- Key Takeaways
- Introduction
- What ILR Actually Means for Your Sponsored Worker
- Why Your Job Is Not Done: ILR Is a Reportable Event
- The 10 Working Day Rule Explained
- How to Report a Worker's ILR on the SMS
- What Happens If You Do Not Report It
- The Hidden Risk: Every Other Worker on Your Licence
- Best Practice: Keep Your SMS and HR Records in Sync
- Common Reportable Events at a Glance
- How Can WorkPermitCloud Help?
- Conclusion
- Glossary
- Frequently Asked Questions
Key Takeaways
- When a sponsored worker is granted Indefinite Leave to Remain (ILR), they are no longer subject to sponsorship conditions and can change role, reduce hours, or move employer freely.
- Your duty as a sponsor does not end there. A worker obtaining ILR is a named reportable event that you must log on your Sponsorship Management System (SMS) within 10 working days of finding out.
- This is a strict Home Office rule, not a courtesy. The 10 working day clock starts from the date you become aware, not your next HR review.
- If you do not report it, the Home Office still treats that person as an active sponsored worker on your licence, which creates a mismatch between your records and reality.
- A single unreported event can trigger a wider compliance investigation that puts your entire licence, and every other sponsored worker on it, at risk.
- The fix is simple: report it on the SMS within 10 working days, update your HR file, and keep your records audit ready at all times.
Introduction
When one of your sponsored workers is granted Indefinite Leave to Remain, it usually feels like a moment to celebrate. It is the result of years of commitment from the employee, and it often signals a long term member of your team who is now settled in the UK. For many employers, that is where the story appears to end. The visa worry is over, the worker is secure, and everyone moves on.
Unfortunately, that is exactly where a quiet compliance risk begins. The grant of ILR changes your worker's status completely, but it does not automatically update your obligations as a licensed sponsor. There is one more step that a surprising number of employers miss, and missing it can expose your whole sponsor licence to scrutiny.
This guide explains precisely what you must do when a sponsored worker gets ILR, why the 10 working day reporting rule matters so much, what happens if you ignore it, and how to keep your records flawless so the Home Office never has a reason to come knocking.
What ILR Actually Means for Your Sponsored Worker
Indefinite Leave to Remain, also known as settlement, gives a person the right to live and work in the UK without any time limit and without immigration conditions attached to their stay. Once a sponsored worker holds ILR, the sponsorship relationship that previously governed their employment effectively falls away. Our guide to indefinite leave to remain and settlement explains what your worker had to show to qualify, including the confirmation they needed from you as their sponsor.
In practical terms, this means the worker is now free. They are no longer tied to the role on their Certificate of Sponsorship, no longer bound to a minimum salary set by the immigration rules, and no longer restricted to working only for you. After ILR, your employee can:
- Change to a different job or occupation code without needing a new Certificate of Sponsorship.
- Reduce their hours or move to part time work without breaching any visa condition.
- Leave your organisation and work for another employer who does not hold a sponsor licence.
- Take time out of work entirely without it affecting their right to remain in the UK.
All of this is their right, and none of it requires your permission. The important point for you as an employer is that the worker has stepped outside the sponsorship system, even though, on paper, your licence may still show them as a sponsored worker.
Why Your Job Is Not Done: ILR Is a Reportable Event
Here is the part that employers most often overlook. Under the Home Office sponsor guidance (Part 3: sponsor duties and compliance), a sponsored worker being granted settlement is a specific, named reportable event. When you become aware that your worker has obtained ILR, or any other immigration status that no longer requires sponsorship, you must report it to the Home Office.
This sits alongside the other changes you are already required to report, such as a worker not turning up for their first day, a significant change in salary, a change of work location, or a worker leaving your employment. The grant of ILR belongs firmly on that list. It is not optional, and it is not something that can wait until your annual HR audit or your next licence renewal.
The reason is straightforward. Your sponsor licence exists to track people whose right to be in the UK depends on your sponsorship. Once that dependency ends, the Home Office needs to know so that its records, and yours, reflect the true position.
The 10 Working Day Rule Explained
The reporting deadline for a worker obtaining ILR is 10 working days from the date you become aware of it. This is one of the tightest and most strictly enforced timeframes in the sponsor guidance, and the Home Office is well known for not accepting excuses about late reporting.
A few practical clarifications make this rule much easier to follow:
- The clock starts when you find out. If your employee tells you in an email on a Monday that they have been granted ILR, that is the trigger date, not the date on their grant letter or the date their eVisa was updated.
- Working days exclude weekends and bank holidays. Even so, the window is short, so build a habit of reporting immediately rather than leaving it to the last day.
- Reporting is done through the SMS. In the vast majority of cases you report the event through your Sponsorship Management System. Only in limited situations would you use a separate sponsor change of circumstances form.
The safest approach is to treat the 10 working day rule as a 48 hour rule in practice. Report it as soon as the news reaches the right person, and you will never be caught out by a missed deadline.
How to Report a Worker's ILR on the SMS
Reporting the event is quick once you know the steps. The table below sets out a simple, repeatable process for your SMS Level 1 user.
| Step | Action | Why It Matters |
| 1 | Confirm the grant of ILR in writing and note the date you became aware. | This fixes the start of your 10 working day reporting window. |
| 2 | Log in to the Sponsorship Management System (SMS) as a Level 1 user. | Only authorised key personnel can submit a report on your licence. |
| 3 | Select the relevant worker and report the change of circumstances. | The event is recorded against the correct individual on your licence. |
| 4 | Report that the worker has been granted settlement and no longer needs sponsorship. | This tells the Home Office the sponsorship relationship has ended. |
| 5 | Save the SMS confirmation and update your internal HR file. | Your records and the Home Office records now match, which is exactly what a compliance officer checks. |
Once the report is submitted, keep a copy of the SMS confirmation with the worker's HR record. If you are ever audited, this single document demonstrates that you met your duty on time.
What Happens If You Do Not Report It
If you fail to report the ILR grant, the Home Office continues to show that person as an active sponsored worker on your licence. That creates a gap between your official records and the reality of your workforce, and that gap is precisely what compliance officers look for.
Imagine the worker, now settled and free to do so, drops their hours, changes role, or moves to a different employer. Your SMS still says they are a sponsored worker in their original job. When the mismatch surfaces, whether through a routine visit, a right to work check, or a data cross reference, it reads as a monitoring failure on your part rather than a normal life event for the employee.
Late or missing reports are treated as breaches of your sponsor duties. Depending on the wider picture, the Home Office can downgrade your licence to a B rating and place you on an action plan, suspend your licence while it investigates, or revoke it entirely in serious cases. None of those outcomes is a good place to be, and all of them are avoidable with a timely report.
The Hidden Risk: Every Other Worker on Your Licence
This is the consequence that catches employers completely off guard. A compliance investigation triggered by one unreported event does not stay neatly contained to that one worker. Once the Home Office has reason to examine your licence, it looks at the whole picture.
Every other migrant on your licence who has not yet obtained ILR has their permission to be in the UK tied to your sponsorship. If your licence is downgraded or suspended, those workers are immediately at risk through no fault of their own. A suspended licence means you cannot issue new Certificates of Sponsorship, and a revoked licence can lead to your existing sponsored workers having their permission cancelled.
In other words, a five minute SMS report that you skipped for one settled worker can put the immigration status of your entire sponsored workforce in jeopardy. When you frame it that way, the cost of getting reporting right is tiny compared with the cost of getting it wrong.
Best Practice: Keep Your SMS and HR Records in Sync
The employers who never get caught out are the ones who do not rely on memory or on a once a year tidy up. They build reporting into their everyday HR process so that a reportable event is logged the moment it happens. A few habits make all the difference:
- Brief your managers and HR team that any news about a worker's immigration status, including ILR, must reach your SMS Level 1 user the same day.
- Keep a live tracker of every sponsored worker, their visa expiry, their salary, their role, and their reporting status.
- Diarise reminders well ahead of visa and right to work check dates so nothing slips.
- Run regular internal audits so that your SMS and your HR files always tell the same story.
This is exactly the kind of ongoing discipline that protects a licence. You can read more practical guidance across our WorkPermitCloud blog library, which covers sponsor duties, licence suspension, HMRC payroll checks, and day to day compliance for UK employers.
Common Reportable Events at a Glance
ILR is one of several worker related changes you must report. The table below summarises the most common reportable events and their deadlines so your team has a quick reference.
| Reportable Event | Reporting Deadline | Where to Report |
| Sponsored worker granted ILR or settlement | 10 working days | SMS |
| Worker does not turn up for their first day | 10 working days | SMS |
| Worker is absent without permission for more than 10 consecutive working days | 10 working days | SMS |
| Worker's contract ends early (resignation or dismissal) | 10 working days | SMS |
| Significant change in salary, role, or work location | 10 working days | SMS |
| Change of business ownership, merger, or takeover | 20 working days | SMS / change of circumstances form |
Deadlines and reportable events are set out in the Home Office sponsor guidance and can change, so always check the current version before relying on a timeframe.
How Can WorkPermitCloud Help?
At WorkPermitCloud, we do not wait for a routine Home Office visit to expose reporting gaps like an unreported ILR. We help you prioritise sponsor licence compliance from day one. Through our thorough HR compliance audits and UKVI compliant software, we keep your SMS and HR records perfectly aligned so your business is protected before the Home Office ever comes knocking. Start with our free HR Compliance Audit tool to check whether your SMS reporting is up to date, explore our compliant HR software to streamline day to day tracking, and visit our UKVI Compliant HR Software service page to ensure every worker on your licence is accounted for.
To speak with one of our specialists or to book an appointment, visit our contact page. 📞 Call us: +44 020 8087 2343 |
Conclusion
When a sponsored worker is granted ILR, it is genuinely good news. The worker is settled, your team gains a long term member, and the visa pressure lifts. The one thing it does not do is end your responsibility as a sponsor. The grant of ILR is a reportable event, and the Home Office expects to see it logged on your SMS within 10 working days.
Skipping that single report is one of the most common, and most avoidable, ways that compliant employers stumble into trouble. A few minutes on the SMS keeps your records accurate, protects your licence, and shields every other sponsored worker who depends on it. Do not let a routine piece of good news become a finding at your next Home Office visit.
If you want certainty that your records match reality for every worker on your licence, run our free HR Compliance Audit and get in touch with the WorkPermitCloud team today.
Glossary
| Term | Definition |
| Indefinite Leave to Remain (ILR) | Also called settlement. The right to live and work in the UK with no time limit and no immigration conditions attached. |
| Sponsor Licence | Home Office permission that allows a UK employer to sponsor non UK workers under routes such as the Skilled Worker visa. |
| Sponsorship Management System (SMS) | The online Home Office portal where sponsors manage their licence, assign Certificates of Sponsorship, and report changes. |
| Reportable Event | A change in a sponsored worker's circumstances that a sponsor is legally required to report to the Home Office, usually within 10 working days. |
| Certificate of Sponsorship (CoS) | An electronic record assigned through the SMS that a worker uses to apply for a sponsored visa. |
| Level 1 User | A key person on the licence with full access to the SMS, including the authority to submit reports and assign Certificates of Sponsorship. |
| Licence Downgrade (B rating) | A reduced licence rating placing the sponsor on a time limited action plan to address compliance failings before the A rating can be restored. |
| Cancellation of permission | The ending of a person’s permission to stay in the UK under Part Suitability of the Immigration Rules, which can follow the revocation of their sponsor’s licence. |
| Compliance Audit | A structured review of a sponsor's HR systems and records to confirm they meet Home Office sponsor duties. |


