UK Sponsor Licence Duties: What Every Licensed Employer Must Know

When the Home Office grants an organisation a sponsor licence, it is not a formality or a one-off administrative approval. It is the beginning of a continuous legal relationship in which the licence holder accepts binding obligations that apply every day, not just at the point of application or at renewal. These obligations are set out in the Workers and Temporary Workers: Guidance for Sponsors (Part 3), which was most recently updated in March 2026.

Failing to understand, or failing to meet, these duties can result in enforcement action ranging from a B-rating downgrade and an action plan through to suspension of the licence and, in serious cases, outright revocation, meaning your sponsored workers could have their visas cancelled within 60 days. In the year to June 2025, the Home Office revoked 1,948 sponsor licences, more than double the previous year's figure. Compliance failure is now the primary cause of licence loss in the UK.

Important - March 2026 update: On 6 March 2026, the Home Office published significantly updated sponsor guidance (version 03/26). New paragraphs L2.6 and L2.7 introduced a Worker Rights and Welfare obligation requiring sponsors to ensure all sponsored workers understand their employment rights under UK law and to retain documented evidence of this. All sponsor licence holders must now comply with this requirement.

The Home Office organises sponsor obligations under four core duties. Every licensed sponsor must comply with all four, at all times:

1. Record Keeping (Appendix D)

You must maintain specific records for every sponsored worker, as set out in Appendix D of the sponsor guidance. These records must be organised, accessible, and available for inspection on demand. The key records include:

• A copy of each sponsored worker's current passport and valid immigration status, accessed through the Home Office online checking service using a share code (not a physical BRP, which is no longer valid proof of right to work).
• Evidence of the right-to-work check: the date it was conducted, who conducted it, and the outcome, including any follow-up checks where leave is time-limited.
• Current and historical contact details (UK address, phone number, email) kept up to date continuously.
• Records of absence: annual leave, sick leave, unpaid leave, and any unauthorised absences.
• Employment records showing that the worker's actual salary, job title, duties, and work location match what was stated on their Certificate of Sponsorship (CoS).
• From March 2026: documented evidence that each sponsored worker has been informed of their employment rights under UK law, including rights under the Employment Rights Act 2025. This is a new Appendix D requirement.

All records must be retained for the full duration of each worker's sponsorship plus at least one year after that sponsorship ends.

2. Reporting Duties (Sponsor Management System)

Certain events affecting your organisation or your sponsored workers must be reported to the Home Office via the Sponsor Management System (SMS) within defined timeframes. The most important deadlines are:

Within 10 working days, report:

• A sponsored worker who does not show up for work on their first day without explanation.
• A sponsored worker absent from work for 10 or more consecutive working days without permission.
• Any change to a sponsored worker's employment: salary change (including any reduction from the CoS level), change of job title or duties, promotion, change of work location, or ending of the sponsored role.
• You stop sponsoring a worker for any reason.

Within 20 working days, report:

• A change of company name or branch name.
• A merger, acquisition, or change of ownership affecting your organisation.
• Your organisation stops trading, enters bankruptcy proceedings, or significantly changes the nature of its business.
• A relevant criminal conviction.

These reporting deadlines are strict. Late or missed reports are among the most common triggers for compliance action. The Home Office checks SMS data against HMRC payroll records to identify inconsistencies. Our UKVI compliant HR software tracks these deadlines and alerts your team automatically.

3. Monitoring Sponsored Workers

As a sponsor, you have an ongoing duty to monitor your sponsored workers throughout their employment. This means keeping track of attendance and absences, ensuring workers are working in the role and at the location described in their CoS, checking that salary continues to meet the required threshold, and keeping immigration status under review, including acting in good time when permission approaches expiry.

You also have a duty to conduct right-to-work checks for all employees before they begin employment, and to conduct follow-up checks for any employee whose permission to work is time-limited. Since the full rollout of the eVisa system, these checks must be conducted using the Home Office online service and a share code. Document verification using physical BRPs is no longer an acceptable standalone approach.

4. Compliance With UK Law

Your licence obliges you to comply with all applicable UK law, not just immigration law. This includes National Minimum Wage legislation, the Working Time Regulations, and health and safety law. As of the March 2026 guidance update, it now also explicitly includes the requirement to ensure that sponsored workers understand their employment rights, reflecting the Employment Rights Act 2025. The Home Office expects sponsors to demonstrate a culture of accountability, not merely technical compliance.

A sponsor licence requires the appointment of specific individuals who carry personal accountability for compliance. Three roles are mandatory:

• Authorising Officer (AO): The most senior person responsible for the organisation's sponsorship activities. The AO must understand the guidance, is accountable for the actions of all SMS users, and is the person the Home Office holds responsible if things go wrong. The March 2026 update added an explicit requirement for the AO to demonstrate they have read and understood the guidance and cascaded that understanding to relevant staff.
• Key Contact (KC): The primary point of communication between the Home Office and your organisation. Must be a paid employee, partner, or director.
• Level 1 User: Handles day-to-day SMS operations, including assigning CoS, reporting changes, updating worker records, and maintaining the accuracy of the SMS profile.

All key personnel must be UK-based and able to take on these responsibilities.