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Sponsor licence duties: what UKVI checks

A licensed sponsor must report worker changes within 10 working days and organisation changes within 20, keep records, and comply with wider UK law. The Home Office can visit unannounced, downgrade to a B-rating with a £1,579 action plan, suspend or revoke the licence, with no right of appeal.

Holding a sponsor licence is the start of a set of continuing duties, not the end of the process. Part 3 of the Home Office sponsor guidance (version 08/26, published 28 August 2026) sets out what a sponsor must report, what records it must hold, how compliance is checked, and what follows if it falls short. Its own opening principle is blunt: "Sponsorship is a privilege not a right."

This page sets out how the published rules work, for employers and for sponsored workers who want to understand what their employer is required to do. It cannot say whether a particular employer is compliant, and it is not advice about a particular compliance case.

When the duties begin and end

Under paragraph C1.8, the sponsor's responsibilities begin on the day the licence is granted and continue until the sponsor surrenders it, the Home Office makes it dormant (for example after a takeover) or revokes it. The Home Office reserves the right to take into account behaviour from any time, including a period when the business held no licence.

Responsibility for each individual worker starts on the day a certificate of sponsorship is assigned. It ends when the certificate is withdrawn or cancelled before use, the worker's permission expires or lapses, the sponsor tells the Home Office it has stopped sponsoring the worker, or, for Scale-up workers, six months after the permission becomes effective.

The duties fall into five groups: reporting, record-keeping, complying with immigration law and the sponsor guidance, complying with wider UK law, and not acting in a way that is "not conducive to the public good".

Reporting changes to a worker's circumstances

Unless the guidance says otherwise, changes affecting a sponsored worker must be reported within 10 working days of the event, using the "Report migrant activity" function in the sponsorship management system (SMS). The listed events are:

  • the worker does not start the role within 28 days of the start date;
  • the worker is absent from work without permission for more than 10 consecutive working days (the report is due within 10 working days after the tenth day);
  • the worker is absent without pay or on reduced pay for more than four weeks in total in a calendar year, subject to the exceptions in section S4 of Part 2;
  • pay falls below the level stated on the certificate (increases need not be reported, with a limited exception for pre-registration nurses);
  • significant changes to the employment, such as job title or core duties within the same occupation code, as permitted by section S9 of Part 2;
  • the normal work location changes, including a worker who will work entirely from home with little or no need to attend a workplace;
  • the sponsor stops sponsoring the worker for any reason.

Reasons to stop sponsoring include the worker's visa being refused or cancelled after any administrative review or appeal has finished, the worker deciding not to take the job, the contract ending early, a legally required professional registration being withdrawn ("such as GMC registration for a doctor"), the worker resigning or being dismissed or made redundant, or the worker being granted settlement.

When reporting that a worker has stopped working or is absent without permission, the sponsor must give the last known address, contact telephone number and personal email addresses. The guidance warns that this information may be used to cancel the worker's permission or take enforcement action. Hybrid working need not be reported, but the sponsor must be ready to explain why it needs to sponsor someone who could work from home abroad.

Reporting changes to the organisation

Section C2 requires most organisation changes to be reported within 20 working days of the sponsor becoming aware of them, except replacing the Authorising Officer or Key Contact. Changes are made through the SMS in most cases and by a change of circumstances form in limited cases.

The list is broad. It includes:

  • a new Authorising Officer or Key Contact, or changes to their details or those of Level 1 Users;
  • the organisation's name, address, contact details or head office;
  • new branches or linked entities;
  • a change in any registration the sponsor must hold to operate lawfully, such as losing charitable status or a regulator's registration;
  • stopping trading, entering insolvency, or a merger or takeover;
  • a relevant criminal conviction of anyone covered by the definition of "you";
  • a change in organisation size or charitable status, which affects the licence fee and the Immigration Skills Charge;
  • substantially changing the nature of the business.

GOV.UK adds that requests can take up to 18 weeks, with a £350 priority service for registering a change within five working days. Level 1 Users must now also keep their own SMS details up to date: the guidance says mandatory multi-factor authentication for SMS users began on 3 September 2026, and inactive SMS accounts will be removed. If a sponsor ends up with no active Level 1 User, the licence is liable to revocation, though the cooling-off period does not apply where the sole reason is the inactive account process.

Record-keeping and right to work

Paragraph C1.37 requires the sponsor to keep specified documents for each sponsored worker, listed with retention periods in Appendix D of the sponsor guidance, on paper or electronically. The sponsor must also provide, on request and within the deadline, any document the Home Office considers relevant to its compliance, for example recruitment practices.

GOV.UK describes the practical systems a sponsor needs: monitoring workers' immigration status, keeping copies of documents including right to work checks, tracking and recording attendance, keeping contact details up to date and reporting problems.

A sponsor that sponsors someone under 18 must keep a parental consent letter and meet care-arrangement duties, and must arrange any Disclosure and Barring Service check that applies. The guidance also reminds sponsors of their obligations under data protection law.

Complying with immigration and wider UK law

Paragraph C1.42 lists what complying with immigration law means in practice. A sponsor must:

  • only sponsor workers who are appropriately qualified, registered or experienced for the job, keep a copy of any required registration or certificate, and stop sponsoring someone who is no longer entitled to do the job;
  • carry out the proper right to work checks;
  • never assign a certificate for a role that is not an eligible role;
  • make sure the actual role matches the occupation code and job description on the certificate. The guidance says that discovering a worker in a role that does not match "will be a mandatory ground for revocation of your sponsor licence" unless it is a permitted change;
  • never let an SMS user assign their own certificate or one to a close relative or partner;
  • check and record whether a worker needs an Academic Technology Approval Scheme certificate;
  • never attempt to recoup prohibited costs from the worker.

Under wider UK law the sponsor must comply with employment law, including National Minimum Wage and the Working Time Regulations, and must enrol employees in a pension scheme where required. It must hold any licence or registration needed to run its type of business, avoid criminal activity and not breach UK or UN sanctions. It must also not behave in a way that is detrimental to the public good, for example fostering hatred, glorifying terrorism or discriminating on protected grounds.

How the Home Office checks

The guidance says sponsors are monitored continually. A compliance check can consist of requests for documents, verification of information, an on-site visit, a video interview and checks with other government departments. HMRC checks are made regularly to confirm sponsored workers are being paid in line with the rules. Visits can be announced or unannounced, and can include any address where a sponsored worker works, including a client site or, for some workers, a home. The sponsor must give staff access on demand and make sure a third party hosting a sponsored worker will co-operate.

The Home Office may check on the basis of reasonable suspicion, a poor previous record or information from other sources, including applications by sponsored workers and reports from the public. It will not tolerate abusive or threatening behaviour towards its staff.

Its available actions are listed together: reduce the certificate allocation, downgrade to a B-rating, suspend, revoke, cancel the sponsored workers' permission, and report suspected crime to the police or other authorities.

Downgrade to a B-rating and the action plan

For relatively minor breaches that can be put right, the Home Office may downgrade an A-rated licence to a B-rating. Before doing so it writes to explain what it proposes and why, and allows 20 working days to respond in writing; there is no oral hearing.

A downgrade has these effects:

  • no new workers can be sponsored until the A-rating is restored, though certificates can still be assigned for workers already sponsored who need to extend;
  • the sponsor must pay the action plan fee of £1,579 within 10 working days, or the licence is revoked;
  • the plan lasts a fixed 3 months, after which a compliance check decides between revocation, a second plan with a new fee, or restoring the A-rating;
  • no branches or new routes can be added during the plan.

A sponsor can only be B-rated twice in a rolling four-year period. A third occasion leads to revocation. Using a certificate to sponsor a new worker while B-rated is itself a ground for revocation. A sponsor with no workers can choose to surrender instead of paying.

The Part 3 annexes list the grounds. Annex C2, "normally revoke", includes failing to carry out sponsor duties, lacking the systems to do so, failing to co-operate with a compliance check, giving false information, failing to supply required documents on time, paying a sponsored worker in cash, and asking a worker to pay the Immigration Skills Charge.

Suspension and revocation

The Home Office may suspend a licence while it investigates. A suspended sponsor cannot assign certificates and is removed from the public register, but must keep complying with its duties. Workers who already hold valid permission are not affected unless the licence is later revoked. A worker's pending application on a certificate assigned before the suspension, or a settlement application the sponsor supports, is not decided until the suspension is resolved. The sponsor has 20 working days to respond in writing.

The mandatory revocation grounds in Annex C1 include knowingly false information in the application, an unspent conviction for a relevant offence, no longer having a trading presence, losing a required registration or licence, a worker in a role that does not match the certificate, a sponsor-assigned certificate for the user's own relative or partner, and failing an action plan.

Revocation takes effect in all routes. The paragraph C10.3 position is that there is no right of appeal and the sponsor cannot reapply for at least 12 months (24 months after more than one revocation). The licence-holder's certificates become invalid, and the sponsored workers' permission is normally shortened. The guidance says that where a worker was not involved in the reason, their permission is normally cut to 60 calendar days, after which they must have applied for permission on a route they qualify for or leave. Where the Home Office believes the worker was complicit, it will normally cancel all remaining permission.

Finding a regulated adviser

Sponsors facing a compliance check, a downgrade proposal or a suspension letter have short response deadlines, often 20 working days, and a response should be in writing with supporting evidence. Workers affected by a sponsor's problems have separate options. GOV.UK sets out how to find an immigration adviser and what regulated advisers can do.

The Migratio directory lists IAA-registered advisers (with their level) and SRA-regulated solicitors, each with their regulator and registration number. Migratio is not regulated by the IAA or the SRA and does not give immigration advice. This page explains how the rules work; it does not tell you what to do in your case.

Questions people ask

How quickly must a sponsor report changes to a worker?

Within 10 working days of the event, unless the guidance says otherwise. Examples are a worker not starting within 28 days, being absent for more than 10 consecutive working days, a pay cut, a change of work location or the sponsor stopping sponsorship.

How long does a sponsor have to report changes to its business?

Generally 20 working days from becoming aware of the change, except when replacing the Authorising Officer or Key Contact. This covers address and name changes, new branches, insolvency, takeovers, and a change in size or charitable status.

Can UKVI visit a sponsor without notice?

Yes. The guidance says compliance checks can be announced or unannounced, including at any address where sponsored workers work. The sponsor must allow staff access on demand and make sure any third-party site cooperates.

What does a B-rating mean for a sponsor?

The sponsor cannot sponsor new workers until the A-rating is restored. It must pay a £1,579 action plan fee within 10 working days and complete a 3-month plan. A sponsor can be B-rated only twice in a rolling four-year period.

Can a revoked sponsor licence be appealed?

No. The guidance says there is no right of appeal against revocation, and the sponsor cannot reapply for at least 12 months, or 24 months after more than one revocation. Sponsored workers normally have their permission shortened to 60 calendar days.

Sources

Last checked 2026-10-10.

Related guides

  • Applying for a sponsor licence: steps and documents — An employer applies online, then must email a signed submission sheet and the required documents within 5 working days. The Home Office checks the business is genuine, trading and able to meet its duties. There is no right of appeal against a refusal, and a six-month cooling-off period usually follows.
  • Sponsor licence cost for employers in 2026 — A UK sponsor licence for the Worker routes costs £611 for a small or charitable sponsor and £1,682 for a medium or large one. Each Skilled Worker certificate of sponsorship then costs £525, plus the Immigration Skills Charge, which the employer must pay and may not recover from the worker.
  • Sponsor licence revoked: what it means for your visa — If your sponsor loses its licence, the Immigration Rules say your permission may be cancelled. Home Office guidance says that where you were not involved, cancellation normally leaves you 60 days to apply for permission with a new sponsor or to leave. There is no appeal or administrative review against cancellation. A temporary arrangement currently protects care workers.
  • Exploited by your sponsor: the October 2026 Skilled Worker change — From October 2026 a new Skilled Worker rule (SW 18.3) lets the Home Office amend the work conditions of a Skilled Worker who has a positive Conclusive Grounds decision from the National Referral Mechanism, so they can do any work for the rest of their permission. It is discretionary, it does not lengthen the visa and it does not give access to public funds.
  • Medium-skilled jobs after July 2025: the ISL and TSL — Since 22 July 2025 the Skilled Worker route is open to degree-level jobs, plus mid-level jobs only if they are on the Immigration Salary List or the Temporary Shortage List, or if the worker already held permission before that date. Both lists have a cut-off date for new certificates.
  • Who can represent you at an immigration appeal — At the First-tier Tribunal (Immigration and Asylum Chamber) you can be represented by anyone not prohibited by section 84 of the Immigration and Asylum Act 1999: in practice a Level 3 IAA-registered adviser, a solicitor, a barrister or another authorised lawyer. You can also represent yourself. Judicial review in the Upper Tribunal needs a representative with rights of audience in the High Court.