Sponsor Licence Monitoring Duties: Employer Guide

Sponsor Licence Monitoring Duties: At a Glance

Sponsor Licence holders have ongoing duties to monitor sponsored workers throughout the period of sponsorship. Employers need systems that provide reliable oversight of attendance, absence, contact details and relevant changes in employment circumstances.

Effective monitoring depends on information moving quickly between line managers, HR, payroll and sponsor licence key personnel. A change may be known somewhere within the business, but still create compliance risk if it does not reach the people responsible for assessing the sponsorship implications.

Monitoring also supports the separate sponsor reporting duties by ensuring potentially reportable events are identified early enough for the employer to establish the facts and take any required action.

This guide explains Sponsor Licence monitoring duties relating to attendance, absence and contact details, what employers should monitor and how to build effective escalation and oversight into everyday workforce management.

 

Section A: Sponsor Licence Monitoring Duties: Attendance, Absence & Contact Details

 

Sponsor monitoring is part of the organisation’s continuing sponsor duties. The employer should be able to identify what is happening within its sponsored workforce and ensure that relevant changes are recorded, reviewed and escalated where compliance action may be required.

Monitoring arrangements should cover key areas including:

 

• attendance and unexpected non-attendance;
• authorised and unauthorised absence;
• required worker contact details;
• salary and working arrangements;
• job role and duties;
• normal work location; and
• continued employment with the sponsor.

 

The practical challenge is that this information often sits across different parts of the organisation. A line manager may identify an attendance problem, HR may record a change of address or employment arrangement and payroll may implement a change affecting salary or hours.

The monitoring framework therefore needs to connect those information sources and provide a clear route for relevant events to reach the people responsible for sponsorship compliance. The employer can then establish whether the matter requires internal action, further investigation or reporting to the Home Office.

Monitoring should operate as part of ordinary workforce management. Employers are better placed to maintain compliance where sponsorship triggers are built into existing HR, payroll and management processes and where responsibility for escalation is clear.

 

 

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Section B: What Are Sponsor Licence Monitoring Duties?

 

Sponsor Licence monitoring duties are the ongoing obligations requiring licensed sponsors to maintain effective oversight of sponsored workers and to have systems capable of identifying relevant changes or compliance issues during the period of sponsorship.

A sponsor must be able to demonstrate that it has appropriate systems and processes for managing its sponsored workforce. In practical terms, this means the organisation should be able to establish:

 

• which workers it currently sponsors;
• whether sponsored workers are attending work as expected;
• whether absences are authorised, explained and appropriately recorded;
• whether sponsored workers’ required contact details remain current;
• where sponsored workers are working;
• whether relevant employment circumstances have changed;
• whether an identified event requires internal action or reporting to the Home Office; and
• whether appropriate records exist to demonstrate how the sponsor has responded.

 

Monitoring is part of the wider sponsor compliance framework. It allows the organisation to identify events that may affect sponsorship and provides the information needed to decide whether a matter needs to be recorded internally, escalated, investigated or reported through the Sponsor Management System (SMS).

Monitoring and reporting should therefore be treated as connected but distinct duties. Monitoring identifies what is happening within the sponsored workforce. Reporting determines whether an identified event must be notified to the Home Office.

A useful operational model is:

Monitor → Identify → Assess → Record → Report where required

This distinction is important. An employer cannot reliably meet its reporting duties if its internal systems are incapable of identifying the events that may need to be reported.

 

 

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Section C: Why Is Monitoring Sponsored Workers Important?

 

Effective monitoring allows employers to identify potential compliance problems early and demonstrate that sponsorship is being actively managed rather than treated as an administrative process completed when the Certificate of Sponsorship was assigned.

A sponsor that cannot explain basic matters concerning its sponsored workforce may struggle to demonstrate effective compliance. For example, concerns may arise where an employer cannot establish:

 

• why a sponsored worker has stopped attending work;
• whether an absence was authorised;
• where a sponsored worker is currently working;
• whether the worker’s contact details are current;
• whether salary or working arrangements have changed;
• whether an identified change was considered for reporting purposes; or
• what action was taken after a potential compliance issue was identified.

 

Weak monitoring can lead to inaccurate sponsor records, missed reporting obligations and difficulties during a Home Office compliance visit or investigation.

Depending on the nature and seriousness of a compliance failure, Home Office action can include restrictions on sponsorship activity, downgrading of the licence, suspension or revocation. A monitoring failure does not automatically result in enforcement action, but inadequate systems may contribute to a wider finding that the sponsor is not meeting its duties.

For this reason, sponsor compliance should be integrated into ordinary HR and workforce management processes wherever possible. Employers should avoid creating an immigration compliance system that operates separately from the systems used by managers, HR and payroll because this increases the risk that important information will not reach the sponsor licence team.

 

 

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Section D: What Must Sponsors Monitor About Sponsored Workers?

 

Sponsor licence holders must maintain effective systems for monitoring sponsored workers throughout the period of sponsorship. The purpose of these systems is to ensure that the employer remains aware of relevant circumstances affecting sponsored workers and can identify events requiring investigation, record keeping or reporting to the Home Office.

Monitoring arrangements should enable the sponsor to maintain oversight of key areas including:

 

• attendance at work;
• authorised and unauthorised absence;
• sickness and other periods of absence;
• the sponsored worker’s required contact details;
• the worker’s normal work location;
• job role and duties;
• salary and working arrangements;
• continued employment with the sponsor; and
• other relevant changes affecting the circumstances in which the worker is sponsored.

 

Not every change will require a report to the Home Office. The purpose of an effective monitoring system is to ensure that relevant changes are identified so that the sponsor can establish the facts and make the correct compliance decision.

This requires more than simply maintaining an employee file. Information about sponsored workers may arise through different parts of the organisation. Attendance information may sit with line managers, salary information with payroll, personal information with HR and sponsor administration with a Level 1 User.

The sponsor therefore needs a process for bringing relevant information together and escalating matters where sponsor compliance action may be required.

 

1. Monitoring Throughout the Sponsorship Lifecycle

 

Monitoring should operate throughout the sponsored worker’s employment rather than only at particular compliance checkpoints.

The employer should establish an accurate baseline when the worker joins the organisation and then maintain sufficient oversight to identify relevant changes from that position.

For example, the employer may initially record the worker’s:

 

• sponsored role;
• salary;
• normal work location;
• working arrangements;
• line manager;
• required contact information; and
• other information relevant to the sponsorship arrangements.

 

Subsequent monitoring can then help the employer identify whether these circumstances have changed and whether the change has any sponsor compliance implications.

 

2. Monitoring Does Not Mean Every Change Is Reportable

 

Employers should distinguish between identifying a change and determining that the change must be reported.

Monitoring systems should capture relevant information. The sponsor can then assess the circumstances against the applicable Home Office requirements.

Depending on the issue, the correct response may be to:

 

• update an internal HR record;
• obtain further information from the worker or manager;
• retain evidence explaining the circumstances;
• review whether the worker continues to meet the conditions of sponsorship;
• escalate the matter to sponsor licence key personnel; or
• make a report through the Sponsor Management System where required.

 

This distinction is important for maintaining the boundary between sponsor monitoring and the separate reporting duties. Monitoring provides the information needed to make the reporting decision.

 

 

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Section E: Monitoring Sponsored Worker Attendance

 

Licensed sponsors must have systems in place to monitor sponsored workers’ attendance and maintain appropriate records of absence.

Attendance monitoring helps the sponsor establish that the worker remains engaged in the sponsored employment and enables the employer to identify unexpected or unexplained non-attendance.

The monitoring method does not have to be identical for every organisation. The appropriate system will depend on factors such as the nature of the work, the employer’s operating model, whether workers are office-based or site-based and whether the organisation operates remote or hybrid working arrangements.

The important point is that the sponsor must have an effective system that works in practice and enables relevant attendance and absence issues to be identified.

 

1. What Attendance Records Should Employers Keep?

 

Employers should use attendance and absence records appropriate to their organisation and workforce. Depending on the working arrangements, relevant evidence may include:

 

Record	Purpose
Attendance records	Evidence whether sponsored workers are attending work as expected.
Timesheets	Record working time where timesheets form part of the employer’s normal working arrangements.
Shift or rota records	Help demonstrate expected and actual attendance for shift-based roles.
Absence records	Record periods when the sponsored worker is absent from work and whether the absence is authorised or otherwise explained.
Leave records	Evidence approved annual leave and other authorised periods away from work.
Manager records	Help evidence attendance concerns, investigations and action taken where relevant.

 

These examples are not intended to prescribe a particular attendance system. Employers should use arrangements appropriate to their business while ensuring that they can demonstrate effective monitoring if their systems are examined by the Home Office.

Attendance information should also be capable of being reconciled with other relevant records where necessary. For example, an unexplained discrepancy between attendance information, payroll records and HR records may require investigation.

 

2. Payroll Records Are Not a Substitute for Attendance Monitoring

 

Payroll information can provide useful evidence about a sponsored worker’s employment, but it does not by itself demonstrate effective attendance monitoring.

A payroll system may show that a worker continued to receive salary during a particular period, but it may not establish:

 

• whether the worker attended work;
• whether an absence was authorised;
• why the worker was absent;
• whether the employer attempted to contact the worker;
• whether the worker remained engaged in the sponsored role; or
• whether the circumstances required sponsor compliance action.

 

Employers should therefore ensure that payroll forms part of a wider monitoring framework rather than being relied upon as the sole evidence of a sponsored worker’s continuing employment circumstances.

 

3. Monitoring Unexplained or Unauthorised Absence

 

Where a sponsored worker fails to attend work without explanation or permission, the employer should investigate promptly.

The organisation’s procedures should enable it to establish:

 

• when the absence began;
• whether the worker had permission to be absent;
• whether the worker has contacted the employer;
• whether the employer has attempted to contact the worker;
• whether there is a legitimate explanation for the absence;
• whether the worker has returned to work;
• whether salary has been affected; and
• whether sponsorship is continuing.

 

The sponsor should retain appropriate evidence of the absence and the steps taken to establish the worker’s circumstances.

 

4. The 10 Consecutive Working Day Rule

 

A specific Home Office reporting requirement applies where a sponsored worker is absent from work without permission for more than 10 consecutive working days.

Where this threshold is reached, the sponsor must report the absence to the Home Office through the Sponsor Management System. The report must be made no later than 10 working days after the tenth day of absence, even where the employer intends to continue sponsoring the worker.

The sponsor should therefore have attendance systems capable of identifying when an unexplained or unauthorised absence is approaching this threshold. Relying on an issue being noticed retrospectively creates a risk that the reporting deadline will be missed.

When dealing with an unauthorised absence, the employer should document relevant information, including the start of the absence, attempts to contact the worker and the subsequent action taken. Where a report is required, the sponsor should provide the worker’s last recorded residential address, telephone number and personal email address where held, together with the start date of the absence, return date if applicable, contact attempts, any salary deductions and whether sponsorship will continue.

The detailed requirements governing reportable events and SMS reporting are considered separately in the Sponsor Licence Reporting Duties guidance.

 

5. Attendance Monitoring Should Trigger Action

 

An attendance system is only effective for sponsor compliance purposes if relevant information is acted upon.

For example, a system may accurately record that a sponsored worker has not attended for several days. If nobody reviews the information or escalates unexplained absence to HR or the sponsor licence team, the employer may still fail to identify a reporting requirement.

Employers should therefore establish an escalation process such as:

Absence identified → Manager checks circumstances → HR informed → Sponsor implications assessed → Action recorded → SMS report made where required

This allows attendance monitoring to operate as part of an active sponsor compliance system rather than simply creating a historic record of when employees were present or absent.

 

 

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Section F: Monitoring Sponsored Worker Absence

 

Sponsor licence holders must have systems capable of identifying and recording sponsored workers’ absences. Effective absence monitoring enables the employer to distinguish between authorised periods away from work and absence without permission, investigate unexpected non-attendance and identify circumstances that may require further sponsor compliance action.

Absence can arise for many legitimate reasons and does not automatically indicate a sponsorship problem. The compliance issue is whether the sponsor maintains appropriate oversight, records relevant absences and responds where the circumstances require action.

Employers should therefore integrate sponsored worker absence monitoring into their ordinary HR procedures while ensuring that immigration compliance implications are considered where appropriate.

 

1. Sickness Absence

 

Sponsored workers may be absent because of illness in the same way as other employees. Sickness absence should ordinarily be managed through the employer’s normal absence management procedures, while ensuring that relevant sponsor compliance considerations are not overlooked.

Depending on the circumstances, records may include:

 

• the dates of sickness absence;
• the reason for absence where appropriately recorded;
• communications between the worker and employer;
• fit notes or other medical evidence where required under the employer’s procedures;
• records of any changes to pay;
• return-to-work discussions; and
• any decisions affecting the worker’s employment arrangements.

 

A period of sickness absence does not automatically mean that sponsorship is affected or that a report must be made to the Home Office. The employer should, however, understand the circumstances and consider whether the absence has resulted in any separate change affecting the sponsored employment.

 

2. Long-Term Sickness Absence

 

Long-term sickness involving a sponsored worker can require additional compliance consideration, particularly where the absence affects salary, working arrangements or the worker’s ability to continue performing the sponsored role.

The employer should maintain appropriate contact with the worker, keep relevant absence records and ensure that any material change in employment circumstances is identified.

Depending on the facts, the sponsor may need to consider:

 

• whether the worker remains employed;
• whether salary has changed during the absence;
• whether the worker remains capable of returning to the sponsored role;
• whether working arrangements have changed;
• whether any sponsor reporting requirement has arisen; and
• whether specialist immigration or employment advice is required.

 

The immigration implications of long-term sickness can depend on the individual circumstances. Employers should therefore avoid assuming either that prolonged sickness automatically creates a sponsorship breach or that no sponsor action will ever be required.

 

3. Annual Leave and Other Authorised Absence

 

Employers should maintain records of authorised periods away from work in accordance with their sponsor and HR record-keeping arrangements.

Examples may include:

 

• annual leave;
• sickness absence;
• family-related leave;
• approved unpaid leave;
• authorised business travel; and
• other agreed periods away from normal work.

 

Clear absence records allow the employer to distinguish an authorised period away from work from absence without permission.

This distinction is particularly important because the Home Office reporting requirement relating to more than 10 consecutive working days applies to absence without permission. Employers therefore need records capable of demonstrating whether an absence was authorised and, where relevant, when that authorisation was given.

Authorised absence can still have sponsor implications where the worker is absent without pay or on reduced pay for more than four weeks in total in a calendar year (1 January to 31 December). For a Scale-up Worker, the relevant period is the period for which the sponsor has sponsorship responsibility. The four weeks can be cumulative and should be assessed against the worker’s normal working pattern. Where no permitted exception applies, the sponsor will normally need to stop sponsoring the worker. Where a permitted exception applies, the absence should still be reported through the SMS.

 

4. Unauthorised Absence

 

Where a sponsored worker is absent from work without permission, the employer should act promptly to establish the circumstances.

A suitable process may involve:

 

1. identifying when the worker stopped attending work;
2. checking whether leave or another form of absence had been authorised;
3. attempting to contact the worker using the contact details held by the organisation;
4. checking whether the worker has contacted a manager or another part of the organisation;
5. recording attempts to establish the worker’s circumstances;
6. determining whether and when the worker has returned to work;
7. considering any effect on salary or continued employment;
8. escalating the matter to the appropriate sponsor licence personnel; and
9. making an SMS report where the applicable reporting threshold is met.

 

Where absence without permission exceeds 10 consecutive working days, the sponsor must apply the Home Office reporting requirement explained above. The employer’s internal absence process should therefore be capable of escalating the matter before the reporting deadline is missed.

 

5. Unpaid and Reduced-Pay Absence

 

Employers should also monitor sponsored workers who are absent without pay or on reduced pay. Specific sponsor rules apply where this exceeds four weeks in total in a calendar year, or during the sponsor’s period of sponsorship responsibility for a Scale-up Worker.

Permitted exceptions include specified family-related leave, statutory neonatal care leave, sickness, jury service, attending court as a witness, qualifying humanitarian or environmental crisis work and legally organised industrial action. Where an exception applies, sponsorship may continue, but the absence should still be reported through the SMS.

HR and payroll systems should therefore be capable of identifying cumulative unpaid or reduced-pay absence and escalating the matter before the relevant threshold is exceeded.

 

6. Keeping Records of Absence Decisions

 

Employers should retain sufficient information to demonstrate how relevant absence issues involving sponsored workers have been handled.

Depending on the circumstances, useful records may include:

 

• absence notifications;
• attendance records;
• leave requests and approvals;
• communications with the sponsored worker;
• records of attempts to contact the worker;
• manager notes;
• fit notes or other relevant evidence;
• return-to-work records;
• records of any effect on salary;
• internal compliance assessments; and
• evidence of any report made through the SMS.

 

The purpose is not simply to accumulate documentation. The sponsor should be capable of demonstrating what happened, what information it obtained, what decision was made and what action followed.

 

7. Repeated or Unusual Absence Patterns

 

Employers should also be alert to repeated or unusual absence patterns that may require investigation even where no individual period of absence immediately triggers a specific reporting requirement.

For example, repeated unexplained non-attendance may indicate a breakdown in the employment arrangements or raise questions about whether the worker is continuing to perform the sponsored role as expected.

The employer should establish the facts rather than make assumptions. Where concerns arise, they should be documented and escalated through the organisation’s sponsor compliance process.

 

 

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Section G: Monitoring Sponsored Worker Contact Details

 

Maintaining sponsored workers’ contact details is a specific sponsor record-keeping requirement and an important component of effective monitoring.

Under the Home Office sponsor record-keeping requirements, sponsors must retain a history of specified contact details for sponsored workers and keep that information up to date.

Accurate contact information also has an important practical purpose. It enables the employer to communicate with the sponsored worker and can become particularly important where the worker unexpectedly stops attending work or the employer needs to establish their circumstances.

 

1. What Contact Details Must Sponsors Keep?

 

Sponsors must maintain a history of the sponsored worker’s required contact details, including:

 

• UK residential address;
• personal email address; and
• telephone number, whether mobile, landline or both where applicable.

 

The history of these details must be kept up to date.

This means the sponsor should not simply retain the information originally supplied when the worker joined the organisation. There should be an effective mechanism for identifying subsequent changes and maintaining the required record.

 

2. How Should Employers Keep Contact Details Updated?

 

There is no need for contact-detail monitoring to operate independently from the employer’s normal HR systems, provided those systems enable the sponsor to meet its obligations effectively.

Practical measures may include:

 

• collecting the required information during onboarding;
• telling sponsored workers that they must notify the employer when relevant contact details change;
• providing an HR or employee self-service process for submitting changes;
• retaining the required history rather than simply overwriting previous information;
• periodically checking the accuracy of information held; and
• ensuring relevant HR personnel understand the sponsor record-keeping requirement.

 

Employers should consider whether their HR technology preserves the required history. A system that simply replaces an old address with a new address without retaining the previous information may not provide the record history required for sponsor compliance purposes.

 

3. Personal Contact Details and Employment Information Are Different

 

Employers should distinguish between the sponsored worker’s required personal contact details and other information that the sponsor needs to monitor.

The core contact-detail requirement concerns the worker’s UK residential address, personal email address and telephone number.

Other information may be important for HR or sponsor compliance purposes but should not be presented as though it forms part of the same Home Office contact-detail requirement.

For example, emergency contact information may be maintained by the employer as part of normal HR administration, but it should not be confused with the specific sponsored-worker contact details required for sponsor record keeping.

Likewise, the worker’s normal work location is an important sponsorship consideration, but it is an employment and sponsorship circumstance rather than a personal contact detail.

 

4. Why Accurate Contact Details Matter

 

Accurate contact information supports both record-keeping compliance and effective workforce monitoring.

This becomes particularly important where a sponsored worker unexpectedly fails to attend work. The employer may need to contact the worker promptly to establish whether the absence is authorised, whether there is an emergency or other legitimate explanation and whether further sponsor compliance action may be required.

Out-of-date information can therefore create multiple problems. It may indicate weakness in the sponsor’s record-keeping systems while also making it more difficult to investigate an unexplained absence.

 

5. Periodic Contact Detail Checks

 

Employers should consider incorporating sponsored worker contact details into periodic compliance reviews.

A review might test whether:

 

• the current UK residential address is recorded;
• the worker’s personal email address is recorded;
• the current telephone number is recorded;
• previous contact details have been retained where required;
• recent changes have been reflected in the appropriate records; and
• the worker understands how to notify the employer of future changes.

 

Periodic checks can be particularly useful for organisations with larger sponsored populations, where relying entirely on workers to remember to notify HR of changes can create gaps in compliance records.

 

 

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Section H: Monitoring Changes in Sponsored Worker Circumstances

 

Sponsor monitoring extends beyond attendance, absence and personal contact details. Employers also need systems capable of identifying relevant changes in the circumstances in which a sponsored worker is employed.

The purpose of monitoring is not to assume that every employment change creates a reporting obligation. Rather, the sponsor needs to identify relevant changes so that their immigration implications can be assessed and any required action taken.

Relevant circumstances may include changes to:

 

• the sponsored worker’s job role or duties;
• salary;
• working hours or other working arrangements;
• normal work location;
• remote or hybrid working arrangements;
• continued employment with the sponsor; and
• other circumstances affecting the basis on which the worker is sponsored.

 

Information about these changes may originate with different parts of the organisation. Employers should therefore ensure that managers, HR personnel, payroll teams and sponsor licence key personnel understand how relevant changes are escalated.

 

1. Monitoring Changes to Job Role and Duties

 

The sponsor should maintain sufficient oversight to confirm that the worker’s actual role in practice continues to correspond with the occupation code and job description for which the Certificate of Sponsorship was assigned, subject to any permitted changes.

Changes to responsibilities can occur naturally during employment. However, a significant change should be identified and considered from a sponsorship perspective rather than being implemented solely as an operational HR matter.

For example, managers should understand that changes involving:

 

• a materially different role;
• substantial changes to duties;
• promotion or restructuring;
• movement into another part of the organisation; or
• other significant changes to the sponsored employment

 

may need to be escalated for immigration compliance review.

The appropriate sponsor action will depend on the nature of the change and the immigration route concerned. A worker carrying out a role that does not correspond with the sponsored occupation and job description, where the change is not permitted, can create serious sponsor licence consequences. Detailed requirements relating to changes in sponsored workers’ circumstances should therefore be considered separately from the monitoring process itself.

 

2. Monitoring Salary Changes

 

Salary information is another area where effective communication between payroll, HR and sponsor licence personnel is important.

A salary change may arise for many reasons, including:

 

• annual pay reviews;
• promotion;
• changes in working hours;
• sickness absence;
• family-related leave;
• unpaid leave;
• changes to allowances or other remuneration arrangements; or
• changes to the worker’s role.

 

Employers should have a process for identifying salary changes affecting sponsored workers before assuming that the change can be treated in the same way as it would be for a non-sponsored employee.

The sponsor should consider whether the revised arrangements remain compliant with the applicable sponsorship requirements and whether the change creates a reporting obligation.

 

3. Monitoring Sponsored Workers’ Work Locations

 

The sponsor should maintain accurate information about where sponsored workers normally carry out their employment.

Work location is distinct from the worker’s personal residential address. It concerns where the sponsored role is being performed and forms part of the wider sponsorship arrangements.

Changes to a sponsored worker’s normal work location can have sponsor reporting implications. This can include circumstances where the worker moves to another branch or begins working at a different client site that was not previously recorded as part of the sponsorship arrangements.

Employers should therefore have procedures that allow relevant work-location changes to be identified and escalated before they become established working arrangements without sponsor compliance having been considered.

 

4. Hybrid and Remote Working

 

Hybrid and remote working arrangements can make traditional attendance monitoring less straightforward, but they do not remove the sponsor’s responsibility to maintain appropriate oversight of sponsored workers.

The method used to demonstrate effective oversight will depend on the nature of the organisation and the worker’s role.

Depending on the circumstances, employers may use information generated through:

 

• physical workplace attendance systems;
• electronic time-recording systems;
• work schedules;
• scheduled meetings;
• project or workflow management systems;
• manager supervision; and
• other appropriate business records.

 

These are examples rather than Home Office-prescribed methods of attendance monitoring. The relevant question is whether the sponsor’s arrangements enable it to maintain effective oversight and identify relevant changes or unexplained absence.

A move to a hybrid working pattern does not, by itself, need to be reported. Sponsors should instead report changes to the worker’s main office work location or new client sites, and must report entirely remote contractual homeworking where there is little or no requirement to attend the sponsor’s premises or a client site. Suitable records of hybrid working arrangements should be maintained.

 

5. Sponsored Workers at Client Sites

 

Some sponsored workers may perform their duties at a client’s premises or another location away from the sponsor’s own workplace.

The sponsor remains responsible for meeting its sponsor duties. Placing a worker at a client site does not transfer responsibility for sponsor compliance to the client.

The employer should retain sufficient oversight to understand:

 

• where the sponsored worker is working;
• what work the individual is undertaking;
• whether the worker is attending as expected;
• whether the working arrangements have changed; and
• whether any change to the normal work location requires sponsor action or reporting.

 

Where a worker moves to a different client site or another work location, the sponsor should assess the change against the applicable Home Office reporting requirements.

 

6. Sponsored Workers With Multiple Work Locations

 

Where a sponsored worker routinely performs duties across several locations, the employer’s records should accurately reflect the working arrangements.

The organisation should also have a process for distinguishing between established working arrangements and subsequent changes that may have sponsor compliance implications.

Managers responsible for workers who move between sites should understand that changes to work location may need to be communicated to HR or sponsor licence personnel rather than being treated solely as an operational deployment decision.

 

7. Monitoring the End of Employment

 

The employer should also have processes capable of identifying promptly when sponsored employment is ending.

This may arise through:

 

• resignation;
• dismissal;
• redundancy;
• expiry of a fixed-term arrangement;
• the worker ceasing to work for the sponsor; or
• another event bringing the sponsored employment to an end.

 

HR processes dealing with leavers should therefore identify sponsored workers and ensure that the appropriate sponsor licence personnel are notified so that any required Home Office reporting can be completed.

 

 

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Section I: Building an Effective Sponsor Licence Monitoring System

 

A sponsor licence monitoring system should be designed so that responsibility for compliance is clear and relevant information flows effectively between the people responsible for managing sponsored workers.

For many employers, compliance failures do not arise because there is no HR policy. They arise because information is identified by one part of the organisation but does not reach the person responsible for assessing its sponsor compliance implications.

An effective monitoring system should therefore connect operational workforce management with sponsor licence administration.

 

1. Who Is Responsible for Monitoring Sponsored Workers?

 

Sponsor compliance may involve several functions within an organisation. Different individuals can perform different operational tasks, but the sponsor remains responsible for ensuring that appropriate systems are in place and that its sponsor duties are met.

 

Role	Typical Monitoring Responsibility
Authorising Officer	Provides senior oversight of the sponsor licence and helps ensure that the organisation has appropriate arrangements for meeting its sponsor duties.
Key Contact	Acts as a principal point of contact between the sponsoring organisation and the Home Office.
Level 1 User	Undertakes authorised sponsor licence administration through the Sponsor Management System and makes relevant reports where required.
HR team	Maintains employee information and manages processes involving absence, personal details and employment changes.
Line managers	May be the first to identify attendance problems, absence, changes in duties or changes in working arrangements.
Payroll team	May identify salary, payment or working-hours changes requiring sponsor compliance consideration.

 

The precise allocation of responsibilities will vary between organisations. What matters is that responsibilities are understood and relevant information is escalated to the appropriate person.

 

2. The Role of the Authorising Officer

 

The Authorising Officer has overall responsibility for the organisation’s sponsorship compliance arrangements and for the activities of SMS users.

This does not mean that the Authorising Officer must personally check every attendance record, process every address change or undertake every administrative task.

Instead, the organisation should have appropriate governance arrangements under which operational monitoring can be carried out by relevant personnel while significant compliance issues are escalated appropriately.

The Authorising Officer should have sufficient visibility of the sponsor compliance framework to understand whether the organisation’s systems are functioning effectively.

 

3. The Role of Line Managers

 

Line managers can play an important role because they often have the closest day-to-day oversight of sponsored workers.

They may be the first people to become aware that:

 

• a worker has stopped attending;
• absence has become prolonged;
• the worker’s duties have changed;
• the worker has moved to another site;
• working arrangements have changed; or
• the worker is no longer performing the role in the expected way.

 

Managers do not necessarily need detailed knowledge of immigration law. They do, however, need to know which types of event should be escalated and who within the organisation should receive that information.

 

4. The Role of HR

 

HR is often central to sponsor monitoring because it maintains many of the records and processes through which relevant changes are identified.

These can include:

 

• onboarding;
• attendance;
• absence management;
• personal contact information;
• changes in role;
• changes in working arrangements;
• leave;
• disciplinary procedures;
• resignation and termination; and
• other employment changes.

 

Where HR and sponsor licence administration are handled by different people, there should be a defined escalation process between them.

 

5. The Role of Payroll

 

Payroll information can reveal changes that have sponsorship implications, particularly in relation to salary and working arrangements.

Employers should therefore ensure that relevant payroll changes affecting sponsored workers are capable of being escalated to HR or sponsor licence personnel.

This is particularly important where a salary change results from circumstances such as reduced hours, unpaid absence or another change to the employment arrangements.

 

6. Connecting HR Systems With Sponsor Compliance

 

Sponsor monitoring is most effective when immigration compliance triggers are incorporated into existing workforce processes.

For example:

Absence recorded → Sponsored worker identified → Compliance implications considered

Address changed → Required contact history updated → Sponsor record checked

Salary changed → Payroll and HR records updated → Sponsorship implications reviewed

Work location changed → Sponsor implications assessed → SMS report made where required

Worker resigns → Leaver process identifies sponsorship → Reporting requirement considered

This approach reduces reliance on individual memory and makes sponsor compliance part of ordinary workforce governance.

 

7. Avoiding Disconnected Compliance Systems

 

One of the most significant practical weaknesses can arise where sponsor licence administration operates separately from the employer’s normal HR processes.

Examples include:

 

• line managers recording absence without notifying HR;
• HR changing employee details without maintaining the required sponsor records;
• payroll implementing salary changes without sponsor compliance review;
• operational managers moving workers between locations without informing the sponsor licence team;
• the sponsor licence team holding information that conflicts with the HR system; and
• no individual having responsibility for resolving discrepancies.

 

Employers should design their monitoring processes around information flow. The objective is to ensure that a relevant event identified anywhere within the organisation reaches the person capable of assessing and acting upon its sponsor compliance implications.

 

 

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Section J: Practical Sponsor Licence Monitoring Framework

 

For employers sponsoring workers, compliance is easier to manage when monitoring duties form part of a defined process rather than relying on individual members of staff to remember immigration requirements.

A practical framework can be structured around six stages:

Recruit → Onboard → Monitor → Record → Review → Report

Each stage should connect with the next so that relevant information about a sponsored worker is captured, assessed and escalated where necessary.

 

1. Recruit

 

Sponsor compliance should be considered before the sponsored worker starts employment.

The employer should ensure that relevant personnel understand the principal circumstances of the sponsored role, including:

 

• the job being sponsored;
• the worker’s duties;
• salary;
• working hours and arrangements;
• normal work location; and
• the proposed start date.

 

This provides an employment and sponsorship baseline against which subsequent changes can be identified.

It also helps prevent a situation where recruitment personnel understand the original sponsorship arrangements but managers, HR or payroll subsequently implement changes without appreciating their immigration implications.

 

2. Onboard

 

When a sponsored worker joins the organisation, the employer should ensure that the individual is correctly identified within its HR and sponsor compliance systems.

The onboarding process should capture the information and documents required for sponsor compliance and explain how relevant changes should be communicated during employment.

Depending on the organisation’s processes, onboarding should ensure that:

 

• the worker is identifiable as a sponsored worker within relevant systems;
• required contact details are recorded;
• the correct work location is recorded;
• relevant employment information corresponds with the sponsorship arrangements;
• attendance and absence procedures are explained;
• the worker understands how to notify the employer of changes to required contact details; and
• appropriate managers understand the internal escalation procedure for sponsor-related issues.

 

Employers should also ensure that access to immigration and personal information is managed appropriately. Managers only need access to information necessary for them to perform their role within the organisation’s compliance process.

 

3. Monitor

 

Once employment begins, the employer must maintain effective systems for monitoring relevant aspects of the sponsored worker’s circumstances.

Monitoring should include, where applicable:

 

• attendance;
• absence;
• required contact details;
• normal work location;
• job role and duties;
• salary and relevant working arrangements;
• continued employment; and
• other changes capable of affecting sponsorship.

 

Monitoring should operate through ordinary business processes wherever possible. This makes it more likely that sponsor compliance reflects what is actually happening within the organisation rather than relying on a separate immigration record that may become disconnected from operational reality.

 

4. Record

 

Relevant information identified through monitoring should be recorded appropriately.

The organisation should be capable of demonstrating what happened, when the relevant event occurred, what information was obtained and what action was taken.

Depending on the circumstances, records may therefore include:

 

• attendance and absence information;
• communications with the worker;
• information supplied by managers;
• changes to required contact details;
• HR records;
• payroll information;
• internal compliance assessments;
• decisions made and the reasons for those decisions; and
• evidence of subsequent reporting where applicable.

 

The detailed Home Office requirements governing documents sponsors must retain are considered separately under Sponsor Licence Record-Keeping Duties. The monitoring process should nevertheless ensure that relevant information is captured rather than relying on records being reconstructed after a compliance issue arises.

 

5. Review

 

Information generated by monitoring should be reviewed where it indicates a potentially relevant change or compliance issue.

For example, where an employer identifies an extended period of absence, it may need to establish:

 

• whether the absence is authorised;
• why the worker is absent;
• whether salary has been affected;
• whether employment is continuing;
• whether the worker remains in the sponsored role; and
• whether any reporting obligation has arisen.

 

Employers should also periodically review their monitoring arrangements more broadly. This can help identify discrepancies between HR, payroll, management and sponsor licence records before they develop into larger compliance problems.

 

6. Report Where Required

 

Where monitoring identifies a reportable event, the organisation should ensure that the information reaches an appropriate Level 1 User or other responsible person so that the required action can be taken through the Sponsor Management System.

Reporting requirements and deadlines depend on the event concerned. Employers should therefore avoid relying on a single general deadline for every type of sponsor change.

The exception addressed specifically in this guide is absence without permission for more than 10 consecutive working days. Where that threshold is reached, the sponsor must make the required report no later than 10 working days after the tenth day of absence.

Other reporting requirements are considered in detail within the separate Sponsor Licence Reporting Duties guidance.

 

 

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Section K: Common Sponsor Licence Monitoring Failures

 

Sponsor monitoring failures are not always caused by an employer deliberately ignoring its obligations. Problems frequently arise because ordinary workforce processes are not connected effectively with sponsor licence compliance.

Employers should understand the practical weaknesses most likely to result in important information being overlooked.

 

1. Treating Monitoring as an Application Requirement

 

A common mistake is to focus heavily on compliance when applying for the Sponsor Licence and then allow those systems to become less effective once the licence has been granted.

Sponsor compliance is ongoing. The employer needs functioning monitoring arrangements throughout the period in which it holds the licence and sponsors workers.

Policies created for the licence application should therefore be implemented in practice, reviewed and adapted as the organisation changes.

 

2. Failing to Monitor Attendance Effectively

 

An employer may have an attendance system but still fail to meet its monitoring objectives if the information is not reviewed or acted upon.

For example, problems can arise where:

 

• absence is recorded but unexplained absence is not investigated;
• different departments use separate attendance systems;
• remote workers fall outside normal attendance procedures;
• managers know that a worker is absent but do not inform HR;
• nobody monitors when an absence without permission is approaching the 10 consecutive working day threshold; or
• attendance records cannot readily be retrieved when required.

 

The sponsor should therefore test both whether attendance information exists and whether the system ensures that relevant issues trigger action.

 

3. Failing to Maintain Contact Detail History

 

Another weakness can arise where the employer maintains a worker’s current address, email address and telephone number but does not preserve the required history of those details.

This can occur where an HR system simply overwrites the previous information whenever an employee updates their profile.

Sponsors should ensure that their systems allow them to retain the required history of sponsored workers’ UK residential addresses, personal email addresses and telephone numbers and that this information is kept up to date.

 

4. Poor Communication Between Managers and HR

 

Line managers are often the first people to become aware of attendance problems or changes in working arrangements.

A monitoring failure can occur where the manager deals with the matter operationally but does not recognise that HR or sponsor licence personnel also need to know.

Examples include:

 

• agreeing a change of work location;
• informally changing duties;
• allowing a different working pattern;
• dealing with repeated absence;
• learning that the worker intends to leave; or
• moving the worker to another team or client site.

 

Managers do not need to determine the immigration consequences themselves. They need a clear escalation route so that the appropriate person can make that assessment.

 

5. HR Systems That Do Not Communicate With Sponsor Processes

 

Large organisations may use separate systems for recruitment, HR, attendance, payroll and immigration administration.

This can create compliance risk where changes entered into one system are not reflected elsewhere.

For example:

 

• HR records a new residential address but the required contact history is not maintained;
• payroll changes salary without notifying the sponsor licence team;
• an absence management system records prolonged absence but no immigration compliance review occurs;
• a manager changes a work location without HR being informed; or
• the sponsor licence team continues to rely on information that is no longer consistent with the worker’s actual circumstances.

 

Employers should therefore consider how information passes between systems rather than simply whether each individual system contains records.

 

6. Assuming Payroll Records Are Sufficient

 

Payment of salary does not establish that the employer has effectively monitored a sponsored worker.

Payroll records may show what a worker has been paid, but they may not explain whether the individual attended work, whether absence was authorised, whether duties changed or whether the worker remained at the expected work location.

Payroll should therefore support the monitoring framework rather than substitute for attendance, absence and workforce oversight.

 

7. Failing to Escalate Salary Changes

 

Salary changes can sometimes be implemented through payroll without the sponsor licence team becoming aware of them.

This may happen following changes to hours, absence, internal restructuring or other employment events.

Employers should ensure that changes affecting sponsored workers are identifiable and capable of being assessed against the applicable sponsorship requirements before the organisation assumes that no immigration action is necessary.

 

8. Failing to Monitor Work Location Changes

 

Operational decisions about where employees work can have sponsor compliance implications.

Problems can arise where sponsored workers are moved between branches, client sites or other locations without the change being considered from a sponsorship perspective.

Employers should ensure that relevant changes to a sponsored worker’s normal work location are escalated so that any applicable SMS reporting requirement can be identified.

 

9. Policies That Do Not Reflect Actual Practice

 

A sponsor may have detailed written procedures but still face compliance difficulties if employees do not follow them.

For example, a policy may state that managers must notify HR immediately about unexplained absence, while managers in practice handle the issue themselves and only involve HR much later.

Employers should therefore test whether their documented procedures correspond with what actually happens within the organisation.

This is particularly important when preparing for a Home Office compliance visit, where the practical operation of sponsor systems may be examined rather than the existence of written policies alone.

 

10. Failing to Review Monitoring Systems as the Organisation Changes

 

A monitoring system that was appropriate when an organisation sponsored five workers may no longer be adequate when it sponsors fifty or several hundred workers.

Likewise, systems may need to change following:

 

• rapid workforce growth;
• business restructuring;
• acquisitions;
• changes in HR personnel;
• implementation of new HR technology;
• increased remote or hybrid working;
• expansion into additional sites; or
• significant increases in the sponsored workforce.

 

Periodic review allows the employer to determine whether its monitoring arrangements remain appropriate to the size, complexity and working practices of the organisation.

 

 

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Section L: What Happens If a Sponsor Fails to Monitor Sponsored Workers?

 

Failure to maintain effective monitoring systems can expose an organisation to sponsor compliance risk. The Home Office expects licensed sponsors to have systems capable of monitoring sponsored workers and identifying relevant changes or events.

A weakness in one individual record will not necessarily result in enforcement action. The Home Office will consider the circumstances, including the nature and seriousness of any breach. However, repeated failures, ineffective systems or evidence that sponsor duties are not being carried out can place the Sponsor Licence at risk.

Monitoring failures can be particularly significant where they result in the sponsor failing to identify or report an event that should have been notified to the Home Office.

 

1. Examples of Monitoring Failures

 

Potential compliance concerns can arise where an employer:

 

• cannot demonstrate how sponsored worker attendance is monitored;
• does not maintain appropriate absence records;
• fails to investigate unexplained absence;
• fails to identify absence without permission exceeding the applicable reporting threshold;
• does not maintain the required history of sponsored workers’ contact details;
• cannot establish where sponsored workers are normally working;
• fails to identify changes in job role, salary or working arrangements;
• does not have an effective process for managers to escalate relevant information;
• maintains inconsistent information across HR, payroll and sponsor records;
• identifies relevant changes but fails to assess whether they need to be reported; or
• has written compliance procedures that are not followed in practice.

 

These issues may cause the Home Office to question whether the sponsor has effective systems for meeting its duties.

 

2. Possible Home Office Action

 

Where the Home Office identifies sponsor compliance failures, the consequences will depend on the nature of the issue, the applicable sponsor guidance and the wider circumstances.

Potential action can include:

 

• requiring the sponsor to address identified compliance weaknesses;
• restrictions affecting sponsorship activity;
• downgrading of the Sponsor Licence where the applicable regime permits this;
• suspension of the Sponsor Licence while concerns are investigated; or
• revocation of the Sponsor Licence in sufficiently serious circumstances or where the applicable grounds for revocation are met.

 

Employers should not assume that every administrative error will lead to suspension or revocation. Equally, monitoring should not be treated as a low-level administrative obligation. Weak monitoring can prevent the sponsor from identifying other breaches and may therefore expose the organisation to wider compliance problems.

 

3. Missed Reporting Obligations

 

One of the principal risks created by poor monitoring is that the employer does not identify an event that needs to be reported.

For example, if managers do not escalate absence information, sponsor licence personnel may be unaware that a worker has been absent from work without permission for more than 10 consecutive working days.

Likewise, if changes to salary, work location or employment arrangements are implemented without sponsor compliance review, the organisation may fail to consider whether an SMS report is required.

This is why monitoring and reporting need to operate as connected processes:

Monitor → Identify → Assess → Record → Report where required

 

4. Wider Sponsor Compliance Risk

 

Monitoring failures can also indicate broader weaknesses in the organisation’s sponsor compliance arrangements.

For example, inaccurate contact information may suggest deficiencies in record keeping. Failure to identify a work-location change may indicate poor communication between operational managers and HR. Unexplained salary discrepancies may indicate that payroll processes are disconnected from sponsor administration.

Employers should therefore investigate the cause of a monitoring failure rather than simply correcting the individual record.

Where the underlying problem is systemic, the organisation should consider whether similar issues may affect other sponsored workers.

 

 

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Section M: Home Office Compliance Visits and Sponsor Monitoring

 

Sponsor monitoring systems can become particularly important during a Home Office compliance visit or other compliance activity.

The Home Office may examine whether the sponsor has appropriate systems for carrying out its duties and whether those systems operate effectively in practice.

Employers should therefore be prepared to demonstrate more than the existence of written HR or immigration policies. They should be able to explain how sponsored workers are actually monitored and how relevant information moves through the organisation.

 

1. What May Be Examined?

 

Depending on the circumstances of the compliance activity, the sponsor may need to demonstrate how it manages matters such as:

 

• identification of sponsored workers;
• attendance monitoring;
• absence recording;
• investigation of unexplained absence;
• maintenance of required contact details;
• changes to work location;
• changes to role or duties;
• salary and payroll information;
• internal escalation procedures;
• sponsor reporting decisions; and
• record keeping.

 

The Home Office may therefore be interested in both the information held by the sponsor and the processes used to generate, review and act upon that information.

 

2. Policies Versus Practice

 

A written sponsor compliance policy can help demonstrate that the organisation has considered its obligations, but the policy needs to correspond with actual working practices.

For example, a policy may state that all unexplained absence involving sponsored workers must be escalated to HR. If managers do not understand or follow that process, the existence of the written policy alone does not ensure effective monitoring.

The same issue can arise where an organisation has procedures requiring sponsored workers to update their contact details but its HR system does not preserve the required history of those details.

Employers should therefore test both:

What does our policy say should happen?

and:

What actually happens in practice?

 

3. Testing Individual Sponsored Worker Files

 

A practical way to test monitoring arrangements is to select a sample of sponsored workers and attempt to reconstruct their current employment circumstances from the organisation’s records.

For each worker, the employer should be able to establish matters such as:

 

• what role the worker is currently performing;
• where the worker normally works;
• who manages the worker;
• whether the worker is attending as expected;
• whether there have been significant periods of absence;
• whether any absence without permission has been investigated;
• whether required contact details are current and their history has been maintained;
• what salary the worker is currently receiving;
• whether duties, salary, location or working arrangements have changed; and
• whether relevant changes have been considered for reporting purposes.

 

If the organisation cannot answer these questions confidently from its systems and records, this may indicate a weakness requiring investigation.

 

4. Testing Information Across Different Systems

 

Employers should also consider whether information is consistent across HR, payroll, attendance and sponsor administration systems.

For example, an internal review might compare:

 

• the worker’s HR record against the sponsorship information held by the organisation;
• salary recorded by HR against payroll;
• absence records against manager records;
• current contact details against the required contact history;
• work-location information against current operational arrangements; and
• identified employment changes against SMS reporting records where relevant.

 

Discrepancies should be investigated rather than simply corrected without explanation. The employer should establish why the inconsistency arose and whether the same process weakness could affect other sponsored workers.

 

5. Internal Sponsor Compliance Reviews

 

Employers do not need to wait for a Home Office compliance visit before testing their monitoring arrangements.

Periodic internal reviews can help identify issues such as:

 

• missing sponsored worker information;
• outdated contact details;
• failure to retain required contact-detail history;
• unexplained gaps in attendance records;
• inconsistent absence information;
• differences between HR and payroll records;
• unreported changes in work location;
• managers who do not understand escalation procedures;
• potential reporting events that were not escalated; and
• procedures that no longer reflect how the organisation operates.

 

Where weaknesses are identified, employers should consider both the immediate record and the underlying process.

Correcting one worker’s file may resolve the immediate discrepancy, but it will not prevent recurrence if the underlying monitoring system remains defective.

 

6. Monitoring as Ongoing Workforce Governance

 

Effective sponsor monitoring should operate continuously rather than being activated only when a Home Office visit is expected.

The objective is to create a system in which relevant workforce events are identified naturally through ordinary business processes and escalated for sponsor compliance review where necessary.

This allows the organisation to move from reactive compliance to ongoing workforce governance.

For employers with significant sponsored populations, this can also make compliance more scalable. Instead of relying on one individual to identify every immigration issue manually, the organisation creates processes through which managers, HR, payroll and sponsor licence personnel each contribute to maintaining accurate oversight.

 

 

 

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Section N: Sponsor Licence Monitoring Checklist for Employers

 

Employers should periodically test whether their sponsor monitoring arrangements work in practice rather than assuming that existing HR processes are sufficient.

The following checklist provides a practical framework for reviewing attendance, absence, contact details, employment changes, internal communication and record keeping.

 

1. Sponsored Worker Identification

 

• Do we maintain an accurate record of all workers currently sponsored by the organisation?
• Can relevant HR personnel identify which employees are sponsored workers?
• Can appropriate line managers identify when an employee is subject to sponsor compliance processes?
• Are responsibilities for monitoring sponsored workers clearly allocated?
• Do managers know who to contact when a sponsor-related issue arises?
• Can sponsor licence personnel obtain relevant information from HR, managers and payroll when required?

 

2. Attendance Monitoring

 

• Do we have an effective system for monitoring sponsored workers’ attendance?
• Does the system reflect the way our workforce actually operates?
• Are remote, hybrid, site-based and other working arrangements covered appropriately?
• Can we identify unexpected non-attendance promptly?
• Do managers know what to do when a sponsored worker fails to attend?
• Can attendance information be retrieved if required during a compliance review?

 

3. Absence Monitoring

 

• Are sponsored workers’ absences recorded?
• Can we distinguish authorised absence from absence without permission?
• Are unexplained absences investigated promptly?
• Are attempts to contact an absent sponsored worker appropriately recorded?
• Do we know when an absence without permission began?
• Do our systems identify when an absence without permission is approaching 10 consecutive working days?
• Is there an escalation process to ensure the applicable Home Office reporting deadline is not missed?
• Are prolonged or unusual periods of absence reviewed for wider sponsorship implications?
• Do we monitor cumulative unpaid or reduced-pay absence against the applicable four-week threshold?

 

4. Sponsored Worker Contact Details

 

• Do we hold each sponsored worker’s current UK residential address?
• Do we hold their current personal email address?
• Do we hold their current telephone number?
• Do we retain the required history of these contact details?
• Does our HR system preserve previous information rather than simply overwriting it?
• Are sponsored workers told how to notify the organisation when their details change?
• Are changes reflected promptly in the appropriate records?
• Do we periodically test whether the contact information held remains current?

 

5. Employment Circumstances

 

• Can we identify changes to sponsored workers’ roles or duties?
• Are promotions and internal transfers escalated for sponsor compliance consideration?
• Are salary changes communicated to appropriate sponsor licence personnel?
• Are changes to working hours or other working arrangements identified?
• Do we identify changes to a sponsored worker’s normal work location?
• Are movements between branches or client sites escalated where appropriate?
• Are hybrid arrangements recorded, with separate review of changes to the main office location, new client sites or entirely remote working?
• Does the leaver process identify sponsored workers whose employment is ending?

 

6. Internal Communication

 

• Do line managers understand which events involving sponsored workers should be escalated?
• Is there a defined communication route between managers, HR, payroll and sponsor licence key personnel?
• Are relevant events assessed promptly for possible sponsor reporting implications?
• Is responsibility for making required SMS reports clearly allocated?
• Is there cover where the person normally responsible for sponsor administration is unavailable?
• Do different departments understand their role within the wider sponsor compliance framework?

 

7. Record Keeping

 

• Can we demonstrate how our sponsor monitoring system operates in practice?
• Are attendance and absence records accessible?
• Can we evidence investigations into absence without permission?
• Can we demonstrate attempts to contact a worker where relevant?
• Is the required history of contact details maintained?
• Are compliance decisions and actions documented appropriately?
• Can relevant records be retrieved efficiently if requested during Home Office compliance activity?
• Do our records provide a coherent explanation of the sponsored worker’s current circumstances?

 

8. Reporting Escalation

 

• Do monitoring systems identify events that may need to be reported?
• Does the relevant information reach an appropriate Level 1 User or other responsible person?
• Are applicable reporting deadlines understood?
• Is there a process for establishing the facts before a reporting decision is made?
• Is evidence of the decision retained where appropriate?
• Can we demonstrate that required reports have been made?

 

 

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Section O: Questions to Ask During a Sponsor Monitoring Review

 

A practical way to assess the effectiveness of sponsor monitoring is to select individual sponsored workers and test whether the organisation can reconstruct their current employment circumstances from its records.

This approach can reveal weaknesses that may not be apparent from reviewing policies alone.

 

1. Questions About the Worker

 

For each sponsored worker selected for review, consider whether the organisation can answer the following questions:

 

• What role is the worker currently performing?
• Are their current duties consistent with the sponsored employment?
• What salary are they currently receiving?
• What are their current working hours and arrangements?
• Where do they normally work?
• Who is their line manager?
• Are they attending work as expected?
• Have they had any significant periods of absence?
• Have they had any periods of absence without permission?
• Are their required contact details current?
• Has the required history of their contact details been retained?
• Have their duties, salary, location or working arrangements changed?
• Have any relevant changes been assessed for sponsor reporting purposes?

 

If these questions cannot be answered confidently using the organisation’s records and systems, the employer should investigate whether there is a weakness in its monitoring arrangements.

 

2. Questions About Attendance and Absence

 

The review should test whether attendance and absence information can be followed from the original event through to any resulting action.

Questions may include:

 

• How is this worker’s attendance monitored?
• Where are their absence records held?
• Who is responsible for reviewing unexplained absence?
• How would HR know if this worker stopped attending?
• How would the sponsor licence team be notified?
• Would the system identify an absence without permission approaching 10 consecutive working days?
• Can we evidence what happened during previous significant absences?

 

3. Questions About Contact Details

 

Employers should test whether the required contact information is both current and historically complete.

Questions may include:

 

• What is the worker’s current UK residential address?
• What is their current personal email address?
• What telephone number is held?
• When were these details last changed?
• Can previous contact details be retrieved?
• How does the worker notify the organisation of a change?
• Does the HR system retain a history or simply overwrite previous information?

 

4. Questions About Internal Information Flow

 

A monitoring review should also test how information moves through the organisation.

For example:

 

• If the worker changes role, who tells the sponsor licence team?
• If payroll changes salary, what compliance check occurs?
• If the manager changes the worker’s location, who reviews the sponsorship implications?
• If the worker stops attending, how quickly will HR know?
• If the worker resigns, does the leaver process automatically identify that sponsorship is involved?
• If the usual Level 1 User is unavailable, who deals with an urgent reporting requirement?

 

The objective is to identify points where information could become trapped within one department or depend excessively on a single individual’s knowledge.

 

5. Questions About Governance

 

Employers should also consider whether the monitoring framework remains appropriate to the organisation as a whole.

Relevant questions include:

 

• Who has overall oversight of sponsor compliance?
• When were monitoring procedures last reviewed?
• Are responsibilities documented?
• Have relevant managers and HR personnel received appropriate training?
• Are sponsor compliance processes included when new HR or payroll systems are introduced?
• Are monitoring arrangements reviewed following restructuring or organisational change?
• Are recurring compliance issues analysed for their underlying cause?

 

6. Acting on Monitoring Review Findings

 

Where an internal review identifies a problem, the employer should consider both the individual issue and the wider process that allowed it to arise.

For example, discovering that one sponsored worker’s previous residential address has not been retained should prompt more than correction of that worker’s record. The organisation should establish whether its HR system has overwritten historical contact information for other sponsored workers.

Likewise, identifying one missed work-location escalation should lead the employer to consider whether managers generally understand when location changes need sponsor compliance review.

A useful remediation process is:

Identify issue → Establish facts → Correct record where appropriate → Assess reporting implications → Identify root cause → Test wider population → Improve process

This approach helps ensure that internal monitoring reviews result in sustainable compliance improvements rather than isolated administrative corrections.

 

 

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Section P: Sponsor Licence Monitoring Duties: Key Takeaways for Employers

 

Sponsor licence monitoring duties require more than retaining documents about sponsored workers. Employers need functioning systems that allow them to maintain oversight of sponsored employees and identify changes that may require investigation, record keeping or reporting to the Home Office.

For most organisations, the core principles are to:

 

• know who the organisation is currently sponsoring;
• maintain effective systems for monitoring sponsored workers’ attendance;
• record relevant periods of absence;
• identify and investigate unexplained absence promptly;
• recognise when absence without permission reaches the applicable Home Office reporting threshold;
• maintain an up-to-date history of required sponsored worker contact details;
• monitor relevant changes to job role, salary, working arrangements and normal work location;
• ensure information reaches the people responsible for sponsor compliance;
• document relevant compliance decisions and actions;
• assess whether identified events trigger an SMS reporting obligation; and
• periodically test whether monitoring systems work in practice.

 

The compliance risk often arises not because an employer is completely unaware of a change, but because information does not move effectively through the organisation.

A line manager may know that a sponsored worker has stopped attending. Payroll may know that salary arrangements have changed. HR may know that the worker has moved address. An operational manager may know that the worker has moved to another location. Sponsor licence personnel may know none of these things unless the organisation has established effective escalation procedures.

Sponsor monitoring should therefore operate as part of wider workforce governance rather than as an isolated immigration administration function.

A practical framework is:

Recruit → Onboard → Monitor → Record → Review → Report

Employers that embed these stages into ordinary HR processes are better placed to identify compliance issues early, maintain accurate sponsor records and demonstrate effective oversight if their systems are examined by the Home Office.

 

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Section Q: Conclusion

 

Sponsor licence monitoring duties require employers to maintain effective oversight of sponsored workers throughout the period of sponsorship. This includes having systems capable of tracking and recording attendance and absence, maintaining the required history of contact details and identifying relevant changes in employment circumstances.

Monitoring should not be treated as a passive record-keeping exercise. The purpose of the system is to enable the sponsor to identify relevant events and determine whether further action is required.

This is particularly important in relation to absence. Sponsors need processes capable of distinguishing authorised absence from absence without permission, investigating unexplained non-attendance and recognising where the specific Home Office reporting threshold is reached. Where a sponsored worker has been absent from work without permission for more than 10 consecutive working days, the applicable reporting requirement must be addressed within the required timeframe.

Effective monitoring also depends on accurate contact information. Sponsors must maintain an up-to-date history of sponsored workers’ UK residential addresses, personal email addresses and telephone numbers. Systems should therefore preserve the required historical information rather than simply replacing old details whenever an employee record is updated.

Employers also need to maintain oversight of wider employment circumstances. Changes to role, duties, salary, working arrangements and normal work location can have sponsorship implications and should be capable of being escalated for appropriate review.

The effectiveness of these systems depends heavily on communication within the organisation. Line managers, HR teams, payroll personnel and sponsor licence key personnel may each hold different pieces of information about a sponsored worker. Employers need clear processes for ensuring relevant information reaches the people responsible for assessing its sponsor compliance implications.

The practical framework remains:

Recruit → Onboard → Monitor → Record → Review → Report

Monitoring should be embedded within ordinary workforce management rather than treated as an occasional immigration administration exercise. Employers should also test their systems periodically to ensure that the procedures described in policies operate effectively in practice.

Where monitoring identifies a potentially significant change, the employer should establish the facts, maintain an appropriate record of its actions and determine whether the matter triggers a separate reporting obligation.

Ultimately, a sponsor should be able to demonstrate that it knows who it sponsors, whether those workers are attending as expected, where they are working, whether required contact information is current and whether relevant changes in their circumstances are being identified and acted upon.

 

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Section R: Frequently Asked Questions

 

What are Sponsor Licence monitoring duties?

Sponsor Licence monitoring duties concern the systems and processes licensed sponsors use to maintain oversight of sponsored workers throughout their employment.

This includes monitoring attendance and absence, maintaining the required history of contact details and identifying relevant changes in employment circumstances. Effective monitoring also enables the sponsor to recognise events that may need to be considered under its separate reporting duties.

 

Do sponsors have to monitor sponsored workers’ attendance?

Yes. Sponsors must have systems in place to monitor sponsored workers’ attendance and maintain appropriate records of absence.

The precise method used will depend on the organisation and the nature of the work. Depending on the working arrangements, employers may use attendance systems, timesheets, shift or rota records, absence systems or other appropriate business records.

The system needs to work in practice and allow the employer to identify unexplained or unauthorised absence.

 

What should an employer do if a sponsored worker does not attend work?

The employer should establish why the worker has failed to attend and whether the absence has been authorised.

Where the absence is unexplained, the sponsor should take appropriate steps to contact the worker, record the absence and attempts to establish the circumstances, and consider whether further sponsor compliance action is required.

The employer should also monitor the duration of any absence without permission because a specific Home Office reporting requirement applies where the absence exceeds 10 consecutive working days.

 

Does every sponsored worker absence have to be reported to the Home Office?

No. An absence does not automatically have to be reported simply because a sponsored worker is away from work.

The employer should establish the nature and circumstances of the absence and determine whether a reporting requirement applies.

However, where a sponsored worker has been absent from work without permission for more than 10 consecutive working days, the sponsor must report the absence through the Sponsor Management System. The report must be made no later than 10 working days after the tenth day of absence, even where the employer intends to continue sponsoring the worker.

 

What is the 10-day absence rule for sponsored workers?

The 10-day rule applies where a sponsored worker is absent from work without permission for more than 10 consecutive working days.

Once the applicable threshold is reached, the sponsor must make the required report to the Home Office through the Sponsor Management System no later than 10 working days after the tenth day of absence.

Employers should therefore have monitoring and escalation procedures capable of identifying an absence before the reporting deadline is missed.

 

Do employers need to monitor sickness absence?

Yes. Sickness absence should form part of the employer’s wider absence monitoring arrangements for sponsored workers.

Routine sickness absence will ordinarily be managed through the employer’s normal absence procedures. However, prolonged or unusual absence may require additional consideration, particularly where it affects salary, working arrangements, continued employment or the worker’s ability to continue performing the sponsored role.

Sickness absence does not automatically mean that sponsorship is affected or that an SMS report is required. The employer should consider the particular circumstances, including whether the worker has moved onto reduced pay or no pay and whether the four-week rule or a permitted exception is engaged.

 

What happens if a sponsored worker is on unpaid or reduced pay for more than four weeks?

Specific sponsor rules apply where unpaid or reduced-pay absence exceeds four weeks in total in a calendar year, or during the sponsor’s period of sponsorship responsibility for a Scale-up Worker. Where no permitted exception applies, the sponsor will normally need to stop sponsoring the worker. Where an exception applies, the absence should still be reported through the SMS.

 

What contact details must sponsors keep for sponsored workers?

Sponsors must maintain a history of specified contact details for sponsored workers and keep that information up to date.

This includes the worker’s:

 

• UK residential address;
• personal email address; and
• telephone number, whether mobile, landline or both where applicable.

 

The requirement concerns maintaining the relevant history, not simply holding the worker’s latest contact details.

 

Do sponsors need to keep previous addresses and contact details?

Yes. The sponsor record-keeping requirements refer to maintaining a history of the sponsored worker’s required contact details.

Employers should therefore check whether their HR systems preserve previous UK residential addresses, personal email addresses and telephone numbers when information is updated.

A system that simply overwrites previous information can create a compliance weakness if the required history is no longer available.

 

How should sponsors keep contact details up to date?

Employers can use their normal HR systems, provided those systems allow the sponsor to maintain the required information effectively.

Practical measures can include requiring sponsored workers to notify HR when relevant contact details change, providing an employee self-service process for submitting changes and periodically checking the accuracy of information held.

The employer should also ensure that the required history is retained when details are updated.

 

Who is responsible for monitoring sponsored workers?

Operational responsibility will usually be shared across the organisation.

Line managers may identify attendance, absence and workplace issues. HR may maintain employment and contact information. Payroll may identify salary-related changes. Sponsor licence key personnel should ensure that relevant information is considered from a sponsorship perspective and that required sponsor action is taken.

The organisation should have clear processes for escalating relevant information between these functions.

 

Does the Authorising Officer have to monitor every sponsored worker personally?

No. The Authorising Officer does not have to undertake every administrative monitoring task personally.

The organisation must, however, have appropriate governance and systems to ensure its sponsor duties are met. Monitoring responsibilities can therefore be allocated to appropriate personnel, provided information is escalated effectively and there is suitable oversight of sponsor compliance.

 

What happens if a sponsor loses contact with a sponsored worker?

The employer should investigate promptly and retain appropriate evidence of attempts to establish the worker’s circumstances.

This may involve using the contact information held by the organisation, checking whether the worker has communicated with their manager or another department and establishing when the worker last attended work.

The sponsor should then consider whether the circumstances trigger any action or reporting requirement under the applicable Home Office sponsor guidance.

 

Do remote and hybrid sponsored workers still need to be monitored?

Yes. Remote or hybrid working does not remove the sponsor’s responsibility to maintain appropriate oversight of sponsored workers.

The method of monitoring may differ from traditional workplace attendance. Depending on the role and working arrangements, employers may use electronic time records, scheduled meetings, workflow systems, manager supervision or other appropriate business records.

A move to a hybrid working pattern does not itself require reporting. Sponsors should instead consider whether there has been a change to the main office work location, a new client site or a move to entirely remote working, which can engage reporting requirements.

 

Do sponsors need to monitor where sponsored workers are working?

Yes. Employers should maintain sufficient oversight to understand where sponsored workers normally perform their sponsored employment.

Changes to normal work location can have sponsor reporting implications, including certain moves between branches or to different client sites.

Employers should therefore ensure that operational decisions affecting work location are escalated for sponsor compliance consideration where appropriate.

 

What if a sponsored worker works at a client site?

The sponsor remains responsible for meeting its sponsor duties. Working at a client site does not transfer the sponsor’s compliance responsibilities to the client.

The employer should maintain appropriate oversight of where the worker is working, whether they are attending as expected and whether there have been relevant changes to the working arrangements.

A move to another client site should also be considered for any applicable sponsor reporting requirement.

 

Do sponsors need to monitor salary changes?

Employers should have systems capable of identifying salary changes affecting sponsored workers so that the immigration implications can be assessed.

Salary changes may arise through promotion, changes in working hours, sickness absence, family-related leave, unpaid leave or other changes in employment circumstances.

The sponsor should consider whether the revised arrangements remain compliant with the applicable sponsorship requirements and whether a reporting obligation arises.

 

Can the Home Office check attendance records during a compliance visit?

The Home Office can examine whether a sponsor has effective systems for carrying out its sponsor duties and whether those systems operate in practice.

Employers should therefore be capable of explaining how sponsored worker attendance and absence are monitored and producing relevant records where required.

The organisation should also be prepared to explain how unexplained absence is investigated and how relevant information is escalated for sponsor compliance review.

 

Is monitoring the same as Sponsor Licence reporting?

No. Monitoring and reporting are connected but distinct sponsor compliance functions.

Monitoring allows the employer to identify what is happening within its sponsored workforce.

Reporting concerns determining whether a particular event or change must be notified to the Home Office and making the required report, generally through the Sponsor Management System.

An effective compliance process therefore operates as follows:

Monitor → Identify → Assess → Record → Report where required

 

How often should sponsor monitoring systems be reviewed?

Monitoring should operate continuously as part of normal workforce management rather than only when the organisation expects a Home Office compliance visit.

Employers should also conduct periodic reviews to identify outdated information, missing records, inconsistencies between systems and weaknesses in internal escalation procedures.

The frequency and scope of internal reviews should reflect factors such as the number of sponsored workers, the complexity of the organisation, workforce changes and the level of sponsor compliance risk.

 

What should an employer do if a monitoring review identifies a compliance problem?

The employer should establish the facts, correct inaccurate records where appropriate and assess whether the issue has created a reporting or other sponsor compliance requirement.

The organisation should also investigate the underlying cause rather than treating the problem solely as an isolated administrative error.

Where the issue resulted from a defective process, the employer should consider whether other sponsored workers may have been affected and whether wider remediation is required.

A practical approach is:

Identify issue → Establish facts → Correct record where appropriate → Assess reporting implications → Identify root cause → Test wider population → Improve process

 

 

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Section S: Glossary

 

Term	Meaning
Authorising Officer (AO)	The Authorising Officer has overall responsibility for the organisation’s sponsorship compliance arrangements and for the activities of SMS users. The Authorising Officer provides senior oversight but does not have to carry out every operational or administrative monitoring task personally.
Authorised Absence	Authorised absence is a period away from work that has been approved or otherwise permitted by the employer in accordance with its employment and absence procedures. This should be distinguished from absence without permission, which can have specific sponsor reporting implications where the applicable Home Office threshold is reached.
Certificate of Sponsorship (CoS)	A Certificate of Sponsorship is an electronic sponsorship record assigned by a licensed sponsor to an eligible worker. It contains information relating to the sponsored employment and is used by the worker in connection with the relevant immigration application.
Compliance Visit	A compliance visit is a Home Office assessment of a sponsor or prospective sponsor. Compliance activity can involve examination of the organisation’s HR systems, sponsor records, sponsored workers and the practical operation of its sponsor compliance arrangements.
Home Office	The Home Office is the UK government department responsible for immigration policy and administration, including the worker sponsorship system.
Key Contact	The Key Contact is one of the sponsor licence key personnel roles and acts as a principal point of contact between the sponsoring organisation and the Home Office.
Level 1 User	A Level 1 User is a person authorised to undertake sponsor licence administration through the Sponsor Management System, subject to the permissions and requirements applying to the role. Level 1 Users can carry out relevant sponsor management functions, including making required reports through the SMS where they have the necessary authority to do so.
Monitoring Duties	Monitoring duties are the systems and processes used by a licensed sponsor to maintain appropriate oversight of sponsored workers. This includes monitoring attendance and absence, maintaining required contact information and identifying relevant changes in employment circumstances so that appropriate sponsor compliance action can be considered.
Normal Work Location	The normal work location is the location or locations associated with the sponsored worker’s employment arrangements. Changes to where a sponsored worker normally works can have sponsor reporting implications and should be identified through the employer’s monitoring processes.
Record-Keeping Duties	Record-keeping duties are the sponsor obligations relating to maintaining specified documents and information concerning sponsored workers and the sponsoring organisation. These include requirements concerning sponsored worker contact details and other documents specified in the applicable Home Office sponsor record-keeping guidance.
Reporting Duties	Reporting duties require sponsors to notify the Home Office of specified events or changes within the applicable requirements and deadlines. Reporting is distinct from monitoring. Monitoring enables the employer to identify an event, while reporting concerns determining whether the event must be notified to the Home Office and completing the required notification.
Sponsor	A sponsor is an organisation authorised by the Home Office to sponsor eligible overseas workers under applicable immigration routes.
Sponsored Worker	A sponsored worker is an individual whose employment is supported by sponsorship from a licensed sponsor under an applicable sponsored work immigration route.
Sponsor Licence	A Sponsor Licence is the authorisation granted by the Home Office that allows an eligible organisation to sponsor qualifying workers under applicable immigration routes, subject to the organisation continuing to meet its sponsor duties.
Sponsor Management System (SMS)	The Sponsor Management System is the online system used by licensed sponsors to administer their Sponsor Licence, manage Certificates of Sponsorship and make relevant notifications to the Home Office.
UK Visas and Immigration (UKVI)	UK Visas and Immigration is part of the Home Office and administers the UK’s visa and immigration system.
Unauthorised Absence	Unauthorised absence generally refers to absence from work that has not been authorised or adequately explained in accordance with the employer’s procedures. For sponsor reporting purposes, employers should pay particular attention to the Home Office requirement concerning a sponsored worker who is absent from work without permission for more than 10 consecutive working days.
Absence Without Permission	Absence without permission is the terminology relevant to the specific Home Office reporting requirement applying where a sponsored worker has been absent from work without permission for more than 10 consecutive working days. Where that threshold is reached, the sponsor must make the required report through the Sponsor Management System no later than 10 working days after the tenth day of absence, even where the employer intends to continue sponsoring the worker.
Sponsor Compliance	Sponsor compliance refers to the systems, processes and actions through which a licensed sponsor meets its ongoing Home Office duties. Monitoring is one component of the wider sponsor compliance framework alongside record keeping, reporting, right to work compliance and appropriate management of sponsored workers.

 

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Section T: Useful Links and Related Guidance

 

Employers managing sponsored workers should use the current Home Office sponsor guidance alongside their internal HR, attendance and compliance procedures. The following official and DavidsonMorris resources provide further guidance on sponsor monitoring, record keeping, reporting and wider Sponsor Licence compliance.

 

Description	URL
Home Office Sponsor Duties and Compliance Guidance This Home Office guidance sets out the principal duties applying to licensed sponsors, including requirements relating to monitoring sponsored workers, reporting relevant events and maintaining sponsor compliance.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
Home Office Sponsor Record-Keeping Guidance Appendix D sets out the documents and information sponsors are required to retain. This includes the requirement to maintain a history of specified sponsored worker contact details, including UK residential address, personal email address and telephone number.	https://www.gov.uk/government/publications/keep-records-for-sponsorship-appendix-d
Sponsor Management System Guidance The Home Office publishes guidance on use of the Sponsor Management System, including sponsor administration and the processes used to notify the Home Office of relevant changes.	https://www.gov.uk/government/publications/sponsor-management-system-sms-user-manual
Immigration Rules The Immigration Rules provide the legal framework for the UK’s immigration routes. Employers should consider the Rules together with the applicable sponsor guidance when assessing the immigration implications of changes affecting sponsored workers.	https://www.gov.uk/guidance/immigration-rules
Skilled Worker Sponsor Guidance Employers sponsoring workers under the Skilled Worker route should also refer to the current route-specific Home Office guidance when considering matters such as sponsored employment, salary, role changes and other circumstances affecting sponsorship.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-sponsor-a-skilled-worker
Sponsor Licence Compliance DavidsonMorris guidance on the wider compliance framework applying to licensed sponsors, including the systems, processes and governance employers need to maintain throughout the life of the Sponsor Licence.	https://www.davidsonmorris.com/sponsor-licence-compliance/
Sponsor Licence Duties Guidance on the principal ongoing obligations imposed on licensed sponsors and the practical measures employers should take to manage those duties.	https://www.davidsonmorris.com/sponsor-licence-duties/
Sponsor Licence Record-Keeping Duties Detailed guidance on the records and documents sponsors are required to maintain, including the distinction between monitoring information and the formal record-keeping requirements applying under the Home Office sponsor guidance.	https://www.davidsonmorris.com/sponsor-licence-record-keeping/
Sponsor Licence Reporting Duties Detailed guidance on events and changes that may need to be notified to the Home Office, applicable reporting deadlines and the practical processes employers should use to ensure relevant information reaches the people responsible for SMS reporting.	https://www.davidsonmorris.com/sponsor-licence-reporting-duties/
Reporting Changes in Sponsored Workers’ Circumstances Guidance on assessing and reporting changes affecting sponsored workers, including relevant changes to employment, salary, duties, work location and other circumstances that may affect sponsorship.	https://www.davidsonmorris.com/report-sponsored-worker-changes/
Sponsor Licence Compliance Audits Guidance on reviewing an organisation’s sponsor systems, sponsored worker records and internal compliance processes to identify and remediate weaknesses before they result in wider Sponsor Licence risk.	https://www.davidsonmorris.com/sponsor-licence-compliance-audit/
Sponsor Licence Compliance Visits Guidance on Home Office compliance activity, the areas that may be examined and how employers can prepare their sponsor systems, records and personnel for scrutiny.	https://www.davidsonmorris.com/sponsor-licence-compliance-visit/
Right to Work Compliance Guidance on employers’ separate duties to prevent illegal working, conduct compliant right to work checks and maintain appropriate evidence.	https://www.davidsonmorris.com/sponsor-licence-right-to-work/
Sponsor Licence Suspension Guidance for employers facing Home Office concerns that have resulted in suspension of the Sponsor Licence, including the implications of suspension and the importance of responding effectively to identified compliance issues.	https://www.davidsonmorris.com/sponsor-licence-suspension/
Sponsor Licence Revocation Guidance on Sponsor Licence revocation, the circumstances in which revocation issues can arise and the consequences for the organisation and its sponsored workforce.	https://www.davidsonmorris.com/sponsor-licence-revocation/

 

DavidsonMorris can advise employers on Sponsor Licence monitoring systems, sponsored worker compliance, internal audits and responding to Home Office compliance concerns. Taking advice before a monitoring weakness develops into a wider compliance issue can help employers identify the appropriate remedial action and protect their ability to sponsor workers.

 

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