Sponsor Licence Change of Circumstances 2025

Among the compliance duties that sponsor licence holders have to meet is the requirement to inform the Home Office of certain changes in circumstances relating to sponsored workers and to the organisation itself. Failure to the meet this duty can result in enforcement action, potentially impacting your permission to sponsor overseas workers.

The following guide looks at what you need to do to comply with the sponsorship rules and ensure your sponsorship licence is kept up to date.

 

Section A: Sponsor licence change of circumstances rules

 

Any organisation that holds a sponsor licence has a duty to report to the Home Office not only any changes to the circumstances of a sponsored worker, but also to the organisation.

In broad terms, employers are responsible for checking that those they sponsor carry out the role for which they are being sponsored in the UK and for monitoring their attendance. As such, sponsors must notify the Home Office if a sponsored worker fails to show for work or is absent without permission, or if there are significant changes to their employment.

Sponsors are also required to inform the Home office if there is any significant change to the sponsor organisation itself. This includes a change of address, any changes to the key personnel named on the licence, as well as any relevant criminal convictions.

 

1. Organisational changes to be reported

 

When it comes to the organisational change of circumstances that must be reported to the Home Office, usually within 20 working days, the employer has a duty to report:

 

• any change to the Authorising Officer (AO) or Key Contact (KC) details
• any amendment to the details of the sponsor organisation, such as its name or the name of any branches, address, contact details or head office details
• any changes to the structure of the sponsor organisation, such as more branches or sites, new linked entities in the UK, or overseas, if licensed on a Global Business Mobility route
• a change in the status of any registration or accreditation the sponsor is legally required to hold to operate or trade in the UK, or which it is required to hold for sponsor licensing purposes, for example, charitable status on the Charity Worker route
• if the sponsor organisation stops trading or goes into an insolvency procedure
• if the sponsor organisation is subject to a merger, takeover, de-merger or outsourcing/insourcing arrangement
• if the owner, director, any key personnel, or anyone involved in the day-to-day running of the sponsor organisation, is convicted of a relevant criminal offence
• any change to the size or charitable status of the organisation, where this affects the sponsor’s eligibility for fee reductions or visa route-specific concessions
• any other changes to the sponsor licence, including where the nature of the business substantially changes, adding or removing a representative, or surrendering the licence.

 

 

2. Sponsored worker changes to be reported

 

When it comes to any relevant circumstances or changes specific to a sponsored worker that must be reported to the Home Office, usually within 10 working days, the employer has a duty to report if:

 

• a sponsored worker does not start the role for which they are being sponsored within 28 days of the start date on their CoS, the ‘valid from’ date on their visa or the date the worker is notified of a grant of entry clearance or permission to stay, whichever is later
• a sponsored worker is absent from work without the employer’s permission for more than 10 working days in a row, even if the employer intends to continue sponsoring the worker
• a sponsored worker is absent from work without pay, or on reduced pay, for more than 4 weeks in total in any calendar year unless a valid exception applies
• a sponsored worker’s salary or pay is otherwise reduced from the level stated on their CoS
• there are significant changes to the worker’s employment, other than those which require a change of employment application, such as a change of job role or core duties, or a promotion, but within the same occupation code
• a sponsored worker’s normal work location changes, including where they will be working at a different site, branch or office of the employer’s organisation, or a different client’s site, not previously declared to the Home Office
• a sponsored worker’s regular working pattern changes, such as moving to fully remote working from home or another address not listed on the licence
• a sponsored worker leaves their employment or is no longer being sponsored for any reason, for example, where the job offer is withdrawn or ends earlier than expected.

 

Importantly, following changes to the sponsor rules in 2022, sponsors no longer need to report if the start date of a migrant worker is delayed for a period under 28 days. However, additional duties arise for sponsors of workers on specific immigration routes. For example, if an employer is sponsoring someone on the Scale up Worker route, they must notify the Home Office of the date that the worker actually starts working for them.

 

Section B: How to report changes in circumstances

 

Most sponsor licence change of circumstances, as well as changes about sponsored workers, can be reported via the sponsorship management system (SMS), although the employer will instead need to complete a ‘sponsor change of circumstances form’ in limited cases.

Any Level 1 User will need to use either the ‘Request changes to licence details’ or the ‘Report migrant activity’ function on the SMS, depending on the nature of the change. Detailed guidance on how to do this can be found online in the relevant SMS user guides (Managing your licence and Reporting worker activity) available on GOV.UK.

In some cases, more than one action may need to be completed on the SMS. For example, if the employer has a change of address, it may also need to change the working address details for its key personnel. In these scenarios, each change must be requested separately.

While certain sponsor licence change of circumstances may be automatically updated in the SMS account once these have been reported, including any change of address, other requested changes will first need to be considered by a Home Office caseworker. For example, if a request is made for a sponsor change of name, the Home Office will need to determine whether the employer must apply for a new licence. If the only reason for the name change is because the sponsor is incorporating for the first time, and nothing else is changing, the name on the licence can be changed without a new application. If, however, the change of name is part of a wider change, for example, if the sponsor is involved in a merger or takeover, an application for a new sponsor licence may need to be made.

If an employer is reporting they are no longer sponsoring a worker, or the worker has been absent from work without their permission, the employer must provide the last recorded residential address, telephone number and personal email address they have for them.

 

1. Sponsor licence change of circumstances form

 

The Sponsor Change of Circumstances Form is a Home Office document for UK sponsor licence holders without SMS  access to report specific changes. It’s not for general updates. The form is limited to adding one Level 1 user (for SMS access), replacing the Authorising Officer (if also sole Level 1 user), surrendering the licence or requesting dormancy. The completed firm should be emailed to sponsors@homeoffice.gov.uk, and processing takes up to 8 weeks.

 

2. How long do sponsors have to report changes?

 

There are strict deadlines in place for reporting sponsor licence change of circumstances, as set out under the official sponsor guidance. With the exception of replacing an AO or KC, changes in respect of the licence or to the organisation itself must be reported no later than 20 working days after the date of the employer becoming aware of the change(s).

In respect of any changes that affect sponsored workers, the employer must again report these changes within certain time limits. Any significant changes to a sponsored worker’s employment or circumstances must usually be reported within 10 working days of the relevant change or event occurring. An employer must also, as soon as reasonably practicable, tell the Home Office if they know or suspect that a worker they are sponsoring has breached their conditions of stay, as well as providing the police with any information that suggests any sponsored worker may be engaged in terrorism or criminal activity.

 

3. Who can notify UKVI of a sponsor licence change of circumstances?

 

In most cases, any sponsor licence change of circumstances must be reported by a Level 1 User using the SMS. However, a sponsor cannot use the SMS to report changes if it no longer has a Level 1 User in place with SMS access. This could be where the only Level 1 User has left the employer’s organisation. A sponsor must have at least one Level 1 User in place at all times, unless surrendering its licence. As such, in scenarios where a Level 1 User is no longer in place, the sponsor must fill in a change of circumstances form to either:

 

• add a Level 1 User, where no-one in the organisation has access to the SMS
• replace an AO, where the new AO will also be the sole Level 1 User
• request surrender of its licence, where no-one in the organisation has access to the SMS
• request that the sponsor licence is made dormant, where no-one has access to the SMS.

 

In the context of any changes specific to a sponsored worker, in addition to Level 1 Users, Level 2 Users can also report changes in migrant activity, but only in respect of CoS they have personally created and assigned, or for CoS which have been transferred to them.

 

4. How long do change of circumstances requests take?

 

Requests can take up to 18 weeks using the standard service. When looking for an expedited decision, sponsors can register a change within 5 working days using the priority service.

Contact the Home Office if your case is within 7 calendar days of the 18-week service standard, noting the submission date in the email subject. You may be eligible for a refund if delays occur due to Home Office issues, such as technical difficulties.

 

5. How much does reporting sponsor licence change of circumstances cost?

 

There is no cost to report a sponsor licence change of circumstances for the standard service. The priority service costs £200 per request.

 

Section C: Priority change of circumstances service

 

The Home Office’s Priority Change of Circumstance Service allows A-rated Worker or Temporary Worker sponsor licence holders to request faster processing of certain change of circumstance submissions made via the SMS.

For a fee of £200 per request, eligible applications are typically considered within 5 working days from the day after payment is received. The service expedites updates such as annual or additional undefined Certificate of Sponsorship (CoS) allocations, adding or changing Level 1 users, replacing or amending the Authorising Officer (AO) or Key Contact, adding a representative or amending organisation details like a business address.

However, it does not guarantee approval of the requests.

The service is also unavailable for changes related to Global Business Mobility (GBM) – UK Expansion Worker, GBM-Service Supplier, GBM-Secondment Worker, Scale-up, Government Authorised Exchange, International Agreement or Seasonal Worker routes.

It also excludes requests for defined CoS, in-progress cases, or those allocated to a caseworker. Premium sponsors should contact their account manager instead.

To request the service, first submit the actual change via SMS. Then, email postlicencepriorityservice@homeoffice.gov.uk with the subject line “Priority service request: [organisation name] ([sponsor licence number]): request type”, attaching the completed Worker and Temporary Worker priority request form. No submission sheet is required, as digital declarations have replaced ‘wet-ink’ signatures since April 2024.

On a practical note, requests are limited to 100 slots per day, and are processed chronologically (unless exceptionally compelling circumstances apply) on working days (Monday to Friday, 7am to 5pm); submissions outside these hours are rejected. As such, they are typically oversubscribed.

If accepted, you’ll receive a Worldpay payment link to pay within 72 hours (including weekends) or the request expires.

Multiple requests for the same licence are allowed but must be in separate emails.

Complex requests or those needing extra checks may exceed 5 days. Sponsors must attach digital copies of all relevant documentation to avoid delays; originals are not required.

If no response is received, assume the request was unsuccessful, e.g., due to daily limits or ineligibility, and reapply the next working day if needed.

 

Section D: Penalties for failing to report a change of circumstances

 

As sponsorship transfers a great deal of responsibility and trust to UK sponsors, significant weight is placed on the importance of trust in the operation of the sponsorship system and the need to ensure that sponsors take their duties seriously. This means that the Home Office will not only continually monitor compliance by sponsors, it will take enforcement action against those whose acts or omissions create a risk to UK immigration control.

If an employer is suspected of breaching their sponsor duties, compliance checks may be undertaken by the Home Office. This could be because of a poor previous record of immigration compliance. It could also result following a report from the public or another government agency. In some cases, a Home Office compliance review may even be undertaken as a result of the sponsor reporting certain changes or migrant activity. For example, reporting a worker’s unauthorised absence may raise questions as to why employment is continuing despite the absence. This could trigger a compliance review into the sponsor’s HR systems and practices.

Still, even if a sponsor is concerned about the risk of a compliance check, the penalties for failing to discharge their reporting duties as a sponsor can have far wider implications. If a sponsor fails to comply with their duty to report any sponsor licence change of circumstances, or a change in the circumstances of a migrant worker, enforcement action will often be taken in response. This could include a decision to downgrade, where the sponsor would be required to follow and pay for an action plan to reinstate their A-rating within 3 months, during which time they would be prohibited from assigning new CoS.

In worst case scenarios, where any non-compliance is especially serious, a sponsor licence could be suspended, with a view to being revoked. Where a revocation decision is made, any existing sponsored workers would need to find an alternative sponsor, otherwise risk having their leave curtailed, and the employer would lose its sponsored migrant workforce.

 

Section E: Need assistance?

 

DavidsonMorris are UK business immigration and sponsorship specialists. We support sponsor licence holders with all aspects of their immigration compliance duties, including guidance on reporting changes of circumstances. Contact us for advice.

 

Section F: Sponsor licence change of circumstances form FAQs

 

What is the Sponsor Change of Circumstances Form?

The Sponsor Change of Circumstances Form is used by licensed sponsors to inform UK Visas and Immigration (UKVI) about any significant changes to their business or sponsorship arrangements.

 

When do sponsors need to submit a Change of Circumstances Form?

Sponsors must notify UKVI as soon as possible if there are changes to their organisation, such as a new company name, change of ownership, amendments to key personnel, or a significant restructuring affecting sponsored workers.

 

How do I submit the form?

Most changes must be reported via the Sponsor Management System (SMS). Where SMS access is unavailable, such as where there is no current Level 1 User, certain limited changes can be submitted using the Sponsor Change of Circumstances Form by email.

 

What happens if a sponsor fails to report changes?

Failing to update UKVI about relevant changes can result in compliance action, including suspension or revocation of the sponsor licence.

 

Can a sponsor add new key personnel using this form?

Sponsors must update their SMS account to add, remove or change key personnel, such as the Authorising Officer or Level 1 User.

 

Is there a fee for submitting a Change of Circumstances request?

Reporting most changes to your sponsor licence is free of charge when using the standard service, which can take up to 18 weeks for processing but fees may apply where a new CoS allocation or application is required as a result of the reported change. If you require expedited processing, the priority service is available at a cost of £200 per request, aiming to process changes within 5 working days.

 

How long does UKVI take to process a change request?

Processing times vary but can take several weeks. Sponsors should check the SMS for updates and be prepared to provide additional information if requested.

 

What if the business undergoes a merger or acquisition?

If a sponsor is involved in a merger, takeover, or significant structural change, they must notify UKVI immediately. In some cases, a new sponsor licence may be required.

 

Can a sponsor update multiple changes at once?

Yes, but each change must be clearly reported and supported with the required documentation. Sponsors should ensure that all changes are correctly recorded in the SMS.

 

Where can sponsors find official guidance?

Sponsors can refer to the Home Office’s official guidance on sponsorship duties, which outlines when and how to report changes via the SMS.

 

Section G: Glossary

 

 

Term	Definition
Sponsor Licence	Permission granted by UKVI to an organisation to hire skilled foreign workers.
Change of Circumstances Form	A form used by licensed sponsors to report significant changes to UKVI.
UKVI (UK Visas and Immigration)	The government department responsible for visa sponsorship and immigration control.
Sponsor Management System (SMS)	The online portal used by sponsors to manage their licence and report changes.
Key Personnel	Individuals appointed to manage a sponsor licence, including the Authorising Officer and Level 1 User.
Authorising Officer	A senior person in a business responsible for ensuring compliance with sponsorship duties.
Level 1 User	A person authorised to access the SMS and make changes on behalf of the sponsor.
Licence Revocation	The cancellation of a sponsor licence by UKVI due to non-compliance.
Licence Suspension	A temporary restriction placed on a sponsor licence while UKVI investigates compliance issues.
Certificate of Sponsorship (CoS)	A digital document issued by a sponsor to a worker to support their visa application.
Merger or Acquisition	A business transaction that may require a new sponsor licence if there are structural changes.
Right to Work Checks	Mandatory checks employers must conduct to verify a worker’s immigration status.
Sponsor Compliance	The obligation for sponsors to follow Home Office rules and report relevant changes.
Reporting Duties	The requirement for sponsors to notify UKVI of key changes such as company details or employment status of sponsored workers.