Sponsor Change of Circumstances Form 2025

Section A: Sponsor Licence Change of Circumstances

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 meet this duty can result in enforcement action, potentially impacting your permission to sponsor overseas workers.

Any organisation that holds a sponsor licence must report certain changes affecting sponsored workers and the organisation itself to the Home Office via the Sponsor Management System (SMS), or in limited circumstances, using the sponsor change of circumstances form.

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, such as a change of address, any changes to the key personnel named on the licence, as well as any relevant criminal convictions.

Most worker-related changes must be reported within 10 working days, and most organisational changes within 20 working days.

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
• any change to a registration, accreditation or approval the sponsor must hold in order to operate lawfully in the UK or 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, demerger 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 (as fee reductions only apply to “small” or “charitable” sponsors as defined by Companies Act criteria)
• 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, but where the delay exceeds 28 days, reporting is mandatory unless an accepted exception applies.

Additional duties also 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 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 form should be emailed to sponsors@homeoffice.gov.uk, and processing takes up to 18 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. 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.

The table below summarises the time limits sponsors must meet when reporting organisational or worker-related changes to the Home Office.

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. The £200 fee applies per request, not per licence, and is non-refundable if the request is rejected.

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 some Temporary Worker routes, for example, Seasonal Worker and Government Authorised Exchange are excluded.

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

The table below sets out which sponsor licence change of circumstances requests can be expedited through the Home Office’s priority service and which cannot.

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.

A submission sheet is required for certain changes (for example, replacing the Authorising Officer or appointing a representative). Digital declarations have reduced wet-ink signatures in some cases, but where the guidance requires a submission sheet, it must still be provided.

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: Change of Circumstances Penalties

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.

The table below highlights the potential consequences of failing to report sponsor licence changes on time or accurately.

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: Summary

Managing a sponsor licence is not just about securing permission to hire overseas workers. It is an ongoing compliance commitment where every organisational and worker-related change must be tracked, assessed and, where relevant, reported to the Home Office within strict timeframes. The change of circumstances process is central to this obligation. While most updates are made through the Sponsorship Management System, some situations require use of the separate change of circumstances form. Sponsors must be clear on which reporting route applies and ensure submissions are accurate, supported by evidence and made within the required deadlines.

The Home Office places considerable trust in sponsors and expects robust governance of immigration compliance. Even apparently minor oversights, such as late reporting of a change of address or failing to update personnel details, can lead to scrutiny, audits, and ultimately enforcement action. With penalties ranging from licence downgrade to full revocation, and consequences extending to loss of key sponsored staff and cooling-off periods before reapplication, the risks are significant. Employers should treat reporting duties as part of wider workforce compliance, ensuring systems and responsibilities are in place to manage sponsorship properly and protect both their immigration status and business continuity.

Section F: 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 G: Sponsor Change of Circumstances Form FAQs

What is the Sponsor Change of Circumstances Form?

The Sponsor Change of Circumstances Form is used only in limited situations where SMS access is unavailable (for example, to add a Level 1 User where none exists, replace an AO who is also the sole Level 1 User, surrender a licence, or request dormancy).

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

Sponsors must notify UKVI within 20 working days of organisational changes (e.g., company name, ownership, key personnel changes, restructures).

How do I submit the form?

Most changes must be reported via the 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 via the standard service is free (processing can take up to 18 weeks). If you need faster consideration and your request type is eligible, the post-licence priority service costs £200 per request and aims for a 5-working-day turnaround.

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 H: Glossary

Section I: Additional Resources and Links