If you hold a sponsor licence, your day job isn’t just hiring and retaining staff — it’s also keeping the Home Office in the loop when your business changes. And the annoying bit is this: plenty of business changes that feel “purely commercial” (new trading name, office move, restructure, acquisition) can become an immigration compliance issue overnight.
In most cases, you’ll be reporting changes through the Sponsor Management System (SMS), and for significant changes to your business you’re generally expected to report them within 20 working days.
Below is a practical guide to the changes that most commonly trigger sponsor reporting — and how to handle them without putting your licence (and your sponsored workers) at risk.
Why sponsor reporting matters more than you think
Sponsor reporting isn’t “admin for admin’s sake”. The Home Office uses your reporting (and your record-keeping) to decide whether you’re still trustworthy as a sponsor — especially after corporate changes, when there’s a higher risk that:
- the business that was originally licensed has effectively changed shape
- HR systems have been disrupted
- sponsored workers have moved teams, locations, or even legal employers
If the Home Office believes you’re not meeting your duties, you could face suspension or revocation, which can block you from assigning new Certificates of Sponsorship (CoS) and create serious problems for your existing sponsored workforce.
And with sponsorship still central to UK hiring — 35,000 Skilled Worker visas were granted to main applicants in the year ending September 2025 — sponsor compliance is not the place to wing it.
The reporting basics: what, who, when, how
How you report
Most sponsor changes are reported through the SMS.
Who reports
Typically your Level 1 user (and in some cases, the Authorising Officer) will submit the report or request via SMS — which is why it’s risky if only 1 person in the business has access.
When you report
For significant business changes, the Home Office position is generally within 20 working days.
1) Mergers and acquisitions: the “change of control” trap
Mergers, takeovers, and many acquisitions often trigger reporting because they can change who legally owns or controls the sponsor. The Home Office explicitly expects sponsors to report being involved in a merger or take-over as a significant business change.
What you should do in practice
Think about it in 2 layers:
- Corporate reality: Who is the legal entity employing the sponsored workers after completion?
- Sponsorship reality: Which entity is responsible for sponsor duties after completion?
If the legal employer changes (or if the sponsor entity effectively ceases to trade), you may be looking at more than a “report” — you may be looking at a new sponsor licence application or a restructuring of responsibility for the sponsored workers.
The documents you’ll usually need ready
- Companies House filings / confirmation statements
- share purchase agreement / asset purchase agreement extracts (relevant parts)
- updated organisational chart
- confirmation of who the new Authorising Officer / Level 1 user will be
- list of sponsored workers impacted (roles, work addresses, CoS details)
2) TUPE transfers: when staff move, sponsor duties move too
TUPE is one of the easiest ways to accidentally break sponsor compliance because the business focuses on “employment law continuity” while sponsorship sits quietly in the background.
The Home Office guidance gives clear examples where sponsored workers transfer under TUPE (or similar protection) during a takeover, and the change must be reported within 20 working days.
Common TUPE scenarios that trigger sponsor reporting
- A licensed sponsor is taken over and sponsored workers move to the new owner under TUPE
- A partial transfer where some workers move and others remain
- A transfer where the buyer doesn’t have a sponsor licence (this is where things get urgent)
The big practical point
If workers have transferred to an entity that can’t lawfully sponsor them, you need to fix that quickly — because your workers’ immigration position can become exposed, and your sponsor licence can end up under scrutiny.
3) New trading names: “but we didn’t change the company…”
This one catches loads of businesses.
Even if your legal entity stays the same, changing your trading name can still trigger reporting because your sponsor licence details need to match reality on the ground — including how the business presents itself, how contracts are issued, and what appears on signage, websites, and payroll documents.
Typical examples
- rebrand after investment
- launching a new consumer brand name
- switching from “Ltd” branding to a group trading name
- franchising or group brand alignment
What to do
- check what name appears on employment contracts and payslips
- ensure sponsored workers’ HR files reflect the change consistently
- report the change through SMS if it affects sponsor licence details
(And don’t forget the basics: if your outward brand changes but your HR files look messy or inconsistent, you’re making compliance visits harder than they need to be.)
4) Change of address: head office moves, new branches, site closures
A change of address sounds simple, but it’s one of the most visible “tell” signs that your sponsor record might be out of date.
The SMS is specifically used to report sponsor changes like a new location or organisational detail updates.
Address-related changes that often need reporting
- moving your head office
- changing your main operating site
- opening a new branch where sponsored workers will work
- closing a location where sponsored workers were based
- moving from serviced offices to a permanent site (or vice versa)
Practical compliance tip
Before you move, make sure you can still evidence:
- right to work checks and onboarding trails
- where sponsored workers are actually working (especially hybrid arrangements)
- updated reporting lines and day-to-day supervision
5) Restructures and “substantial change in business activity”
Not every restructure is reportable, but some are — especially where you’ve substantially changed the nature of your business (another example the Home Office gives of a significant change).
Examples
- pivoting from consultancy to software product business
- selling off a business division that employed sponsored workers
- changing operating model (e.g., moving all staff to client sites)
- insolvency events or stopping trading (also explicitly flagged)
This is where it pays to take advice early, because reporting is only half the job — you also need to make sure your sponsorship setup still reflects a genuine, compliant employment arrangement.
A quick “do this now” checklist after a corporate change
If you’ve had (or you’re about to have) a merger, acquisition, TUPE transfer, rebrand, or office move, run this checklist:
- Confirm the legal employing entity for each sponsored worker post-change
- Confirm who holds (or should hold) sponsorship responsibility
- Check your SMS users — make sure you have active access and cover
- Prepare a list of sponsored workers affected, including work addresses
- Update HR records so they remain consistent and auditable
- Submit the required SMS reports within 20 working days where applicable
- Keep a clean “transaction file” so you can evidence what changed and when (useful if UKVI visits)
Where to get help if you’re not sure
The safest approach is to treat sponsorship as part of your transaction checklist — not an afterthought once completion emails have gone round.
If you want help tightening up sponsor reporting and protecting your licence during business changes, Garth Coates can support you with everything from Sponsor Licence Compliance reviews to Sponsor Licence Application work, plus crisis support if you’re facing Sponsor Licence Suspension and Revocation.
Next steps
If your business is going through a merger, acquisition, TUPE transfer, rebrand, or relocation, don’t leave sponsor reporting to chance. A quick, structured compliance check now can save you a much bigger problem later — especially if you’re sponsoring workers on the Skilled Worker route and need your licence to stay clean.
Get in touch with the team at Garth Coates today via the Contact page and we’ll help you map the change properly, report what needs reporting, and keep your sponsor licence protected.
Ready to move forward with your UK immigration plans? Garth Coates Solicitors can guide you at every step — from eligibility checks and document preparation to submission and follow-up. If you’re launching a business, our uk start up visa team can help you build a strong application. Need support with work routes? Speak to a trusted skilled worker visa solicitor today. We also advise on the uk self sponsorship visa for entrepreneurs seeking more control. Studying in the UK? Our student visa solicitors are here to help — contact us now for tailored advice.
