Sponsor Licence Personnel Records: What Employers Have to Keep

Sponsor Licence Personnel Records: At a Glance

Sponsor licence personnel records help employers evidence who is responsible for sponsorship, who has authority to carry out sponsor functions and who can access the Sponsor Management System (SMS).

Strong personnel governance also creates continuity when key personnel leave, change role or transfer responsibility. Employers should be able to show how sponsor duties are allocated, how SMS access is controlled and how sponsorship knowledge is maintained within the organisation.

These governance records sit alongside the wider sponsor licence record-keeping requirements covering sponsored workers, recruitment, right to work and employment records.

This guide explains which sponsor licence personnel records employers should maintain, why they matter and how they support effective sponsor governance and Home Office compliance.

 

Section A: Sponsor Licence Personnel Records: What Employers Should Keep

 

Sponsor licence personnel records are the internal records used to show how responsibility for sponsorship compliance is allocated, controlled and maintained within the organisation.

They should enable the employer to identify:

 

• who is responsible for managing sponsorship activities;
• who has authority to perform sponsorship-related tasks;
• who has access to the Sponsor Management System (SMS);
• how sponsorship responsibilities are transferred when personnel change; and
• how relevant individuals are supported in meeting their sponsor duties.

 

The records should provide a clear governance trail showing who controls sponsorship functions and how those arrangements operate in practice. Their value lies in demonstrating active management of the licence through defined responsibility, appropriate authority, controlled system access and continuity of knowledge.

 

1. Why are sponsor licence personnel records important?

 

A sponsor licence application establishes the organisation’s initial suitability to sponsor workers, but sponsor duties continue throughout the life of the licence. Personnel records provide evidence of the governance structure supporting those ongoing obligations.

 

Area	Evidence of good practice
Responsibility	Clear identification of who manages sponsorship compliance.
Authority	Evidence that responsible individuals have appropriate organisational authority.
SMS access	Records showing who can access and manage the Sponsor Management System.
Knowledge	Evidence that relevant individuals understand sponsor duties and internal processes.
Continuity	Records showing how responsibilities are managed when personnel change.

 

Personnel governance can weaken where former employees retain unnecessary system access, key personnel information is outdated, responsibility becomes unclear or individuals managing sponsorship do not understand the functions they perform.

Employers should therefore keep personnel governance records current and reconcile them periodically against SMS access, organisational responsibilities and actual working arrangements.

 

 

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Section B: What Personnel Records Should Sponsor Licence Holders Keep?

 

Sponsor licence holders should maintain clear and current personnel records showing who is responsible for managing sponsorship, who has access to sponsorship systems and how compliance responsibilities are controlled within the organisation.

Some records are required as part of the sponsor’s formal Home Office obligations, while others represent good governance practice that can help the organisation demonstrate effective management of its sponsor licence. Employers should therefore distinguish between specific Home Office record-keeping requirements and the wider personnel evidence they retain to support their compliance arrangements.

The records maintained should enable the employer to demonstrate:

 

• who has overall responsibility for sponsor licence compliance;
• who performs specific sponsorship-related functions;
• who is authorised to use the Sponsor Management System;
• how access to sponsorship systems is controlled;
• how responsibilities are allocated between relevant personnel;
• how changes in personnel or responsibilities are managed;
• how the organisation maintains continuity when key individuals are absent or leave; and
• how relevant personnel are supported in understanding their sponsor duties.

 

The appropriate level of documentation will depend on the size and structure of the organisation and the complexity of its sponsorship activities. A business sponsoring a small number of workers may operate a relatively straightforward system, while a larger organisation with multiple sites, departments and SMS users may require considerably more detailed governance arrangements.

 

1. Records Relating to Sponsor Licence Key Personnel

 

Sponsor licence holders are required to nominate individuals to perform specified key personnel roles in connection with the management of their licence. These include the Authorising Officer, Key Contact and Level 1 User. Existing Level 2 Users may remain temporarily during the transitional period, but no new Level 2 Users can be appointed from 9 September 2026. Remaining Level 2 Users must be converted to Level 1, where eligible, or deactivated by 8 March 2027.

Employers should maintain accurate internal information about the individuals performing these roles and ensure that the information held by the organisation remains consistent with its current sponsorship arrangements.

Relevant personnel records may include:

 

Record	Purpose
Name and contact details	Identifies the individuals currently responsible for sponsorship functions.
Job title and organisational position	Shows where the individual sits within the organisation and the authority associated with their role.
Sponsor licence role	Identifies whether the individual acts as Authorising Officer, Key Contact, Level 1 User or Level 2 User.
Appointment date	Provides an internal record of when sponsorship responsibility began.
Allocated responsibilities	Documents the sponsorship functions the individual is expected to perform.
Changes in responsibility	Provides an audit trail where duties or organisational roles change.
Removal or replacement	Records when an individual ceases to perform a sponsorship role and, where relevant, who assumes responsibility.

 

These internal governance records should complement, rather than replace, any information or changes that the sponsor is required to record or report through the Sponsor Management System. Sponsors must also ensure that the formal contact details provided to the Home Office for Key Personnel remain accurate and comply with the applicable sponsor guidance, including the requirement for secure individual email addresses and the appropriate business or permitted representative address.

 

2. Records Relating to Sponsor Management System Access

 

The Sponsor Management System is central to the administration of a sponsor licence. Employers should therefore maintain appropriate internal records showing who has access to the SMS and ensure that access remains controlled and appropriate.

An internal SMS access record can help the organisation identify:

 

• which individuals currently have SMS access;
• whether they are Level 1 or Level 2 Users;
• the reason they require access;
• the sponsorship functions they perform;
• when access was granted;
• whether their access remains necessary; and
• when access was removed or changed.

 

Maintaining a separate internal SMS access register is not, in itself, a substitute for complying with the Home Office rules governing SMS users. It is, however, a useful governance control that can help employers demonstrate that system access is actively managed.

The Home Office is also rolling out mandatory multi-factor authentication across SMS accounts. Rollout began on 3 September 2026 and is being introduced to existing sponsors on a phased basis, with completion expected by November 2026. MFA applies immediately to organisations granted a sponsor licence on or after 9 September 2026. Level 1 Users should have accurate date of birth, mobile telephone number and email details recorded for authentication purposes, while any remaining Level 2 Users should have an accurate email address. Key Personnel email addresses should be secure, personal to and accessible only by the named individual. Passwords, user IDs and one-time passcodes must not be shared.

 

3. When Should SMS Access Be Reviewed?

 

SMS access should not be treated as permanent simply because an individual was previously authorised to use the system. Employers should review access whenever circumstances change and as part of periodic sponsor compliance reviews.

A review may be appropriate where:

 

• an employee leaves the organisation;
• an employee moves to a different role or department;
• sponsorship responsibilities are transferred to another member of staff;
• the organisation restructures its HR, compliance or global mobility functions;
• an external representative no longer requires access; or
• the organisation identifies that an existing user no longer has a business need to access the SMS.

 

The organisation should be able to establish who currently has access to the SMS and why that access remains appropriate.

Sponsors should also review inactive SMS User accounts. Current Home Office guidance treats an SMS User account as inactive where it has not been accessed for 12 months. Where the Home Office identifies inactive accounts, affected Level 1 Users may be required to log in and check or update their details within 3 months. Inactive accounts can then be deactivated. If this leaves the sponsor with no active Level 1 User, the licence can be suspended and the sponsor given 28 days to nominate at least one eligible Level 1 User, with revocation normally following if the position is not corrected. The Home Office recommends that a Level 1 User accesses the SMS at least once a month.

This is particularly important where personnel changes occur frequently or sponsorship responsibilities are distributed across different teams or locations.

 

4. Personnel Records Should Reflect the Current Position

 

Personnel governance records have limited compliance value if they do not reflect how sponsorship is actually managed.

Employers should therefore avoid retaining records that show an historic organisational structure while responsibility has moved elsewhere in practice.

For example, an internal compliance document may identify one employee as responsible for sponsorship while another employee now performs the role. Similarly, an organisational chart may identify a former Authorising Officer or SMS user whose responsibilities have since changed.

Periodic reconciliation of personnel records, SMS access and actual working practices can help identify these discrepancies before they become a compliance issue.

 

 

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Section C: Records Relating to Sponsor Licence Key Personnel

 

Sponsor licence holders should be able to identify clearly who performs each key personnel role and how responsibility for sponsorship is allocated within the organisation. The Authorising Officer and Key Contact do not receive SMS access automatically by virtue of holding those roles; they require a separate Level 1 User appointment if they need to access the system.

The principal key personnel roles are the Authorising Officer, Key Contact and Level 1 User. Existing Level 2 Users may remain temporarily during the transitional period, but no new Level 2 Users can be appointed from 9 September 2026. Remaining Level 2 Users must be converted to Level 1, where eligible, or deactivated by 8 March 2027. The detailed eligibility requirements and functions of these roles are considered separately in the Sponsor Licence Key Personnel guide.

For personnel record purposes, the employer should focus on maintaining an accurate governance trail showing who holds each role, when responsibility began, what responsibilities have been allocated and how changes are managed.

 

1. Authorising Officer Records

 

The Authorising Officer has overall responsibility for the organisation’s sponsorship compliance arrangements, although day-to-day sponsorship tasks may be delegated to other appropriately authorised personnel. Under current sponsor guidance, the Authorising Officer should be the most senior person responsible for the recruitment of sponsored workers and ensuring sponsor duties are met, or, where the sponsor does not recruit those it sponsors, the most senior person responsible for the organisation’s activity as a licensed sponsor.

The role should therefore be reflected clearly within the organisation’s internal sponsor governance records.

Employers should maintain appropriate information showing:

 

• who currently holds the Authorising Officer role;
• when the individual was appointed;
• their job title and position within the organisation;
• their authority within the organisation;
• their responsibilities for overseeing sponsor licence compliance, deciding how many staff require SMS access and at what level, and overseeing the activities of SMS users;
• any material changes to their organisational role or sponsorship responsibilities;
• periods where responsibility has had to be reassigned or managed differently; and
• the appointment of a replacement where the Authorising Officer changes.

 

The records should support the position that the Authorising Officer is genuinely capable of exercising appropriate oversight of sponsorship activities rather than simply being a name associated with the licence.

Where operational sponsorship work is carried out by HR, global mobility, recruitment, legal or other personnel, the organisation should still be able to explain how the Authorising Officer maintains appropriate oversight of those activities. The Home Office recommends that the Authorising Officer checks the Certificates of Sponsorship assigned to workers at least once a month.

Employers should also ensure that any changes affecting the Authorising Officer are dealt with in accordance with the applicable Home Office requirements and are not merely updated within the organisation’s internal records.

 

2. Key Contact Records

 

The Key Contact acts as the main point of contact between the sponsor and the Home Office in relation to the sponsor licence.

Internal personnel records should make clear who performs this function and provide accurate information about the individual and their role.

Relevant records may include:

 

• the identity of the current Key Contact;
• their job title or relationship with the sponsor;
• current contact information;
• the date they assumed the role;
• internal responsibilities associated with the role; and
• details of any replacement or transfer of responsibility.

 

Accurate information is particularly important because communications relating to sponsorship may require action by the organisation. Internal uncertainty over who is responsible for receiving, reviewing or escalating Home Office communications can increase compliance risk.

Where the Key Contact changes, the sponsor should consider both the internal governance implications and any action required through the Sponsor Management System or under the applicable sponsor guidance.

 

3. Level 1 User Records

 

Level 1 Users perform important sponsor licence management functions through the Sponsor Management System. Employers should therefore maintain appropriate internal records of the individuals who have Level 1 access.

These records may show:

 

• the identity of each Level 1 User;
• their role within or relationship with the organisation;
• when access was granted;
• why SMS access is required;
• the sponsorship functions they are expected to perform;
• any internal limits or approval procedures governing their activities;
• changes to their responsibilities; and
• when access is removed.

 

The detailed permissions and eligibility requirements applying to Level 1 Users should be considered separately. From a personnel governance perspective, the employer should be able to demonstrate that it knows who has Level 1 access, that such access is actively controlled and that at least one eligible Level 1 User is maintained throughout the life of the licence. The sponsor should also be able to establish that the applicable internal-status and immigration-status eligibility requirements for its primary Level 1 User arrangements continue to be met.

 

4. Level 2 User Records

 

Where existing Level 2 Users remain during the transitional period, employers should maintain an accurate internal record of those users and the reason access continues to be provided. No new Level 2 Users can be appointed from 9 September 2026, and remaining Level 2 Users must be converted to Level 1, where eligible, or deactivated by 8 March 2027.

Level 2 access is more limited than Level 1 access. Employers should nevertheless apply appropriate governance controls and should not assume that more limited access removes the need for oversight.

Relevant records may include:

 

• the identity of each Level 2 User;
• their organisational role;
• the reason SMS access is required;
• when access was granted;
• the functions they are expected to perform; and
• when access is changed or removed.

 

5. Recording Changes to Key Personnel

 

Personnel records should provide a clear audit trail when key personnel change.

This may involve:

 

• appointing a new Authorising Officer;
• changing the Key Contact;
• adding a new Level 1 User;
• converting an eligible existing Level 2 User to Level 1 or deactivating a remaining Level 2 User;
• changing an existing user’s responsibilities;
• removing access when an employee leaves; or
• reallocating responsibilities following an internal restructure.

 

Internal records should show when the change occurred, who assumed responsibility and what consequential actions were taken.

An internal record of the change is not necessarily sufficient on its own. Where the change is one that has to be notified to the Home Office or implemented through the SMS, the sponsor should ensure that the relevant reporting or system action is also completed within the applicable requirements.

 

6. Avoiding Dependency on One Individual

 

An organisation can create unnecessary compliance risk if knowledge of its sponsor licence is concentrated in one individual.

For example, problems may arise where:

 

• only one employee understands how the SMS is operated;
• important sponsorship information is held in an individual employee’s files or email account;
• there is no documented procedure for routine sponsor tasks;
• nobody has been identified to deal with sponsorship matters during absence;
• there is no handover process when responsible personnel leave.

 

Employers should therefore consider business continuity as part of sponsor personnel governance. This can include documenting procedures, allocating appropriate backup responsibilities and ensuring that sponsorship information is retained within organisational systems rather than depending on the personal knowledge of one employee.

The objective is to ensure that the organisation, rather than a particular individual, retains effective control of its sponsor licence obligations.

 

 

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Section D: Training and Evidence of Sponsor Compliance Knowledge

 

Sponsor licence holders should ensure that the individuals responsible for sponsorship understand the duties relevant to their roles and the organisation’s internal procedures for meeting those duties.

Home Office sponsor guidance does not create a general requirement for every sponsor to maintain a standalone training record for every individual involved in sponsorship. Employers should therefore distinguish between documents that are expressly required under the sponsor record-keeping rules and additional governance evidence retained to demonstrate effective compliance management.

As a matter of good sponsor governance, employers should consider retaining evidence of relevant training, guidance and compliance processes. This can help demonstrate that the individuals responsible for sponsorship have been given the information and support necessary to perform their functions effectively.

 

1. What Sponsor Compliance Training Should Cover

 

The appropriate training will depend on the individual’s responsibilities. Not every member of staff involved in sponsorship needs the same level of knowledge.

Relevant topics may include:

 

• the organisation’s sponsor duties;
• the responsibilities associated with the sponsor licence;
• the role of the Authorising Officer and other key personnel;
• use and control of the Sponsor Management System;
• sponsor licence record-keeping requirements;
• sponsor reporting duties and applicable reporting deadlines;
• monitoring sponsored workers;
• right to work procedures;
• internal escalation procedures where a potential compliance issue is identified;
• procedures for dealing with changes affecting sponsored workers;
• procedures for dealing with organisational and personnel changes; and
• the potential consequences of sponsor non-compliance.

 

Training should be relevant to the functions actually performed by the individual. For example, an employee responsible for maintaining sponsored worker records may require different operational knowledge from an Authorising Officer responsible for overall oversight of the sponsor licence.

 

2. What Evidence of Training Should Employers Retain?

 

Where sponsor compliance training or guidance is provided, maintaining appropriate evidence can help the organisation demonstrate that compliance responsibilities are actively managed.

Depending on the organisation’s arrangements, this evidence may include:

 

Evidence	What It Can Demonstrate
Training dates	When relevant sponsor compliance training or briefings were provided.
Attendance records	Which employees or key personnel received the training.
Training materials	The subjects and compliance requirements covered.
Internal guidance	The procedures staff are expected to follow when carrying out sponsorship activities.
Role-specific instructions	The responsibilities allocated to particular individuals or teams.
Refresher training records	Evidence that knowledge is reviewed rather than relying solely on initial training.
Compliance update records	Evidence that relevant personnel have been informed of material changes to sponsor requirements or internal procedures.

 

The objective is not to generate unnecessary paperwork. The evidence retained should be proportionate to the organisation’s sponsorship activities and should support the employer’s ability to demonstrate that relevant personnel understand how sponsor compliance is managed.

 

3. Training New Sponsor Licence Personnel

 

Where an employee assumes responsibility for sponsorship, the organisation should consider what information and support they require before performing the role independently.

For example, a newly appointed Authorising Officer or Level 1 User may need to understand:

 

• the organisation’s current sponsor licence arrangements;
• their individual responsibilities;
• the organisation’s sponsored worker population;
• how the SMS is managed;
• where sponsor records are stored;
• who is responsible for reporting relevant changes;
• how sponsored worker compliance is monitored;
• how right to work processes interact with sponsorship;
• how potential breaches are escalated; and
• which internal or external advisers are involved in sponsor management.

 

Where responsibility is transferred from an existing member of staff, the handover should cover outstanding compliance actions as well as routine procedures.

 

4. Refresher Training and Changes to Sponsor Requirements

 

Sponsor compliance knowledge can become outdated. Home Office guidance, immigration requirements and internal organisational processes can change over time.

Employers should therefore consider whether refresher training or compliance updates are required when:

 

• relevant Home Office sponsor guidance changes;
• internal sponsor procedures are revised;
• new immigration routes or sponsorship activities are introduced;
• the organisation substantially increases the number of sponsored workers;
• responsibility moves between departments or individuals;
• an internal audit identifies a knowledge gap;
• a compliance issue or reporting failure occurs; or
• the Home Office identifies concerns during a compliance visit or other engagement.

 

The organisation should be able to show that its sponsor compliance arrangements evolve when its obligations or operational circumstances change.

 

5. Creating a Sponsor Governance File

 

Employers may find it useful to maintain a central sponsor governance file containing the principal records relating to the management and oversight of the sponsor licence.

A sponsor governance file could include:

 

• current key personnel details;
• records of Authorising Officer responsibility and oversight;
• current SMS users and their access levels;
• internal sponsor compliance responsibilities;
• relevant training and briefing records;
• current sponsor compliance procedures;
• records of changes to personnel and responsibilities;
• handover records;
• periodic access reviews;
• internal compliance review or audit records; and
• records of remedial action taken following identified compliance issues.

 

A sponsor governance file is an internal compliance tool rather than a substitute for the specific documents that sponsors are required to retain under the Home Office sponsor record-keeping requirements.

Used effectively, however, it can provide a central record of how the organisation manages sponsorship and help demonstrate that compliance responsibilities are allocated, understood and periodically reviewed.

 

 

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Section E: Managing Personnel Changes, Departures and Changes in Responsibility

 

Sponsor licence personnel records should be maintained throughout the life of the licence. They should not simply record who was responsible for sponsorship when the licence was first granted.

Personnel responsible for sponsorship may leave the organisation, change roles, move between departments or acquire different responsibilities. The organisation itself may also restructure, merge functions, outsource activities or change the way immigration compliance is managed.

Employers should have processes for identifying these changes and considering their implications for sponsor licence governance, Sponsor Management System access and any reporting or updating requirements that may apply.

 

1. Recording Changes in Sponsor Responsibilities

 

Where responsibility for sponsorship changes, the employer should maintain a clear internal record of the transition.

Depending on the circumstances, the record may identify:

 

• the individual who previously held the responsibility;
• the individual assuming the responsibility;
• the effective date of the change;
• the sponsorship functions being transferred;
• any outstanding compliance actions at the date of transfer;
• any changes required to SMS access;
• any internal systems or permissions that need to be updated;
• the handover arrangements;
• any training or guidance provided to the incoming individual; and
• any Home Office notification or SMS action considered or completed.

 

The objective is to avoid a gap between the formal allocation of responsibility and what is happening operationally within the organisation.

 

2. Employees Leaving the Organisation

 

The departure of an employee involved in sponsor licence management should trigger a review of their sponsorship responsibilities and system access.

This is particularly important where the departing employee is:

 

• the Authorising Officer;
• the Key Contact;
• a Level 1 User;
• a remaining Level 2 User during the applicable transitional period;
• responsible for maintaining sponsored worker records;
• responsible for monitoring sponsored workers;
• responsible for right to work procedures; or
• responsible for identifying or reporting changes affecting sponsored workers.

 

The organisation should determine whether the individual needs to be replaced, whether responsibilities need to be reassigned and whether any changes need to be made or reported through the Sponsor Management System.

 

3. Removing Access When Personnel Leave

 

Removing unnecessary system access should form part of the organisation’s leaver process where the departing individual has been involved in sponsorship.

The review should not necessarily be limited to the Sponsor Management System. Depending on the individual’s responsibilities, the employer may also need to consider access to:

 

• internal immigration compliance systems;
• sponsored worker personnel files;
• right to work records;
• shared compliance folders;
• HR databases;
• recruitment systems;
• global mobility systems;
• compliance calendars and monitoring tools; and
• shared email accounts used for immigration or sponsorship matters.

 

Where appropriate, responsibility for outstanding sponsorship actions should also be transferred before or immediately following the employee’s departure.

A leaver process that disables ordinary IT access but does not consider sponsorship responsibilities can leave gaps in compliance management.

 

4. Documenting Sponsor Licence Handovers

 

A documented handover can be particularly valuable where an employee with substantial sponsorship responsibilities leaves or changes role.

The handover may cover:

 

• current sponsored workers;
• outstanding SMS actions;
• pending Certificates of Sponsorship;
• upcoming reporting deadlines;
• outstanding right to work follow-up checks;
• worker absences or changes requiring review;
• pending changes to employment;
• Home Office correspondence;
• ongoing sponsor licence applications or requests;
• scheduled internal compliance reviews;
• known compliance issues; and
• the location of relevant sponsor records.

 

The level of detail required will depend on the departing individual’s responsibilities. Where the employee has played a central role in sponsor management, a more formal handover may be appropriate.

 

5. Maintaining Continuity of Sponsor Licence Management

 

Employers should consider whether their sponsorship arrangements would continue to operate effectively if a key individual became unavailable unexpectedly.

Potential weaknesses include:

 

• only one individual understanding the organisation’s sponsor procedures;
• only one appropriate person having operational knowledge of the SMS;
• compliance deadlines being stored in a personal diary;
• important Home Office correspondence being directed to an account that is not monitored by others;
• sponsorship records being stored locally rather than within organisational systems; and
• no documented process for reallocating responsibilities during absence or departure.

 

Effective continuity arrangements can reduce dependency on individual members of staff and help ensure that sponsor duties continue to be managed during periods of absence, staff turnover or organisational change. The sponsor should ensure that it continues to have at least one eligible active Level 1 User throughout the life of the licence.

 

6. Promotions and Internal Transfers

 

A personnel change does not have to involve an employee leaving the organisation.

An individual may remain employed but move into a different role, department, office or group company. The employer should consider whether the change affects their continuing involvement in sponsorship.

Questions to consider include:

 

• Does the individual still perform the same sponsorship function?
• Do they still require SMS access?
• Has their authority within the organisation changed?
• Should responsibility transfer to another employee?
• Do internal sponsor governance records need updating?
• Does the change affect any information held on the SMS?
• Does the change trigger any action under the applicable sponsor guidance?

 

The fact that an employee remains within the organisation should not result in unnecessary sponsorship permissions continuing indefinitely.

 

7. Organisational Restructuring

 

Personnel governance should also be reviewed where the organisation changes the structure through which sponsorship is managed.

This may arise following:

 

• a merger or acquisition;
• an internal corporate restructuring;
• a change in ownership or control;
• the creation of a centralised HR or global mobility function;
• the transfer of responsibilities between group companies;
• the outsourcing or insourcing of immigration support;
• the closure or opening of business locations; or
• a significant reorganisation of HR, recruitment or compliance teams.

 

Some corporate changes can have wider implications for the sponsor licence itself and may involve specific Home Office reporting requirements or, depending on the circumstances, consideration of whether a new sponsor licence is required.

Those wider requirements fall outside the personnel-record focus of this guide and should be considered as part of the organisation’s broader sponsor licence business change procedures.

 

8. Personnel Records Should Provide a Continuous Governance Trail

 

The practical question for an employer is whether it can demonstrate continuous control of sponsorship as personnel and circumstances change.

A well-maintained record should make it possible to understand:

 

• who was responsible for sponsorship at a particular time;
• when responsibility changed;
• who assumed the relevant responsibilities;
• how access and authority were transferred;
• whether outstanding compliance matters were handed over; and
• whether any necessary Home Office or SMS action was taken.

 

This creates a more defensible compliance position than relying on current personnel information alone, particularly where the organisation has experienced significant staff turnover or structural change.

 

 

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Section F: Sponsor Licence Personnel Records During Home Office Compliance Visits

 

A Home Office compliance visit may examine not only whether required documents are available, but also whether the organisation has effective systems for managing its sponsor duties in practice.

Personnel and governance records can therefore be important evidence during a compliance assessment. They can help an employer explain who is responsible for sponsorship, how authority is allocated, who has access to the Sponsor Management System and how the organisation maintains continuity when personnel change.

The existence of an internal personnel record does not, by itself, establish compliance. Home Office officers may consider whether the organisation’s documented procedures reflect what actually happens in practice and whether relevant personnel understand the responsibilities they perform.

 

1. What May the Home Office Examine?

 

The scope of a compliance visit will depend on the circumstances, but an assessment of sponsor governance may involve consideration of:

 

Area	What the Sponsor May Need to Demonstrate
Responsibility	The organisation can identify who has responsibility for managing sponsorship and specific sponsor duties.
Authority	Relevant individuals have appropriate authority to perform or oversee their allocated functions.
SMS control	The organisation knows who has SMS access and access is appropriately controlled.
Knowledge	Relevant personnel understand the sponsor duties and procedures connected with their roles.
Governance	The organisation has processes for managing sponsorship rather than relying on informal or undocumented arrangements.
Continuity	Responsibility can continue to be managed when employees leave, change roles or are unavailable.

 

The Home Office may also examine wider sponsor records and systems, including sponsored worker records, right to work evidence, recruitment information, salary and employment records, reporting processes and worker monitoring arrangements. These wider requirements are considered separately in our Sponsor Licence Record Keeping guide.

 

2. Personnel Records to Have Available

 

As part of compliance visit preparation, employers should consider whether they can readily produce appropriate information about the personnel responsible for sponsorship.

Depending on the organisation’s structure, relevant governance evidence may include:

 

• details of the current Authorising Officer;
• details of the current Key Contact;
• details of current Level 1 Users and any remaining Level 2 Users during the transitional period;
• records showing how sponsorship responsibilities are allocated;
• current organisational or responsibility charts where used;
• internal sponsor compliance procedures;
• appropriate records relating to SMS access;
• evidence of relevant sponsor compliance training or briefings;
• records of changes to key personnel or responsibilities;
• handover records where significant sponsorship responsibilities have transferred;
• periodic compliance or access reviews; and
• records of remedial action following identified compliance weaknesses.

 

Not every item in this list represents a standalone document expressly required by the Home Office sponsor record-keeping rules. Some are internal governance evidence that can assist the employer in demonstrating how its sponsor duties are managed.

 

3. Home Office Interviews With Sponsor Personnel

 

During a compliance visit, relevant members of staff may be asked about the organisation’s sponsorship arrangements and the procedures they follow.

Employers should therefore avoid treating compliance preparation as a document-only exercise.

Personnel involved in sponsorship should understand the aspects of the compliance framework relevant to their responsibilities. Depending on their role, they may need to explain matters such as:

 

• who has overall responsibility for the sponsor licence;
• who operates the Sponsor Management System;
• how sponsored workers are monitored;
• where sponsorship records are maintained;
• how reportable events are identified and escalated;
• how right to work checks are managed;
• what happens when a sponsored worker is absent;
• how changes to employment are identified;
• how personnel changes affecting sponsor management are handled; and
• who should be contacted internally where a potential compliance problem arises.

 

The relevant employee does not necessarily need to know every aspect of sponsor compliance. Their knowledge should, however, be consistent with the responsibilities they actually perform.

 

4. Documents and Practice Should Be Consistent

 

A significant governance weakness can arise where documented procedures do not correspond with actual working practices.

For example, an organisation may have a written procedure stating that one employee monitors sponsored worker absences, while in practice another department performs the function without a clear escalation process.

Other potential inconsistencies include:

 

• an organisational chart identifying an individual who no longer manages sponsorship;
• an outdated list of SMS users;
• internal procedures referring to employees who have left the organisation;
• responsibility matrices that have not been updated following restructuring;
• staff describing a different process from the organisation’s written procedure; or
• records showing compliance checks that employees cannot explain how to perform.

 

Periodic review can help ensure that the employer’s personnel records remain consistent with operational reality.

 

5. Questions Employers Should Be Able to Answer

 

Before a Home Office compliance visit, employers should consider whether they can answer basic governance questions quickly and accurately.

These may include:

 

• Who is the current Authorising Officer?
• Who is the current Key Contact?
• Who currently has Level 1 SMS access and are any Level 2 Users still active during the transitional period?
• Why does each SMS user require access?
• Who monitors sponsored workers?
• Who is responsible for sponsor reporting?
• Who maintains sponsorship records?
• Who manages right to work compliance?
• How are potential sponsor breaches escalated?
• What happens if the principal person responsible for sponsorship is absent?
• When were sponsorship responsibilities last reviewed?
• How are leavers and changes to key personnel managed?

 

Difficulty answering these questions may indicate that sponsor governance has become overly informal or dependent on individual employees.

 

6. Reviewing Personnel Records Before a Compliance Visit

 

Where a compliance visit is announced, employers should review their personnel governance arrangements alongside the wider sponsor compliance audit.

The review should consider:

 

• whether key personnel information is current;
• whether SMS users remain appropriate;
• whether former users have been removed;
• whether responsibilities are clearly documented;
• whether relevant staff understand their responsibilities;
• whether internal procedures reflect current working practices;
• whether recent personnel changes have been properly managed;
• whether outstanding handover or access issues remain unresolved; and
• whether any required SMS updates or Home Office reports remain outstanding.

 

Employers should not manufacture or retrospectively alter records to create the appearance that historic processes were followed when they were not. Where a review identifies a genuine weakness, the organisation should establish the facts, assess the compliance implications and take appropriate corrective action.

 

7. Personnel Governance as Part of Compliance Readiness

 

Strong compliance readiness requires more than assembling documents shortly before a Home Office visit.

Employers should be able to demonstrate an established system in which sponsorship responsibilities are allocated, SMS access is controlled, personnel changes are managed and relevant employees understand the procedures they are expected to follow.

Periodic internal review of personnel governance can therefore form an important part of a wider sponsor licence compliance audit.

Where the Home Office has announced a visit, employers should also consider the broader issues covered in our Sponsor Licence Compliance Visit guide.

 

 

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Section G: Common Sponsor Licence Personnel Record Mistakes

 

Personnel record weaknesses often arise not because an employer has deliberately ignored its sponsor duties, but because sponsorship arrangements have evolved without the underlying governance records, access controls and responsibilities being updated.

Staff turnover, promotions, restructuring and changes in the number of sponsored workers can all result in a compliance framework that no longer reflects how sponsorship is actually managed.

Employers should therefore look for practical weaknesses as part of their periodic sponsor compliance reviews.

 

1. Outdated Key Personnel Information

 

One of the most obvious risks is allowing key personnel information to become outdated.

This may occur where:

 

• the Authorising Officer leaves or changes role;
• the Key Contact changes;
• a Level 1 User leaves the organisation;
• a remaining Level 2 User no longer requires access;
• responsibilities transfer between departments; or
• the organisation restructures without reviewing its sponsorship arrangements.

 

An employer should not assume that updating its internal organisation chart or HR records is sufficient. It should also consider whether the change requires action through the Sponsor Management System or under the applicable Home Office sponsor guidance.

 

2. Unclear Ownership of Sponsor Compliance

 

Sponsor compliance frequently involves several business functions. Depending on the organisation, HR, recruitment, payroll, legal, global mobility, line management and operational teams may all have responsibilities relevant to sponsored workers.

Problems can arise where everyone is involved but nobody has clearly defined responsibility for ensuring that required actions are completed.

For example:

 

• HR may maintain personnel records;
• recruitment may manage Certificates of Sponsorship;
• payroll may identify salary changes;
• line managers may monitor attendance;
• global mobility may manage immigration applications; and
• an external adviser may provide immigration advice.

 

The employer should understand how information moves between these functions and who is ultimately responsible for deciding whether an event requires sponsor compliance action.

A responsibility matrix or documented internal procedure can be useful where sponsorship activities are distributed across several teams.

 

3. Poor Control of SMS Access

 

Sponsor Management System access should be actively controlled rather than allowed to accumulate over time.

Potential weaknesses include:

 

• former employees remaining recorded as SMS users;
• employees retaining access after moving to unrelated roles;
• more individuals having access than the organisation operationally requires;
• the employer being unable to identify all current users;
• responsibilities changing without permissions being reviewed; and
• external users retaining access after their involvement with the organisation has ended;
• outdated SMS user contact information affecting MFA;
• passwords, user IDs or one-time passcodes being shared;
• SMS users becoming inactive through prolonged non-use; and
• no eligible active Level 1 User remaining.

 

Employers should periodically reconcile their internal records against current SMS access and consider whether each user continues to require the permissions they hold.

 

4. No Evidence of Sponsor Compliance Training or Guidance

 

A sponsor may have knowledgeable personnel but retain little evidence of how those individuals were instructed about their responsibilities.

While there is not a general Home Office requirement for every sponsor to maintain a standalone training record for every member of staff involved in sponsorship, retaining proportionate evidence of training, briefings and internal procedures can support the organisation’s wider governance arrangements.

A lack of documented guidance may become particularly problematic where responsibilities have transferred between employees or where several departments perform different parts of the sponsor compliance process.

Employers should consider whether relevant personnel can explain:

 

• their sponsorship responsibilities;
• the procedures they are expected to follow;
• when matters should be escalated;
• where relevant records are maintained; and
• who is responsible for taking action where a potential sponsor issue arises.

 

5. No Documented Handover

 

Personnel changes can create significant compliance gaps where responsibilities are transferred informally.

For example, an employee may leave while there are outstanding:

 

• SMS reports;
• Certificate of Sponsorship actions;
• right to work follow-up checks;
• sponsored worker changes;
• Home Office correspondence;
• compliance investigations; or
• internal audit actions.

 

Without an effective handover, these matters can be missed even where a replacement employee is appointed quickly.

The organisation should therefore consider both the transfer of the role and the transfer of outstanding compliance activity.

 

6. Treating Personnel Records as a One-Time Requirement

 

Personnel governance should not be reviewed only when the sponsor licence is first obtained or when a Home Office compliance visit is announced.

A sponsor’s organisational structure can change considerably over time.

An employer that has held a sponsor licence for several years may have experienced:

 

• multiple changes of HR personnel;
• changes to senior management;
• new business locations;
• departmental restructuring;
• increased numbers of sponsored workers;
• new SMS users;
• changes in external advisers; and
• changes to internal compliance systems.

 

Personnel records should evolve with these changes.

 

7. Relying Too Heavily on External Advisers

 

External immigration advisers can support an organisation with sponsor licence management, but the sponsor remains responsible for meeting its sponsor duties.

Employers should therefore avoid arrangements where internal personnel have little understanding of the organisation’s sponsorship activities because operational knowledge sits entirely with an external provider.

The organisation should retain appropriate internal oversight and be able to identify:

 

• who internally has responsibility for the sponsor licence;
• what functions are performed by the external adviser;
• what functions remain with the employer;
• how information is communicated between the employer and adviser;
• who approves or instructs sponsorship actions; and
• what happens if the external relationship ends.

 

External support should form part of the sponsor’s governance framework rather than replacing internal responsibility for compliance.

 

8. Allowing Written Procedures to Become Outdated

 

A written sponsor compliance procedure is only useful if it reflects current working practices.

Employers should review procedures where:

 

• responsible personnel change;
• new HR or recruitment systems are introduced;
• the organisation restructures;
• compliance responsibilities move between teams;
• Home Office sponsor requirements materially change; or
• an internal audit identifies that documented procedures are no longer being followed.

 

Outdated documentation can create confusion and may make it more difficult for the organisation to demonstrate how its sponsor duties are actually managed.

 

9. Failing to Connect Personnel Governance With Wider Sponsor Duties

 

Personnel governance should not operate separately from the organisation’s wider sponsor compliance framework.

The individuals responsible for sponsorship need effective connections with the business functions that generate information relevant to sponsor duties.

For example, the sponsor compliance team may need information from:

 

• payroll when salary changes occur;
• HR when employment terms change;
• line managers when attendance issues arise;
• recruitment when sponsored roles are being filled;
• corporate teams when organisational changes occur; and
• IT or HR when employees with sponsorship responsibilities leave.

 

The employer should therefore consider not only who formally manages the sponsor licence, but also whether the organisation has effective processes for relevant information to reach those individuals.

 

10. Personnel Governance Warning Signs

 

Employers should consider further review where any of the following applies:

 

• staff are unsure who the Authorising Officer is;
• the organisation cannot readily identify all SMS users;
• former employees remain associated with sponsorship functions;
• responsibility for reporting is unclear;
• different departments assume another team is responsible for compliance actions;
• there is no clear process for personnel handovers;
• key sponsorship knowledge is concentrated in one individual;
• internal procedures identify employees who have left;
• staff responsible for sponsorship have received no recent guidance or updates; or
• the organisation would struggle to explain its sponsor governance arrangements during a Home Office compliance visit.

 

These issues do not necessarily mean that a sponsor has breached its duties. They should, however, prompt further investigation because they may indicate weaknesses in the systems used to manage sponsorship.

 

 

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Section H: Sponsor Licence Personnel Records Checklist

 

A periodic personnel records review can help employers identify weaknesses in sponsor governance before they result in missed reporting obligations, uncontrolled SMS access or difficulties during a Home Office compliance assessment.

The following checklist can be used as part of an internal sponsor licence compliance review. It is not a substitute for the specific record-keeping requirements contained in the Home Office sponsor guidance. Instead, it provides a practical framework for reviewing the personnel and governance arrangements supporting the organisation’s sponsor licence.

 

1. Authorising Officer Checklist

 

Employers should review whether:

 

• the organisation can readily identify its current Authorising Officer;
• the Authorising Officer’s internal details are accurate and current;
• their organisational role remains appropriate;
• their sponsorship responsibilities are clearly understood;
• they have sufficient oversight of the organisation’s sponsorship activities;
• they are the appropriate senior person responsible for sponsored recruitment and sponsor duties, or for the organisation’s activity as a licensed sponsor where applicable;
• they oversee the number and level of SMS users and the activities carried out by those users;
• the Home Office recommendation to review assigned Certificates of Sponsorship at least monthly is incorporated into the organisation’s oversight arrangements;
• day-to-day responsibilities delegated to other personnel are clearly understood;
• changes affecting the Authorising Officer have been documented;
• former Authorising Officers have been appropriately replaced;
• relevant internal procedures reflect the current Authorising Officer; and
• any required Home Office or SMS action following a change has been considered and completed.

 

2. Key Contact Checklist

 

Employers should check whether:

 

• the current Key Contact is correctly identified;
• their contact details are accurate;
• their role within or relationship with the organisation remains current;
• they understand their function as the principal point of contact;
• relevant Home Office communications are received and appropriately escalated;
• changes to the Key Contact are documented internally; and
• any required SMS updates have been completed.

 

3. Level 1 and Level 2 User Checklist

 

Employers should review current SMS access and ask:

 

• Who currently has Level 1 access?
• Are any Level 2 Users still active during the transitional period?
• Does each individual still require access?
• Is the level of access appropriate to the functions they perform?
• Are internal records of SMS users current?
• Have employees who left the organisation been removed where required?
• Have employees who changed role had their continuing access reviewed?
• Has access held by external representatives been reviewed?
• Are sponsorship responsibilities clear between different SMS users?
• Is there sufficient continuity if a principal SMS user is unavailable?
• Are Level 1 User date of birth, mobile telephone number and email details accurate for MFA purposes?
• Do any remaining Level 2 Users have an accurate email address?
• Are Key Personnel email addresses secure and personal to the named individual?
• Are passwords, user IDs and one-time passcodes kept individual and not shared?
• When did each SMS user last access the system?
• Are any users inactive or approaching 12 months without access?
• Is at least one eligible active Level 1 User maintained at all times?
• Is Level 1 access being maintained in line with the Home Office recommendation to access the SMS at least once a month?
• Have all remaining Level 2 Users been identified for conversion or deactivation by 8 March 2027?

 

The purpose of this review is not to create an unnecessary standalone register. It is to ensure that the sponsor retains effective oversight and control of access to the system through which important sponsorship functions are performed.

 

4. Sponsor Compliance Responsibility Checklist

 

Employers should be able to identify who is responsible for the different operational aspects of sponsorship.

Depending on the organisation, this may include responsibility for:

 

• overall sponsor licence oversight;
• Certificate of Sponsorship administration;
• SMS reporting;
• sponsored worker record keeping;
• monitoring sponsored worker attendance and absences;
• identifying changes to sponsored employment;
• salary monitoring;
• right to work compliance;
• Home Office correspondence;
• personnel changes affecting the sponsor licence;
• corporate changes affecting sponsorship;
• internal compliance audits; and
• escalating potential breaches.

 

Where responsibilities are divided between departments, the organisation should also understand how information moves between those departments.

 

5. Training and Guidance Checklist

 

Training records are not automatically a standalone Home Office record-keeping requirement for every individual involved in sponsorship. However, employers should consider whether they have proportionate evidence that relevant personnel have been given appropriate information and guidance.

Questions may include:

 

• Have relevant personnel been given guidance on their sponsor responsibilities?
• Is training appropriate to the functions each individual performs?
• Are internal sponsor compliance procedures available to relevant staff?
• Is there evidence of relevant training or briefings where these have been provided?
• Are new personnel given an appropriate sponsorship handover or induction?
• Are material changes to sponsor requirements communicated to relevant personnel?
• Is refresher training considered where processes or responsibilities change?
• Can employees explain the procedures relevant to their own roles?

 

6. Personnel Change Checklist

 

When an employee involved in sponsorship leaves, changes role or transfers responsibilities, employers should consider:

 

• whether their sponsorship responsibilities need to be reassigned;
• whether a replacement key person needs to be appointed;
• whether SMS access needs to be changed or removed;
• whether access to internal compliance systems needs to be removed;
• whether outstanding compliance matters need to be handed over;
• whether internal procedures or organisational charts need updating;
• whether relevant colleagues need to be informed;
• whether training is required for the incoming individual; and
• whether any Home Office notification or SMS action is required.

 

7. Sponsor Licence Handover Checklist

 

Where significant sponsorship responsibilities transfer between individuals, the handover should consider any outstanding matters requiring action.

These may include:

 

• pending Certificates of Sponsorship;
• outstanding SMS reports;
• reporting deadlines;
• changes affecting sponsored workers;
• pending right to work follow-up checks;
• Home Office correspondence;
• scheduled compliance reviews;
• outstanding audit findings;
• known compliance concerns;
• pending personnel changes;
• corporate changes with potential sponsor licence implications; and
• the location of relevant records and compliance documentation.

 

8. Compliance Visit Readiness Checklist

 

Employers should consider whether they could answer the following questions if contacted by the Home Office:

 

• Who manages the sponsor licence today?
• Who has overall responsibility for sponsor compliance?
• Who currently has access to the SMS?
• Why does each SMS user require access?
• Who is responsible for maintaining sponsored worker records?
• Who monitors sponsored workers?
• Who identifies reportable events?
• Who is responsible for submitting required reports?
• Who manages right to work compliance?
• How are potential compliance problems escalated?
• How are personnel changes affecting sponsorship managed?
• What happens if the principal person responsible for sponsorship is unavailable?

 

An organisation that cannot answer these questions readily should consider whether its sponsorship governance arrangements require further review.

 

9. Recommended Sponsor Governance File

 

A central sponsor governance file can help employers maintain an accessible record of how sponsorship responsibilities are managed.

Depending on the organisation, the file may contain:

 

• current key personnel details;
• Authorising Officer governance information;
• current SMS user information;
• responsibility matrices;
• internal sponsor procedures;
• training and briefing evidence;
• personnel change records;
• handover documentation;
• SMS access reviews;
• internal compliance review records;
• remedial action records; and
• records of periodic governance reviews.

 

The sponsor governance file should be treated as an internal management tool. It does not replace the specific documents and records that sponsors are required to retain under the Home Office sponsor guidance.

Used alongside the organisation’s wider sponsor compliance records, however, it can provide a useful evidence trail showing that responsibility, access, knowledge and continuity are being actively managed.

 

 

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Section I: How Long Should Sponsor Licence Personnel Records Be Kept?

 

Employers should distinguish between the specific document retention requirements imposed by the Home Office and the wider personnel and governance records that an organisation may retain to demonstrate how its sponsor licence has been managed.

Home Office sponsor guidance specifies retention requirements for particular documents relating to sponsored workers and sponsorship activity. Those requirements should be followed for the documents to which they apply.

However, not every internal governance document discussed in this guide, such as an internal SMS access review, training record, responsibility matrix or handover note, is subject to a separate prescribed Home Office retention period.

Employers should therefore avoid applying a single retention period indiscriminately to every document connected with sponsorship.

 

1. Mandatory Sponsor Record Retention Requirements

 

Sponsors must retain the documents specified by the applicable Home Office sponsor guidance, including the documents identified in the Home Office guidance on keeping records for sponsored workers.

The applicable retention period can depend on the type of document and the circumstances in which it is held. Employers should therefore check the current Home Office requirements rather than assuming that every sponsor record is subject to the same retention rule.

These formal sponsor record-keeping requirements are considered in more detail in our Sponsor Licence Record Keeping guide.

 

2. Retaining Internal Personnel Governance Records

 

For internal sponsor governance records that are not subject to a specific Home Office retention period, employers should adopt a proportionate retention approach that reflects the purpose for which the information is being retained.

In practice, it may be useful to retain sufficient historical evidence to establish:

 

• who held key personnel roles during relevant periods;
• who had responsibility for particular sponsor compliance functions;
• who had SMS access and when;
• when responsibility transferred between individuals;
• what handover arrangements were implemented;
• what relevant training or guidance was provided;
• when governance or access reviews took place; and
• what remedial action was taken following identified compliance issues.

 

This can be particularly important where a compliance issue relates to events that occurred before the current members of the HR, immigration or compliance team assumed responsibility.

 

3. Do Not Automatically Delete Records When Personnel Change

 

Replacing an Authorising Officer, Key Contact or SMS user does not necessarily mean that every record relating to the previous individual should immediately be deleted.

Historic records may help explain how the sponsor licence was managed during an earlier period and provide evidence of:

 

• when an individual held a particular responsibility;
• when their responsibility ended;
• when access was removed;
• who replaced them;
• how outstanding matters were transferred; and
• what action the organisation took following the change.

 

The organisation should nevertheless have a legitimate reason for continuing to retain personal information and should not retain records indefinitely merely because they relate to sponsorship.

 

4. Data Protection and Sponsor Personnel Records

 

Sponsor licence personnel records may contain personal data relating to employees, former employees, external representatives and other individuals involved in sponsorship.

Employers should therefore consider their obligations under applicable data protection law when determining how personnel governance records are stored and retained.

Relevant considerations may include:

 

• the purpose for which the information is being retained;
• whether continued retention remains necessary;
• the organisation’s lawful basis for processing the information;
• data minimisation;
• accuracy of the information;
• appropriate security and access controls;
• the organisation’s wider document retention policy; and
• secure deletion when the information is no longer required.

 

Sponsor compliance requirements and data protection obligations should therefore be considered together. Employers need to retain sufficient information to meet applicable sponsorship obligations and support legitimate compliance requirements without retaining unnecessary personal data indefinitely.

 

5. Establishing a Sponsor Records Retention Policy

 

Larger sponsors in particular may benefit from incorporating sponsorship records into their wider document retention framework.

A retention schedule can identify different categories of sponsorship information and distinguish between:

 

Record Category	Retention Approach
Documents specifically required by Home Office sponsor guidance	Retain for the period required by the applicable sponsor guidance.
Sponsored worker employment and immigration records	Apply the relevant Home Office requirements together with applicable employment, immigration and data protection considerations.
Key personnel governance records	Retain proportionately where required to evidence the management and history of sponsor responsibilities.
SMS access governance records	Retain sufficient information to demonstrate appropriate control and relevant changes in access.
Training and briefing records	Retain where they support evidence of compliance knowledge and governance, subject to the organisation’s retention policy.
Handover and personnel change records	Retain where relevant to demonstrating continuity and the management of sponsorship responsibilities.
Internal audit and remedial action records	Retain proportionately where they evidence compliance reviews, identified issues and corrective action.

 

The policy should be reviewed when Home Office requirements change or where the organisation materially changes the way it manages sponsorship.

 

6. The Practical Retention Question

 

When deciding whether an internal sponsor personnel record should continue to be retained, employers should consider both compliance value and data protection requirements.

A practical question is:

If the Home Office later asked the organisation to explain who was responsible for sponsorship at this point in time and how the relevant activity was controlled, would the organisation have sufficient evidence to provide a reliable answer?

If the answer is no, the employer should consider whether its governance record retention arrangements are adequate.

This does not justify indefinite retention of every document. Rather, sponsors should operate a documented and proportionate retention framework that distinguishes between mandatory Home Office records and additional governance evidence maintained to support effective sponsor licence compliance.

 

 

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Section J: How Personnel Records Fit Within Wider Sponsor Licence Compliance

 

Sponsor licence personnel records form one part of a wider compliance framework. Effective sponsor governance depends on the people responsible for sponsorship being connected to the systems, records and business functions that allow the organisation to meet its ongoing sponsor duties.

Personnel records should therefore not be managed in isolation. The individuals responsible for sponsorship need access to relevant information about sponsored workers, employment changes, attendance, salary, right to work status and organisational changes so that appropriate compliance action can be taken.

 

1. Personnel Governance Records vs Sponsored Worker Records

 

It is important to distinguish between records showing who manages sponsorship and records relating to the sponsored workers themselves.

 

Personnel Governance Records	Wider Sponsor Compliance Records
Who manages sponsorship	Records relating to individual sponsored workers
Authorising Officer and key personnel information	Required immigration and employment documents
SMS access and user governance	Right to work evidence
Allocation of sponsor responsibilities	Recruitment records where required
Training and internal guidance evidence	Salary and employment records
Personnel changes and handovers	Absence and attendance information
Internal compliance responsibility	Worker contact information and other required records
Governance reviews	Evidence relating to sponsored employment and compliance with the relevant immigration route

 

Both categories can be relevant during a Home Office compliance assessment, but they serve different purposes.

The wider documents that sponsors are required to retain are considered separately in our Sponsor Licence Record Keeping guide.

 

2. Personnel Records and Sponsor Reporting Duties

 

Effective personnel governance supports compliance with sponsor reporting duties because the organisation needs to identify reportable events and ensure that responsibility for taking action is clearly allocated.

Employers should know who is responsible for:

 

• identifying potentially reportable changes;
• assessing whether a change requires Home Office action;
• obtaining the information required to make a report;
• submitting reports through the SMS where required;
• retaining appropriate evidence of the underlying event; and
• escalating uncertainty or potential non-compliance.

 

Personnel changes can themselves also create reporting or SMS management issues. A change involving the Authorising Officer, Key Contact or SMS users should therefore trigger consideration of whether any Home Office action is required.

The applicable reporting obligations and deadlines are considered in our Sponsor Licence Reporting Duties guide.

 

3. Personnel Records and Right to Work Compliance

 

Right to work compliance and sponsor licence compliance are separate but closely connected employer responsibilities.

The organisation should clearly identify who is responsible for carrying out right to work checks and how relevant information is communicated to those responsible for sponsorship.

Personnel governance arrangements should address matters such as:

 

• who performs right to work checks;
• who verifies that the appropriate process has been followed;
• where evidence of checks is retained;
• who monitors time-limited permission where follow-up action is required;
• how concerns about an employee’s immigration status are escalated; and
• how information relevant to a sponsored worker is communicated to the sponsor compliance function.

 

Employers should avoid arrangements where right to work processes operate independently from sponsor management without an effective route for relevant information to be shared.

Further guidance is available in our Right to Work employer guide.

 

4. Personnel Records and Sponsored Worker Monitoring

 

Sponsors need systems capable of monitoring matters relevant to their sponsor duties. Personnel governance should identify who operates those systems and who is responsible for acting on the information they generate.

For example, line managers may identify an absence, payroll may identify a salary change and HR may process a change of job title. The sponsor compliance function needs a mechanism for receiving and assessing information that may have sponsorship implications.

Employers should therefore consider:

 

• which departments generate information relevant to sponsorship;
• who is responsible for passing that information to the appropriate person;
• who assesses the sponsorship implications;
• who has authority to take the required action; and
• how completion of the action is recorded.

 

Clear personnel responsibilities help connect day-to-day workforce management with the organisation’s formal sponsor duties.

 

5. Personnel Governance and Internal Sponsor Licence Audits

 

An internal sponsor licence audit should examine both the records relating to sponsored workers and the personnel and systems responsible for maintaining compliance.

A personnel governance review may examine:

 

• whether key personnel information is current;
• whether SMS access remains appropriate;
• whether responsibilities are clearly allocated;
• whether relevant staff understand their duties;
• whether internal procedures remain current;
• whether personnel changes have been properly managed;
• whether information flows effectively between departments;
• whether there is excessive reliance on one individual;
• whether previous compliance weaknesses have been addressed; and
• whether governance arrangements remain proportionate to the scale of sponsorship activity.

 

The results can then be considered alongside the organisation’s wider Sponsor Licence Compliance Audit.

 

6. Personnel Governance Should Reflect the Scale of Sponsorship

 

There is no single internal governance model suitable for every sponsor.

A smaller employer sponsoring a limited number of workers may operate an effective system involving a small number of appropriately trained personnel and straightforward internal procedures.

A large employer may require a more structured framework involving:

 

• central immigration or global mobility teams;
• local HR functions;
• multiple SMS users;
• formal responsibility matrices;
• documented escalation procedures;
• central compliance calendars;
• periodic internal audits;
• formal training programmes; and
• oversight across multiple sites or business divisions.

 

The relevant question is whether the organisation’s arrangements allow it to meet its sponsor duties consistently and demonstrate effective control of sponsorship.

 

7. Building a Sustainable Sponsor Compliance Framework

 

A mature sponsor governance framework typically combines clear ownership, controlled system access, documented procedures, appropriate staff knowledge and periodic review.

Employers should aim to establish arrangements in which:

 

• responsibility for sponsorship is clearly allocated;
• key personnel information remains current;
• SMS access is controlled and periodically reviewed;
• relevant personnel understand their responsibilities;
• changes in personnel trigger appropriate compliance action;
• knowledge is retained within the organisation when employees leave;
• relevant information moves effectively between business functions;
• potential compliance issues are escalated promptly; and
• governance arrangements are periodically tested through internal review.

 

This approach helps move sponsor compliance away from reactive administration and towards an established organisational control framework capable of supporting the licence over the longer term.

 

 

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Section K: Sponsor Licence Personnel Records FAQs

 

What personnel records should a sponsor licence holder keep?

Sponsor licence holders should maintain records that allow them to identify who is responsible for managing sponsorship, who holds key personnel roles, who has access to the Sponsor Management System and how sponsorship responsibilities are allocated and controlled.

Depending on the organisation, useful governance records may include key personnel details, SMS user information, responsibility matrices, internal sponsor procedures, training or briefing records, personnel change records, handover documentation and internal compliance review records.

These governance records should be distinguished from the specific sponsored worker documents that employers are required to retain under the Home Office sponsor record-keeping requirements.

 

Are sponsor licence personnel records mandatory?

Some information relating to sponsor licence personnel is required as part of the formal sponsorship framework, including the appointment and management of the sponsor’s key personnel and SMS users.

However, not every internal governance document discussed in this guide is an expressly prescribed Home Office record. For example, an internal responsibility matrix, training log or SMS access review may be used as good governance evidence without being a standalone document specifically required by the sponsor guidance.

Employers should therefore distinguish between mandatory Home Office requirements and additional records retained to demonstrate effective sponsor governance.

 

Who are the key personnel on a sponsor licence?

The principal sponsor licence key personnel roles are the Authorising Officer, Key Contact and Level 1 User. Existing Level 2 Users may remain temporarily during the transitional period, but no new Level 2 Users can be appointed from 9 September 2026. Remaining Level 2 Users must be converted to Level 1, where eligible, or deactivated by 8 March 2027.

The eligibility requirements, responsibilities and restrictions applying to these roles are considered in our Sponsor Licence Key Personnel guide.

 

What records should employers keep about the Authorising Officer?

Employers should maintain accurate information identifying the current Authorising Officer and their position within the organisation.

Internal governance records may also document their responsibilities, the date they assumed the role, how they oversee sponsor compliance and any subsequent change or transfer of responsibility.

The Authorising Officer has overall responsibility for the organisation’s sponsorship compliance arrangements, although day-to-day sponsorship tasks may be delegated to other appropriately authorised personnel.

 

Should employers keep a record of Sponsor Management System users?

Employers should maintain appropriate internal oversight of who has access to the Sponsor Management System and whether that access remains necessary and appropriate.

An internal SMS access record can be a useful way of recording current Level 1 Users and any remaining Level 2 Users during the transitional period, when access was provided, why access is required and when access is changed or removed.

A standalone internal SMS access register should be viewed as a governance control rather than as a substitute for complying with the Home Office rules governing SMS users.

 

Should former employees retain SMS access?

Where an employee leaves the organisation, their sponsorship responsibilities and SMS access should be reviewed promptly and appropriate action taken.

The employer should also consider whether the departure affects a key personnel role, whether responsibilities need to be transferred and whether any action is required through the SMS or under the applicable Home Office sponsor guidance.

 

Do sponsors have to keep training records?

There is not a general requirement for every sponsor to maintain a standalone training record for every individual involved in sponsorship.

However, retaining proportionate evidence of relevant training, briefings and internal guidance can help demonstrate that the organisation actively manages sponsor compliance and that personnel responsible for sponsorship have been given appropriate information about their duties.

 

What should happen when the Authorising Officer leaves?

The organisation should identify the implications for its sponsor licence promptly, appoint an appropriate replacement where required and complete any necessary action in accordance with the applicable sponsor guidance.

Internally, the employer should also ensure that sponsorship responsibilities, outstanding compliance matters, relevant records and any necessary system access are transferred appropriately.

The departure should not create a period in which responsibility for the sponsor licence is unclear.

 

What should be included in a sponsor licence handover?

The content of a handover will depend on the responsibilities of the individual concerned. It may need to address outstanding SMS actions, Certificates of Sponsorship, reporting deadlines, sponsored worker changes, right to work follow-up checks, Home Office correspondence, internal compliance issues and upcoming audit activity.

The incoming individual should also know where relevant sponsor records are maintained and how potential compliance issues are escalated.

 

How often should sponsor licence personnel records be reviewed?

There is no single review frequency suitable for every internal governance record. Employers should keep personnel information current and review their arrangements when relevant changes occur.

Periodic review is also advisable as part of the organisation’s wider sponsor compliance programme.

A review may be particularly appropriate following staff departures, promotions, internal transfers, restructuring, changes to SMS users, material changes to sponsorship activity or changes to relevant Home Office requirements.

 

How long should sponsor licence personnel records be retained?

The applicable retention period depends on the type of record.

Documents that fall within specific Home Office sponsor record-keeping requirements should be retained for the period prescribed by the applicable guidance.

Internal governance records that do not have a specific Home Office retention period should be retained proportionately according to their compliance purpose, the organisation’s document retention framework and applicable data protection requirements.

Employers should avoid assuming that every document connected with sponsorship has the same retention period.

 

Can the Home Office ask about sponsor licence personnel during a compliance visit?

Yes. A Home Office compliance assessment can examine whether the sponsor has appropriate systems and processes for meeting its duties and whether relevant personnel understand how those systems operate.

The employer may therefore need to explain who manages the sponsor licence, who has SMS access, how responsibilities are allocated and how personnel changes are managed.

Relevant employees may also need to explain the procedures connected with the sponsor compliance functions they perform.

 

What happens if sponsor personnel records are out of date?

Outdated personnel records can indicate wider weaknesses in sponsor governance, particularly where they result in unclear responsibilities, inappropriate SMS access or failures to deal with changes affecting key personnel.

The consequences will depend on the underlying circumstances. An outdated internal document is not necessarily, by itself, evidence of a breach. Employers should establish whether the discrepancy reflects a wider failure to meet sponsor duties or complete required Home Office actions.

 

Can an external immigration adviser manage sponsor licence responsibilities?

External advisers can support sponsors with immigration and sponsor licence administration, subject to the applicable rules governing key personnel and SMS access.

However, using an external adviser does not remove the sponsor’s responsibility for complying with its sponsor duties.

The employer should maintain appropriate internal oversight and understand which responsibilities are performed internally, which functions are supported externally and how relevant information is exchanged between the organisation and its adviser.

 

What is a sponsor governance file?

A sponsor governance file is an internal collection of records used to document how an organisation manages its sponsor licence.

It may include key personnel information, SMS access records, responsibility matrices, internal procedures, training evidence, handover documents, personnel change records and internal audit information.

A sponsor governance file is not a separate Home Office requirement and does not replace the specific documents sponsors are required to retain. It can, however, provide a useful central evidence trail demonstrating how sponsor compliance is managed and reviewed.

 

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Section L: Sponsor Licence Personnel Records: Employer Compliance Summary

 

Sponsor licence personnel records help employers demonstrate that responsibility for sponsorship is clearly allocated, appropriately controlled and capable of continuing when personnel or organisational circumstances change.

Effective personnel governance is not simply a question of maintaining documents. Employers should be able to show how their sponsor licence is managed in practice, who has authority to perform relevant functions, who has access to the Sponsor Management System and how compliance responsibilities are transferred when personnel change.

Some personnel information forms part of the formal Home Office sponsorship framework. Other records discussed in this guide, such as internal responsibility matrices, training evidence, access reviews and handover records, are governance tools that can help an employer demonstrate effective management rather than standalone documents expressly required in every case by the Home Office.

 

1. Key Actions for Sponsor Licence Holders

 

As part of their ongoing sponsor governance arrangements, employers should:

 

• maintain accurate information about current sponsor licence key personnel;
• ensure sponsorship responsibilities are clearly allocated;
• understand who currently has Level 1 SMS access and whether any Level 2 Users remain during the transitional period;
• review whether SMS access remains necessary and appropriate;
• remove or amend access when personnel leave or change roles;
• ensure relevant personnel understand the sponsor duties connected with their functions;
• consider retaining proportionate evidence of relevant training and compliance guidance;
• document significant transfers of sponsorship responsibility;
• ensure outstanding compliance matters are included in personnel handovers;
• maintain sufficient organisational knowledge to avoid excessive dependence on one individual;
• connect sponsor personnel with HR, payroll, recruitment, right to work and other relevant business functions;
• review personnel governance following restructuring or other significant organisational change;
• complete any required Home Office reporting or SMS action when relevant personnel change; and
• include personnel governance within periodic sponsor licence compliance reviews.

 

2. The Compliance Test for Employers

 

A useful test is whether the organisation could explain its sponsor governance arrangements clearly if questioned by the Home Office.

The employer should be able to answer:

 

• Who has overall responsibility for the sponsor licence?
• Who performs the principal sponsorship functions?
• Who currently has access to the SMS?
• How is that access controlled?
• How do relevant personnel know what they are required to do?
• How does information about sponsored workers reach the people responsible for sponsor compliance?
• How are personnel changes and departures managed?
• How does the organisation maintain continuity when responsible individuals are unavailable?
• How are potential compliance problems identified and escalated?
• When were these arrangements last reviewed?

 

If the organisation would struggle to provide clear and consistent answers, this may indicate that its personnel governance arrangements require further review.

 

3. Sponsor Compliance Should Be Organisational, Not Personal

 

One of the central objectives of effective sponsor governance is to ensure that compliance capability belongs to the organisation rather than depending entirely on the knowledge of individual employees.

Personnel will inevitably change. Authorising Officers may leave, SMS users may move roles, HR teams may restructure and external advisers may change. The sponsor should nevertheless remain capable of meeting its duties without significant disruption.

Clear responsibilities, controlled access, documented procedures, effective handovers and appropriate governance records can help preserve that organisational capability.

Employers should therefore treat sponsor licence personnel records as part of an ongoing compliance framework rather than an administrative exercise completed when the licence is first obtained.

 

4. Reviewing Sponsor Licence Personnel Records

 

Personnel governance should be reviewed periodically and whenever there is a material change affecting the people or systems responsible for sponsorship.

A review can help identify outdated key personnel information, unnecessary SMS access, unclear responsibilities, inadequate handover arrangements and gaps between documented procedures and actual working practices.

Where weaknesses are identified, employers should establish the underlying facts, determine whether any sponsor duties have been affected and take appropriate corrective action.

Where there are concerns about wider sponsor compliance, the personnel review should form part of a broader Sponsor Licence Compliance Audit covering the organisation’s records, reporting processes, sponsored worker monitoring and operational systems.

 

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Section M: Glossary

 

Term	Meaning
Authorising Officer (AO)	The Authorising Officer is the individual with overall responsibility for the organisation’s sponsorship compliance arrangements. Day-to-day sponsorship tasks may be delegated to other appropriately authorised personnel, but the Authorising Officer retains an important oversight role within the sponsor management structure.
Key Contact	The Key Contact is the individual nominated to act as the principal point of contact between the sponsor licence holder and the Home Office in relation to the sponsor licence.
Key Personnel	Key personnel are the individuals appointed to specified roles for the management of a sponsor licence. The principal roles are the Authorising Officer, Key Contact and Level 1 User and, during the transitional period, any remaining Level 2 Users.
Level 1 User	A Level 1 User is an individual authorised to access the Sponsor Management System and carry out sponsorship management functions permitted by the Home Office. The precise functions available should be checked against the current sponsor guidance.
Level 2 User	A Level 2 User is a legacy SMS user role with more limited access to the Sponsor Management System. No new Level 2 Users can be appointed from 9 September 2026. Existing Level 2 Users may continue temporarily during the transitional period but must be converted to Level 1, where eligible, or deactivated by 8 March 2027.
Sponsor Licence	A sponsor licence is the Home Office authorisation that enables an eligible organisation to sponsor qualifying workers under relevant UK immigration routes, subject to the organisation continuing to meet its sponsor duties.
Sponsor Duties	Sponsor duties are the ongoing compliance obligations applying to organisations holding a sponsor licence. They include requirements relating to record keeping, reporting, monitoring sponsored workers and complying with relevant UK immigration requirements and sponsor guidance.
Sponsor Management System (SMS)	The Sponsor Management System is the Home Office online system used by licensed sponsors to administer their licence and carry out sponsorship-related activities, including specified reporting and Certificate of Sponsorship functions.
Sponsor Governance	Sponsor governance refers to the internal arrangements through which an organisation allocates, manages, monitors and reviews responsibility for sponsor licence compliance. This can include the allocation of responsibilities, management of key personnel, control of SMS access, internal procedures, training, escalation arrangements, personnel handovers and compliance reviews.
Sponsor Governance File	A sponsor governance file is an internal collection of documents used to record how the organisation manages and oversees its sponsor licence. It is not a separate Home Office requirement and does not replace mandatory sponsor records. It can, however, provide useful evidence of how responsibilities, system access, personnel changes and compliance processes are managed.
Sponsor Licence Compliance Visit	A sponsor licence compliance visit is a Home Office assessment of a sponsor or prospective sponsor. Depending on the circumstances, the Home Office may examine records, systems, processes, personnel knowledge and the organisation’s ability to meet its sponsor duties.
Sponsor Licence Compliance Audit	A sponsor licence compliance audit is an internal or externally supported review of the organisation’s sponsorship arrangements. It can be used to identify compliance weaknesses, test systems and records and prepare the organisation for potential Home Office scrutiny.
Personnel Governance Records	Personnel governance records are internal records relating to the people responsible for managing sponsorship. They can include information about key personnel, SMS users, allocated responsibilities, training, personnel changes, handovers and governance reviews. Not every personnel governance record is an expressly prescribed Home Office record. Employers should distinguish these internal governance records from documents that must be retained under the applicable sponsor guidance.
Sponsored Worker Records	Sponsored worker records are documents and information relating to workers sponsored by the organisation. The Home Office specifies particular documents that sponsors are required to retain, with the applicable requirements addressed in the sponsor guidance and associated record-keeping guidance.
Home Office	The Home Office is the UK government department responsible for immigration and the sponsorship system. Sponsor licensing and compliance functions are administered through UK Visas and Immigration (UKVI), which forms part of the Home Office.
UK Visas and Immigration (UKVI)	UK Visas and Immigration is the part of the Home Office responsible for administering the UK visa and immigration system, including the operation and enforcement of the sponsor licensing regime.

 

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Section N: Useful Links

 

Further guidance on sponsor licence personnel records, key personnel, Sponsor Management System access and wider sponsor compliance can be found in the following DavidsonMorris and official government resources.

 

Resource	URL
Sponsor Licence Compliance: Complete Employer Guide Overview of sponsor compliance duties, systems, governance and employer responsibilities.	https://www.davidsonmorris.com/sponsor-licence-compliance/
Sponsor Licence Duties: Employer Compliance Guide Detailed guidance on the ongoing duties that apply to licensed sponsors.	https://www.davidsonmorris.com/sponsor-licence-duties/
Sponsor Licence Record-Keeping Duties Guidance on the documents, records and evidence sponsors are required to maintain.	https://www.davidsonmorris.com/sponsor-licence-record-keeping/
Sponsor Licence Reporting Duties Guidance on reportable worker, personnel and organisational changes and the applicable reporting framework.	https://www.davidsonmorris.com/sponsor-licence-reporting-duties/
Sponsor Licence Compliance Checklist Practical compliance checklist covering sponsor systems, records, personnel and ongoing controls.	https://www.davidsonmorris.com/sponsor-licence-compliance-checklist/
Sponsor Licence Key Personnel: Roles & Requirements Guidance on the Authorising Officer, Key Contact, Level 1 User and transitional Level 2 User arrangements.	https://www.davidsonmorris.com/sponsor-licence-key-personnel/
Authorising Officer: Sponsor Licence Duties & Requirements Guidance on the Authorising Officer role, eligibility, responsibilities and sponsor oversight.	https://www.davidsonmorris.com/sponsor-licence-authorising-officer/
Key Contact: Sponsor Licence Role & Responsibilities Guidance on the Key Contact role and the sponsor’s principal Home Office contact arrangements.	https://www.davidsonmorris.com/sponsor-licence-key-contact/
Level 1 User: Sponsor Licence Role & Responsibilities Guidance on Level 1 User eligibility, SMS access and sponsor management responsibilities.	https://www.davidsonmorris.com/sponsor-licence-level-1-user/
Level 2 User: Sponsor Licence Role & Permissions Guidance on the legacy Level 2 User role and the current transitional arrangements.	https://www.davidsonmorris.com/sponsor-licence-level-2-user/
Sponsor Management System (SMS): Employer Guide Guidance on operating the SMS, managing access and carrying out sponsor administration.	https://www.davidsonmorris.com/sponsor-management-system/
How to Change Sponsor Licence Key Personnel Guidance on replacing or updating sponsor key personnel and managing related SMS action.	https://www.davidsonmorris.com/change-sponsor-licence-key-personnel/
Sponsor Licence Compliance Audit: How to Prepare Guidance on testing sponsor records, personnel, systems and operational controls.	https://www.davidsonmorris.com/sponsor-licence-compliance-audit/
Sponsor Licence Compliance Visits: Employer Guide Guidance on Home Office compliance visits, preparation and potential outcomes.	https://www.davidsonmorris.com/sponsor-licence-compliance-visit/
Sponsor Licence Right to Work Compliance Guidance on right to work controls and their interaction with sponsor licence duties.	https://www.davidsonmorris.com/sponsor-licence-right-to-work/
Sponsor Licence Civil Penalties Guidance on civil penalty exposure and its relevance to sponsor compliance.	https://www.davidsonmorris.com/sponsor-licence-civil-penalties/
Home Office — Sponsorship Information for Employers and Educators Official collection of Home Office sponsorship guidance and supporting materials.	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Workers and Temporary Workers: Sponsor Duties and Compliance Primary Home Office guidance covering sponsor duties, compliance requirements and Home Office action.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
Home Office Appendix D: Keeping Documents – Guidance for Sponsors Official guidance setting out the documents and records sponsors are required to retain.	https://www.gov.uk/government/publications/keep-records-for-sponsorship-appendix-d
UK Immigration Rules Official Immigration Rules governing sponsored work routes and related immigration requirements.	https://www.gov.uk/government/collections/immigration-rules

 

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