Section A: About the UK Sponsor Licence
A sponsor licence is the statutory authorisation that allows a UK-based organisation to employ overseas nationals in roles that require immigration sponsorship. Issued by UKVI, it grants the employer permission to assign Certificates of Sponsorship (CoS) to qualifying workers under specific visa categories. Without a sponsor licence, an employer cannot lawfully employ a non-UK national in most skilled or temporary work routes, regardless of business need or candidate suitability.
The sponsor licensing regime exists to protect the integrity of the UK labour market, ensuring that only compliant and trustworthy employers can sponsor migrant workers. It is designed to support controlled labour migration, giving employers access to international talent while safeguarding the rights and opportunities of resident workers.
For employers, a clear understanding of how the sponsor licence system works, the different types of licence available, and the compliance obligations it imposes is vital before starting an application. Holding a licence is not a one-off administrative formality. It is an ongoing legal and operational commitment that extends beyond recruitment to the day-to-day management, monitoring and reporting of sponsored workers. Misjudging the scope of these duties, or failing to meet them, can result in refusals, enforcement action and disruption to business operations.
1. What is a Sponsor Licence
A sponsor licence is formal permission granted by the Home Office for an organisation to employ non-UK nationals in eligible roles under defined immigration categories. It acts as a formal assurance to UKVI that the business is genuine, operating lawfully in the UK, financially sound, and equipped with the necessary human resources systems to fulfil sponsorship duties.
Sponsorship duties extend beyond initial recruitment. They include monitoring the immigration status and right to work of sponsored workers, maintaining detailed personnel and compliance records, and reporting relevant changes to UKVI within set deadlines.
The underlying purpose of the licence system is twofold. It ensures that economic migration meets the needs of the UK economy, particularly in addressing skills shortages, while preventing unlawful working and exploitation. It also creates a formal vetting process so that only organisations with proven integrity and capability can bring overseas workers into the UK workforce.
2. Sponsor Licences within the Points-Based Immigration System
The UK operates a points-based immigration system, under which visa applicants must meet certain criteria such as having a job offer from an approved sponsor, meeting the skill level requirement for the role, satisfying the English language requirement, and in many cases meeting a minimum salary level.
For most work routes, holding a valid Certificate of Sponsorship from an A-rated sponsor is a mandatory component for the applicant to score enough points to be granted a visa.
The sponsor licence therefore acts as a gateway. Without it, an employer cannot issue a CoS, and without a CoS, a worker cannot submit a qualifying visa application. This creates a direct link between an employer’s compliance and a worker’s immigration status. UKVI can take immediate action if an employer breaches its duties, including suspending or revoking the licence, which will directly impact sponsored workers and can result in curtailment of their visas.
3. Types of Sponsor Licence
UKVI offers two main categories of sponsor licence: Worker and Temporary Worker.
The Worker licence is for long-term employment routes and covers categories including:
- Skilled Worker
- Senior or Specialist Worker visa (Global Business Mobility)
- Minister of Religion
- International Sportsperson
These routes usually require roles to meet specific skill levels and, for most categories, minimum salary thresholds.
The Temporary Worker licence is for short-term or role-specific appointments and includes:
- Scale-up Worker – for people coming to work for a fast-growing UK business
- Creative Worker – to work in the creative industry, for example as an entertainer or artist (up to 2 years)
- Charity Worker – for unpaid workers at a charity (up to 1 year)
- Religious Worker – for those working in a religious order or organisation (2 years)
- Government Authorised Exchange – work experience (1 year), research projects or training, for example practical medical or scientific training (2 years) to enable a short-term exchange of knowledge
- International Agreement – where the worker is coming to do a job which is covered by international law, for example employees of overseas governments
- Graduate Trainee (Global Business Mobility) – for workers transferring to their employer’s UK branch as part of a graduate training programme
- Service Supplier (Global Business Mobility) – for workers with a contract to provide services for a UK company (6 or 12 months)
- UK Expansion Worker (Global Business Mobility) – for workers sent to the UK to set up a new branch or subsidiary of an overseas business
- Secondment Worker (Global Business Mobility) – for workers transferring from overseas to work for a different UK business as part of a high-value contract
- Seasonal Worker – allows people to come to the UK and work in horticulture (for example, picking fruit and vegetables) for up to 6 months, or poultry from 18 October to 31 December each year
These visas are often used for seasonal peaks, project-based work, or specialist assignments where the worker is not expected to remain in the UK long term.
Selecting the correct sponsor licence type is a strategic decision with long-term operational consequences. The chosen category determines which visa routes an organisation can sponsor under, the types of roles it can fill, and the compliance obligations it must maintain. A mismatch between licence type and actual recruitment needs can lead to refusal, reduced utilisation of the licence, or unnecessary administrative and regulatory burdens.
An organisation may apply for one or both categories, depending on its recruitment needs. Applying for multiple routes provides greater recruitment flexibility and may reduce the need for future variation applications.
However, applying for both requires meeting separate eligibility tests and supplying distinct supporting evidence for each category, which can increase the preparation workload and compliance scope.
Sponsoring under the wrong category can result in application refusals and unnecessary delays to the recruitment process.
4. Sponsor Licence Benefits and Responsibilities
Holding a sponsor licence allows an organisation to lawfully recruit from the global labour market. For industries facing acute skills shortages, such as health and social care, engineering, construction, education, and technology, this can be decisive in meeting staffing and growth needs. It also allows employers to access talent with highly specialised skills that may not be available within the domestic workforce.
However, these benefits come with significant responsibilities. Sponsors must:
- Keep accurate and up-to-date records for every sponsored worker in accordance with Appendix D requirements.
- Report changes in a worker’s circumstances, such as changes in role, salary, location, or employment status, within strict deadlines via the Sponsor Management System (SMS).
- Ensure that sponsored roles continue to meet visa conditions throughout the worker’s employment.
Failing to meet these obligations can result in Home Office enforcement action, including licence downgrading, suspension, or revocation. This can force employers to terminate sponsored employment, damage business continuity, and harm organisational reputation. As a result, many employers integrate sponsorship compliance into their wider HR and legal governance frameworks, treating it as a core operational function rather than an administrative afterthought.
DavidsonMorris Strategic Insight
A sponsor licence is considered a privilege by the Home Office, and the employer cannot underestimate the resource commitment demanded, both when you apply for a licence and on an ongoing basis to meet the compliance duties. There is scope for lip service. Through the application process, the Home Office are looking for proof of genuine commitment to the sponsorship regime.
Section B: Sponsor Licence Eligibility Criteria
Before beginning an application, an organisation must establish whether it can meet the strict eligibility and suitability requirements set by UKVI. These requirements are designed to ensure that only compliant, genuine, and operationally capable employers can sponsor overseas workers. Attempting to apply without meeting them is likely to result in refusal, the loss of the application fee, and potentially a cooling-off period before a new application can be made.
The eligibility assessment goes beyond a basic checklist. It requires clear evidence of the organisation’s lawful presence, financial health, operational capability, and readiness to meet ongoing compliance duties. UKVI will scrutinise the organisation’s trading history, the legitimacy of the vacancies it intends to fill, and the suitability of the key personnel named in the application. Where specific sectors have additional regulatory requirements, such as care or education, these must also be satisfied before submission.
1. Business Types and Legal Status Requirements
A sponsor licence can only be granted to an organisation that is lawfully operating in the UK and is capable of meeting its sponsorship duties. Eligible entities include:
- Private limited companies and public limited companies
- Public bodies and government departments
- Partnerships and limited liability partnerships (LLPs)
- Charities and not-for-profit organisations
- Educational institutions
- Sole traders engaged in genuine business activity
The organisation must hold any mandatory registrations for its type. For example:
- Companies must be incorporated and registered at Companies House
- Charities must be registered with the Charity Commission or the relevant regulator for their jurisdiction
- Educational institutions must be recognised and registered with the appropriate UK regulator
UKVI will verify that the organisation is established, actively trading, and capable of offering genuine employment that meets immigration route requirements. Businesses that are dormant, newly incorporated without evidence of operational activity, or lacking a physical presence in the UK will not meet this test.
2. ‘Genuine Organisation’ and ‘Genuine Vacancy’ Tests
UKVI applies two key tests:
a. Genuine Organisation Test – This assesses whether the applicant is a legitimate, lawfully trading business. UKVI will review company accounts, VAT registration, PAYE records, proof of trading premises, and the nature of business operations. Businesses must be able to show they are not solely established for the purpose of sponsoring workers.
b. Genuine Vacancy Test – This ensures the roles being sponsored are real, meet the relevant visa route’s skill and salary thresholds, and are needed for the operation of the business. Jobs created purely to facilitate a visa for a specific person, or roles that do not reflect the organisation’s core activities, will fail this test. Where job descriptions are vague, inconsistent, or do not align with standard occupational classifications, UKVI is likely to refuse the application.
3. Suitability Requirements
Applicants must demonstrate a clean compliance history with immigration law, employment law, and other UK regulatory obligations. This means no history of:
- Employing illegal workers
- Breaching the National Minimum Wage or Working Time Regulations
- Failing to pay taxes or national insurance contributions
- Ignoring licensing or regulatory requirements relevant to the sector
UKVI will also conduct suitability checks on key personnel, including the Authorising Officer, Key Contact and Level 1 Users. These individuals must not have unspent convictions for relevant offences such as immigration breaches, fraud, dishonesty, money laundering, or other serious crimes. They must not have been previously involved in a sponsor licence that was revoked for compliance failings.
Financial solvency is also assessed. The organisation must not have outstanding debts to the Home Office or other UK government departments unless formal repayment arrangements are in place and being adhered to. Insolvent companies or those subject to winding-up proceedings will not be eligible.
4. Specific Rules for Certain Sectors
Some industries are subject to additional, route-specific eligibility criteria:
- Health and Social Care – Care providers applying to sponsor care workers or senior care workers must be registered with the Care Quality Commission (CQC) in England, or the relevant regulatory body in Scotland, Wales, or Northern Ireland. Applications from unregistered care providers will be refused, regardless of other compliance readiness.
- Education – Schools, colleges, and universities must hold the correct registration with the Department for Education or equivalent authority, and meet any quality assurance standards set by the relevant education regulator.
- Sports – Organisations sponsoring international sportspersons must be endorsed by the relevant sports governing body approved by UKVI.
Where such sector-specific requirements apply, they are mandatory and non-negotiable, and can result in automatic application refusal.
5. Consequences of Applying When Ineligible
Submitting an application without meeting the eligibility criteria wastes the application fee and may trigger a Home Office-imposed cooling-off period, often up to 12 months, before a new application can be lodged. It may also cause reputational damage and prompt increased scrutiny in any future application.
Employers should carry out a thorough pre-application audit against the full UKVI requirements. Where gaps exist—such as missing registrations, insufficient trading history, or inadequate HR systems—these should be addressed before submission. Engaging in remedial preparation not only improves the likelihood of success but can also reduce the risk of prolonged compliance monitoring once the licence is granted.
DavidsonMorris Strategic Insight
Don’t apply before you’re ready. The application form is the easy part, and once that is submitted, you only have five working days to send in the supporting documents. Once the application is with the Home Office, you can be inspected at any time.
Prepare your internal HR operations for auditing and collate the documents before completing the form. In reality, depending on your current situation, the pre-application preparation phase can sometimes take up to 3 months.
Section C: Required Documents
Every sponsor licence application must be supported by specific evidence showing that the organisation is eligible and suitable to hold a licence. These evidential requirements are set out in Appendix A of the Sponsor Guidance, which specifies both the number and type of documents required.
The Home Office applies these requirements strictly. Failing to submit the correct combination of documents, in the correct format, is a frequent cause of refusal.
The required documents vary depending on the organisation’s size, structure, and sector. UKVI uses them to confirm that the organisation is lawfully operating in the UK, has robust systems to manage sponsorship, and meets any route-specific or sector-specific criteria. While most applicants must submit at least four specified documents, the exact requirements depend on the organisation’s profile and the visa routes applied for. A thorough review of Appendix A before applying is therefore essential to avoid errors and omissions.
1. Appendix A Sponsor Licence Documents
Appendix A sets out the evidential framework for all sponsor licence applications. Documents submitted must:
- Demonstrate that the organisation is a genuine and legally established entity operating in the UK
- Show that the organisation is financially stable and compliant with UK laws and regulations
- Confirm that the organisation is registered with any required statutory or regulatory bodies
- Provide evidence that the organisation has the capability and systems to comply with sponsorship duties
Appendix A is structured into tables, with each table applying to a specific type of organisation. Selecting documents from the wrong table, or failing to meet the table-specific requirements, will result in refusal.
Organisation Type | Minimum Evidence Required | Examples of Acceptable Documents |
---|---|---|
Established Company | At least four documents from the relevant Appendix A table. | Certificate of Incorporation from Companies House; VAT registration certificate; employer’s liability insurance (min £5m cover); recent business bank statements; latest audited accounts signed by a registered auditor. |
Charity / Not-for-Profit | At least four documents, including proof of charitable status. | Charity Commission registration; governing document/constitution; business bank statements; proof of operating premises. |
Public Body | At least four documents confirming statutory status and operations. | Proof of statutory status; official funding allocation letters; organisational structure chart; evidence of business bank account. |
Start-up / Trading Less Than 18 Months | At least four documents from the start-up list in Appendix A. | Evidence of business premises (lease or title deeds); HMRC registration for PAYE; business bank statements; VAT certificate if registered. |
Sector-Specific Requirements | Mandatory documents in addition to core evidence. | CQC registration for health and social care; endorsement from approved governing body for sport; registration with education regulator for schools/colleges/universities. |
General Rules | All documents must be clear, legible, and match application details exactly. | Discrepancies in names, addresses, or registration details can cause refusal; submit within five working days of application. |
2. Organisation Type
In most cases, at least four documents from the relevant Appendix A table must be submitted, although UKVI can request additional evidence if they consider it necessary. The selection must align with the organisation’s legal form and trading status.
Examples:
- Companies – Certificate of Incorporation from Companies House, VAT registration certificate, employer’s liability insurance certificate, recent business bank statements, latest audited accounts signed by a registered auditor
- Charities – Charity Commission registration, governing document or constitution, business bank statements, proof of operating premises
- Public bodies – Evidence of statutory status, official funding allocation letters, organisational structure chart
- Start-ups (trading under 18 months) – Evidence of business premises, HMRC registration for PAYE, business bank statements, VAT certificate if registered
Submitting fewer than the minimum required documents, or including documents not listed in Appendix A, will lead to automatic refusal.
3. Examples of Acceptable Evidence
Acceptable evidence includes, but is not limited to:
- Recent business bank statements issued within the last three months
- Certificate of VAT registration issued by HMRC
- Employer’s liability insurance certificate with a minimum £5 million cover from an approved insurer
- Current signed lease agreement or title deeds for business premises
- Audited accounts signed by a registered auditor
- HMRC registration confirmation for PAYE and Corporation Tax
All evidence must be clear, legible, and, where relevant, on official letterhead or containing verifiable company details such as company registration number and trading address.
4. Common Mistakes with Document Preparation and Submission
Frequent mistakes include submitting documents from the wrong Appendix A table for the organisation type, providing outdated or incomplete documents, such as expired insurance certificates, failing to ensure that names, addresses, and registration details match exactly across all documents and the application form, and omitting mandatory evidence for specific sectors, such as CQC registration for care providers.
UKVI imposes a strict five working day deadline from the date the online application is submitted to receive the supporting documents. Missing this deadline will result in the application being automatically rejected without a refund.
5. When and How the Home Office May Verify Documents
UKVI can and often will carry out verification checks. These may include:
- Contacting banks, insurers, or regulatory bodies to confirm the authenticity of submitted documents
- Using third-party data sources to validate registration and trading information
- Conducting a compliance visit to inspect HR, recruitment, and record-keeping systems before granting a licence
If UKVI cannot verify the documents, or finds discrepancies that call into question the organisation’s legitimacy or compliance readiness, the application is likely to be refused. In some cases, such findings can also lead to further investigations into the organisation’s right to work processes or employment practices.
DavidsonMorris Strategic Insight
The supporting documents are one of more complicated aspects of the licence application. The burden is on the employer to decipher the guidance under Appendix A, and to submit the required documents that apply to their organisation. Get this wrong and the application can be delayed as more information is requested or the application is rejected or refused. It is also usually advisable to submit additional documents, in anticipation of potential queries and to fully support your eligibility.
Section D: Key Personnel Roles
When applying for a sponsor licence, an organisation must nominate individuals to specific key personnel roles. These roles are integral to the governance, operation, and compliance management of the licence. UKVI assigns legal and operational accountability for the licence’s use to these individuals, making their selection a critical decision for any sponsor.
The appointment of key personnel is not an administrative formality. Each role has defined legal and operational responsibilities, and the individuals appointed must meet strict suitability standards. The same person may hold more than one role, provided they meet the requirements for each, but over-reliance on a single person increases compliance and operational risk. Sponsors should select personnel with sufficient seniority, authority, and commitment to manage the sponsor licence consistently over its full validity period.
1. Authorising Officer – Senior Responsibility
The Authorising Officer (AO) is the most senior person responsible for the sponsor licence. They hold ultimate accountability for the organisation’s compliance with its sponsorship duties and for the conduct of all staff using the Sponsor Management System (SMS).
Although the AO does not need to manage the SMS day-to-day, they must ensure robust systems are in place for licence management and compliance monitoring. UKVI expects the AO to have genuine decision-making authority, including the ability to allocate budget and resources to meet sponsorship obligations.
Any compliance failings linked to the licence — including reporting failures, record-keeping breaches, or misuse of Certificates of Sponsorship — will be attributed to the AO. If UKVI finds serious non-compliance, the AO’s suitability to act in the role may be questioned in future applications, even for other organisations.
2. Key Contact – Main Home Office Liaison
The Key Contact acts as the primary point of communication between the sponsor and UKVI. They are responsible for managing all correspondence, including formal notices, audit notifications, compliance queries, and updates relating to the sponsor licence.
While the role can be combined with that of the Authorising Officer, many organisations appoint a separate Key Contact to ensure prompt and dedicated responses to UKVI. Timely responses are crucial because Home Office correspondence often carries strict deadlines, and delays or missed responses can trigger compliance concerns or escalate into enforcement action.
3. Level 1 and Level 2 Users – SMS Access and Duties
Level 1 Users have full operational access to the SMS. They can assign Certificates of Sponsorship, report changes in worker circumstances, update sponsor details, and manage other key licence functions. At least one Level 1 User must be an employee, office holder, or partner of the sponsoring organisation. Additional Level 1 Users may be appointed, including third-party representatives, provided they are approved by UKVI.
Level 2 Users have restricted SMS access. They can usually assign Certificates of Sponsorship and update certain worker records but cannot make broader changes to the sponsor’s details or manage other users. This role is often used for delegating administrative tasks while keeping tighter control over strategic licence functions.
Both Level 1 and Level 2 Users must understand the significance of accurate and timely reporting. Errors or omissions on the SMS can amount to compliance breaches and lead to enforcement action.
4. Eligibility Checks for Key Personnel
All key personnel must:
- Be based in the UK for most of the time
- Have no unspent criminal convictions for immigration offences, fraud, dishonesty, money laundering, or other serious crimes
- Not be subject to a bankruptcy restriction order or company director disqualification
- Not have been involved in a sponsor licence that was revoked due to compliance failings while they held a key personnel role
UKVI conducts background checks on all nominated personnel. If any individual fails these checks or is deemed unsuitable, the entire application can be refused. The same suitability tests apply when replacing key personnel during the licence period.
5. Strategic Considerations When Selecting Key Personnel
Key personnel appointments should be made with long-term operational continuity in mind. A sponsor licence typically lasts four years, and changes in personnel can cause compliance gaps if not managed proactively.
Best practice includes:
- Appointing more than one Level 1 User to ensure operational resilience if one user leaves or is absent
- Scheduling periodic reviews to confirm that all key personnel details in the SMS are accurate and up to date
- Ensuring that all personnel understand their duties and are supported with adequate training in sponsorship compliance
If you fail to maintain suitable and active key personnel, this can constitute a breach of the licence duties and grounds for enforcement action.
DavidsonMorris Strategic Insight
Another area of high risk with in the licence application is the key personnel. Not everyone can act as a key personnel. You have to fill these appointments with suitable individuals. Your nominated individual(s) will be subject to background checks so internal vetting is advisable to identify and avoid potential issues before you formally nominate them.
Section E: How to Apply for a Sponsor Licence
The sponsor licence application process is conducted online through the Home Office’s Sponsor Management System (SMS) and must be supported by documentary evidence meeting the requirements of Appendix A of the Sponsor Guidance. It is not simply an administrative form-filling exercise. A successful application requires advance preparation, accurate and consistent data entry, and an understanding of sponsorship compliance obligations before the licence is granted.
An incomplete, inaccurate, or unsupported application can lead to refusal, forfeiture of the application fee, and a potential cooling-off period before reapplying. This can delay recruitment plans and, in some sectors, jeopardise contractual or operational commitments.
The steps below outline the correct procedure for preparing and submitting a sponsor licence application in accordance with UKVI requirements.
Stage / Priority | What is Required |
---|---|
1. Eligibility assessment | Confirm the organisation meets UKVI’s eligibility and suitability criteria, including lawful operation in the UK, compliance history, and key personnel suitability. |
2. Select correct licence type | Determine whether to apply for a Worker, Temporary Worker, or both categories, based on recruitment needs and visa routes required. |
3. Appoint key personnel | Nominate an Authorising Officer, Key Contact, and at least one Level 1 User, ensuring each meets UKVI’s suitability requirements. |
4. Prepare supporting documents | Identify the correct Appendix A table for your organisation type, gather at least four required documents, and ensure they match application details exactly. |
5. Complete online application form | Accurately enter organisation details, visa routes requested, key personnel information, and HR systems description on the Sponsor Management System. |
6. Submit supporting evidence | Send required Appendix A documents to UKVI within five working days of submitting the online form, via secure upload or post. |
7. Pay correct application fee | Confirm size classification (small/charitable or medium/large) and pay the appropriate non-refundable fee. |
8. Prepare for UKVI checks | Be ready for additional information requests or a pre-licence compliance visit to assess HR systems, record-keeping, and vacancy genuineness. |
9. Post-decision readiness | If granted, set up SMS access for authorised users, train staff, and ensure compliance systems are operational from day one. |
1. Sponsor licence online application form
The process begins with the online application form, which is relatively straightforward. The nominated Authorising Officer or Level 1 User will initiate the application on behalf of the organisation, entering information such as:
- Organisation name and trading address
- Companies House or charity registration numbers
- Details of key personnel
- Sector or industry classification
Every detail has to exactly match the supporting documents. Even minor discrepancies, such as a difference between a trading name and the name on a bank statement, can trigger additional checks and requests for clarification, so should be double-checked before submitting.
2. Supporting Documents
Once the online application is submitted, the organisation has five working days to submit its required supporting documents. The documents to be submitted have to comply with the requirements under Appendix A.
Given th
Documents may be uploaded electronically via the secure UKVI submission link or, if necessary, sent by post. Electronic submission is strongly recommended as it reduces handling time and allows for immediate confirmation of receipt. All documents must:
- Be clear and legible
- Be in the correct format
- Display the organisation’s correct legal name and other identifying details
Failure to provide the required evidence within the five working days will result in automatic refusal.
3. Sponsor Licence Application Fees
Applying for and maintaining a sponsor licence carries both upfront and ongoing financial commitments. These include government fees, recurring charges for ongoing sponsorship activity, and potential professional support costs. The total cost depends on the organisation’s size, the licence type, the number of workers sponsored, and the visa routes used. Budgeting for these costs from the outset is important to avoid cashflow pressures and to ensure that the organisation can sustain sponsorship long-term.
a. Application processing fee
The Home Office charges a non-refundable application fee when a sponsor licence application is submitted. The fee depends on whether the sponsor qualifies as a small or charitable sponsor or as a medium or large sponsor under UKVI’s definitions.
- Small or charitable sponsors – reduced fee of £579
- Medium or large sponsors – higher fee of £1,576
To qualify as a small sponsor, an organisation typically needs to satisfy at least two of these conditions: an annual turnover of no more than £15 million, total assets valued at £7.5 million or less, or a workforce of 50 or fewer employees. For charitable sponsor status, the organisation must be a registered charity in England or Wales, Scotland, or Northern Ireland, with unregistered Northern Irish charities providing evidence of their charitable tax status from HMRC. Other qualifying charitable entities include excepted charities, exempt charities, and ecclesiastical corporations set up for charitable objectives.
Incorrect fee payment can delay processing or, if not corrected, invalidate the application entirely. Sponsors should confirm their classification before submission to avoid this risk.
The fee is payable per application and is not refunded if the application is refused or withdrawn.
b. Certificate of Sponsorship (CoS) Fees
For each sponsored worker, the sponsor must assign a CoS via the SMS and pay the relevant CoS fee. The amount depends on the visa route. Some Temporary Worker categories are exempt from this fee.
The CoS fee is separate from the Immigration Skills Charge and is payable when the CoS is assigned. Errors in assignment can lead to wasted fees and compliance issues.
c. Immigration Skills Charge (ISC)
The ISC applies to most Worker route sponsorships, including Skilled Worker visas. It is payable when the CoS is assigned and is calculated based on the size of the organisation (large sponsors pay a higher rate) and the length of the sponsorship period.
Exemptions apply for certain roles, such as PhD-level occupations or specified shortage occupations. For large sponsors, the ISC can represent a significant cost when sponsoring multiple workers over several years.
d. Legal or Compliance Support
Many sponsors engage external legal or compliance advisers to prepare and submit the initial application, conduct pre-application compliance audits, manage SMS usage and reporting and train HR teams on sponsor duties. These costs vary depending on the scope of work, as well as the complexity of the application and the organisation’s compliance history.
4. Sponsor Licence Application Processing Times
The standard UKVI processing time for a sponsor licence application is approximately eight weeks. However, the Home Office may take longer if additional verification checks are required, or a pre-licence compliance visit is arranged, or where there are discrepancies in the information provided
An optional priority service is available for an additional fee, which can reduce the decision time to around 10 working days, though slots are limited and allocated on a first-come, first-served basis.
During processing, UKVI may request additional information or clarification. Any such requests will carry strict deadlines, often as short as five working days. Failing to respond in full and on time can result in refusal. Sponsors should therefore ensure that the nominated Key Contact and Level 1 User monitor communications daily throughout the process.
Risk | Description | Potential Consequence | How to Mitigate |
---|---|---|---|
Incorrect or incomplete documents | Submitting the wrong combination of documents under Appendix A or missing required information. | Automatic rejection or refusal, loss of application fee, delays to recruitment. | Identify the correct Appendix A table for your organisation, prepare evidence in advance, and cross-check all details. |
Procedural errors | Mistakes in the online form or failure to submit documents within the 5-working-day deadline. | Application rejection and need to restart the process from scratch. | Double-check form entries against evidence, and prepare all documents before submitting the application. |
Minor compliance concerns | Issues such as vague job descriptions or unclear HR processes identified by UKVI. | Requests for further information causing delays, or outright refusal. | Conduct a pre-application compliance audit to resolve weaknesses before applying. |
Unsuitable key personnel | Authorising Officer, Key Contact, or Level 1 User fails UKVI suitability checks. | Refusal of the application and possible cooling-off period. | Vet all key personnel for eligibility, compliance history, and criminal record before naming them in the application. |
Poor pre-licence visit performance | HR systems and processes do not meet UKVI standards during an inspection. | Refusal of the application despite acceptable documents. | Ensure systems work in practice, train staff, and prepare for possible unannounced visits. |
Refusal and cooling-off period | Application is refused due to eligibility or compliance failings. | Loss of fee and up to 12 months before reapplying. | Address all refusal reasons in full, improve systems, and reapply only when fully compliant. |
DavidsonMorris Strategic Insight
The application process itself is relatively straightforward, but be aware that small issues can cause delays or even rejections. A typo on the application form, paying the wrong application fee or submitting the supporting documents past the deadline could mean your application is rejected and you would have to start again.
Section F: Home Office Assessment Process
Once a sponsor licence application is submitted with the required supporting documents, UK Visas and Immigration assesses whether the organisation meets the eligibility and suitability requirements in the Sponsor Guidance. Assessment is not limited to paperwork. UKVI considers the organisation’s trading history and governance, the capacity of its HR systems to meet sponsor duties, the suitability of key personnel, and the credibility of the roles for which sponsorship is sought. Where risk indicators are present, UKVI may seek third‑party verification or arrange a pre‑licence compliance visit before making a decision. Outcomes can include grant, refusal, or grant with conditions in the form of a rating downgrade and an action plan.
1. Possible Pre‑Licence Compliance Visits
UKVI may conduct a visit before deciding the application. Visits may be announced or unannounced. The purpose is to test whether the organisation can meet sponsor duties in practice rather than in theory. Compliance officers typically review right to work processes, including how initial checks, repeat checks, and follow‑up checks are recorded. They sample HR files against Appendix D record‑keeping requirements, check how attendance and absences are monitored, and look at how changes to role, salary, or work location would be captured and reported on the Sponsor Management System.
Officers assess the genuineness of the vacancy by reviewing job descriptions, SOC code selection, salary against the applicable threshold and going rate, and where relevant any client contracts if the worker will perform duties at a third‑party site. They will ask the Authorising Officer and Level 1 Users to explain how SMS tasks are controlled, how deadlines are met, and how governance operates during staff absence or turnover. A poor visit outcome can lead to refusal even if the document bundle is in order.
2. Factors the Home Office Considers
Caseworkers assess a range of factors that go to eligibility and suitability. They check that the organisation is genuine and lawfully operating, with an active UK trading presence and appropriate registrations for its sector. They review the suitability of key personnel, including residence in the UK for most of the time and the absence of unspent convictions for relevant offences. They look at immigration and employment compliance history, including any civil penalties for illegal working, past licence sanctions, unpaid tax or National Insurance, and outstanding debts to government departments where no repayment plan exists.
Role credibility is assessed against the route rules. Caseworkers test whether the role meets the skill level for the chosen SOC code, whether salary meets the applicable threshold and going rate, and whether duties align with the organisation’s business model. They also review the adequacy of HR systems to meet reporting deadlines, maintain required records, and cooperate with compliance activity. Where information is unclear or inconsistent, UKVI may issue a request for further information with short response deadlines.
3. Risk Assessment by Sector and Job Role
UKVI applies a risk‑based approach. Sectors with high turnover, dispersed worksites, or a history of sponsor non‑compliance can attract closer scrutiny. Care providers face checks on regulator registration and capacity to supervise staff across multiple locations. Hospitality and seasonal agriculture may be queried on scheduling, supervision, and pay practices. Project‑based IT and consultancy models that deploy workers on client sites are often asked for client contracts, statements of work, and evidence of day‑to‑day control by the sponsor rather than the client.
Job roles linked historically to non‑compliance or exploitation, and roles that attract high application volumes, are more likely to be examined to confirm that vacancies are genuine and that salaries and duties meet route rules. Where third‑party confirmation is relevant, UKVI may contact banks, insurers, regulators, or governing bodies to verify claims.
4. How Refusal Decisions Are Made
If UKVI is not satisfied that eligibility or suitability is met, or if evidence cannot be verified, the application will be refused. Typical grounds include failing the genuine organisation or genuine vacancy tests, unsuitable key personnel, weak HR systems identified during a visit, inconsistent or incomplete evidence, previous breaches of immigration or employment law, or significant outstanding debts to government. Refusal decisions are issued in writing, set out the reasons, and confirm any cooling‑off period before reapplication. There is no normal right of appeal or administrative review. The practical options are to remedy the issues and reapply after any cooling‑off period or to consider public law challenge where the decision is arguably unlawful, procedurally unfair, or irrational.
A refusal is recorded and may lead to greater scrutiny in any later application. Organisations intending to reapply should address every refusal reason with updated evidence and, where relevant, improved governance, systems, and personnel arrangements to demonstrate compliance capability from day one.
5. Licence Application Outcome
Once UKVI has completed its assessment, the organisation will receive a formal written decision. This outcome determines whether the business can proceed with sponsoring overseas workers and, if so, under what conditions. Understanding each possible outcome, including the operational and compliance implications, allows employers to act quickly and plan effectively for next steps.
A grant of a sponsor licence permits the organisation to begin sponsoring under the approved routes. A refusal ends the process, may impose a period during which reapplication is barred, and is recorded on UKVI’s internal systems for reference in future applications. There is no statutory right of appeal against a decision, though in limited cases a judicial review challenge may be possible where the decision is alleged to be unlawful or procedurally unfair.
a. Sponsor licence granted
If approved, the sponsor licence will be issued with an A-rating, confirming that the organisation meets all eligibility and suitability standards and is authorised to assign CoS for the approved visa routes.
The licence is valid for four years from the date of grant. It can be renewed before expiry if the organisation wishes to continue sponsoring. To maintain the A-rating throughout the licence period, the sponsor must meet all duties, including reporting changes within required timeframes, keeping full Appendix D records, and ensuring that sponsored roles continue to meet route requirements.
If compliance concerns arise after grant, UKVI can downgrade the licence to a B-rating, requiring the sponsor to follow an action plan at additional cost. If the action plan is not completed within the set timeframe, further enforcement could follow, such as licence suspension or revocation.
Once a licence is granted, the organisation should:
- Access the Sponsor Management System (SMS) immediately to review account settings and user permissions
- Allocate CoS in line with recruitment needs, ensuring each meets the relevant visa route requirements
- Train all Level 1 and Level 2 Users on correct SMS use and sponsor compliance duties
- Ensure all reporting and record-keeping systems are fully operational from day one
- Inform HR, recruitment, and operational teams of their responsibilities under the sponsor licence
Early operational readiness is essential, as UKVI may carry out a post-licence compliance visit within months of grant. Demonstrating strong systems from the outset reduces the risk of enforcement action and supports retention of an A-rating over the long term.
b. Sponsor licence refused
If the licence is refused, UKVI will set out the refusal reasons in writing. Common grounds include:
- Failure to provide the correct or sufficient Appendix A documents within the deadline
- Inconsistencies between the application and supporting evidence
- Failing the genuine organisation or genuine vacancy test
- Appointment of unsuitable key personnel
- Weak or non-compliant HR and monitoring systems identified during a pre-licence visit
- Evidence of past breaches of immigration or employment law
In most cases, a refusal triggers a cooling-off period before reapplication is imposed. If the refusal was due to minor evidential gaps, the cooling-off period may be shorter, but UKVI’s decision on timing is final.
A cooling-off period prevents repeated applications without addressing the reasons for refusal. During this period, no new sponsor licence applications can be submitted, even for a different category. Submitting an application in breach of the cooling-off restriction will result in automatic rejection and loss of the application fee.
To improve prospects of success after the cooling-off period, employers should:
- Rectify all issues identified by UKVI in the refusal notice
- Upgrade or replace HR systems to ensure full compliance capability
- Review the suitability of all nominated key personnel against UKVI’s criteria
- Conduct an internal audit or seek an external compliance review before reapplying
DavidsonMorris Strategic Insight
The Home Office will look beyond the paperwork. They will forensically examine your compliance operations, often requiring real time demonstrations of your systems and processes. A pre-application mock audit can simulate the investigation stage, and help identify weaknesses before the Home Office comes in.
Section G: Sponsor Licence Duties
Holding a sponsor licence imposes continuing legal and operational duties for the full validity of the licence, not just during recruitment. UKVI enforces these duties to prevent system abuse, protect sponsored workers from exploitation, and ensure that only genuine, compliant organisations can maintain sponsorship rights. These duties apply from the day the licence is granted and remain in force until the licence is surrendered, revoked, or expires.
Failing to meet these can result in enforcement action, including downgrading to a B-rating, suspension, or full revocation. Any such sanction can lead to the loss of all current sponsored workers through visa curtailment, immediate operational disruption, reputational harm, and in some cases long-term restrictions on reapplying.
Stage | Main Actions | Compliance Focus | Risks if Neglected |
---|---|---|---|
Pre-application | Assess eligibility, select correct licence type, prepare Appendix A documents, appoint key personnel, and conduct a compliance audit. | Eligibility criteria, correct document selection, key personnel suitability, robust HR systems. | Refusal of application, loss of fee, cooling-off period before reapplying. |
Application submission | Complete SMS online form accurately, submit supporting evidence within 5 working days, pay correct fee. | Accuracy of form entries, matching documentation, meeting submission deadlines. | Automatic rejection, delays, loss of application fee. |
Home Office assessment | Respond promptly to requests for additional information, prepare for potential pre-licence compliance visit. | Demonstrating genuine vacancies, operational HR compliance, system readiness. | Refusal despite correct documentation; prolonged decision times. |
Licence granted | Assign CoS for approved visa routes, set up SMS access for authorised users, train staff on sponsor duties. | Accurate CoS assignment, role compliance with visa rules, trained SMS users. | Compliance breaches, Home Office downgrades, loss of ability to assign CoS. |
Ongoing compliance | Maintain Appendix D records, report changes via SMS within deadlines, monitor sponsored workers’ visa conditions. | Timely reporting, accurate record-keeping, continuous compliance monitoring. | Licence suspension or revocation, curtailment of workers’ visas. |
Renewal | Apply before expiry, pay renewal fee, provide any requested compliance evidence. | Demonstrating ongoing compliance throughout the licence term. | Loss of sponsorship ability, disruption to workforce planning. |
1. Reporting and Record-Keeping
Sponsors must comply with the record-keeping rules in Appendix D of the Sponsor Guidance. These rules specify the exact documents and information that must be retained for each sponsored worker, including:
- A copy of the worker’s passport and current visa or immigration status document
- Evidence of right to work checks carried out before employment commenced and at required follow-up intervals
- The worker’s current and historic contact details (address, phone, email)
- Records of absences, annual leave, sickness, unpaid leave, and unauthorised absence
- Evidence of any change in job title, duties, salary, or work location
These records must be retained for at least one year after sponsorship ends or until the next compliance audit is complete, whichever is later.
In addition, sponsors must report specific changes to UKVI via the Sponsor Management System (SMS) within strict deadlines — often 10 working days — including:
- Termination of employment or non-attendance
- Significant job changes affecting title, duties, SOC code, salary, or location
- Changes to the organisation’s structure, ownership, key personnel, or contact details
Failing to make required reports within the deadline is a breach of sponsor duties.
2. Using the SMS for Certificate of Sponsorship Assignments
The Sponsor Management System is the secure platform for managing both the sponsor licence and the sponsored workforce. It must be used to:
- Assign CoS to eligible workers
- Report relevant changes in the worker’s circumstances
- Apply for additional CoS allocations where demand exceeds the current allowance
- Update organisational details and personnel appointments
Only approved Level 1 and Level 2 Users may access the SMS, and their actions are traceable in audit logs. All users must receive training on correct use, as inaccuracies — for example, incorrect SOC codes or salary figures — can cause compliance breaches, visa refusals, and potential sanctions against the sponsor.
3. Monitoring Sponsored Workers’ Immigration Status and Attendance
Sponsors must have proactive systems for monitoring immigration status and work eligibility, including:
- Regularly verifying that the worker’s visa remains valid and meets the route requirements
- Confirming that the worker continues to perform the role stated in their CoS
- Monitoring attendance and identifying patterns of absence that could indicate non-compliance with visa conditions
If a breach is identified — for example, a worker overstaying their visa or working in an unauthorised role — the sponsor must take immediate action and report it to UKVI within the required deadline.
4. Avoiding Breaches and Risk of Suspension or Revocation
UKVI can downgrade, suspend, or revoke a licence where it finds non-compliance. Frequent causes include:
- Missed reporting deadlines
- Assigning CoS for roles that do not meet route requirements
- Employing a worker outside the terms of their visa
- Providing false, incomplete, or misleading information to UKVI
- Revocation is the most severe sanction, leading to curtailment of all sponsored workers’ visas. Sponsors should schedule regular internal compliance audits to identify and address weaknesses before they become enforcement issues.
5. Preparing for Compliance Audits
UKVI can audit a sponsor at any time, with or without prior notice. Audits may be conducted on-site or remotely and will review:
- Worker records and HR systems
- Evidence of right to work checks and compliance with Appendix D
- SMS usage and accuracy of data entries
- Processes for identifying and reporting changes
- Organisations that maintain continuous readiness through periodic internal reviews, thorough documentation, and trained staff will be in a far stronger position to pass an audit without disruption or sanction.
DavidsonMorris Strategic Insight
Sponsorship has to be embedded across the full employment lifecycle for sponsored workers. It’s not just relevant during the recruitment stage. As a sponsor, you will have ongoing responsibilities to monitor absences, report certain changes within strict timeframes and your record keeping has to be on point. The Home Office is proactive in investigating compliance and takes enforcement action for breaches. Ignorance of the rules and human error are not acceptable as excuses.
Section H: Summary
Securing a UK sponsor licence is a multi-stage process that demands preparation, accurate evidence, and an understanding of ongoing compliance obligations. From the initial eligibility checks and document preparation under Appendix A, through the online application and potential pre-licence compliance visit, each stage is an opportunity for UKVI to assess whether the organisation is both capable and committed to meeting sponsor duties.
Approval brings significant benefits, granting access to the global talent pool and enabling recruitment under the approved visa routes. However, the grant of a licence marks the beginning of a continuous compliance obligation. Sponsors must meet reporting and record-keeping duties, use the Sponsor Management System accurately, and ensure all sponsored roles meet immigration route requirements throughout employment.
Refusals can lead to cooling-off periods and heightened scrutiny on future applications. Proactive measures — such as regular internal audits, strong HR systems, trained key personnel, and budgeting for the full costs of sponsorship — are essential to protect the licence and reduce the risk of enforcement action.
A well-managed sponsor licence is both a strategic recruitment asset and a legal responsibility. Treating it as a core element of organisational governance, rather than an administrative formality, gives employers the best chance of sustaining their sponsorship capability for the long term.
Section I: FAQs
Can any business apply for a sponsor licence?
No. Only organisations that are lawfully operating in the UK and can meet UKVI’s eligibility and suitability requirements may apply. This includes having appropriate registrations, compliant HR systems, and suitable key personnel.
How long does a sponsor licence last?
A sponsor licence is valid for four years from the date of grant. It must be renewed before expiry to continue sponsoring workers. Renewal requires payment of a further application fee and proof of continued compliance.
How long does the application process take?
The standard processing time is around eight weeks from submission of the application and supporting documents. A priority service is available for an additional fee, which can reduce this to around 10 working days, though availability is limited.
What happens if my application is refused?
UKVI will issue a written refusal notice explaining the reasons. In most cases, there is no right of appeal. A cooling-off period of up to 12 months may apply before reapplying, during which time the issues raised must be addressed.
What are my main duties after the licence is granted?
Sponsors must comply with reporting and record-keeping duties under Appendix D, ensure all Certificates of Sponsorship are assigned accurately, monitor sponsored workers’ immigration status and role, and cooperate with UKVI compliance activity.
Can I lose my sponsor licence after it is granted?
Yes. UKVI can downgrade, suspend, or revoke a licence if it finds evidence of non-compliance. Revocation results in curtailment of all sponsored workers’ visas, meaning they must leave the UK or switch to another route if eligible.
Do I need professional help to apply for a sponsor licence?
While it is not mandatory, many organisations use professional legal or compliance support to prepare their application, conduct a pre-application audit, and provide ongoing compliance training. This can reduce the risk of refusal or enforcement action.
What is the Immigration Skills Charge and who pays it?
The Immigration Skills Charge is a fee payable by the sponsoring employer for most Worker route visas, such as Skilled Worker. It is payable at the point of assigning a CoS and varies depending on organisation size and the length of sponsorship.
Will UKVI visit my business before granting a licence?
They may. UKVI has the discretion to conduct a pre-licence compliance visit to assess HR systems, confirm vacancy details, and test compliance readiness. A poor outcome can result in refusal even if the documents are in order.
What is the difference between an A-rating and a B-rating?
An A-rating means the sponsor meets all compliance standards and can assign CoS. A B-rating means the sponsor must follow an action plan to address compliance failings and cannot assign new CoS until restored to an A-rating.
Section J: Glossary of Key Terms
Term | Definition |
---|---|
Appendix A | Part of the Sponsor Guidance setting out the evidential requirements for a sponsor licence application, including the number and type of documents needed depending on the organisation’s structure and sector. |
Appendix D | The section of the Sponsor Guidance that specifies record-keeping requirements for sponsors, detailing what documents must be retained for each sponsored worker and for how long. |
A-rating | The rating given to a sponsor licence that meets all UKVI compliance standards, allowing the organisation to assign Certificates of Sponsorship immediately for approved visa routes. |
B-rating | A downgraded rating for a sponsor licence due to compliance concerns. Sponsors must follow an action plan to regain an A-rating and cannot assign new Certificates of Sponsorship until upgraded. |
Certificate of Sponsorship (CoS) | An electronic record issued by a licensed sponsor to a worker, confirming details of their role and enabling them to apply for a relevant visa under the UK’s points-based system. |
Cooling-off period | A mandatory period, typically up to 12 months, during which an organisation cannot reapply for a sponsor licence after certain refusals or following licence revocation. |
Genuine Organisation Test | A UKVI assessment to confirm that the sponsor is a legitimate, lawfully operating UK business with an active trading presence and not established solely to sponsor workers. |
Genuine Vacancy Test | A UKVI test to ensure the sponsored role is real, meets the relevant visa route’s skill and salary thresholds, and is required for the sponsor’s business operations. |
Immigration Skills Charge (ISC) | A fee payable by employers when assigning a CoS for most Worker route visas, aimed at incentivising investment in the resident workforce. The amount depends on the sponsor’s size and the length of sponsorship. |
Key Personnel | Individuals named on a sponsor licence with defined roles: Authorising Officer, Key Contact, and Level 1/Level 2 Users, each with specific responsibilities for licence management and compliance. |
Points-based Immigration System | The UK’s framework for assessing visa applications based on meeting defined criteria such as job offer, skill level, salary, and English language ability, with sponsorship often a mandatory requirement. |
Sponsor Management System (SMS) | The secure online platform used by licensed sponsors to manage their licence, assign Certificates of Sponsorship, update details, and report changes to UKVI. |
Sponsor Licence | Home Office authorisation that allows a UK organisation to sponsor non-UK nationals to work in eligible roles under specified visa routes. |
UK Visas and Immigration (UKVI) | The Home Office directorate responsible for managing the UK’s visa system, including sponsor licensing, immigration enforcement, and visa application processing. |
Section K: Additional Resources and Links
Resource | Description | Link |
---|---|---|
UKVI Sponsor Licence Guidance | Official Home Office guidance for employers on applying for and managing a sponsor licence, including eligibility criteria, application process, and compliance duties. | https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators |
Appendix A: Sponsor Licence Documents | Details the documentary evidence required to support a sponsor licence application, tailored to the organisation’s type and sector. | https://www.gov.uk/government/publications/supporting-documents-for-sponsor-applications-appendix-a |
Appendix D: Record-Keeping for Sponsors | Lists the documents sponsors must retain for each sponsored worker and the minimum retention periods, as required by UKVI. | https://www.gov.uk/government/publications/keep-records-for-sponsorship-appendix-d |
Skilled Worker Visa: Overview | Explains the eligibility criteria, job requirements, and application process for workers applying under the Skilled Worker route. | https://www.gov.uk/skilled-worker-visa |
Immigration Skills Charge Guidance | Outlines when the Immigration Skills Charge applies, current rates, exemptions, and payment process. | https://www.gov.uk/immigration-skills-charge |
Right to Work Checks for Employers | Official Home Office guidance on conducting right to work checks to avoid civil penalties and ensure compliance with UK immigration law. | https://www.gov.uk/check-job-applicant-right-to-work |
Register of Licensed Sponsors | The live list of organisations licensed to sponsor workers under the UK’s points-based immigration system. | https://www.gov.uk/government/publications/register-of-licensed-sponsors-workers |