Good sponsor licence management depends on accurate records, timely reporting and keeping the right people in control of your Sponsorship Management System (SMS). Most changes affecting sponsored workers must be reported within 10 working days, while many significant organisational changes must be reported within 20 working days. Missing a reporting duty can lead to compliance action, including downgrade, suspension or revocation depending on the breach.
If a sponsor is downgraded to a B-rating, it must normally pay £1,579 for a Home Office action plan. While subject to the action plan, it cannot assign Certificates of Sponsorship to new workers or add new routes or branches to the licence. Building sponsor licence management best practice into everyday HR processes is therefore important.
Who should manage the SMS?
Sponsors must have at least one eligible Level 1 User in place at all times. If the only Level 1 User leaves, normal SMS reporting can become difficult and a sponsor change-of-circumstances process may be required to restore access.
Review key personnel on a sponsor licence regularly and make sure responsibilities are clear. More than one suitable Level 1 User can reduce operational risk, particularly where staff are absent or leave the organisation.
What to report and when
| Event | Reporting position | Practical point |
|---|---|---|
| Worker has not started within the permitted 28-day period | Report through SMS | Check the start-date rules before continuing sponsorship |
| Unauthorised absence exceeding 10 consecutive working days | Report no later than 10 working days after the tenth day | Keep attendance and investigation records |
| Salary reduction from the amount stated on the CoS | Normally within 10 working days | Salary increases do not generally need reporting |
| Significant role, title or duty change within the same occupation code | Normally within 10 working days | A different occupation code may require a new application |
| Employment ends early | Within 10 working days | Report that sponsorship has stopped |
| Major organisational change | Generally within 20 working days | Ownership changes can require a new sponsor licence |
The Home Office specifically requires reporting where a worker is absent without permission for more than 10 consecutive working days. It also requires reporting where unpaid or reduced-pay absence exceeds four weeks in total in a calendar year, unless an applicable exception in the sponsor guidance applies.
Salary and duties should also be checked against Skilled Worker sponsorship salary rules and SOC codes and job descriptions. The same compliance requirements matter where a business owner uses what is commonly described as self sponsorship.
Tracking absences properly
Sponsors should maintain reliable records of attendance, absence and working arrangements. Before agreeing extended unpaid leave, review the rules on managing unpaid leave for sponsored workers. If employment ends because the role disappears, see the curtailment guidance when a sponsored job disappears.
Hybrid working does not automatically need to be reported merely because a sponsored worker splits time between home and their normal workplace. However, sponsors must report changes to the worker’s main office location, new regular client sites and arrangements where the worker becomes fully or almost entirely remote. Suitable records of working patterns should also be retained. Our guide to multi-site and hybrid working explains the practical position.
Keeping your A-rating
An A-rating is the normal rating for a compliant sponsor. Maintaining it means keeping sponsorship information consistent across HR, payroll and the SMS, carrying out appropriate right to work checks and retaining the records required by Home Office guidance.
Businesses should build these systems when making a sponsor licence application, rather than waiting for a sponsor licence compliance visit. This is particularly important for staff sponsored through the Skilled Worker visa route.
Full requirements are available on the GOV.UK sponsor guidance pages.
Frequently asked questions
Do I have to report every salary increase?
No. Salary increases do not generally need to be reported, although specific exceptions apply. Salary reductions from the figure stated on the CoS normally do require reporting.
Does hybrid working need to be reported?
Not simply because an employee adopts a hybrid pattern. Changes to the main work location, new regular client sites and fully remote arrangements can require reporting.
What happens if my sponsor licence becomes B-rated?
You will normally have to follow a Home Office action plan and pay the £1,579 action-plan fee. During that period, sponsorship activity is restricted until you regain an A-rating.
If your SMS records have not been reviewed recently, Garth Coates immigration solicitors can assess your sponsorship records and compliance procedures.
