What Are the Ongoing Compliance Duties?
Obtaining a sponsor licence is only the beginning. Once licensed, employers take on a continuing set of legal and administrative obligations to the Home Office. The Home Office treats sponsorship as a privilege and expects sponsors to play an active role in ensuring the immigration system is not abused. Compliance obligations fall into three broad categories: record-keeping duties, reporting duties, and cooperation duties.
What Records Must a Licensed Sponsor Keep?
- A copy of each sponsored worker's valid passport or travel document, including any visa or entry clearance
- The sponsored worker's National Insurance number (once obtained)
- Proof of the sponsored worker's current UK contact address
- A copy of their Biometric Residence Permit or eVisa status documentation
- A record of start date, contract, job title, and salary
- Evidence of any absences from work
- Records of right-to-work checks conducted on all employees
What Changes Must Be Reported to the Home Office?
Reports must be made via the Sponsorship Management System (SMS) within prescribed timeframes. Reporting obligations include: a sponsored worker not commencing employment or failing to attend within the first 10 working days (report within 10 working days); absence from work for more than 10 consecutive working days without authorisation; a change in salary, job title, or work location outside the terms of their CoS; employment being terminated for any reason; any significant change in the organisation's structure, ownership, or activities; and any criminal conviction affecting Key Personnel.
Consequences of Failing to Meet Compliance Duties
- Downgrade from A to B rating — restricts the ability to take on new sponsored workers until improvement measures are satisfied
- Suspension — prevents assigning new Certificates of Sponsorship while an investigation is conducted
- Revocation — all sponsored workers must find a new sponsor or leave the UK; a twelve-month bar on reapplying
- Civil penalties — up to £45,000 per worker for a first offence, £60,000 for repeat offences (2025)
- Criminal prosecution — in the most serious cases
What Is the Sponsorship Management System (SMS)?
The SMS is the Home Office's secure online portal through which sponsors manage all aspects of their licence — assigning Certificates of Sponsorship, reporting changes, updating organisational information, and monitoring the status of sponsored workers. The Level 1 User is responsible for day-to-day management. Access credentials must not be shared with unauthorised individuals.
Can Sponsor Licence Fees Be Passed to the Sponsored Worker?
No. Employers are explicitly prohibited from passing the cost of a sponsor licence, Certificate of Sponsorship, or Immigration Skills Charge to the sponsored worker — whether through salary deductions, contractual obligations, or loan arrangements. Doing so is a serious compliance breach and can result in licence revocation.