Sponsor Licence Management: Employer Guide

Sponsor Licence Management: At a Glance

A sponsor licence requires active management throughout the organisation’s sponsorship activities. Once granted, the licence becomes an ongoing operational responsibility for the employer.

Sponsor licence management covers control of the licence itself, the people authorised to administer it, access to the Sponsor Management System (SMS), the sponsorship of individual workers and changes within the organisation that may affect its sponsor position.

Effective management depends on clear ownership and reliable information flows between recruitment, HR, payroll, management and those responsible for operating the sponsor licence.

Many events with sponsorship consequences originate elsewhere in the business. A sponsored worker may change role, salary or work location. An employee with SMS access may leave. The organisation may open a new site, restructure a department or change its corporate arrangements. Unless those developments reach the sponsorship function promptly, the employer can lose control of its licence information and associated obligations.

Employers therefore need a management framework that connects sponsorship requirements with ordinary business processes and ensures relevant changes are identified, assessed and acted on.

A useful sponsor licence management model is:

Governance → People → Access → Workers → Events → Evidence → Review → Escalation

The framework should give the organisation clear visibility over who is responsible for the licence, who can access and operate it, which workers are sponsored, what events require action and how potential problems are identified and escalated.

This guide explains how employers can structure and manage these arrangements in practice, while the detailed rules relating to specific sponsor roles, SMS functions, reporting duties and compliance requirements are considered separately in the relevant specialist guides.

 

Section A: What is Sponsor Licence Management?

 

Sponsor licence management is the ongoing process of administering and controlling an organisation’s sponsor licence after it has been granted by the Home Office.

It covers the people, systems and procedures used to manage sponsorship and keep the information held by UK Visas and Immigration (UKVI) aligned with the organisation and its sponsored workforce.

In practice, sponsor licence management typically involves:

• assigning clear internal responsibility for the licence;
• maintaining appropriate key personnel;
• controlling access to the Sponsor Management System (SMS);
• keeping the organisation’s sponsor licence details accurate;
• managing Certificates of Sponsorship;
• maintaining oversight of sponsored workers;
• identifying changes or events that may require action or reporting;
• ensuring relevant information moves between HR, recruitment, payroll and sponsor licence personnel;
• reviewing sponsorship arrangements periodically; and
• escalating potential problems before they develop into wider compliance issues.

 

1. Sponsor Licence Management vs Sponsor Compliance

 

Sponsor licence management and sponsor compliance are closely connected, but they address different aspects of the sponsorship framework.

Sponsor licence management concerns how the employer organises, administers and controls its sponsorship activities.

Sponsor compliance concerns whether the employer is meeting the duties and requirements imposed on licensed sponsors by the Home Office.

The management framework determines how those compliance obligations are carried out in practice.

HR may, for example, know that certain changes affecting sponsored workers have to be reported. If there is no reliable process for communicating salary, role or workplace changes to the person responsible for the SMS, the organisation remains exposed even though the underlying reporting requirement is understood.

Effective sponsor licence management provides the operational infrastructure through which sponsor duties can be met consistently.

Sponsorship therefore needs to be integrated into wider business processes. Relevant information can sit across recruitment, HR, payroll, line management, legal, compliance and operational teams, and the management framework needs to connect those functions.

For larger employers in particular, responsibility may be distributed across different teams, locations and reporting lines. The organisation needs a mechanism for ensuring that sponsorship-relevant information reaches the appropriate person in sufficient time for any required action to be taken.

The sponsor remains responsible for its licence and sponsorship activities. Internal delegation and external advisers can support administration and oversight, but the organisation retains responsibility for complying with its obligations as a licensed sponsor.

 

 

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Section B: Who is Responsible for Managing a Sponsor Licence?

 

Responsibility for managing a sponsor licence ultimately sits with the sponsoring organisation.

An employer can allocate different sponsorship functions to different people and can use external professional advisers to assist with aspects of licence administration. However, delegating these activities does not remove the sponsor’s responsibility for ensuring that the licence is properly managed.

For this reason, employers should avoid treating sponsor licence management as the responsibility of a single SMS user working in isolation. Effective management requires clear ownership at both organisational and operational level.

 

1. The Authorising Officer

 

The Authorising Officer is the senior person within the organisation with overall responsibility for its activities as a licensed sponsor.

The role should provide appropriate senior oversight of sponsorship within the organisation. While the Authorising Officer does not necessarily need to carry out routine SMS administration personally, they should have sufficient visibility of how the licence is being managed and whether appropriate systems and controls are operating.

In practice, the Authorising Officer should be able to understand:

• how sponsorship is being used within the organisation;
• who has access to the SMS;
• who is responsible for day-to-day licence administration;
• how sponsored workers are being monitored;
• how relevant business and workforce changes are identified;
• how Certificates of Sponsorship are controlled; and
• how sponsorship problems are escalated.

The sponsor is expected to maintain an eligible Authorising Officer throughout the life of the licence. The organisation should therefore have arrangements for dealing promptly with the departure, replacement or loss of eligibility of the person holding the role.

The detailed eligibility requirements and responsibilities of the role are considered in our separate Authorising Officer guide.

 

2. The Key Contact

 

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

This is primarily a communications role and should not be confused with overall responsibility for managing the licence. Depending on the organisation’s arrangements, the Key Contact may also hold another sponsor management role, but employers should understand the functions of each role separately.

 

3. Level 1 Users

 

Level 1 Users carry out many of the practical functions involved in operating the sponsor licence through the SMS.

Depending on their permissions and the action required, this can include maintaining licence information, reporting relevant changes, managing sponsored-worker information, assigning Certificates of Sponsorship and dealing with sponsor licence administration.

Level 1 access therefore carries significant operational responsibility.

Employers should control who receives this access rather than treating Level 1 User status as a routine administrative permission. The organisation should know who its current users are, why they require access and whether they remain appropriate people to operate the licence.

Sponsors are also required to maintain an eligible Level 1 User throughout the life of the licence. This makes continuity planning particularly important where the organisation relies heavily on one Level 1 User.

 

4. Level 2 Users

 

Level 2 User access is being phased out of the sponsorship system.

From 9 September 2026, sponsors can no longer appoint new Level 2 Users. Existing Level 2 Users must be converted to Level 1 Users, where they are eligible to hold that role, or their accounts must be deactivated by 8 March 2027. Remaining Level 2 User accounts are due to be deactivated after that date.

Employers that still have Level 2 Users should therefore review those accounts as part of their current sponsor licence management arrangements rather than treating Level 2 access as a continuing long-term user category.

Where an existing Level 2 User performs functions that the organisation still requires, the employer should consider whether the individual is eligible and appropriate to become a Level 1 User and take the necessary action within the applicable timeframe.

 

5. HR, Recruitment and Payroll Teams

 

Some of the most important people involved in sponsor licence management may never access the SMS.

Recruitment teams may identify that sponsorship is required.

HR may hold information about changes to a sponsored worker’s role, working arrangements, absence or employment.

Payroll may identify salary changes.

Line managers may be the first people to know that a worker has changed duties, moved location or stopped attending work.

Corporate management may be responsible for changes to ownership, structure or business operations.

The sponsor licence management process therefore needs to connect these functions with the people responsible for sponsorship.

It is not sufficient for the SMS team to understand the immigration rules if the rest of the organisation does not know when information needs to be passed to them.

 

6. Using External Advisers

 

Employers can use immigration advisers or legal representatives to support sponsor licence management.

Depending on the arrangement, an adviser may assist with matters such as SMS administration, reporting changes, Certificates of Sponsorship, sponsor licence queries and identifying potential compliance issues.

External support can be particularly useful where an organisation sponsors workers infrequently or does not maintain a dedicated internal immigration function.

However, outsourcing administration should not result in the employer losing visibility or control of its licence.

The organisation still needs internal processes capable of identifying relevant events and communicating them to the adviser. An external adviser cannot report a salary change, for example, if nobody within the business tells them that the change has occurred.

The sponsor remains responsible for complying with its sponsor duties and for ensuring that its licence is properly managed.

 

7. Avoiding Single-Person Dependency

 

One of the most significant practical weaknesses in sponsor licence management is excessive reliance on one individual.

If only one person understands the licence, holds the relevant organisational knowledge or routinely operates the SMS, their unexpected absence or departure can create immediate problems.

Employers should therefore build continuity into their management arrangements.

This can include maintaining appropriate alternative SMS access, documenting key processes, ensuring more than one appropriate person understands the organisation’s sponsorship arrangements and having a procedure for dealing with changes to key personnel.

The objective should be to create an organisational system for managing sponsorship rather than a licence that depends on the knowledge and availability of one employee.

 

 

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Section C: Building a Sponsor Licence Management Structure

 

A sponsor licence should have a defined management structure rather than being administered through informal arrangements.

The appropriate structure will depend on the size and complexity of the organisation. A smaller employer may have only a few people involved in sponsorship, while a larger organisation may need to coordinate HR, recruitment, payroll, legal, compliance and operational teams across multiple locations.

The principle is the same in either case: responsibility should be clear, information should flow to the right people and important sponsorship decisions should not depend on assumptions about who is dealing with them.

 

1. Establishing Organisational Ownership

 

There should be clear senior-level ownership of the sponsor licence.

This is particularly important because sponsorship decisions can have consequences beyond the individual worker concerned. Problems with the management of one sponsored worker can expose weaknesses in the employer’s wider systems and potentially place the sponsor licence at risk.

Senior ownership should therefore provide oversight of issues such as:

• how and when the organisation uses sponsorship;
• who is authorised to administer the licence;
• whether sponsorship responsibilities are adequately resourced;
• whether relevant departments understand their role;
• whether appropriate controls are operating;
• significant compliance concerns; and
• matters requiring escalation or professional advice.

This does not mean senior management needs to approve every routine SMS transaction. The purpose is to ensure there is identifiable organisational accountability above the level of day-to-day administration.

 

2. Establishing Operational Ownership

 

Employers should also identify who is responsible for the routine management of the licence.

Operational responsibility can include:

• monitoring the sponsor licence;
• maintaining appropriate access to the SMS;
• coordinating information from other departments;
• overseeing Certificates of Sponsorship;
• monitoring sponsored workers;
• identifying reportable events;
• ensuring required actions are completed;
• maintaining relevant records; and
• escalating potential problems.

Where these responsibilities are shared between several people, the division of responsibility should be explicit.

A common weakness is for several departments to be involved in sponsorship while each assumes that another person is responsible for taking the necessary immigration action.

 

3. Connecting HR to Sponsor Licence Management

 

HR is usually central to effective sponsor licence management because many events affecting sponsored workers arise through normal employment processes.

For example, HR may become aware of:

• a proposed salary change;
• a promotion;
• a change in job title or duties;
• a change in working location;
• long-term or unauthorised absence;
• maternity, paternity or other forms of leave;
• changes to working hours;
• a resignation;
• dismissal or redundancy; or
• another change to the worker’s employment.

The management framework should ensure that relevant changes are considered from a sponsorship perspective before, or as soon as, they take effect.

This is particularly important where the HR employee processing the change is not the person responsible for the sponsor licence.

 

4. Connecting Recruitment to Sponsor Licence Management

 

Recruitment teams also need a defined route into the sponsorship process.

Before an offer involving sponsorship progresses too far, the appropriate person should be able to consider matters such as whether the role is capable of being sponsored, whether the proposed terms are compatible with the relevant immigration route and whether the organisation has the necessary Certificate of Sponsorship available.

This helps prevent sponsorship being treated as an administrative step at the end of recruitment after important decisions have already been made.

The recruitment process should therefore contain a clear trigger for referring potential sponsored hires to the relevant immigration or sponsor licence personnel.

 

5. Connecting Payroll to Sponsor Licence Management

 

Payroll information can be particularly important where changes affect the remuneration of sponsored workers.

An organisation should avoid a situation where payroll implements a salary change without the sponsorship function knowing about it.

The appropriate process will vary between employers, but sponsored-worker status should be visible enough within relevant systems for changes affecting remuneration to be identified and referred for immigration consideration where necessary.

Periodic comparison between payroll information and sponsorship records can also help identify discrepancies that may otherwise remain unnoticed.

 

6. Connecting Line Managers to Sponsor Licence Management

 

Line managers can be an important source of information because they often know about operational changes before HR or the sponsor licence team.

A manager may know, for example, that a sponsored employee has:

• stopped attending work;
• started performing materially different duties;
• moved to another team;
• begun working at another location; or
• indicated that they intend to leave the organisation.

Employers do not necessarily need line managers to understand detailed sponsor guidance. They do, however, need managers to understand which types of events should be referred internally.

The objective is to create reliable escalation rather than expecting every manager to become an immigration specialist.

 

7. Defining Responsibility by Function

 

For organisations with regular sponsorship activity, it can be useful to document responsibility by function.

Function	Management Responsibility	Typical Owner
Sponsor governance	Overall oversight and escalation	Authorising Officer / senior management
SMS administration	Routine licence administration	Level 1 User
Recruitment	Identifying sponsorship requirements	Recruitment / HR
Sponsored workers	Monitoring employment-related changes	HR
Salary information	Identifying relevant remuneration changes	HR / payroll
Certificates of Sponsorship	Approval and assignment controls	Sponsor licence team / authorised SMS user
Business changes	Identifying organisational events affecting the licence	Senior management / legal / company secretarial
Compliance concerns	Investigation and escalation	Authorising Officer / legal / compliance

The precise allocation is less important than ensuring there are no gaps between functions.

 

8. Building Trigger-Based Management

 

An effective sponsor management structure should operate around events, rather than relying solely on periodic checks.

Typical recruitment and sponsorship triggers can include:

New hire → sponsorship assessment → CoS approval → visa process → onboarding

During employment, the trigger sequence can include:

Role change → salary change → absence → location change → immigration status change → termination

At organisational level, triggers can include:

New premises → restructuring → acquisition → change of ownership → change of key personnel → change in trading circumstances

Each trigger should prompt the organisation to ask a simple question:

Does this event affect the sponsor licence or a sponsored worker, and does anything need to be done?

This approach embeds sponsorship into normal business processes instead of relying on the sponsor licence team to discover relevant changes retrospectively.

 

9. Documenting the Management Structure

 

The employer should be able to explain how its sponsor licence is managed in practice.

This does not necessarily require a complicated sponsorship manual. The level of documentation should be proportionate to the organisation and its sponsorship activities.

However, an effective framework should make it possible to identify:

• who owns the licence;
• who operates the SMS;
• who can approve sponsorship activity;
• which departments provide relevant information;
• how sponsored-worker changes are identified;
• how business changes are escalated;
• who takes action when an issue arises; and
• what happens if the usual person responsible is unavailable.

The test is whether the organisation has a functioning management system rather than a collection of individuals who each understand only their own part of the sponsorship process.

 

 

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Section D: Managing the Sponsor Management System

 

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

It is an essential operational tool, but employers should not confuse the SMS with the organisation’s wider sponsor licence management system.

The SMS records and facilitates sponsorship activity. It does not, by itself, identify every relevant event occurring elsewhere within the organisation, determine whether an action is appropriate or ensure that the organisation’s internal information is accurate.

Effective sponsor licence management therefore requires employers to combine proper use of the SMS with appropriate internal governance, HR processes, records and controls.

 

1. What is the SMS Used For?

 

Depending on the sponsor’s licence, routes and permissions, the SMS is used for functions including:

• maintaining and updating sponsor licence information;
• managing authorised SMS users;
• reporting relevant organisational changes;
• reporting relevant changes concerning sponsored workers;
• requesting Certificates of Sponsorship where required;
• assigning Certificates of Sponsorship;
• viewing sponsorship information and activity; and
• making certain requests relating to the sponsor licence.

Because actions taken through the SMS can affect the sponsor licence and individual workers, access and use should be controlled rather than treated as routine administrative activity.

 

2. Establish Clear Responsibility for SMS Administration

 

The organisation should know who is responsible for routine SMS administration and who has authority to make or approve significant sponsorship decisions.

These are not necessarily the same thing.

For example, a Level 1 User may have the technical ability to assign a Certificate of Sponsorship, but the organisation may require an internal recruitment, HR or management approval before the assignment takes place.

Similarly, the ability to submit information through the SMS does not necessarily mean that the user should decide independently whether a particular change is reportable.

A controlled process therefore distinguishes between:

Authority to approve an action → authority to carry out the SMS transaction

This distinction becomes increasingly important as sponsorship activity grows.

 

3. Control Significant SMS Activity

 

Employers should identify which SMS activities require additional internal control.

Depending on the organisation, these may include:

• assigning a Certificate of Sponsorship;
• requesting additional Certificates of Sponsorship;
• adding or changing SMS users;
• changing key personnel;
• reporting significant changes concerning sponsored workers;
• reporting changes to the sponsoring organisation; and
• responding to Home Office correspondence or requests.

For higher-risk actions, employers may decide that an approval or verification stage is appropriate before the SMS transaction is completed.

The purpose is not to create unnecessary bureaucracy. It is to reduce the risk of an individual user making a significant sponsorship decision without the organisation having verified the underlying facts.

 

4. Maintain an Internal Audit Trail

 

The SMS contains information about sponsorship activity, but employers should also maintain sufficient internal records to explain important decisions and actions.

For significant transactions, the organisation should be able to establish:

• what event occurred;
• when the organisation became aware of it;
• who assessed the sponsorship implications;
• what decision was made;
• who approved the action;
• when any required SMS action was completed; and
• where the supporting evidence is retained.

This is particularly valuable where several people are involved in the management of the licence or where an issue is reviewed months or years after the original event.

 

5. Reconcile the SMS with Internal Systems

 

The information held on the SMS should not be considered in isolation.

Employers should periodically compare relevant sponsorship information against their internal systems and records.

Depending on the organisation, this may involve comparing:

SMS → HR system → payroll → right to work records → sponsored-worker records → corporate information

For example, the organisation may compare the sponsored-worker population recorded internally with current employment records, payroll information and relevant SMS data.

This type of reconciliation can identify problems such as:

• a worker who has left but remains on internal sponsorship records;
• a salary recorded internally that differs from sponsorship information;
• a work location that has changed;
• outdated key personnel;
• an SMS user who no longer requires access;
• licence information that no longer reflects the organisation; or
• an event that occurred internally but was never considered from a sponsorship perspective.

Reconciliation is therefore both a management control and an early-warning mechanism.

 

6. Manage Outstanding SMS Actions

 

Where an event requires investigation or action, it should not disappear into an informal email chain or depend on one person remembering to deal with it.

A practical workflow is:

Event identified → sponsorship impact assessed → action identified → responsible person assigned → deadline recorded → action completed → evidence retained

The organisation should be able to distinguish between matters that have been identified, matters that are being investigated and matters that have been completed.

This is particularly important where the relevant Home Office reporting period is running while the organisation is gathering information internally.

 

7. SMS Access Does Not Equal Governance Authority

 

One of the most important distinctions in sponsor licence management is between access to the SMS and authority within the organisation.

An employee may have extensive SMS permissions because they need to perform day-to-day administrative functions. That does not necessarily mean they should have unilateral authority to decide:

• whether a particular role should be sponsored;
• whether a Certificate of Sponsorship should be assigned;
• whether a proposed employment change is acceptable;
• how a significant compliance concern should be handled; or
• how the organisation should respond to a potentially serious Home Office issue.

The employer should therefore define both system permissions and decision-making authority.

 

8. Keep SMS Knowledge Current

 

The Home Office can change SMS functionality, user requirements and sponsor guidance.

Employers should therefore avoid relying solely on procedures created when the sponsor licence was first granted.

The organisation should ensure that the people responsible for operating the SMS are using current Home Office guidance and are aware of material changes affecting the system.

This has become particularly important during 2026 because the Home Office has introduced significant changes affecting SMS access, including the phased introduction of multi-factor authentication and the withdrawal of Level 2 User access.

Detailed guidance on the operation of the system is considered separately in our Sponsor Management System (SMS): Employer Guide.

 

 

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Section E: Controlling Access to Your Sponsor Licence

 

Access to the Sponsor Management System should be treated as a controlled organisational permission.

SMS users can carry out actions that affect the sponsor licence and the workers sponsored under it. Employers should therefore know who has access, why they require it and whether the level of access remains appropriate.

Access controls should form part of the organisation’s wider sponsor licence governance rather than being managed solely as an IT or administrative issue.

 

1. Limit SMS Access to Appropriate Users

 

Employers should only provide SMS access where there is a genuine operational requirement and the individual satisfies the applicable Home Office requirements for the relevant role.

The number of users required will depend on the size, structure and sponsorship activity of the organisation.

A smaller employer may need relatively few users. A larger sponsor may require several Level 1 Users to provide appropriate operational coverage across different teams or locations.

The objective is not necessarily to minimise the number of users. It is to ensure that access is necessary, appropriate and controlled.

 

2. SMS Credentials Must Not Be Shared

 

SMS accounts are personal to the individual user.

Passwords, authentication information and multi-factor authentication passcodes should not be shared with colleagues, managers, external advisers or anyone else.

An organisation should not operate a sponsor licence through shared login credentials or allow one employee to access the SMS using another person’s account.

This remains the case even where sharing credentials may appear operationally convenient, for example because the usual SMS user is absent.

Continuity should instead be addressed by maintaining appropriate authorised users and succession arrangements.

 

3. Multi-Factor Authentication for SMS Users

 

From 3 September 2026, the Home Office began the phased introduction of mandatory multi-factor authentication (MFA) for SMS users.

The rollout is expected to cover all sponsors, with MFA enabled for organisations granted a sponsor licence on or after 9 September 2026 and implementation being extended across the existing sponsor population.

MFA adds an additional authentication step when users access the SMS.

Employers should ensure that individual SMS users understand the new authentication requirements and that internal processes do not encourage users to disclose passwords or MFA passcodes to other people.

The introduction of MFA also reinforces the principle that SMS access belongs to an authorised individual rather than to a department or generic organisational account.

Where SMS administration is supported by an external adviser, employers should ensure that access arrangements comply with the current Home Office requirements rather than sharing the credentials or authentication information of an internal user.

 

4. Review SMS Access Regularly

 

SMS access should be reviewed periodically rather than left unchanged indefinitely.

A review should establish:

• which individuals currently have SMS access;
• what level of access they hold;
• whether they still work for the organisation;
• whether they remain in an appropriate role;
• whether they still require access;
• whether their details remain current;
• whether any existing Level 2 User accounts require action during the phase-out of that user category; and
• whether the organisation has sufficient Level 1 User coverage to maintain continuity.

This review can form part of the organisation’s wider sponsor licence reconciliation process.

 

5. Inactive SMS User Accounts

 

Employers should also monitor whether authorised SMS users are actually using their accounts.

Under current Home Office arrangements, an SMS User account can be regarded as inactive where the user has not accessed the account for 12 months or more.

UKVI can take action to deactivate inactive accounts. Sponsors should therefore not assume that an authorised user will remain available indefinitely simply because their details continue to appear within the organisation’s historic sponsorship arrangements.

This creates an important continuity issue where an employer relies on a single Level 1 User.

If the deactivation process leaves the organisation without an active Level 1 User, UKVI can suspend the sponsor licence and require the sponsor to nominate an eligible Level 1 User within 28 days. Failure to address the position within the required period can place the sponsor licence at risk of revocation.

Employers should therefore incorporate account activity into their access reviews and ensure they maintain an eligible and operational Level 1 User rather than merely a person who is nominally recorded as holding the role.

 

6. Remove or Review Access When People Leave or Change Roles

 

SMS access should form part of the organisation’s joiner, mover and leaver processes.

Where an SMS user leaves the organisation, changes role or no longer requires access, the sponsor should consider promptly what action is required.

This may include:

• removing or changing the individual’s SMS access;
• appointing or nominating an appropriate replacement;
• reviewing whether a key personnel change needs to be made;
• transferring outstanding sponsorship work;
• checking whether any actions remain incomplete; and
• ensuring the organisation retains sufficient authorised users to operate the licence.

Access should not remain active simply because nobody remembered to remove it.

 

7. Managing the Level 2 User Phase-Out

 

Employers with existing Level 2 Users need to take specific action following the Home Office decision to withdraw the Level 2 User category.

Since 9 September 2026, sponsors have not been able to appoint new Level 2 Users.

Existing Level 2 Users should be reviewed to determine whether:

• the individual still requires SMS access;
• the individual is eligible and suitable to become a Level 1 User;
• their functions should be transferred to another authorised user; or
• their account should be deactivated.

Existing Level 2 Users must be converted to Level 1 Users, where eligible, or have their accounts deactivated by 8 March 2027. Remaining Level 2 User accounts are due to be deactivated after that date.

Sponsors should therefore treat the phase-out as an active management exercise rather than waiting for historic Level 2 accounts to cease functioning.

 

8. Avoid Single-User Access

 

Where appropriate for the organisation, relying on only one person with practical access to the SMS creates an avoidable operational risk.

The problem can become immediate if that individual:

• leaves unexpectedly;
• becomes unavailable through illness or absence;
• changes role;
• loses eligibility;
• has their SMS account deactivated through inactivity; or
• is otherwise unable to access the system when an urgent action is required.

Employers should consider whether additional eligible Level 1 User coverage is appropriate to the size and complexity of their sponsorship activities.

This does not mean granting access unnecessarily. It means balancing access control against operational resilience.

 

9. Controlling External Adviser Access

 

Where an external adviser assists with sponsor licence management, the organisation should clearly define the adviser’s role and access arrangements.

The employer should understand:

• what actions the adviser is authorised to undertake;
• which actions require prior employer approval;
• how information will be provided to the adviser;
• who within the organisation remains responsible for sponsorship decisions;
• how urgent matters will be communicated; and
• what happens if the adviser relationship ends.

An adviser should not be used as a substitute for internal organisational awareness of sponsorship activity.

 

10. Maintain an SMS Access Register

 

As a management control, employers may find it useful to maintain an internal register of people with SMS access.

The register can record:

• the user’s name;
• their sponsor management role;
• their internal position;
• the reason access is required;
• the date access was granted;
• the date access was last reviewed;
• whether any action is required; and
• where relevant, the date access was removed.

This does not replace the SMS itself. Its purpose is to give the organisation a simple management view of who is authorised to interact with the licence and whether that access remains appropriate.

The underlying principle is that sponsor licence access should be deliberate, identifiable, secure, current and no broader than the organisation requires.

 

 

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Section F: Keeping Sponsor Licence Details Accurate

 

A sponsor licence should reflect the organisation that actually exists and operates in practice.

Businesses change over time. They move premises, open additional locations, change personnel, restructure operations, alter trading arrangements and grow or reduce their workforce. If these developments are not connected to sponsor licence management, the information held by UKVI can gradually become outdated.

Employers should therefore have a process for identifying changes that may affect the sponsor licence and ensuring they are assessed against the current Home Office requirements.

 

1. What Sponsor Licence Information Should Employers Monitor?

 

The information that may require consideration will depend on the organisation and the nature of the change, but employers should maintain visibility over matters including:

• the organisation’s legal name;
• trading names;
• registered and operating addresses;
• additional business locations;
• key personnel;
• SMS users;
• corporate structure;
• ownership and control;
• relevant registrations or regulatory arrangements;
• the organisation’s size or status where this is relevant to sponsorship;
• the immigration routes covered by the licence; and
• material changes affecting the organisation’s sponsored workforce or sponsorship activities.

Not every internal business change requires the same action. The important management requirement is that potentially relevant events are identified and considered rather than occurring without the sponsorship function becoming aware of them.

 

2. Connect Corporate Changes to Sponsor Licence Management

 

One of the most significant management risks arises where corporate activity takes place without anyone considering the sponsor licence implications.

For example, sponsorship issues can arise in connection with:

• changes in ownership;
• mergers and acquisitions;
• TUPE transfers;
• corporate restructuring;
• changes to the employing entity;
• business disposals;
• insolvency events;
• changes to branches or operating structures; and
• other material changes to the organisation.

A sponsor licence is not simply transferable between legal entities. Certain corporate changes can require specific reporting, applications or other action within prescribed timeframes.

For this reason, sponsorship should form part of the organisation’s corporate change process rather than being considered after a transaction has completed.

Detailed treatment of mergers, acquisitions, TUPE, restructuring and ownership changes belongs within the separate Sponsor Licence & Business Changes guidance.

 

3. Managing Address and Location Changes

 

Changes to business addresses and operating locations should be referred into the sponsor management process.

This can include situations where the organisation:

• moves its principal place of business;
• opens a new location;
• closes an existing site;
• relocates part of its workforce;
• changes where sponsored workers are based; or
• changes the way different business locations are used.

The sponsorship implications will depend on the particular circumstances. Employers should therefore avoid assuming that an address change is merely an administrative facilities matter.

 

4. Managing Changes to Key Personnel

 

Key personnel information should remain current throughout the life of the sponsor licence.

If an Authorising Officer, Key Contact or relevant SMS user leaves, changes role, becomes ineligible or otherwise ceases to perform their sponsorship function, the employer should identify the issue promptly and determine what action is required.

This is particularly important for the Authorising Officer and Level 1 User roles because sponsors are expected to maintain eligible individuals in the required positions throughout the life of the licence.

Employers should not wait for a periodic sponsor licence review to discover that a key person left the organisation several months earlier.

Changes to key personnel should therefore be integrated into normal joiner, mover and leaver procedures.

 

5. Monitoring Changes to Business Size or Status

 

Changes to an organisation’s size or status can also be relevant to sponsorship.

For example, growth in turnover or workforce numbers, changes in charitable status or other developments may affect how the organisation is treated for particular sponsorship-related purposes.

The sponsor licence team should therefore have a mechanism for identifying potentially relevant changes rather than relying indefinitely on the organisation’s position when the licence was originally granted.

 

6. Do Not Rely on the Original Sponsor Licence Application

 

A common management mistake is to treat the information submitted when the sponsor licence was obtained as the permanent description of the organisation.

The original application is a historical snapshot.

As the business evolves, sponsor licence information and the organisation’s actual circumstances can diverge unless changes are actively managed.

The management question should therefore not be:

“Was this information correct when we applied?”

It should be:

“Does the information relevant to our sponsor licence accurately reflect the organisation now?”

 

7. Review Sponsor Licence Information Periodically

 

In addition to responding to individual business events, employers should periodically review the information associated with their sponsor licence.

A review may consider:

• current organisational details;
• business addresses and locations;
• key personnel;
• SMS users;
• licensed routes;
• sponsored-worker information;
• Certificate of Sponsorship arrangements;
• outstanding requests or actions; and
• significant organisational changes since the previous review.

The purpose is to identify discrepancies that may not have been detected through event-driven processes.

 

8. Sponsor Licence Reporting Deadlines

 

Where a change is reportable, employers need to identify the applicable Home Office deadline.

Under the sponsor guidance, certain changes relating to sponsored workers generally have to be reported within 10 working days of the relevant event, unless the guidance specifies otherwise.

Specified organisational and corporate changes can be subject to a 20-working-day requirement.

These should not be treated as universal rules that apply to every sponsorship event. Different requirements can apply depending on the nature of the change, the immigration route and the relevant Home Office guidance.

Employers should therefore establish the applicable requirement for the particular event rather than relying on a general assumption that every worker change has a 10-working-day deadline or every business change has a 20-working-day deadline.

Where there is uncertainty, the relevant current sponsor guidance should be checked before the organisation decides what action to take.

 

9. Use Internal Deadlines That Allow Time for Action

 

An organisation should not design its internal process around discovering a change on the final day of the applicable Home Office reporting period.

Internal escalation should happen as soon as the relevant event is known.

A practical management sequence is:

Business or worker change → sponsorship impact considered → responsible person identified → applicable requirement checked → action completed → evidence retained

Where possible, internal notification deadlines should provide sufficient time for the sponsorship team to establish the facts, obtain advice where necessary and complete any required action within the applicable Home Office timeframe.

 

10. Maintain a Change Log

 

For organisations with regular sponsorship activity, maintaining a change log can provide a useful management control.

The log can record:

• the date the event occurred;
• the date the sponsorship team became aware of it;
• the worker or organisational issue involved;
• whether sponsorship action was required;
• the applicable deadline;
• who was responsible for the action;
• when the action was completed; and
• where supporting evidence is retained.

This allows the employer to monitor outstanding matters and provides an audit trail showing how relevant events have been managed.

 

11. Managing Planned Changes Before They Happen

 

Where a change is planned, the strongest management approach is usually to consider the sponsorship implications before implementation.

This is particularly important for potentially significant matters such as:

• changes to a sponsored worker’s role or duties;
• salary changes;
• changes to working arrangements or principal work location;
• corporate restructuring;
• business acquisitions or disposals;
• changes in ownership;
• changes to the employing entity; and
• replacement of key sponsor personnel.

Early consideration allows the employer to determine whether the proposed change is permissible, whether a report or other action is required and whether specialist advice should be obtained before the change takes effect.

The underlying management principle is simple: the sponsor licence should evolve with the organisation rather than fall progressively out of alignment with it.

 

 

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Section G: Managing Sponsored Workers

 

Managing sponsored workers is a central part of sponsor licence management.

The employer needs to maintain visibility of its sponsored workforce throughout the employment lifecycle rather than treating sponsorship as complete once a Certificate of Sponsorship has been assigned and the worker has obtained immigration permission.

A practical lifecycle is:

Recruit → Sponsor → Onboard → Monitor → Change → Extend → Terminate

Each stage can create sponsorship issues that need to be identified, assessed and, where necessary, acted upon.

 

1. Maintain an Accurate Sponsored-Worker Population

 

The organisation should be able to identify which members of its workforce are currently sponsored.

Depending on the organisation’s systems, relevant management information may include:

• the worker’s name;
• immigration route;
• job title and role;
• occupation code where relevant;
• salary and working hours;
• principal work location;
• Certificate of Sponsorship details;
• visa or immigration permission expiry date;
• employment status;
• relevant right to work information; and
• any outstanding sponsorship actions.

The purpose is not simply to duplicate information held elsewhere. It is to ensure the employer has sufficient visibility to manage its sponsored population and identify events that may require action.

 

2. Build Sponsorship Checks into Onboarding

 

The onboarding process should connect the worker’s immigration position with the employer’s HR and sponsorship systems.

Before or at the start of employment, the organisation should ensure that relevant information is correctly recorded and that the people responsible for managing the worker understand that sponsorship considerations may apply to subsequent employment changes.

The onboarding process may include:

• completing the appropriate right to work process;
• confirming the worker’s immigration permission;
• checking relevant employment information against the sponsorship arrangements;
• recording relevant immigration and sponsorship dates;
• ensuring the worker is identifiable within appropriate HR systems as a sponsored worker; and
• identifying who will monitor subsequent changes affecting the worker.

This creates the connection between recruitment, immigration permission and ongoing employment management.

 

3. Monitor Changes During Employment

 

Sponsored workers should not disappear from the sponsorship process once they have started work.

Employers need systems capable of identifying potentially relevant changes during employment, including changes involving:

• job title;
• role and duties;
• occupation code;
• salary;
• working hours;
• principal work location;
• working arrangements;
• contractual arrangements;
• absence;
• employment status; and
• the employing entity.

Not every change will require the same immigration or SMS action. The management requirement is to ensure that relevant changes are identified and assessed rather than implemented without sponsorship being considered.

 

4. Assess Employment Changes Before Implementation

 

Where possible, potentially significant changes affecting a sponsored worker should be reviewed before they take effect.

This is particularly important where an employer proposes to change:

• the worker’s role;
• their substantive duties;
• their salary;
• their working hours;
• their principal work location; or
• the entity employing them.

The immigration consequences will depend on the worker’s route, circumstances and the nature of the proposed change.

Some changes may require an SMS report. Others may require more substantial immigration action. Some may not require a report at all.

Employers should therefore avoid assuming that because a change is permissible under the employment contract it is automatically permissible under the worker’s sponsorship arrangements.

 

5. Promotions and Internal Moves

 

Promotions and internal moves can create sponsorship issues where they alter the worker’s duties, occupation, salary, hours, work location or other relevant aspects of the sponsored role.

An internal transfer should therefore trigger a sponsorship assessment before the change is finalised.

The relevant team should establish:

• what the worker does currently;
• what they will do after the proposed change;
• whether the occupation remains the same for sponsorship purposes;
• whether salary and other requirements continue to be met;
• whether an SMS report is required; and
• whether the proposed change requires any further immigration action.

This is an example of why sponsor licence management needs to be integrated into ordinary HR processes.

 

6. Salary Changes

 

Changes to the salary of a sponsored worker should be referred for sponsorship consideration.

This applies particularly where salary is reduced, but employers should not assume that an increase is automatically irrelevant.

The effect of a salary change can depend on the relevant immigration route, the worker’s circumstances, the reason for the change and the requirements applicable to the sponsored role.

HR and payroll processes should therefore include a mechanism for identifying sponsored workers before remuneration changes are implemented.

A useful internal control is:

Proposed salary change → sponsored-worker check → immigration assessment → approval → payroll implementation → any required SMS action

This helps prevent payroll information and sponsorship records from diverging.

 

7. Absence and Attendance

 

Absence can also have sponsorship implications.

Employers should maintain appropriate systems for monitoring sponsored workers’ attendance and identifying absences that may require consideration under the sponsor guidance.

The relevant action can depend on the nature, duration and reason for the absence.

Managers and HR personnel should therefore know how to escalate potentially significant attendance issues rather than assuming that all absence is solely an internal employment matter.

The sponsor management process should allow the organisation to establish:

• when the absence began;
• why the worker is absent;
• whether the absence is authorised;
• whether pay has been affected;
• whether sponsorship action may be required; and
• what evidence should be retained.

 

8. Work Locations and Hybrid Working

 

Employers should maintain appropriate visibility over where sponsored workers are carrying out their sponsored roles.

Changes to a worker’s principal office or work location can have sponsorship implications, and working at new client sites or other locations may also require consideration depending on the circumstances.

However, employers should distinguish a relevant change of work location from hybrid working itself.

Under current Home Office sponsor guidance, sponsors do not generally need to report simply because a sponsored worker moves to a hybrid working pattern. This does not remove the need to report other relevant changes to the worker’s normal work location where the reporting requirements apply.

Sponsors should also maintain appropriate information about sponsored workers’ working patterns and locations so that they can explain where and how the sponsored role is being performed if required.

The management process should therefore distinguish between:

• ordinary hybrid working arrangements;
• a change to the worker’s principal office or work location;
• working at additional organisational locations;
• working at client sites; and
• other material changes affecting where the sponsored role is performed.

Where the position is unclear, the current route-specific and sponsor guidance should be checked before deciding whether reporting or other action is required.

 

9. Monitor Immigration and Sponsorship Expiry Dates

 

Employers should maintain visibility over relevant immigration and sponsorship dates rather than relying on workers to raise approaching expiry dates themselves.

Where continued employment will require further immigration permission or sponsorship action, the organisation should identify the issue sufficiently early to allow the position to be assessed and any necessary steps to be taken.

A management system may therefore include reminders or review points before relevant expiry dates.

The appropriate lead time will depend on the circumstances, but the objective should be to avoid urgent decisions caused by expiry dates that were already known to the organisation.

 

10. Managing the End of Employment

 

The end of a sponsored worker’s employment should trigger the sponsor management process.

This can include resignation, dismissal, redundancy or another event bringing the sponsored employment to an end.

The organisation should ensure that the sponsorship team becomes aware of the termination promptly so that the applicable Home Office requirements can be considered and any required action taken within the relevant timeframe.

Termination processes should therefore connect HR offboarding with sponsor licence administration.

A sponsored worker should not simply leave payroll and the HR system without the sponsorship implications also being considered.

 

11. Make Sponsored Status Visible to the Right People

 

Effective management does not necessarily require every employee or manager to know an individual’s immigration history.

It does require the relevant decision-makers to know when a proposed employment action needs to be referred for sponsorship consideration.

A useful internal trigger is:

Is this employee sponsored? → Does this proposed change need immigration review before implementation?

This can be incorporated into HR workflows for promotions, salary reviews, changes of role, changes of location, absence management and termination.

 

12. Reconcile Sponsored-Worker Information

 

Periodic reconciliation can help identify inconsistencies between sponsorship information and the worker’s actual employment circumstances.

A practical comparison may involve:

SMS → sponsorship tracker → HR record → payroll → right to work record → current employment position

The organisation should investigate material differences rather than assuming one system is automatically correct.

For example, if payroll shows a different salary from the sponsorship record, the employer should establish when the change occurred, why it occurred, whether the sponsorship implications were considered and whether any action remains necessary.

The objective is to maintain an accurate and explainable picture of the sponsored workforce throughout the employment lifecycle.

 

 

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Section H: Managing Certificates of Sponsorship

 

Certificates of Sponsorship (CoS) are a core operational component of sponsor licence management.

A CoS is not a physical certificate. It is an electronic sponsorship record created and assigned through the Sponsor Management System. The information entered on the CoS is used as part of the worker’s immigration application and should accurately reflect the role and sponsorship arrangements being offered.

Employers should therefore treat CoS assignment as a controlled sponsorship decision rather than a routine administrative transaction.

 

1. Separate the Sponsorship Decision from CoS Assignment

 

A Level 1 User may have the technical ability to assign a CoS through the SMS, but the organisation should determine who has authority to approve sponsorship before that transaction takes place.

A practical process is:

Sponsorship requirement identified → eligibility assessed → sponsorship approved → CoS information verified → CoS assigned through SMS

This distinction helps prevent CoS assignment becoming an administrative response to a recruitment request without the underlying sponsorship position first being considered.

 

2. Check the Role Before Assigning a CoS

 

Before a CoS is assigned, the employer should verify the information relevant to the proposed sponsorship.

Depending on the immigration route and circumstances, this may include checking:

• the identity of the proposed worker;
• the relevant immigration route;
• the job title;
• the proposed duties;
• the appropriate occupation code;
• the salary;
• the working hours;
• the work location;
• the proposed employment dates;
• whether the role meets the applicable sponsorship requirements;
• whether the worker meets relevant route requirements;
• whether the organisation is licensed to sponsor under the relevant route; and
• whether the correct type of CoS is being used.

The precise eligibility rules belong within the relevant immigration route guidance. From a sponsor management perspective, the important point is that the organisation should verify the sponsorship basis before committing the CoS.

 

3. Defined and Undefined Certificates of Sponsorship

 

Employers using the Skilled Worker route need to understand whether a Defined or Undefined Certificate of Sponsorship is required in the particular circumstances.

The distinction affects how the CoS is obtained and managed through the SMS.

Because the detailed rules governing Defined and Undefined CoS are a separate sponsorship issue, employers should refer to the relevant specialist guidance rather than relying on a simplified rule within their general sponsor licence management process.

What matters operationally is that the organisation identifies the correct CoS type before assignment and allows sufficient time for any required application or allocation process.

 

4. Manage CoS Availability and Future Demand

 

Employers that sponsor workers regularly should monitor anticipated CoS requirements rather than dealing with each recruitment exercise in isolation.

Relevant management information may include:

• anticipated sponsored recruitment;
• existing sponsored workers who may require further sponsorship;
• available CoS allocation;
• pending requests;
• assigned CoS;
• unused CoS; and
• expected recruitment or workforce changes that may increase demand.

This allows sponsorship capacity to be considered alongside workforce planning.

It can also reduce the risk of recruitment being delayed because the organisation only discovers that additional sponsorship action is required when it is ready to assign the CoS.

 

5. Control Who Can Approve CoS Assignment

 

Employers should decide internally who has authority to approve the assignment of a CoS.

The approval process should be proportionate to the organisation’s sponsorship volume and risk profile.

For example, approval may involve confirmation from:

• recruitment that the proposed appointment has been authorised;
• HR that the employment terms are correct;
• the sponsorship or immigration function that the relevant requirements have been checked; and
• an authorised SMS user that the CoS information has been verified before assignment.

For some organisations, one appropriately qualified person may perform several of these functions. For larger employers, they may be divided between teams.

The key control is that a CoS should not be assigned simply because somebody asks an SMS user to issue one.

 

6. Maintain a CoS Approval Record

 

Where appropriate, employers should maintain an internal record showing why a CoS was approved.

A standard CoS approval record may capture:

• the worker;
• the proposed immigration route;
• the sponsored role;
• the occupation code;
• the salary and hours;
• the work location;
• the proposed sponsorship dates;
• the relevant CoS type;
• the person who checked the sponsorship position;
• the person who approved assignment; and
• the date the CoS was assigned.

This provides an internal audit trail and can help the employer explain the basis on which sponsorship was approved.

 

7. Verify CoS Information Before Submission

 

Information entered onto a CoS should be checked before assignment.

Errors can create problems for the worker’s immigration application and can also raise questions about the sponsor’s management processes.

Particular attention should be given to information such as:

• the worker’s personal details;
• job title;
• occupation code;
• job description;
• salary;
• hours;
• work address;
• employment dates; and
• other route-specific information required on the CoS.

The person carrying out the SMS transaction should work from verified information rather than reconstructing the employment details from memory or informal messages.

 

8. Avoid Uncontrolled CoS Assignment

 

Operational pressure can create risk where recruitment teams or hiring managers regard CoS assignment as an urgent administrative step required to complete a hire.

The sponsor should resist processes that bypass appropriate checks because a candidate is waiting or a recruitment deadline is approaching.

Where the required information is incomplete or the sponsorship position is unclear, the issue should be resolved before assignment.

The fact that the SMS allows an authorised user to complete a transaction does not establish that the underlying sponsorship decision is correct.

 

9. Monitor Assigned and Unused CoS

 

CoS management should continue after allocation or assignment.

Employers should maintain appropriate oversight of CoS that have been:

• made available to the organisation;
• assigned to workers;
• used in immigration applications;
• withdrawn or otherwise affected by changes; or
• left unused.

Where a proposed hire does not proceed, the sponsorship team should be informed rather than leaving the matter disconnected from the organisation’s wider CoS records.

 

10. Connect the CoS to the Sponsored-Worker Record

 

The CoS should form part of a continuous sponsorship record rather than existing as a standalone SMS transaction.

A useful management sequence is:

Recruitment approval → CoS assignment → immigration application → right to work process → employment → sponsored-worker monitoring

This allows the organisation to connect the basis on which the worker was sponsored with their subsequent employment circumstances.

If the role later changes, the employer can compare the proposed change against the original sponsorship position and determine whether further action is required.

 

11. Apply Controls Proportionate to Sponsorship Volume

 

A business sponsoring one or two workers will not necessarily need the same CoS management infrastructure as an organisation assigning hundreds of Certificates of Sponsorship each year.

Controls should be proportionate, but the underlying principles remain the same:

• confirm that sponsorship is appropriate;
• verify the information;
• use the correct CoS process;
• control who can approve assignment;
• retain an appropriate record of the decision; and
• connect the CoS to ongoing management of the sponsored worker.

The objective is to ensure that every CoS can be traced back to a considered and controlled sponsorship decision.

 

 

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Section I: Managing Changes Affecting the Sponsor Licence

 

Changes within the workforce or the organisation are one of the main sources of sponsor licence management risk.

The difficulty is rarely that employers deliberately ignore their sponsorship responsibilities. More commonly, a change takes place somewhere within the business but the people responsible for the sponsor licence do not become aware of it quickly enough to assess whether action is required.

Effective sponsor licence management therefore depends on having a reliable process for identifying relevant changes, assessing their sponsorship implications and completing any required action within the applicable timeframe.

 

1. Identify Worker-Related Changes

 

Changes affecting sponsored workers should trigger consideration of the sponsorship position.

Depending on the circumstances, relevant events can include:

• a change in job title;
• a change in duties or responsibilities;
• a promotion or internal transfer;
• a salary change;
• a change in working hours;
• a change in principal work location;
• certain changes involving client sites or other work locations;
• significant absence or attendance issues;
• changes affecting the worker’s employment status;
• changes to the employing entity;
• resignation;
• dismissal;
• redundancy; or
• another event affecting the basis on which the worker is sponsored.

Not every event will require the same response. Some changes may require an SMS report, some may require further immigration action and others may require no Home Office action.

The management requirement is to ensure that the event reaches somebody capable of making that assessment.

 

2. Identify Organisational Changes

 

Employers should also maintain a process for identifying organisational events that may affect the sponsor licence.

These can include:

• changes to the organisation’s name;
• changes to addresses or business locations;
• changes to key personnel;
• changes to SMS users;
• changes in ownership or control;
• mergers and acquisitions;
• TUPE transfers;
• corporate restructuring;
• changes to the employing entity;
• business disposals;
• insolvency events; and
• other material changes to the organisation or its sponsorship arrangements.

Some structural changes can have consequences that go considerably beyond updating information on the SMS. A sponsor licence is not transferable between legal entities, and certain changes can require a new sponsor licence application or other specific action.

These matters should therefore be escalated for assessment rather than treated as routine sponsor administration.

 

3. Build Sponsorship into Change Management

 

Sponsorship should be integrated into the organisation’s existing change-management processes.

For workforce changes, this may mean adding a sponsorship check to HR procedures dealing with promotions, salary reviews, transfers, changes in hours, location changes and termination.

For organisational changes, it may mean ensuring that legal, finance, company secretarial or senior management teams know when the sponsor licence needs to be considered.

A practical escalation process is:

Change identified → sponsorship team notified → immigration impact assessed → required action identified → deadline recorded → approval obtained → SMS or other action completed → evidence retained

This creates a clear route from the business event to the sponsorship response.

 

4. Understand the Applicable Reporting Deadline

 

Where a change is reportable, the employer needs to establish the correct deadline for that particular event.

Under the sponsor guidance, certain changes relating to sponsored workers generally have to be reported within 10 working days, unless otherwise specified.

Specified organisational and corporate changes can be subject to a 20-working-day requirement.

These are not universal deadlines for every sponsorship event.

The applicable requirement can depend on the nature of the change, the relevant immigration route and the current Home Office guidance. Employers should therefore avoid applying a blanket rule that all worker events have 10 working days or all organisational events have 20 working days.

The correct reporting requirement should be established for the particular circumstances.

 

5. Use Shorter Internal Escalation Deadlines

 

The Home Office reporting deadline should not become the organisation’s internal notification deadline.

If HR waits until the end of the relevant reporting period before informing the sponsorship team, there may be insufficient time to establish the facts, determine the correct action and complete the required process.

Employers should therefore aim for relevant events to be escalated internally as soon as they are identified.

For example:

Manager identifies change → HR informed immediately → sponsorship team notified → requirement assessed → action completed within applicable Home Office timeframe

This provides a buffer for investigation and professional advice where required.

 

6. Maintain a Sponsor Change Log

 

Organisations with regular sponsorship activity can benefit from maintaining a central log of potentially relevant changes.

The log may record:

• the worker or organisational issue;
• the date the event occurred;
• the date the sponsorship function became aware of it;
• the person who referred the matter;
• the sponsorship assessment;
• whether action was required;
• the applicable deadline;
• the person responsible for completing the action;
• the completion date; and
• where supporting evidence is retained.

This allows outstanding actions to be monitored and reduces reliance on individual memory or email correspondence.

 

7. Assess Planned Changes Before Implementation

 

Where an organisation knows that a change is going to occur, the sponsorship implications should ideally be considered before implementation.

This is particularly important where the proposed change concerns:

• a sponsored worker’s substantive duties;
• occupation code;
• salary;
• working hours;
• principal work location;
• employing entity;
• a corporate restructuring;
• a merger or acquisition;
• a TUPE transfer; or
• a change in ownership or control.

Considering the issue in advance allows the employer to establish whether the proposed arrangement is compatible with the existing sponsorship position and what steps may be required.

It is generally easier to manage a sponsorship issue before a commercial or employment change has taken effect than to correct the position retrospectively.

 

8. Distinguish Routine Changes from Structural Events

 

Not all sponsor licence changes should be managed through the same process.

A routine update concerning an individual sponsored worker may be capable of being assessed and handled through the organisation’s normal sponsorship procedures.

A merger, acquisition, change in ownership, TUPE transfer or change in employing entity may require a significantly more detailed analysis.

The sponsor management framework should therefore contain an escalation threshold.

Where a change potentially affects the identity, ownership or structure of the sponsor, the transfer of sponsored workers or the continuing validity of the existing licence arrangements, the matter should be treated as a corporate sponsorship issue and reviewed under the relevant Home Office requirements.

Detailed guidance on these situations is provided separately within our Sponsor Licence & Business Changes resources.

 

9. Record Why No Action Was Required

 

Good sponsor licence management does not mean reporting every change to the Home Office.

There will be situations where an event is reviewed and the conclusion is that no SMS report, new application or other sponsorship action is required.

For material issues, it can be useful to retain a brief record of that assessment.

This can establish:

• what happened;
• what facts were considered;
• which requirement was checked;
• why no action was considered necessary; and
• who made or approved the decision.

This can be particularly useful if the issue is subsequently questioned during an internal review or Home Office compliance activity.

 

10. Create a Reliable Route for Every Material Change

 

The objective is not to make every business decision dependent on the sponsorship team.

It is to ensure that relevant changes have a reliable route into sponsor licence management.

The organisation should be able to move from:

Business event → identification → assessment → action → evidence

without depending on chance or on one individual recognising the immigration implications.

The underlying principle is that every material workforce or organisational change with potential sponsorship implications should have a route into the sponsor management process.

 

 

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Section J: Managing Sponsor Licence Records

 

Effective sponsor licence management depends on the employer being able to retrieve evidence showing how its sponsorship activities have been managed.

The relevant information may be distributed across HR systems, payroll, recruitment records, right to work records, the Sponsor Management System, email correspondence, absence records, line management records and files held by external advisers.

The objective is not necessarily to store every sponsorship document in one location. It is to ensure that the organisation knows what records it holds, where they are located, who is responsible for them and how they can be retrieved when required.

 

1. Establish Clear Ownership of Sponsor Records

 

Employers should define responsibility for maintaining sponsorship-related records.

Depending on the organisation, different records may be held by different functions. For example:

• recruitment may hold information relating to the original recruitment process;
• HR may maintain personnel and employment records;
• payroll may hold salary and payment information;
• the sponsor licence team may maintain CoS and SMS records;
• line managers may hold information relating to attendance or working arrangements;
• legal or compliance teams may hold records relating to investigations or corporate changes; and
• external advisers may hold immigration applications, advice and correspondence.

The sponsor should understand how these records fit together and how relevant information can be accessed when required.

 

2. Maintain a Sponsored-Worker Record

 

Each sponsored worker should have an identifiable record that allows the employer to understand the basis of their sponsorship and their current employment position.

Depending on the applicable requirements and the organisation’s systems, this may connect information relating to:

• the worker’s identity;
• right to work;
• immigration permission;
• Certificate of Sponsorship;
• job title and duties;
• occupation code;
• salary and working hours;
• work location;
• employment contract;
• relevant recruitment information;
• absence and attendance;
• changes during employment;
• SMS reports or other sponsorship actions; and
• the end of sponsored employment.

The detailed Home Office document-retention requirements should be checked against the current sponsor guidance and Appendix D: Keeping Documents – Guidance for Sponsors.

This general management guide should not be treated as a substitute for the specific document and retention requirements that apply to sponsors.

 

3. Record Important Sponsorship Decisions

 

Employers should consider retaining an appropriate record of significant sponsorship decisions rather than recording only the final SMS transaction.

A useful decision trail is:

Issue identified → facts established → applicable requirement considered → decision made → approval obtained → SMS or other action completed → evidence retained

For example, where a sponsored worker changes role, the organisation may retain sufficient information to explain:

• the worker’s previous role;
• the proposed new role;
• the duties involved;
• the salary and hours;
• the sponsorship assessment;
• the action considered necessary; and
• when that action was completed.

This can be significantly more useful than an isolated note stating that the SMS was updated.

 

4. Record Material SMS Activity

 

For significant SMS actions, employers should be able to identify what was done and why.

This may include records relating to:

• CoS assignment;
• changes to key personnel;
• changes to SMS users;
• reports concerning sponsored workers;
• reports concerning the organisation;
• requests submitted through the SMS;
• responses to Home Office correspondence; and
• correction of previously identified issues.

The appropriate level of internal documentation will depend on the significance of the action and the organisation’s sponsorship activity.

The purpose is to maintain an explainable audit trail rather than to create unnecessary duplication of every item recorded on the SMS.

 

5. Distinguish Current Information from Historic Information

 

Sponsor records should make it possible to distinguish the organisation’s current position from its historic position.

This is particularly important where workers have changed roles, salaries, locations or other employment arrangements over time.

If records simply overwrite previous information, it may become difficult to establish what the position was at a particular point in the worker’s sponsorship history.

Employers should therefore consider how material historic information is preserved where it is relevant to demonstrating previous sponsorship decisions and compliance.

 

6. Use Appropriate Version Control

 

Where sponsorship documents are updated over time, basic version control can prevent uncertainty about which information was relied upon.

This can be relevant to documents such as:

• job descriptions;
• employment contracts;
• salary information;
• organisational charts;
• sponsorship procedures;
• CoS approval records;
• internal compliance reviews; and
• corporate documentation.

The employer should be able to establish which version applied when a material sponsorship decision was made.

 

7. Follow the Current Appendix D Requirements

 

The Home Office specifies sponsor record-keeping requirements through its sponsor guidance, including Appendix D.

Employers should use the current version of the relevant guidance when determining what documents must be retained and for how long.

Record-keeping requirements can vary depending on the document and circumstances. Employers should therefore avoid relying on a single general retention period for every sponsorship record.

Where the organisation’s own document-retention policy would result in relevant sponsorship evidence being destroyed earlier than permitted under the applicable sponsor requirements, the sponsorship requirements need to be incorporated into the organisation’s retention framework.

 

8. Records Held by External Advisers

 

Where an immigration adviser maintains sponsorship or immigration records on behalf of the employer, the organisation should understand what is being retained and how it can obtain the information when required.

The sponsor should not become dependent on an adviser to such an extent that it cannot establish its own sponsorship position without requesting reconstruction of historic activity.

The employer should consider:

• which records are held internally;
• which records are held by the adviser;
• how records are shared between them;
• who retains evidence of SMS actions;
• how quickly information can be retrieved; and
• what happens to the records if the adviser relationship ends.

The use of an adviser does not remove the sponsor’s responsibility for its licence or its sponsor duties.

 

9. Prepare Records for Home Office Scrutiny

 

Records should be maintained on the assumption that the employer may need to explain its sponsorship arrangements to the Home Office.

This does not mean creating a separate compliance file purely for a potential inspection. It means maintaining records in a way that allows the organisation to demonstrate what happened and how it responded.

A useful management question is:

If UKVI asked about this sponsored worker or this sponsor licence action today, could we retrieve the relevant information and explain what happened without reconstructing the position from memory?

If the answer is no, the record-management process may require improvement.

 

10. Reconcile Records Across Systems

 

Different organisational systems should not be assumed to contain identical information.

Periodic reconciliation can identify discrepancies between:

SMS → HR → payroll → right to work records → sponsored-worker records → corporate records

For example, if the HR system shows one salary, payroll shows another and the sponsorship records contain a third figure, the employer should investigate the discrepancy.

Likewise, if corporate records show that a business location has closed but sponsor licence information still reflects the historic position, the issue should be assessed.

The purpose of reconciliation is not simply to find administrative errors. It is to test whether the organisation’s sponsorship records continue to reflect what is actually happening within the business.

 

11. Records Should Support an Explainable Sponsorship History

 

The strongest sponsor record systems do more than store documents.

They allow the organisation to reconstruct the sponsorship history of a worker, decision or organisational change.

For a material issue, the records should make it possible to understand:

What happened → when it happened → when the sponsor knew → what was considered → what was decided → what action was taken → what evidence supports the position

This creates a clear connection between sponsor licence management, compliance and organisational accountability.

 

 

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Section K: Sponsor Licence Management Calendar

 

Sponsor licence management should operate continuously, but employers can also benefit from a structured management calendar.

The Home Office does not prescribe a monthly, quarterly or annual sponsor licence management timetable. The frequency of internal reviews should therefore reflect the organisation’s size, sponsorship activity, workforce structure and risk profile.

However, combining event-driven management with scheduled reviews can help employers identify problems that have not been captured through day-to-day processes.

A practical framework is:

Continuous → Events

Monthly → Operational checks

Quarterly → Reconciliation and access review

Annually → Governance and full sponsor management review

 

1. Continuous: Event-Driven Sponsor Management

 

The most important sponsor management activity takes place when relevant events occur.

The organisation should have processes capable of identifying events such as:

• a proposed sponsored hire;
• assignment of a Certificate of Sponsorship;
• a sponsored worker starting employment;
• a change in role or duties;
• a salary or hours change;
• a change in principal work location;
• significant absence;
• a sponsored worker leaving employment;
• a key sponsor licence person leaving or changing role;
• a change affecting SMS access;
• a change to organisational information;
• a merger, acquisition or restructuring; or
• another event with potential sponsorship implications.

These events should be assessed when they happen rather than waiting for the next scheduled sponsor licence review.

 

2. Monthly: Operational Sponsor Licence Checks

 

For organisations with regular sponsorship activity, a monthly operational review can provide a useful management checkpoint.

The review may consider:

• new sponsored workers;
• workers who have left;
• recent employment changes;
• outstanding SMS actions;
• approaching immigration expiry dates;
• Certificates of Sponsorship assigned during the period;
• unused or anticipated CoS requirements;
• outstanding Home Office correspondence;
• changes involving key personnel or SMS users; and
• issues awaiting advice or escalation.

The purpose is not to repeat every action already completed during the month. It is to identify matters that remain outstanding or may have fallen between different organisational processes.

 

3. Quarterly: Reconcile Sponsor Information

 

A broader periodic reconciliation can compare sponsorship information with the organisation’s operational records.

A useful review sequence is:

SMS → sponsored-worker population → HR → payroll → right to work records → corporate information

The employer can use this exercise to identify inconsistencies such as:

• workers appearing in one system but not another;
• differences in salary information;
• changes in roles or work locations;
• employees who have left;
• outdated sponsor licence information;
• unresolved sponsorship actions; or
• corporate changes that have not been assessed.

The appropriate frequency will depend on sponsorship volume and organisational risk. Quarterly reconciliation is a management recommendation rather than a Home Office-mandated timetable.

 

4. Quarterly: Review SMS Access

 

Employers should periodically review who has access to the SMS.

The review should consider:

• current Level 1 Users;
• whether each user remains eligible and requires access;
• whether any user has changed role or left;
• whether any account is becoming inactive;
• whether sufficient Level 1 User coverage exists;
• whether any existing Level 2 User account requires conversion or deactivation during the phase-out period; and
• whether external adviser access remains appropriate.

Particular attention should be given to SMS users who are not accessing the system regularly. Under current Home Office arrangements, an SMS User account may be regarded as inactive where the user has not accessed it for 12 months or more, and UKVI can deactivate inactive accounts.

The organisation should therefore ensure that it maintains an eligible and operational Level 1 User rather than relying on an account that exists in name but is no longer actively used.

 

5. Review Certificate of Sponsorship Requirements

 

Employers that sponsor workers regularly should periodically consider anticipated CoS demand.

This can involve reviewing:

• planned international recruitment;
• existing workers who may require further sponsorship;
• current CoS availability;
• pending requests;
• assigned CoS;
• unused CoS; and
• known recruitment campaigns or workforce changes.

Connecting CoS planning with recruitment forecasts can help avoid unnecessary delays when a sponsored hire is ready to proceed.

 

6. Annual Sponsor Licence Management Review

 

Even where no sponsor licence renewal application is required, employers should consider carrying out a broader periodic review of their sponsorship arrangements.

For many organisations, an annual review provides a practical governance checkpoint.

The review can examine:

• sponsor licence governance;
• the Authorising Officer and other key personnel;
• SMS users and access controls;
• sponsored-worker information;
• CoS processes;
• licence information;
• reporting and change-management procedures;
• record keeping;
• HR and payroll integration;
• recruitment processes;
• corporate changes;
• training requirements;
• continuity arrangements; and
• previously identified compliance issues.

The review should not simply confirm that procedures exist. It should test whether they are operating effectively in practice.

 

7. Use the Annual Review to Replace the Lost Renewal Trigger

 

Since routine four-year sponsor licence renewal was removed for most Worker and Temporary Worker sponsors, many organisations no longer have a recurring Home Office renewal application that naturally prompts them to review their sponsorship arrangements.

For most sponsors, the licence can continue for as long as the organisation remains eligible and continues to meet the applicable requirements. Certain routes, including Scale-up and UK Expansion Worker sponsorship, remain subject to different validity arrangements.

The absence of routine renewal does not reduce the need for active licence management.

Employers may therefore find it useful to retain their own annual sponsor licence review as an internal governance discipline, even where there is no Home Office renewal application to complete.

 

8. Schedule Sponsor Management Training

 

Training should not be limited to the people who operate the SMS.

Depending on their responsibilities, relevant training or awareness may be appropriate for:

• Authorising Officers;
• Level 1 Users;
• HR personnel;
• recruitment teams;
• payroll personnel;
• line managers;
• legal or compliance teams; and
• senior managers involved in significant organisational changes.

The level of training should reflect the person’s role.

A line manager may only need to understand which events must be escalated internally, while a Level 1 User will require a more detailed understanding of the SMS and relevant sponsor requirements.

 

9. Test the Management Framework

 

Employers should periodically test whether their sponsor licence management processes work in practice.

This can involve selecting a sample of sponsored workers and checking whether the organisation can reconcile:

CoS information → immigration status → right to work → HR record → payroll → current role → salary → work location → SMS activity

The employer can also test whether:

• relevant records can be retrieved promptly;
• key personnel understand their responsibilities;
• line managers know how to escalate changes;
• SMS access remains appropriate;
• business changes reach the sponsorship function; and
• identified issues are followed through to completion.

This can be carried out as an internal sponsor licence audit or mock compliance review.

 

10. Increase Review Frequency When Risk Changes

 

A fixed calendar should not prevent the organisation from increasing oversight when circumstances change.

More frequent review may be appropriate where:

• the number of sponsored workers increases significantly;
• the organisation expands into new locations;
• new HR or payroll systems are introduced;
• key sponsorship personnel change;
• the organisation undergoes restructuring;
• a merger or acquisition is planned;
• compliance weaknesses have been identified;
• the Home Office has raised concerns; or
• there are significant changes to sponsor guidance or SMS requirements.

The management calendar should therefore be proportionate and responsive rather than treated as a rigid timetable.

The objective is to combine continuous event-driven management with periodic structured review so that the sponsor licence remains under active organisational control.

 

 

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Section L: Managing a Sponsor Licence Across Multiple Sites or Business Units

 

Managing a sponsor licence can become more complex where an organisation operates across multiple offices, sites, divisions or business units.

The central challenge is maintaining consistent sponsorship governance while ensuring that information arising locally reaches the people responsible for the sponsor licence.

A central sponsor licence team cannot manage events it does not know about. Equally, allowing individual sites or business units to operate sponsorship independently without appropriate oversight can create inconsistent practices and gaps in control.

For larger organisations, an effective model will often combine central governance with reliable local information flows.

 

1. Centralise Governance, Not Necessarily Every Task

 

Employers do not necessarily need every sponsorship-related activity to be carried out by one central team.

Local HR teams, recruiters and managers may legitimately perform parts of the process, particularly in organisations with geographically dispersed workforces.

However, the organisation should maintain consistent governance over matters such as:

• sponsorship policy;
• authority to sponsor workers;
• CoS approval;
• SMS access;
• interpretation of sponsor requirements;
• significant worker changes;
• corporate changes;
• compliance concerns; and
• escalation to senior management or professional advisers.

This allows local teams to support the process without creating separate and inconsistent sponsorship regimes within the same organisation.

 

2. Create Local Escalation Routes

 

Local HR teams and managers should know which events need to be referred to the central sponsorship function.

Examples can include:

• a sponsored worker changing role;
• a promotion;
• a salary or hours change;
• a change in principal work location;
• significant absence;
• a worker leaving employment;
• a proposed sponsored recruit;
• changes affecting a local business site; and
• changes involving the structure or ownership of a business unit.

The local team does not necessarily need to determine the immigration consequences. Its role can simply be to recognise the trigger and escalate it promptly.

A useful model is:

Local event → local HR or manager → central sponsorship function → assessment → action → confirmation back to local team

 

3. Coordinate Multiple Recruitment Teams

 

Organisations with multiple recruitment teams should ensure that sponsorship is handled consistently.

Without central controls, different business units may adopt different approaches to questions such as:

• when sponsorship is available;
• which roles can be sponsored;
• when immigration advice is required;
• who can approve a sponsored hire;
• who requests or assigns a CoS; and
• what information has to be provided before assignment.

A standard sponsorship referral or approval process can reduce inconsistency and prevent individual recruiters from making assumptions about immigration eligibility.

 

4. Maintain Visibility of Sponsored Workers Across Locations

 

The sponsor should be able to identify its sponsored workers regardless of where they are based within the organisation.

For a multi-site employer, this may require a central sponsorship record containing information about:

• the worker;
• their business unit;
• their principal work location;
• their role;
• their salary;
• their line manager;
• their immigration route;
• relevant immigration expiry dates; and
• the local HR contact responsible for employment information.

This allows the central sponsorship function to understand the organisation’s sponsored population without relying on separate local records that may not be consistent.

 

5. Manage Movement Between Sites and Business Units

 

Internal movement should trigger consideration of whether the worker’s sponsorship position is affected.

A move between offices within the same sponsoring legal entity may raise different issues from a transfer to another company within a corporate group.

Employers should not assume that because two businesses are part of the same group, a sponsored worker can move freely between them under the existing sponsor licence.

The assessment should consider matters such as:

• whether the legal employer is changing;
• whether the role or duties are changing;
• whether the principal work location is changing;
• whether salary or working hours are changing;
• whether the worker remains within the scope of the existing sponsorship; and
• whether reporting, a new CoS, a new immigration application or other action may be required.

Where the employing entity may change, the issue should be escalated before the transfer takes place.

 

6. Control Local Decision-Making

 

Local managers may have authority to make employment decisions, but those decisions can have sponsorship consequences.

For example, a manager may wish to:

• promote a sponsored employee;
• change their duties;
• increase or reduce their hours;
• change their salary;
• move them to another location; or
• transfer them to another business unit.

The organisation should make clear that relevant changes involving sponsored workers require sponsorship consideration before implementation.

This does not mean removing normal management authority. It means ensuring immigration consequences form part of the decision-making process.

 

7. Use Local Sponsorship Contacts Where Appropriate

 

Larger employers may benefit from identifying a sponsorship contact within each major site, division or business unit.

The local contact does not necessarily need SMS access.

Their role may instead be to:

• identify sponsored workers within the local workforce;
• ensure relevant changes are escalated;
• support collection of required information;
• help maintain local records;
• communicate central sponsorship procedures; and
• act as a contact point between local management and the central sponsorship team.

This can provide a practical bridge between central governance and local operations.

 

8. Standardise Sponsor Management Processes

 

Multi-site organisations should aim to use consistent processes across the business.

Standardised processes may cover:

• sponsorship approval;
• CoS requests;
• new sponsored-worker onboarding;
• role and salary changes;
• work-location changes;
• absence escalation;
• termination;
• record keeping;
• SMS activity; and
• escalation of potential compliance issues.

Standardisation helps the organisation test whether the same controls are operating across different parts of the business.

 

9. Centralise Data While Verifying Locally

 

A central sponsorship record can provide visibility across the organisation, but the information should be periodically verified against local employment records.

A practical reconciliation may involve:

Central sponsorship record → local HR → payroll → line manager → SMS

This can identify differences between what the central team believes is happening and the worker’s actual circumstances at a particular location.

For example, a central record may show that a worker remains in their original role while the local manager has changed their day-to-day responsibilities.

Local verification can therefore identify changes that formal HR or sponsorship systems have not captured.

 

10. Understand the Position of Different Group Companies

 

Employers operating through corporate groups should distinguish carefully between different legal entities.

The fact that companies share ownership, management, branding, premises or HR systems does not automatically mean that they are covered in the same way by a particular sponsor licence.

Before sponsored workers are moved between group companies or sponsorship arrangements are reorganised, the employer should establish:

• which legal entity holds the sponsor licence;
• which entity employs the worker;
• which entities or arrangements are covered by the licence;
• whether the proposed change affects sponsorship; and
• whether any new application, reporting or immigration action is required.

Changes involving group structures, mergers, acquisitions and transfers can raise complex sponsor licence issues and should be reviewed under the relevant corporate change requirements.

 

11. Scale the Sponsor Management Framework as the Organisation Grows

 

A sponsor management process that works for an organisation with five sponsored workers may become inadequate when the sponsored workforce grows to 50 or 500.

Growth can increase:

• the volume of CoS activity;
• the number of employment changes;
• the number of people involved in recruitment;
• the number of HR and payroll transactions;
• the number of business locations;
• the number of SMS users required;
• the volume of sponsor records; and
• the likelihood that relevant information becomes fragmented.

Employers should therefore review whether their management framework remains proportionate as sponsorship activity increases.

The objective is to maintain the same level of organisational control as the sponsorship population and business structure become more complex.

 

 

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Section M: What Happens When the Person Managing the Sponsor Licence Leaves?

 

The departure of a person involved in managing the sponsor licence should be treated as a sponsor licence event rather than simply an ordinary employee offboarding exercise.

The risk is particularly significant where the departing employee is an Authorising Officer, Key Contact, Level 1 User or the person who holds most of the organisation’s practical knowledge about sponsorship.

Employers should have continuity arrangements that allow sponsorship activity to continue without relying on the credentials, knowledge or availability of one individual.

 

1. Identify the Person’s Sponsor Licence Responsibilities

 

When someone involved in sponsorship is due to leave, the organisation should establish exactly what responsibilities they hold.

This may include:

• acting as Authorising Officer;
• acting as Key Contact;
• holding Level 1 User access;
• holding an existing Level 2 User account during the current phase-out period;
• assigning Certificates of Sponsorship;
• maintaining sponsored-worker records;
• monitoring immigration expiry dates;
• managing Home Office correspondence;
• coordinating external immigration advisers;
• maintaining sponsorship trackers;
• monitoring outstanding SMS actions; or
• providing internal sponsorship advice to HR and recruitment teams.

The employer should identify both the person’s formal sponsor management role and the practical functions they perform.

This distinction matters because an employee may have accumulated substantial operational responsibility even where their formal SMS role appears relatively limited.

 

2. Act Before the Individual Leaves Where Possible

 

Where a departure is planned, the sponsor should use the notice period to transfer sponsorship responsibilities.

This can include:

• identifying replacement key personnel where required;
• ensuring appropriate Level 1 User coverage;
• reviewing outstanding sponsorship actions;
• transferring relevant records;
• documenting recurring processes;
• reviewing approaching deadlines;
• transferring adviser relationships;
• checking outstanding Home Office correspondence; and
• ensuring the replacement personnel understand the organisation’s sponsored-worker population.

Leaving these issues until after the employee has departed can create unnecessary operational and compliance risk.

 

3. Maintain an Eligible Authorising Officer

 

If the departing individual is the Authorising Officer, the organisation should consider the replacement arrangements promptly.

Sponsors are expected to maintain an eligible Authorising Officer throughout the life of the licence.

The replacement should satisfy the applicable Home Office eligibility requirements and be sufficiently senior and appropriately positioned to take overall responsibility for the organisation’s activities as a licensed sponsor.

The role should not simply be transferred to another employee because they are available. The organisation should consider whether the proposed replacement is suitable to exercise the required oversight.

 

4. Maintain an Eligible and Operational Level 1 User

 

The sponsor should also ensure that it continues to have an eligible Level 1 User capable of operating the SMS.

This is particularly important where the departing employee is the organisation’s only active Level 1 User.

A sponsor should not assume that another employee can simply use the departing person’s login details. SMS accounts are personal to the authorised user, and passwords and multi-factor authentication information must not be shared.

If the organisation needs another person to operate the SMS, that person should be appointed and given access through the appropriate authorised process.

 

5. Never Transfer SMS Credentials

 

The departure of an SMS user does not justify sharing or transferring their login credentials.

The departing employee should not provide their password or multi-factor authentication passcode to their replacement, manager, HR department or external adviser.

Likewise, the organisation should not maintain a departing employee’s SMS account so that another person can continue using it.

The correct approach is to establish appropriate authorised access for the person who will take over the relevant functions.

 

6. Review Existing Level 2 User Accounts

 

If the departing employee is an existing Level 2 User, the organisation should consider the position in the context of the current withdrawal of the Level 2 User category.

Since 9 September 2026, sponsors have not been able to appoint new Level 2 Users.

Existing Level 2 Users must be converted to Level 1 Users, where eligible and appropriate, or have their accounts deactivated by 8 March 2027. Remaining Level 2 User accounts are due to be deactivated after that date.

The organisation should therefore avoid attempting to replace a departing Level 2 User with another Level 2 User. Instead, it should determine how the relevant functions will be handled under the Level 1 User arrangements.

 

7. Review Outstanding Sponsor Licence Actions

 

Before responsibility transfers, the employer should identify all outstanding sponsorship matters being handled by the departing person.

This may include:

• CoS requests;
• CoS assignments;
• worker changes awaiting assessment;
• SMS reports;
• licence changes;
• Home Office requests;
• immigration expiry dates;
• pending visa applications;
• compliance issues;
• planned sponsored recruitment; and
• corporate changes with sponsorship implications.

A formal handover list can help prevent an outstanding action from being lost when responsibility changes.

 

8. Transfer Organisational Knowledge

 

One of the greatest risks created by a departure may be the loss of knowledge rather than the loss of SMS access itself.

The departing employee may know:

• why particular sponsorship decisions were made;
• where supporting documents are stored;
• which workers require particular attention;
• which matters are awaiting advice;
• how internal sponsorship processes operate;
• which managers or HR personnel provide relevant information; and
• what historic issues have affected the licence.

Where possible, this knowledge should be transferred and documented before the employee leaves.

A sponsor licence management framework should not depend on undocumented knowledge held by one person.

 

9. Review Sponsor Records

 

A change in the person managing the licence provides a useful opportunity to review the organisation’s sponsorship records.

The incoming person should be able to identify:

• the current sponsored-worker population;
• active Certificates of Sponsorship and relevant CoS activity;
• current key personnel;
• current SMS users;
• outstanding actions;
• upcoming immigration expiry dates;
• recent worker changes;
• recent organisational changes;
• current Home Office correspondence; and
• previously identified compliance concerns.

This helps establish a clear baseline for the transfer of responsibility.

 

10. Remove Obsolete Access

 

Once an employee no longer requires SMS access, the organisation should ensure the account and relevant sponsor management arrangements are reviewed and updated as required.

This should form part of the employer’s normal leaver process rather than depending on somebody remembering separately that the individual had sponsor licence responsibilities.

A useful control is to include the following question within employee offboarding:

Does this employee hold any sponsor licence, key personnel or SMS responsibilities?

If the answer is yes, the departure should automatically be referred to the person responsible for sponsor licence management.

 

11. Deal Promptly with Unexpected Departures

 

Not every departure can be planned.

An employee may leave without notice, become seriously ill or otherwise become unavailable unexpectedly.

Where this happens, the employer should establish immediately:

• which sponsor management roles the individual held;
• whether the organisation still has an eligible Authorising Officer;
• whether there is an eligible and operational Level 1 User;
• whether urgent SMS actions are outstanding;
• whether any reporting deadlines are running;
• whether Home Office correspondence requires action;
• where the relevant records are held; and
• who will assume operational responsibility.

The organisation should then take the necessary steps to restore appropriate sponsor management arrangements.

 

12. Avoid Inactive Level 1 User Risk

 

Continuity planning should also consider whether the organisation’s remaining SMS users are actually active.

Under current Home Office arrangements, an SMS User account can be treated as inactive where the user has not accessed it for 12 months or more, and UKVI can deactivate inactive accounts.

This means an employer should not assume it has adequate continuity simply because another person is historically recorded as a Level 1 User.

If the deactivation process leaves the sponsor without an active Level 1 User, UKVI can suspend the sponsor licence and require the organisation to nominate an eligible Level 1 User within 28 days. Failure to resolve the position within the required period can place the licence at risk of revocation.

Employers should therefore ensure that continuity arrangements rely on eligible and operational users rather than dormant accounts.

 

13. Build Sponsor Responsibilities into Joiner, Mover and Leaver Processes

 

The strongest approach is to integrate sponsor licence responsibilities into the organisation’s wider personnel controls.

A practical model is:

Joiner → appropriate role and access established

Mover → sponsorship responsibilities and access reviewed

Leaver → responsibilities transferred and obsolete access removed

This applies both to sponsored workers and to the employees responsible for administering the sponsor licence.

The underlying principle is that the sponsor licence belongs to the organisation, not to the individual administrator.

People can change, but the organisation must retain the knowledge, access, governance and systems required to continue managing the licence properly.

 

 

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Section N: Common Sponsor Licence Management Mistakes

 

Sponsor licence problems often develop through weaknesses in management rather than a single deliberate breach of the sponsor rules.

An organisation may have experienced HR staff, competent SMS users and external immigration support but still be exposed if responsibility is fragmented, information does not move between teams or sponsorship processes depend too heavily on individual knowledge.

Recognising common management weaknesses can help employers identify where their own arrangements need improvement.

 

1. Relying on One Person to Manage Everything

 

One of the most common weaknesses is allowing one individual to become responsible for almost every aspect of sponsorship.

That person may operate the SMS, maintain the sponsored-worker tracker, communicate with advisers, monitor expiry dates, assign Certificates of Sponsorship and answer internal immigration questions.

The arrangement may appear efficient while that individual remains available, but it creates significant dependency.

If they leave unexpectedly, become unavailable or lose SMS access, the organisation can struggle to establish what actions are outstanding and how the licence has been managed.

Employers should therefore build continuity into their sponsorship arrangements and avoid allowing essential knowledge to exist only in one person’s head.

 

2. Nobody Clearly Owns the Sponsor Licence

 

The opposite problem can also occur: several people are involved in sponsorship, but nobody has clear responsibility for ensuring the overall system works.

HR may assume the Level 1 User is responsible. The Level 1 User may assume the Authorising Officer is responsible. Recruitment may assume HR is dealing with sponsorship, while senior management assumes the immigration adviser is managing everything.

This creates gaps between functions.

The organisation should therefore distinguish between senior governance responsibility, operational responsibility and the individual tasks performed by different teams.

 

3. Treating the SMS as the Sponsor Management System

 

The Sponsor Management System is a Home Office platform. It is not a substitute for the employer’s internal sponsor management framework.

The SMS cannot automatically identify that:

• HR has changed a sponsored worker’s salary;
• a line manager has changed the worker’s duties;
• payroll information no longer matches sponsorship records;
• a business location has closed;
• an SMS user has changed role;
• a corporate transaction is being planned; or
• a sponsored worker has stopped attending work.

The employer needs internal processes capable of identifying these events and connecting them to the sponsorship function.

 

4. Failing to Review SMS Users

 

SMS access should not remain unchanged indefinitely.

Employers should periodically check whether users remain employed, eligible, appropriately positioned and operationally active.

This has become particularly important following the 2026 changes affecting SMS access, including the phased introduction of multi-factor authentication, the withdrawal of the Level 2 User category and the Home Office approach to inactive SMS accounts.

Existing Level 2 User accounts require active management during the phase-out period, while users who have not accessed the SMS for 12 months or more may be treated as inactive and their accounts can be deactivated by UKVI.

 

5. Allowing Former Staff to Remain in Sponsor Arrangements

 

When an employee leaves, their sponsor licence responsibilities should be reviewed as part of the offboarding process.

This applies particularly where the person is an Authorising Officer, Key Contact or SMS user.

Employers should not discover months later that a person recorded in a key sponsor role no longer works for the organisation.

A simple leaver control asking whether the employee holds any sponsor licence responsibilities can help ensure the issue is escalated immediately.

 

6. HR Changes Do Not Reach the Sponsorship Team

 

Many sponsorship problems begin as ordinary HR events.

A worker may receive a promotion, salary adjustment, new duties, different hours or a change of work location. If the sponsorship team is not informed, the immigration implications may never be considered.

Employers should therefore embed sponsorship triggers into relevant HR workflows.

A useful question is:

Is this employee sponsored, and does this proposed change need immigration review before implementation?

 

7. Assigning Certificates of Sponsorship Without Adequate Controls

 

A CoS should not be assigned merely because a recruiter or hiring manager requests one.

The organisation should have a process for verifying the proposed role, relevant immigration route, occupation code, salary, hours, work location and other information required for sponsorship before assignment.

Where the sponsorship position is unclear, the issue should be resolved before the CoS is assigned rather than attempting to correct the position later.

 

8. Allowing Sponsor Licence Information to Become Outdated

 

Businesses change continuously, while sponsor licence information can remain static unless somebody actively maintains it.

Changes involving addresses, business locations, key personnel, SMS users, organisational structure or ownership can therefore create discrepancies between the organisation and its sponsorship records.

Employers should combine event-driven reporting with periodic review of licence information.

 

9. Managing Reporting Deadlines from Memory

 

Employers should not rely on staff remembering reporting deadlines without checking the applicable current guidance.

Certain sponsored-worker changes generally have to be reported within 10 working days, while specified organisational changes can be subject to 20-working-day requirements, but these are not universal deadlines for every event.

The correct requirement should be established for the particular circumstances and recorded where action is required.

Internal escalation should also occur earlier than the Home Office deadline to allow sufficient time for assessment and action.

 

10. Discovering Corporate Changes Too Late

 

Corporate transactions can create significant sponsor licence consequences.

If the sponsorship team only becomes aware of a merger, acquisition, TUPE transfer, restructuring or ownership change after completion, the organisation may already be working within a limited timeframe for required action.

Sponsorship should therefore form part of corporate transaction planning where a licensed sponsor or sponsored workers are involved.

Significant structural events should be escalated under the relevant corporate change requirements rather than treated as routine SMS updates.

 

11. Failing to Reconcile Different Systems

 

HR, payroll, recruitment, right to work and sponsorship systems can gradually develop different versions of the same worker information.

Periodic reconciliation can identify discrepancies between:

SMS → sponsorship records → HR → payroll → right to work records → current employment circumstances

Differences should be investigated rather than assuming that one system is automatically correct.

 

12. Treating External Advisers as a Substitute for Internal Management

 

External immigration advisers can provide valuable support, but they cannot replace the employer’s internal information flows.

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

The organisation therefore still needs processes for identifying sponsored-worker changes, corporate events and other sponsorship issues and communicating them to the adviser promptly.

The sponsor remains responsible for its licence and sponsorship activities.

 

13. Reviewing Compliance Only When the Home Office Makes Contact

 

Waiting for a Home Office compliance visit, information request or other intervention before reviewing the sponsor licence is a reactive approach.

Employers should periodically test their sponsorship arrangements while they have the opportunity to identify and address weaknesses themselves.

Internal reviews can consider governance, SMS access, sponsored-worker information, CoS processes, reporting arrangements, records and the flow of information between departments.

 

14. Failing to Scale Sponsor Management as the Organisation Grows

 

Processes that were adequate when an organisation sponsored two workers may not remain adequate when it sponsors 20, 100 or several hundred.

Growth can increase the volume of:

• CoS activity;
• sponsored recruitment;
• worker changes;
• SMS transactions;
• HR and payroll events;
• business locations;
• records;
• internal stakeholders; and
• potential compliance issues.

The sponsor management framework should therefore develop alongside the organisation’s sponsorship activity.

 

15. Treating Sponsor Management as an Immigration-Only Function

 

Sponsor licence management sits at the intersection of immigration, recruitment, HR, payroll, operations and corporate management.

If sponsorship is isolated within an immigration function, relevant information may not reach it.

The strongest management arrangements connect sponsorship to the ordinary events occurring throughout the business.

The objective is not to turn every employee into an immigration specialist. It is to ensure that relevant people recognise when an event needs to be escalated.

 

16. The Common Pattern Behind Sponsor Management Failures

 

Many sponsor licence management failures follow a similar pattern:

Business event occurs → sponsorship implications are not recognised → information does not reach the right person → required assessment does not take place → deadline or action is missed → records become inconsistent → problem is discovered later

The strongest sponsor management systems interrupt that sequence at the beginning.

They ensure the organisation can reliably identify relevant events, direct them to the appropriate person, determine what action is required and retain evidence of what was done.

 

 

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Section O: Sponsor Licence Management Checklist

 

A sponsor licence management checklist can help employers test whether the licence remains under effective organisational control.

The checklist should not be treated as a substitute for the Home Office sponsor guidance or as confirmation that every sponsor duty has been met. Its purpose is to provide a structured management review covering the people, systems, workers, processes and information involved in operating the licence.

Employers can adapt the checklist to reflect the size, structure and complexity of their organisation and sponsored workforce.

 

1. Governance

• Is there clear senior ownership of the sponsor licence?
• Does the Authorising Officer understand their responsibilities?
• Is the Authorising Officer still eligible and appropriately positioned within the organisation?
• Is responsibility for day-to-day sponsor licence management clearly allocated?
• Are sponsorship decisions subject to appropriate internal authority?
• Is there a defined process for escalating significant sponsorship or compliance concerns?
• Does senior management receive appropriate information about material sponsor licence issues?

 

2. Key Personnel

• Are the organisation’s current key personnel details accurate?
• Does the organisation continue to have an eligible Authorising Officer?
• Is the Key Contact information current?
• Does the organisation maintain an eligible and operational Level 1 User?
• Have departures or role changes affecting key personnel been dealt with appropriately?
• Are replacement arrangements in place where a key person is due to leave?
• Are relevant sponsor responsibilities incorporated into joiner, mover and leaver procedures?

 

3. SMS Access

• Does the organisation know who currently has SMS access?
• Does each user still require access?
• Are users eligible and appropriate for the permissions they hold?
• Are SMS accounts being used only by the individuals to whom they were issued?
• Are passwords and multi-factor authentication passcodes kept personal and secure?
• Have inactive or unnecessary accounts been identified?
• Has the organisation checked whether any SMS User account has been inactive for 12 months or more?
• Does the organisation have sufficient Level 1 User coverage to maintain continuity?
• Have existing Level 2 Users been identified for conversion to Level 1 User status, where eligible and appropriate, or deactivation before the end of the phase-out period?
• Are external adviser access arrangements appropriately controlled?

 

4. Sponsor Licence Information

• Does the information associated with the sponsor licence reflect the organisation as it currently operates?
• Are the organisation’s name and relevant trading details current?
• Are business addresses and locations accurate?
• Are key personnel details current?
• Are relevant corporate details accurate?
• Have significant changes since the previous review been assessed for sponsorship purposes?
• Are the immigration routes covered by the licence still appropriate to the organisation’s sponsorship activity?

 

5. Sponsored Workers

• Can the organisation identify its complete current sponsored-worker population?
• Does it know which immigration route applies to each sponsored worker?
• Are current roles, duties, occupation codes, salaries and hours appropriately recorded?
• Are principal work locations known?
• Are relevant working patterns and locations capable of being explained where required?
• Are immigration permission expiry dates monitored?
• Are changes during employment being referred for sponsorship consideration?
• Are worker departures connected to the sponsor management process?

 

6. Certificates of Sponsorship

• Is there a defined process for approving sponsorship before a CoS is assigned?
• Is the proposed role checked against the relevant sponsorship requirements?
• Are occupation code, duties, salary, hours, work location and employment dates verified before assignment?
• Is the correct type of CoS being used?
• Does the organisation know who can approve CoS assignment?
• Are significant CoS decisions appropriately documented?
• Are assigned and unused CoS monitored?
• Is anticipated CoS demand considered alongside recruitment planning?

 

7. Reporting and Change Management

• Do HR, recruitment, payroll and relevant managers know which events should be escalated?
• Is there a process for identifying worker-related changes?
• Is there a process for identifying organisational changes?
• Are applicable Home Office reporting deadlines checked for the particular event rather than assumed?
• Are internal escalation deadlines sufficiently early to allow assessment and action?
• Are outstanding reports or actions tracked?
• Are material decisions that no Home Office action is required appropriately recorded?
• Are planned changes considered before implementation where possible?

 

8. HR and Payroll Integration

• Can HR identify sponsored workers when employment changes are proposed?
• Are salary changes referred for sponsorship consideration?
• Are changes in hours, role, duties or work location referred appropriately?
• Are absence and attendance issues capable of being escalated?
• Does payroll know how to identify changes affecting sponsored workers?
• Are payroll records periodically reconciled against sponsorship information?
• Are termination processes connected to sponsor licence administration?

 

9. Recruitment Integration

• Does recruitment identify potential sponsorship requirements early in the hiring process?
• Are sponsored roles assessed before an offer progresses too far?
• Is there a defined route for referring sponsorship questions?
• Are hiring managers prevented from bypassing sponsorship controls because a recruitment exercise is urgent?
• Are recruitment approval and CoS assignment connected through a controlled process?

 

10. Sponsor Records

• Does the organisation know where sponsorship records are held?
• Is responsibility for maintaining relevant records clearly allocated?
• Can sponsored-worker records be retrieved promptly?
• Are material sponsorship decisions documented?
• Are significant SMS actions capable of being explained?
• Can current information be distinguished from historic information?
• Is appropriate version control used for material documents?
• Are current Appendix D requirements being followed?
• Are records held by external advisers accessible to the sponsor?

 

11. Internal Reconciliation

• Does the organisation periodically compare SMS information with its internal records?
• Are sponsorship records compared with HR information?
• Are relevant salary details compared with payroll?
• Are right to work records connected to the sponsored-worker population?
• Are discrepancies investigated rather than ignored?
• Can the organisation reconcile its current sponsored-worker population across relevant systems?

A useful reconciliation model is:

SMS → sponsorship records → HR → payroll → right to work → current employment position

 

12. Business Changes

• Does the sponsorship function become aware of significant organisational changes?
• Are mergers, acquisitions and TUPE transfers referred for sponsor licence assessment?
• Are changes in ownership or control escalated?
• Are restructures assessed where they may affect sponsorship?
• Are changes to the employing entity identified before implementation?
• Are new or closed business locations considered?
• Is sponsorship included within relevant corporate transaction planning?

 

13. Training

• Have key sponsor personnel received appropriate training?
• Do Level 1 Users understand current SMS requirements?
• Are relevant personnel aware of the 2026 changes to SMS access, including MFA and the Level 2 User phase-out?
• Do HR personnel understand the types of employment changes that should be escalated?
• Do recruitment teams understand when sponsorship needs to be considered?
• Do payroll personnel understand the significance of changes affecting sponsored workers?
• Do relevant line managers know which events should be referred?
• Is training refreshed when responsibilities or Home Office requirements materially change?

 

14. Continuity and Resilience

• Would the organisation still be able to operate its sponsor licence if the principal administrator left tomorrow?
• Is there sufficient Level 1 User coverage?
• Are remaining Level 1 Users active rather than dormant?
• Is essential sponsorship knowledge documented?
• Can another appropriate person identify outstanding actions?
• Can sponsor records be accessed without relying on one employee?
• Are external adviser arrangements documented?
• Is there a process for responding to unexpected departures?

 

15. Management Review Outcome

 

A sponsor licence review should result in identified actions rather than simply a completed checklist.

Each issue can be categorised, for example, as:

No action required → Improvement recommended → Action required → Urgent escalation

Where action is required, the organisation should record:

• the issue identified;
• the action required;
• the person responsible;
• the applicable deadline;
• whether professional advice is required;
• when the action was completed;
• what evidence has been retained; and
• whether follow-up review is necessary.

The central question is not simply whether the organisation can complete a checklist.

It is whether the employer can demonstrate that it maintains effective control over the people, systems, sponsored workers, Certificates of Sponsorship, organisational changes and information that make up its sponsorship arrangements.

 

 

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Section P: What Happens if a Sponsor Licence is Poorly Managed?

 

Poor sponsor licence management can develop into a compliance problem even where the employer did not deliberately disregard its sponsor duties.

Weak governance, outdated information, uncontrolled SMS access, missed reporting events or incomplete records can prevent the organisation from demonstrating that it is exercising effective control over its sponsorship activities.

The consequences will depend on the nature, seriousness and extent of the issue. A management weakness does not automatically result in formal Home Office action, but unresolved weaknesses can increase the risk of non-compliance and enforcement.

 

1. Management Weaknesses Can Become Compliance Breaches

 

Many sponsor compliance problems begin with an operational failure.

For example:

HR changes a sponsored worker’s role → sponsorship team is not informed → immigration implications are not assessed → required action is not taken → records and sponsorship position become inconsistent

Similar problems can arise where:

• a salary change is not communicated;
• a sponsored worker leaves but the sponsorship function is not notified;
• an organisational change is not assessed;
• a key person leaves and is not replaced appropriately;
• SMS access is not maintained correctly;
• a reporting requirement is overlooked;
• a CoS is assigned using inaccurate information; or
• required records cannot be produced.

The management failure and the eventual compliance breach may therefore be different stages of the same problem.

 

2. The Home Office Can Examine How the Licence is Being Managed

 

Licensed sponsors can be subject to Home Office compliance activity during the life of the licence.

The Home Office may examine whether the organisation is meeting its sponsor duties and whether the systems used to manage sponsored workers are effective in practice.

Depending on the circumstances, scrutiny may involve matters such as:

• sponsor licence information;
• key personnel and SMS users;
• Certificates of Sponsorship;
• sponsored-worker records;
• right to work processes;
• roles and salaries;
• work locations;
• attendance and absence;
• reporting processes;
• record keeping;
• HR systems; and
• the employer’s ability to identify and respond to relevant changes.

This is why sponsor licence management should be capable of operating in practice rather than existing only as a written policy.

 

3. Poor Records Can Make an Otherwise Manageable Issue More Difficult

 

An employer may sometimes have taken appropriate action but be unable to demonstrate what happened because the supporting records are incomplete.

This can make it difficult to establish:

• when an event occurred;
• when the sponsor became aware of it;
• what information was considered;
• what decision was made;
• whether the SMS was updated;
• when action was taken; and
• why a particular course of action was considered appropriate.

Effective sponsor management therefore requires both action and evidence.

A useful principle is:

Identify → assess → act → record → review

 

4. Problems Can Extend Beyond One Sponsored Worker

 

A discrepancy involving one worker may be isolated.

However, where the issue results from a wider weakness in the employer’s systems, the Home Office may consider whether the same problem affects other sponsored workers.

For example, an unexplained salary discrepancy involving one worker may prompt broader questions about how sponsored-worker salaries are recorded and monitored across the organisation.

Similarly, a missed employment change may raise questions about whether HR changes are routinely connected to sponsor licence management.

Employers investigating an identified issue should therefore consider both:

the individual case

and

the underlying system that allowed the problem to occur.

 

5. The Home Office Can Take Compliance Action

 

Where the Home Office identifies sponsor non-compliance, the action taken will depend on the circumstances and the applicable sponsor guidance.

Potential consequences can include:

• requests for information or evidence;
• further compliance scrutiny;
• restrictions affecting sponsorship activity;
• downgrading of the sponsor licence;
• an action plan;
• suspension of the sponsor licence; or
• revocation of the sponsor licence.

The appropriate response will depend on the nature and seriousness of the findings and the relevant Home Office enforcement provisions.

 

6. What Does a B-Rating Mean?

 

Where the Home Office downgrades a sponsor from an A-rating to a B-rating, the sponsor can be required to follow a Home Office action plan and pay the applicable action plan fee.

While B-rated, the organisation is generally unable to sponsor new workers.

Limited exceptions can apply where the sponsor is assigning a CoS to an existing sponsored worker who is applying for further permission to stay with the same sponsor.

The sponsor is expected to make the required improvements and regain its A-rating within the period specified by the Home Office, which will not exceed three months.

Failure to make the required improvements can place the sponsor licence at risk of revocation.

A B-rating should therefore be treated as a significant compliance event requiring active senior management oversight.

 

7. Sponsor Licence Suspension

 

Where the Home Office has concerns about a sponsor, it may suspend the licence while the issues are considered.

Suspension can have immediate operational implications for the organisation’s ability to use the licence and progress sponsorship activity.

The employer should treat a suspension notice as an urgent matter.

The response may require the organisation to:

• understand each allegation or concern;
• secure relevant evidence;
• review affected sponsored-worker files;
• review SMS activity;
• identify any wider systems issue;
• correct remediable weaknesses where appropriate;
• prepare representations within the applicable timeframe; and
• consider the potential impact on existing and planned sponsored workers.

Sponsor licence suspension is a specialist enforcement issue and should be addressed under the relevant suspension procedures rather than treated as routine licence administration.

 

8. Sponsor Licence Revocation

 

Revocation is one of the most serious outcomes for a licensed sponsor.

If a sponsor licence is revoked, the organisation loses its ability to sponsor workers under that licence.

Revocation can also have significant consequences for sponsored workers and the organisation’s future recruitment plans.

The detailed grounds for revocation, the consequences for sponsored workers and the employer’s options following enforcement action fall within the separate Problems & Enforcement sponsor licence territory.

Employers facing potential revocation should treat the matter as an urgent specialist issue.

 

9. Poor Sponsor Management Can Affect Recruitment

 

The consequences of weak licence management are not limited to regulatory enforcement.

Sponsorship problems can disrupt recruitment and workforce planning.

For example, the organisation may experience difficulty where:

• a CoS cannot be assigned when required;
• SMS access is unavailable;
• the organisation cannot establish its current sponsorship position;
• licence information requires correction;
• a proposed hire exposes an unresolved compliance issue;
• the licence is downgraded or suspended; or
• planned corporate changes affect sponsorship arrangements.

For employers dependent on international recruitment, sponsor licence management is therefore also a workforce continuity issue.

 

10. Poor Management Can Affect Existing Sponsored Workers

 

Sponsor licence problems can also create uncertainty for existing sponsored workers.

Employees may depend on the organisation’s sponsorship for their immigration status and continued ability to work in the UK.

Where serious sponsor enforcement action occurs, the consequences can therefore extend beyond the organisation itself.

This makes early identification and resolution of sponsor management problems particularly important.

 

11. Repeated Small Failures Can Indicate a Wider Systems Problem

 

Employers should avoid considering each sponsorship error entirely in isolation.

Repeated minor failures may indicate that the underlying management framework is not working effectively.

Examples might include:

• repeatedly late internal escalation of worker changes;
• recurring discrepancies between HR and payroll;
• multiple outdated sponsored-worker records;
• frequent uncertainty over who is responsible for SMS action;
• repeated problems retrieving documents;
• SMS users remaining in place after organisational changes; or
• different business units applying different sponsorship processes.

In these circumstances, correcting the individual records may not be enough.

The employer should identify why the failures are recurring and address the underlying process.

 

12. What Should an Employer Do When it Identifies a Sponsor Licence Problem?

 

Where a potential problem is identified, employers should avoid either ignoring it or making unnecessary SMS changes before understanding the position.

A structured response can involve:

1. Identify the issue

Establish precisely what may have gone wrong.

2. Establish the facts

Determine the relevant dates, worker information, SMS history, employment records and organisational circumstances.

3. Check the applicable requirement

Establish what the sponsor guidance and immigration requirements required in the circumstances.

4. Assess the extent of the issue

Determine whether the problem is isolated or potentially affects other workers or processes.

5. Determine the appropriate action

Consider whether an SMS report, correction, disclosure, process change, professional advice or other action is required.

6. Record the response

Maintain an appropriate record of the issue, assessment, decision and action taken.

7. Address the underlying cause

If the problem resulted from a weakness in the management framework, correct the process as well as the individual case.

 

13. Early Intervention is Usually Better Than Reconstruction

 

Sponsor licence management is most effective when problems are identified while the underlying facts, documents and personnel are still readily available.

An issue that can be investigated immediately may become considerably more difficult to reconstruct months or years later.

This is particularly relevant where employees have left, systems have changed or historic records are dispersed across different parts of the organisation.

The purpose of active sponsor licence management is therefore not merely to avoid enforcement.

It is to ensure that the employer can identify, explain and address sponsorship issues before they become larger operational or compliance problems.

 

 

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Section Q: When Should Employers Get Advice?

 

Many aspects of sponsor licence management can be handled internally where the organisation has appropriate personnel, systems and knowledge.

However, employers should recognise when an issue has moved beyond routine licence administration and requires specialist immigration advice.

This is particularly important where a decision could affect the sponsor licence itself, the immigration position of a sponsored worker or the organisation’s ability to recruit internationally.

 

1. Before Assigning a CoS Where the Position is Unclear

 

Employers should consider obtaining advice before assigning a Certificate of Sponsorship where there is uncertainty about whether the proposed role or worker meets the relevant sponsorship requirements.

This may include uncertainty concerning:

• the appropriate immigration route;
• the occupation code;
• the nature of the role;
• the required skill level;
• salary requirements;
• working hours;
• work location;
• the structure of the employment arrangement;
• whether the role is genuinely eligible for sponsorship; or
• whether a particular CoS should be assigned.

It is generally preferable to resolve these issues before the CoS is assigned rather than attempting to correct an avoidable problem afterwards.

 

2. Before Making Significant Changes to a Sponsored Worker’s Employment

 

Advice may be appropriate where an employer proposes a material change to a sponsored worker’s employment and the sponsorship consequences are unclear.

Examples can include:

• a significant change in duties;
• a promotion;
• a change of occupation;
• a salary reduction;
• a significant change in working hours;
• a transfer to another part of the business;
• a change of employing entity;
• a substantial change in work location; or
• a restructuring affecting the worker’s position.

The correct immigration treatment should be established before the employment change is implemented where possible.

 

3. When a Reporting Deadline May Have Been Missed

 

If the employer discovers that a potentially reportable event occurred previously and may not have been reported within the applicable timeframe, the position should be assessed promptly.

The employer should establish:

• what happened;
• when the event occurred;
• when the organisation became aware of it;
• what the applicable sponsor requirement was;
• whether any action was already taken;
• whether the SMS currently contains accurate information; and
• whether the issue may affect other sponsored workers or processes.

Employers should avoid making assumptions about the correct remedial action before establishing the facts and applicable requirements.

 

4. When Sponsor Licence Information May Be Incorrect

 

Advice may be appropriate where an employer identifies a material discrepancy between its actual organisational position and the information associated with its sponsor licence.

This can arise following changes involving:

• business addresses;
• trading arrangements;
• key personnel;
• ownership;
• corporate structure;
• business locations; or
• other significant organisational information.

The appropriate response will depend on the nature of the change and when it occurred.

 

5. Before a Merger, Acquisition, TUPE Transfer or Restructuring

 

Corporate changes can have significant sponsor licence implications and should be considered before implementation where possible.

This is particularly important because a sponsor licence is not simply transferable from one legal entity to another.

Employers should consider obtaining specialist advice where a transaction involves:

• a merger;
• an acquisition;
• a sale of a business or part of a business;
• a TUPE transfer;
• a change in ownership or control;
• a corporate restructuring;
• a change in employing entity;
• insolvency-related restructuring; or
• movement of sponsored workers between group companies.

The detailed requirements for these situations fall within the separate sponsor licence Corporate Change territory.

 

6. When Key Personnel Arrangements Break Down

 

Advice may be required where the organisation no longer has appropriate key personnel arrangements or is uncertain how to restore them.

This may arise where:

• the Authorising Officer leaves unexpectedly;
• the only active Level 1 User becomes unavailable;
• an SMS account is deactivated;
• key personnel no longer satisfy the applicable requirements;
• there is uncertainty about who can be appointed;
• an external adviser relationship ends unexpectedly; or
• the organisation cannot access or operate the SMS appropriately.

These issues should be addressed promptly because they can affect the organisation’s ability to manage the licence and meet its sponsor duties.

 

7. When a Compliance Problem is Identified

 

Employers should consider specialist advice where an internal review identifies potentially significant sponsor non-compliance.

Examples can include:

• incorrect CoS information;
• unreported worker changes;
• significant record-keeping failures;
• salary discrepancies;
• workers performing materially different roles from those sponsored;
• systemic right to work issues;
• unreported organisational changes;
• inappropriate SMS access or use;
• repeated reporting failures; or
• concerns affecting several sponsored workers.

The employer should determine both the immediate response and whether the issue indicates a wider weakness in its sponsorship systems.

 

8. Before or During a Home Office Compliance Visit

 

Employers may seek advice when preparing for a Home Office sponsor compliance visit, particularly where they have identified areas of concern.

Preparation can include reviewing:

• sponsor licence information;
• key personnel;
• SMS access;
• the sponsored-worker population;
• Certificates of Sponsorship;
• HR and payroll records;
• right to work processes;
• reporting arrangements;
• record keeping;
• absence monitoring;
• work locations; and
• previous compliance issues.

Where the Home Office is already carrying out an investigation or compliance exercise, employers should ensure that information provided is accurate, consistent and appropriately supported by evidence.

 

9. When the Home Office Requests Information

 

A Home Office request for documents, information or explanations should be reviewed carefully before the organisation responds.

The employer should understand:

• what information has been requested;
• the response deadline;
• which records are relevant;
• whether the records reveal any discrepancies;
• whether different internal systems contain inconsistent information; and
• whether the response raises wider sponsor compliance issues.

Where the request concerns a potentially significant compliance matter, specialist advice may help the organisation establish the factual and legal position before responding.

 

10. Following a Sponsor Licence Downgrade

 

A downgrade to a B-rating should be treated as a significant compliance event.

The organisation will need to understand the Home Office findings, comply with the relevant action plan and address the identified weaknesses within the required period.

Because a B-rating can restrict the organisation’s ability to sponsor new workers and failure to achieve the required improvements can place the licence at risk of revocation, senior management should maintain active oversight of the remediation process.

 

11. Following Sponsor Licence Suspension

 

Sponsor licence suspension requires urgent attention.

The organisation may need to respond to detailed Home Office allegations within a specified timeframe while also assessing the implications for existing sponsored workers and planned recruitment.

The employer should establish:

• the precise grounds for suspension;
• the evidence relevant to each allegation;
• whether any factual assertions require correction;
• whether compliance failures have occurred;
• whether the issue is isolated or systemic;
• what remedial action has already been taken;
• what further remediation is appropriate; and
• how representations should address the Home Office concerns.

Suspension should be handled as a specialist sponsor enforcement matter rather than ordinary sponsor licence administration.

 

12. Where Revocation is Threatened or Has Occurred

 

Where the Home Office is considering revocation, or the sponsor licence has already been revoked, the consequences can be significant for both the organisation and its sponsored workers.

Urgent advice may be required to understand the Home Office decision, the available options and the implications for the workforce.

The detailed legal and strategic issues arising from suspension and revocation fall within the separate Problems & Enforcement sponsor licence territory.

 

13. When the Organisation’s Sponsorship Model is Becoming More Complex

 

Employers do not need to wait for a problem before seeking advice.

A review may be appropriate where the organisation is:

• rapidly increasing international recruitment;
• expanding its sponsored workforce;
• opening additional sites;
• centralising or decentralising HR functions;
• introducing new HR or payroll systems;
• restructuring recruitment processes;
• moving sponsorship responsibilities between teams;
• changing external immigration providers; or
• moving from occasional sponsorship to sponsorship as a regular workforce strategy.

In these circumstances, the issue is not necessarily whether the organisation has already breached its sponsor duties. It is whether the management framework remains appropriate for the scale and complexity of sponsorship activity.

 

14. Use Advice to Support, Not Replace, Internal Sponsor Management

 

Professional advisers can support employers with technical immigration questions, complex sponsorship decisions, compliance reviews, Home Office investigations and enforcement matters.

They cannot replace the organisation’s own responsibility for identifying what is happening within its workforce and business.

The strongest model is therefore:

Internal ownership → reliable information flows → early identification → specialist advice where required → documented action

This allows external advice to be used where it adds value while the organisation retains effective control of its sponsor licence.

 

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Section R: Sponsor Licence Management FAQs

 

What is sponsor licence management?

 

Sponsor licence management is the ongoing process of controlling and administering an organisation’s sponsor licence after it has been granted.

It includes maintaining appropriate key personnel, controlling SMS access, managing Certificates of Sponsorship, keeping licence information accurate, monitoring sponsored workers, identifying relevant business and employment changes, maintaining records and ensuring that issues are escalated and addressed appropriately.

Effective sponsor licence management connects the organisation’s immigration responsibilities with its HR, recruitment, payroll and wider business processes.

 

Who should manage a sponsor licence?

 

The organisation should have clear senior and operational ownership of the sponsor licence.

The Authorising Officer has overall responsibility for the organisation’s activities as a licensed sponsor, while Level 1 Users perform important functions through the Sponsor Management System.

In practice, effective licence management will usually also require information from HR, recruitment, payroll, line managers and other parts of the organisation.

The precise structure will depend on the size and complexity of the employer, but responsibility should be clearly allocated rather than assumed.

 

What does an Authorising Officer do?

 

The Authorising Officer is the senior person with overall responsibility for the organisation’s activities as a licensed sponsor.

The role should not be treated as a purely nominal appointment. The Authorising Officer should have sufficient organisational authority and oversight to understand how sponsorship is being managed and to ensure that appropriate systems are operating.

The sponsor must maintain an eligible Authorising Officer throughout the life of the licence.

 

What does a Level 1 User do?

 

A Level 1 User has access to the Sponsor Management System and can carry out a range of sponsor licence functions, subject to the permissions and requirements applying to the account.

Level 1 Users may be involved in activities such as assigning Certificates of Sponsorship, reporting changes and maintaining sponsor licence information.

Employers should ensure that they maintain an eligible and operational Level 1 User and that access is restricted to appropriate authorised individuals.

 

Can sponsors still appoint Level 2 Users?

 

No new Level 2 Users can be appointed from 9 September 2026.

Existing Level 2 Users are being phased out. Sponsors should convert an existing Level 2 User to a Level 1 User where the individual is eligible and the appointment is appropriate, or deactivate the Level 2 User account by 8 March 2027.

Remaining Level 2 User accounts are due to be deactivated after that date.

Employers should therefore review any existing Level 2 User arrangements as part of their current sponsor licence management.

 

Can more than one person manage a sponsor licence?

 

Yes. Employers should generally avoid creating unnecessary dependency on a single individual.

Different people may have different responsibilities, including senior governance, SMS administration, HR processes, sponsored-worker monitoring and recruitment.

The important point is that responsibilities are defined and coordinated so that relevant information reaches the people responsible for sponsorship.

 

Can an immigration adviser manage our sponsor licence?

 

An external immigration adviser can support the organisation with sponsor licence administration and technical immigration matters and, where permitted, may have an authorised role within the sponsor management arrangements.

However, the sponsor remains responsible for its licence and sponsor duties.

An adviser also depends on the organisation providing accurate and timely information about what is happening within the business and its workforce.

Employers should therefore use advisers to support internal sponsor management rather than as a substitute for it.

 

What is the Sponsor Management System?

 

The Sponsor Management System, commonly referred to as the SMS, is the Home Office online system used by licensed sponsors to administer important aspects of their sponsor licence.

It is used for functions including assigning Certificates of Sponsorship and making certain reports and changes.

The SMS should not be confused with the organisation’s overall sponsor management framework. The SMS records and processes sponsorship activity, but the employer still needs internal systems capable of identifying when action is required.

 

Do SMS users need multi-factor authentication?

 

The Home Office began the phased introduction of multi-factor authentication for SMS users from 3 September 2026.

Organisations granted a sponsor licence on or after 9 September 2026 have MFA enabled, with the wider rollout being implemented across the sponsor population.

SMS users should follow the current Home Office requirements applying to their account.

Passwords and multi-factor authentication passcodes must not be shared between users.

 

What happens if an SMS user does not log in for a long time?

 

Under current Home Office arrangements, an SMS User account may be regarded as inactive where the user has not accessed the system for 12 months or more. UKVI can deactivate inactive accounts.

This is particularly important where an organisation relies on a person as its only Level 1 User.

If the sponsor is left without an active Level 1 User, UKVI can suspend the licence and require the organisation to nominate an eligible Level 1 User within 28 days. Failure to resolve the position can place the licence at risk of revocation.

Employers should therefore review SMS access periodically rather than assuming an old account remains an effective continuity arrangement.

 

How often should a sponsor licence be reviewed?

 

The Home Office does not prescribe a universal monthly, quarterly or annual internal sponsor licence review timetable.

Employers should manage relevant events as they occur and supplement this with periodic reviews appropriate to the scale and complexity of their sponsorship activity.

For example, an organisation may use monthly operational checks, periodic reconciliation of HR and sponsorship data and a broader annual sponsor licence review.

These frequencies are management controls rather than prescribed Home Office review intervals.

 

What changes need to be reported on a sponsor licence?

 

Sponsors can have reporting obligations in relation to both sponsored workers and the sponsoring organisation.

Potentially relevant events can include certain changes to a sponsored worker’s employment or circumstances, changes involving key personnel and specified organisational or corporate changes.

The applicable requirement and deadline depend on the particular event.

Certain worker-related changes generally have to be reported within 10 working days, while specified organisational changes can be subject to 20-working-day requirements. These should not be treated as universal deadlines for every sponsor licence change.

Employers should check the current sponsor guidance for the particular circumstances.

 

What should employers check before assigning a Certificate of Sponsorship?

 

Before assigning a CoS, the employer should verify that the proposed sponsorship is appropriate and that the information being entered is accurate.

This can include checking the immigration route, occupation code, job duties, salary, working hours, work location and other information relevant to the sponsorship.

The organisation should also ensure that the CoS has been appropriately authorised internally.

Where eligibility or the correct sponsorship treatment is unclear, the issue should be resolved before assignment.

 

Does a sponsor need to report hybrid working?

 

A sponsor does not need to make a report simply because a sponsored worker moves to a hybrid working pattern.

However, employers should continue to maintain appropriate information about where sponsored workers are working.

Changes to a worker’s main office or other relevant work locations, including certain client-site arrangements, may require consideration under the applicable sponsor reporting requirements.

Employers should therefore distinguish ordinary hybrid working from a substantive change in the worker’s principal work arrangements or location.

 

What happens if the person managing the sponsor licence leaves?

 

The organisation should identify the individual’s formal and operational sponsorship responsibilities and arrange an appropriate handover.

This may involve replacing key personnel, establishing new SMS access, transferring records, identifying outstanding actions and ensuring that sponsorship knowledge is retained within the organisation.

SMS credentials should never simply be transferred to another employee.

Where the departing person is the only active Level 1 User or the Authorising Officer, the position should be addressed promptly.

 

Can HR manage a sponsor licence?

 

HR can play a central role in sponsor licence management, and many organisations locate operational sponsorship responsibility within their HR function.

However, the employer must still maintain the key personnel required under the sponsor regime and ensure that the individuals performing relevant functions meet the applicable requirements.

HR should also be connected to recruitment, payroll, line management and senior governance because many sponsorship issues arise outside the HR team itself.

 

What records should a sponsor licence holder keep?

 

Sponsors are required to retain specified records and documents relating to their sponsorship activities and sponsored workers.

The detailed requirements are set out in the Home Office sponsor guidance, including Appendix D: Keeping Documents – Guidance for Sponsors.

Employers should use the current guidance to determine what must be retained and for how long rather than applying a single retention period to every sponsorship record.

From a management perspective, records should also allow the organisation to understand and explain significant sponsorship decisions and actions.

 

Does a sponsor licence need to be renewed?

 

For most sponsors licensed under the Worker and Temporary Worker routes, routine four-year sponsor licence renewal was removed from 6 April 2024.

Most affected licences can continue without a periodic renewal application provided the sponsor remains eligible and continues to meet the relevant requirements.

Different validity arrangements continue to apply to certain routes, including Scale-up and UK Expansion Worker sponsorship, where the licence is subject to a maximum four-year period.

Employers should therefore check the position applying to their particular licence rather than assuming that every sponsor licence is indefinite.

 

Can a sponsor licence be transferred to another company?

 

A sponsor licence is not transferable from one legal entity to another simply because a business is sold, acquired, reorganised or transferred within a corporate group.

Mergers, acquisitions, TUPE transfers, changes in ownership and other corporate changes can create specific sponsor licence requirements.

Employers should consider the sponsorship implications before the transaction is completed where possible.

 

What happens if sponsor licence information is wrong?

 

The appropriate response depends on what information is incorrect, why the discrepancy arose and how long it has existed.

The employer should establish the facts, check the applicable sponsor requirement and determine whether an SMS update, report, correction or other action is required.

Where the discrepancy may amount to a significant compliance issue, specialist advice may be appropriate before action is taken.

 

What happens if we miss a sponsor reporting deadline?

 

A missed reporting deadline can amount to sponsor non-compliance and should be assessed promptly.

The employer should establish what happened, the applicable reporting requirement, when the organisation became aware of the event and whether the issue is isolated or indicates a wider management problem.

The organisation should then determine the appropriate remedial action and retain a record of how the issue was addressed.

 

Can poor sponsor licence management lead to suspension or revocation?

 

Yes. Serious or persistent sponsor non-compliance can result in Home Office enforcement action, including downgrading, suspension or revocation of the sponsor licence, depending on the circumstances and applicable guidance.

Poor management does not automatically result in enforcement, but weaknesses in governance, reporting, records, SMS administration or sponsored-worker oversight can contribute to compliance failures.

Employers should therefore address management weaknesses before they develop into wider sponsor compliance problems.

 

What is the best way to manage a sponsor licence?

 

Effective sponsor licence management combines clear governance with reliable operational processes.

A practical framework is:

Governance → People → Access → Workers → Events → Evidence → Review → Escalation

The organisation should know who owns the licence, who can access the SMS, which workers are sponsored, which business and employment events require consideration, where the supporting evidence is held, how the licence is reviewed and when an issue needs to be escalated.

The objective is to make sponsorship part of the organisation’s normal management processes rather than an isolated immigration administration task.

 

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Section S: Conclusion

 

A sponsor licence should be treated as an ongoing organisational responsibility rather than an administrative permission that can be left unattended once granted.

Effective sponsor licence management requires employers to maintain control over the people, systems, sponsored workers, Certificates of Sponsorship, business changes and records connected with the licence.

The strongest management framework can be summarised as:

Governance → People → Access → Workers → Events → Evidence → Review → Escalation

Governance establishes who is accountable for sponsorship. Appropriate key personnel and SMS users ensure that authorised individuals can operate the licence. HR, recruitment, payroll and management processes identify relevant worker and organisational events. Records provide evidence of what happened and what action was taken. Periodic review tests whether the system continues to work, while escalation ensures that complex or potentially serious issues receive appropriate attention.

The practical objective is to make sponsorship part of the organisation’s normal operating processes.

A salary change should reach the sponsorship function because payroll and HR processes recognise the worker as sponsored. A promotion should trigger immigration consideration before implementation. A departing SMS user should automatically trigger an access review. A corporate transaction should reach the sponsor licence team before completion. A sponsored worker leaving should generate the appropriate sponsorship assessment and action.

When these connections operate effectively, the organisation is less dependent on individuals remembering immigration rules or manually identifying sponsorship issues after the event.

Employers should also distinguish between sponsor licence management and the wider question of sponsor compliance. Licence management provides the governance, administration and operational controls through which the organisation manages sponsorship. Sponsor compliance concerns whether the organisation is meeting the duties and requirements imposed on licensed sponsors.

The two are closely connected, but they are not identical.

Good sponsor licence management creates the infrastructure through which sponsor compliance can be maintained.

As the organisation changes, its sponsor management framework should change with it. Growth in sponsored-worker numbers, new sites, changes in personnel, new HR systems, corporate restructuring and increased international recruitment can all require the management model to be reviewed.

The continuing question for the employer is therefore not simply:

“Do we have a sponsor licence?”

It is:

“Can we demonstrate that our sponsor licence remains under effective organisational control?”

For employers that depend on sponsored workers, maintaining that control is an important part of protecting the organisation’s ability to recruit internationally, retain sponsored employees and respond confidently to Home Office scrutiny.

 

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Section T: Sponsor Licence Management Glossary

 

Term	Meaning
Authorising Officer (AO)	The senior person with overall responsibility for the organisation’s activities as a licensed sponsor. The sponsor must maintain an eligible Authorising Officer throughout the life of the sponsor licence.
Certificate of Sponsorship (CoS)	An electronic sponsorship record assigned by a licensed sponsor to an eligible worker. It contains information about the worker, proposed employment and sponsorship and is used in support of the worker’s immigration application.
Defined Certificate of Sponsorship	A type of Certificate of Sponsorship generally required when sponsoring a Skilled Worker who is applying for entry clearance from outside the UK. The sponsor must obtain the Defined CoS through the Sponsor Management System before it can be assigned to the worker.
Home Office	The UK government department responsible for immigration and the sponsorship system. UK Visas and Immigration operates as part of the Home Office.
Key Contact	The individual who acts as the main point of contact between the sponsoring organisation and UKVI in relation to the sponsor licence.
Key Personnel	The individuals appointed to perform specified roles in relation to the sponsor licence. These include the Authorising Officer, Key Contact and relevant SMS users. Sponsors should ensure that their key personnel continue to meet the applicable Home Office requirements.
Level 1 User	An authorised user with access to the Sponsor Management System and permissions to carry out a range of sponsor licence functions. Level 1 Users can perform important administrative activities such as assigning Certificates of Sponsorship and reporting certain changes, subject to the applicable SMS permissions and sponsor requirements. Sponsors should maintain an eligible and operational Level 1 User throughout the life of the licence.
Level 2 User	A historic category of SMS user with more restricted permissions than a Level 1 User. From 9 September 2026, sponsors can no longer appoint new Level 2 Users. Existing Level 2 Users should be converted to Level 1 Users where eligible and appropriate, or their accounts should be deactivated by 8 March 2027. Remaining Level 2 User accounts are due to be deactivated after that date.
Multi-Factor Authentication (MFA)	An additional security measure used when accessing the Sponsor Management System. The Home Office began the phased introduction of MFA for SMS users from 3 September 2026. Organisations granted a sponsor licence on or after 9 September 2026 have MFA enabled, with implementation being rolled out more widely across sponsors. SMS passwords and MFA passcodes are personal to the authorised user and must not be shared.
Sponsor	An organisation licensed by the Home Office to sponsor eligible workers under specified immigration routes. The sponsoring organisation remains responsible for its sponsor licence and sponsor duties even where aspects of licence administration are delegated internally or supported by an external immigration adviser.
Sponsor Compliance	The employer’s compliance with the duties and requirements imposed on licensed sponsors by the Home Office. Sponsor compliance includes areas such as reporting, record keeping, monitoring sponsored workers and complying with the wider requirements of the sponsorship regime. It is closely connected with sponsor licence management but represents a distinct area of responsibility.
Sponsor Licence	Home Office authorisation allowing an eligible organisation to sponsor qualifying workers under the immigration routes covered by its licence. A sponsor licence remains subject to continuing Home Office requirements and must be actively managed throughout its life.
Sponsor Licence Management	The ongoing organisational process of administering and controlling a sponsor licence after it has been granted. It includes governance, key personnel, SMS access, Certificates of Sponsorship, sponsored-worker administration, maintenance of licence information, management of relevant changes, record keeping, periodic review and escalation of potential problems.
Sponsor Management System (SMS)	The Home Office online system used by licensed sponsors to administer important aspects of their sponsor licence. The SMS is used for activities including assigning Certificates of Sponsorship and reporting or requesting certain changes. The SMS is an administrative platform and should not be confused with the employer’s wider internal sponsor licence management framework.
Sponsored Worker	A worker whose immigration permission is based on sponsorship provided by an organisation holding the appropriate sponsor licence. The sponsor is responsible for carrying out the sponsor duties that apply in relation to the worker during the relevant period of sponsorship.
Sponsor Duties	The continuing obligations imposed on licensed sponsors under the Home Office sponsor guidance. These include requirements relating to areas such as reporting, record keeping, monitoring sponsored workers and compliance with the wider sponsorship regime.
SMS User	An individual authorised to access the Sponsor Management System on behalf of a licensed sponsor. SMS accounts are personal to the authorised user. Login credentials, passwords and MFA passcodes must not be shared. Under current Home Office arrangements, an SMS User account may be regarded as inactive where the user has not accessed the system for 12 months or more, and UKVI can deactivate inactive accounts.
UK Visas and Immigration (UKVI)	The part of the Home Office responsible for administering the UK immigration system, including the sponsorship regime.
Undefined Certificate of Sponsorship	A type of Certificate of Sponsorship used for eligible sponsorship circumstances that do not require a Defined CoS. Sponsors may have an annual allocation of Undefined CoS and can request additional allocation where required, subject to the applicable Home Office process.

 

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Section U: Useful Links & References

 

The following Home Office and GOV.UK resources provide the primary official guidance relevant to managing a UK sponsor licence. Employers should refer to the current version of the applicable guidance when making sponsorship decisions, as sponsor requirements and Sponsor Management System procedures can change.

 

 

Resource	URL
Workers and Temporary Workers: Guidance for Sponsors – Part 1: Apply for a Licence Home Office guidance covering the sponsor licensing framework, including requirements relating to sponsor eligibility, key personnel and the administration of a sponsor licence.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-1-apply-for-a-licence
Workers and Temporary Workers: Guidance for Sponsors – Part 2: Sponsor a Worker Home Office guidance covering the sponsorship of workers, including Certificates of Sponsorship and requirements applying when sponsoring workers under the relevant routes.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-2-sponsor-a-worker
Workers and Temporary Workers: Guidance for Sponsors – Part 3: Sponsor Duties and Compliance Home Office guidance covering ongoing sponsor duties, including reporting responsibilities, record keeping, compliance requirements and the consequences of sponsor non-compliance.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
Appendix D: Keeping Documents – Guidance for Sponsors Official Home Office guidance specifying records and documents sponsors are required to retain in connection with their sponsored workers and sponsorship activities.	https://www.gov.uk/government/publications/keep-records-for-sponsorship-appendix-d
Sponsor Management System Manuals The Home Office publishes a series of Sponsor Management System manuals explaining how sponsors should carry out different administrative functions within the SMS. Employers responsible for operating the SMS should use the current manual relevant to the particular action they are undertaking rather than relying solely on previous experience of the system.	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Sponsor Management System Manual 13: Multi-Factor Authentication SMS Manual 13 contains the Home Office instructions relating to multi-factor authentication for Sponsor Management System users. This is particularly relevant following the phased introduction of MFA from September 2026. SMS users should follow the current Home Office instructions applicable to their account and must not share passwords or MFA passcodes.	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Sponsor a Skilled Worker GOV.UK information for employers on sponsoring workers, including the sponsor licensing process and employer responsibilities.	https://www.gov.uk/uk-visa-sponsorship-employers
Immigration Rules – Appendix Skilled Worker The Immigration Rules governing the Skilled Worker route, including the requirements applying to sponsored employment under the route.	https://www.gov.uk/guidance/immigration-rules/immigration-rules-appendix-skilled-worker
Immigration Rules – Appendix Temporary Work Routes The Immigration Rules contain the requirements for the various Temporary Work and other sponsored work routes. Employers should refer to the appendix applicable to the particular immigration route being used.	https://www.gov.uk/guidance/immigration-rules
Right to Work Checks: Employer Guidance Home Office guidance explaining how employers should conduct right to work checks and establish a statutory excuse against liability for a civil penalty for illegal working where the relevant requirements are met.	https://www.gov.uk/government/publications/right-to-work-checks-employers-guide
Using the Employer Checking Service GOV.UK information on using the Employer Checking Service where an employer cannot verify an individual’s right to work through the usual documentary or online checking process and the applicable conditions for using the service are met.	https://www.gov.uk/employee-immigration-employment-status

 

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