties.

Sponsors should therefore maintain their systems on an ongoing basis rather than preparing for compliance only when Home Office scrutiny is expected.

 

21. What happens if we discover a sponsor licence mistake?

 

The organisation should first establish the facts and identify the sponsorship requirement affected.

It should then determine what corrective, reporting or other action may be required and retain an appropriate record of its assessment and response.

The underlying cause should also be addressed.

Where the issue may amount to a significant compliance failure, affect sponsored workers or involve a historic pattern of errors, specialist advice may be appropriate.

 

22. What can happen if a sponsor fails to manage its licence properly?

 

The consequences depend on the nature and seriousness of the failure.

Where UKVI identifies sponsor compliance concerns, action can include increased scrutiny, a compliance visit, downgrading, an action plan, suspension or revocation of the licence depending on the circumstances and applicable Home Office policy.

Problems that have reached this stage fall within Sponsor Licence Problems & Enforcement, rather than routine licence management.

 

 

Conclusion

 

Managing a sponsor licence is an ongoing business responsibility.

Obtaining the licence gives an organisation access to the sponsorship system, but effective management requires much more than occasional use of the Sponsor Management System.

Employers need to know who owns the licence, who can use the SMS, how Certificates of Sponsorship are controlled, which workers are sponsored, how relevant changes are identified, what records are maintained and when UKVI action is required.

The strongest management systems connect sponsorship to ordinary business processes.

Recruitment identifies sponsorship requirements. HR identifies employment changes. Payroll identifies remuneration changes. Managers escalate changes affecting sponsored workers. Corporate teams identify organisational developments. The sponsor team assesses the immigration consequences and takes the required action.

This creates a continuous management cycle:

OWN → CONTROL → MONITOR → REPORT → RECORD → REVIEW

For employers that rely on international recruitment, maintaining this framework protects more than an administrative licence. It supports continued access to sponsored workers and helps the organisation remain prepared for Home Office scrutiny.

Where the issue moves beyond routine administration into whether the organisation is meeting its Home Office obligations, employers should refer to our Sponsor Compliance guidance.

Where UKVI has identified concerns or is taking action against the licence, see our guidance on Sponsor Licence Problems & Enforcement.

 

Glossary

 

Term	Meaning
Authorising Officer	The senior person with responsibility for the sponsor licence and oversight of the organisation's sponsorship activities and SMS users.
Certificate of Sponsorship (CoS)	An electronic sponsorship record assigned by a licensed sponsor to an individual worker. The worker uses the CoS reference when making the relevant immigration application.
Defined Certificate of Sponsorship	A type of CoS required for Skilled Worker applicants applying for entry clearance from outside the UK.
Home Office	The UK government department responsible for immigration policy and administration, including the sponsorship system.
Key Contact	The person nominated to act as the principal point of contact between the sponsor and UKVI.
Key Personnel	The individuals appointed to specified roles connected with the sponsor licence, including the Authorising Officer, Key Contact and relevant SMS users.
Level 1 User	An authorised SMS user with access to a broad range of sponsor licence management functions, subject to the applicable permissions and Home Office requirements.
Level 2 User	An SMS user with more restricted permissions than a Level 1 User.
Occupation Code (SOC Code)	The occupational classification used within the immigration system to identify the type of work being sponsored and determine relevant route requirements.
Right to Work Check	The prescribed process used by an employer to establish an individual's right to work in the UK and, where applicable, obtain a statutory excuse against liability for illegal working.
Sponsor	An organisation licensed by the Home Office to sponsor eligible workers under specified immigration routes.
Sponsor Compliance	The continuing obligations and standards that licensed sponsors are required to meet under the sponsorship system.
Sponsor Duties	The responsibilities imposed on licensed sponsors, including relevant reporting, record keeping, monitoring and compliance requirements.
Sponsor Licence	Home Office authorisation allowing an eligible organisation to sponsor qualifying workers under the immigration routes covered by its licence.
Sponsor Licence Rating	The rating attached to a sponsor licence. Sponsors are generally granted an A-rating on approval, while compliance action can affect the licence's rating or status.
Sponsor Management System (SMS)	The Home Office online system used by licensed sponsors to administer their sponsor licence and carry out sponsorship functions.
Sponsored Worker	A worker whose immigration permission is based on sponsorship provided by a licensed sponsor under an applicable work route.
Sponsorship Route	An immigration route under which an organisation may be authorised to sponsor eligible workers.
TUPE	The Transfer of Undertakings (Protection of Employment) Regulations, which can apply where employees transfer between employers following certain business transfers or service provision changes. Sponsor licence implications need to be considered separately where sponsored workers are affected.
UKVI	UK Visas and Immigration, part of the Home Office responsible for administering the UK's visa and immigration system.
Undefined Certificate of Sponsorship	A type of CoS used for eligible Skilled Worker applications made from within the UK and for applicants under other sponsored work routes where an Undefined CoS is required, subject to the applicable rules.

 

Useful Links & Resources

 

Resource	Why it is useful
Workers and Temporary Workers: guidance for sponsors – Part 1: Apply for a licence	Home Office guidance on sponsor licence eligibility, application requirements and the framework applying to licensed sponsors.
Workers and Temporary Workers: guidance for sponsors – Part 2: Sponsor a worker	Home Office guidance on sponsoring workers, including Certificates of Sponsorship and route-related sponsorship requirements.
Workers and Temporary Workers: guidance for sponsors – Part 3: Sponsor duties and compliance	The principal Home Office guidance on ongoing sponsor duties, reporting, compliance activity and consequences of non-compliance.
Workers and Temporary Workers: guidance for sponsors – Appendix D: record-keeping duties	Sets out the records and evidence sponsors are required to retain in relation to sponsored workers and sponsorship activity.
Workers and Temporary Workers: guidance for sponsors – Glossary	Provides Home Office definitions of key terms used throughout the sponsorship system.
Sponsor Management System manuals	Home Office manuals explaining how sponsors use the SMS to administer their licence, manage users, update information and carry out sponsorship actions.
GOV.UK: UK visa sponsorship for employers	Government overview of sponsor licences, sponsorship responsibilities and the process for sponsoring workers.
GOV.UK: Check a job applicant's right to work	Official guidance for employers carrying out right to work checks.
DavidsonMorris: Sponsor Licence Guide	The master guide to the UK sponsor licence system for employers.
DavidsonMorris: Sponsor Management System Guide	Detailed guidance on using the SMS and managing access and sponsorship activity.
DavidsonMorris: Sponsor Licence Key Personnel	Guidance on the personnel responsible for the licence and their respective roles.
DavidsonMorris: Certificates of Sponsorship	Detailed guidance on obtaining, assigning and managing Certificates of Sponsorship.
DavidsonMorris: Sponsor Licence Reporting Duties	Guidance on identifying and reporting relevant worker and organisational changes.
DavidsonMorris: Sponsor Licence Record Keeping	Detailed guidance on sponsor document and record-keeping requirements.
DavidsonMorris: Sponsor Compliance	Guidance on the ongoing duties and compliance standards applying to licensed sponsors.
DavidsonMorris: Sponsor Licence Problems & Enforcement	Guidance for employers dealing with sponsor compliance concerns, downgrading, suspension, revocation and other Home Office enforcement action.