Sponsor Licence Compliance: What UK Employers Need to Know

Sponsor Licence Compliance: What UK Employers Need to Know

Holding a sponsor licence comes with significant responsibilities. Failing to meet your compliance duties can result in your licence being downgraded, suspended, or revoked — leaving your sponsored workers unable to continue working. Here's what you need to know.

Your Core Duties as a Sponsor

The Home Office sets out five key duties for all licence holders:

1. Record-Keeping Duties

You must keep copies of key documents for each sponsored worker, including:

• Passport and visa (with right-to-work endorsement)
• Contact details (current UK address and phone number)
• National Insurance number
• Employment contract and job description
• Absence records (particularly important — see below)

Records must be kept for the duration of sponsorship and for one year after sponsorship ends.

2. Reporting Duties

You must report certain events to the Home Office via the Sponsorship Management System (SMS) within 10 working days, including:

• A sponsored worker fails to start their job
• A sponsored worker is absent without permission for 10+ consecutive working days
• A worker's job title, salary, or work location changes significantly
• A sponsored worker leaves your employment (for any reason)
• Any significant changes to your organisation (e.g. mergers, change of address, insolvency)

3. Migrant Tracking Duties

You must have systems in place to track and monitor your sponsored workers, including:

• Monitoring their immigration status and visa expiry dates
• Keeping track of their attendance and absences
• Ensuring they are doing the job they were sponsored for

4. Compliance with Immigration Law

You must not:

• Employ anyone without the right to work in the UK
• Assign a CoS to a worker for a role that doesn't exist or doesn't meet skill/salary requirements
• Help anyone breach immigration conditions

5. Cooperating with the Home Office

You must cooperate with any Home Office enquiries, including:

• Allowing compliance visits to your premises
• Providing documents and information when requested
• Reporting suspected illegal working

Compliance Visits

UKVI can visit your premises at any time, with or without notice. During a visit, they will typically:

• Interview your Authorising Officer and HR team
• Review personnel files for sponsored workers
• Check your record-keeping and reporting processes
• Inspect your premises and working conditions
• Verify that sponsored workers are present and doing their jobs

How to Prepare

• Keep all documents organised and easily accessible
• Ensure key personnel know their responsibilities
• Conduct regular internal audits of your sponsorship records
• Have a clear process for reporting changes via the SMS

Common Compliance Failures

The most common reasons for licence issues include:

• Late or missing reports (especially for leavers and no-shows)
• Inadequate record-keeping (missing right-to-work copies, outdated addresses)
• Failure to monitor absences (not tracking unauthorised absences)
• Assigning CoS for inappropriate roles (below skill level or salary threshold)
• Key personnel not understanding their duties

Consequences of Non-Compliance

Action	Impact
Action plan	Minor issues; you're given time to fix problems
Downgrade to B-rating	Restrictions on sponsoring new workers; must meet action plan
Suspension	Cannot assign new CoS; existing workers unaffected temporarily
Revocation	Licence cancelled; sponsored workers must find new sponsor within 60 days or leave the UK

Best Practices

• Appoint a dedicated compliance officer or team to manage sponsorship duties
• Use calendar reminders for visa expiry dates and reporting deadlines
• Train all relevant staff on their responsibilities, not just key personnel
• Conduct quarterly audits of sponsorship records
• Stay updated on changes to immigration rules and guidance

Final Thoughts

Compliance is not optional — it's a condition of holding your licence. The good news is that with proper systems and regular attention, maintaining compliance is straightforward. Treat it as an ongoing priority, not an afterthought, and your licence will serve your business well for years to come.