Sponsor licence compliance support is ongoing legal help for employers that already hold the right to hire overseas workers. Its purpose is to make sure the business reports changes through the Sponsorship Management System (SMS) on time, keeps the required records, pays sponsored workers at least the required minimum and is ready for a Home Office inspection at any moment. These duties decide whether a company keeps its licence and the ability to assign new certificates of sponsorship.
What sponsor licence compliance support is and why employers need it
A sponsor licence allows a UK business to assign certificates of sponsorship (CoS) and sponsor overseas workers for work visas, most often the Skilled Worker visa. Getting the licence is only the start. From the day it is granted, the business becomes a sponsor and takes on continuing duties to the Home Office: reporting changes, keeping records and monitoring the employment of every sponsored worker.
Since 6 April 2024, sponsors no longer need to renew their licence every four years: once granted, it remains valid for an indefinite period. For employers, this means there is no longer a formal “reset” every few years — compliance can be checked at any time, not only at renewal. The duties are set out in the official guidance Workers and Temporary Workers: guidance for sponsors, Part 3. The current version, 08/26, applies from 28 August 2026.
In practice, compliance support is most valuable for small and medium-sized businesses where sponsor duties sit with a director or a single HR manager. In larger groups, it often works as an independent audit: an outside adviser reviews internal processes and finds weak points before an inspector does. If a business is only planning to hire from abroad, the first step is to apply for a sponsor licence, with compliance support starting as soon as the licence is granted.
Benefits of seeking professional sponsor licence compliance support
- Tracking of SMS reporting deadlines for every worker and the business
- Audits of sponsored workers’ files against Appendix D requirements
- Checks of salaries against certificates of sponsorship and thresholds
- Right to work checks completed before each new worker starts
- Preparation of key personnel for interviews with Home Office officers
- Support with a downgraded rating, suspension or licence revocation
- Guidance on fees and the ban on passing sponsorship costs to workers
Each of these points rests on a specific sponsor duty from the Home Office guidance. Below is what the business is actually required to do and where breaches happen most often.
Sponsor duties: what the Home Office expects from employers
In short, a sponsor must report changes, keep records, recruit only for genuine roles suitable for sponsorship, pay at least the salary stated on the certificate and make sure workers comply with their visa conditions. The guidance for sponsors groups these duties into several areas, and a breach of any of them can lead to a downgraded rating, suspension or revocation of the licence.
Key sponsor licence requirements under current Home Office rules
- Reporting changes to sponsored workers to UKVI within 10 working days
- Reporting changes to the sponsoring business within 20 working days
- Record keeping for every sponsored worker in line with Appendix D
- Right to work checks completed before employment begins
- Payment of a salary no lower than the amount stated on the CoS
- Employment only in a role that matches the assigned occupation code
- No recovery from workers of fees that sponsors are barred from passing on
Responsibility for these duties lies with the key personnel the business appoints in the SMS. The Authorising Officer is a senior person responsible for the sponsor’s compliance overall. The Key Contact is the main point of contact for UKVI. Level 1 users work in the system day to day: they assign certificates, submit reports and update licence details. Problems with these roles are common in their own right — for example, when the Authorising Officer left the business long ago and nobody replaced them in the system.
Another core duty is to recruit only for genuine vacancies that are suitable for sponsorship. The worker’s job title and duties must match the occupation code on their certificate. If the actual work differs significantly from what was declared, the Home Office may treat this as a serious breach.
SMS reporting: which changes to report and when
The Sponsorship Management System (SMS) is the online system sponsors use to assign certificates and report changes to the Home Office. Most reports are tied to strict deadlines counted in working days, and missing a deadline is a breach in itself, even if nothing went wrong in substance.
| Event | Reporting deadline |
|---|---|
| The worker does not start work on the expected start date | 10 working days |
| Absence without the employer’s permission for more than 10 consecutive working days | 10 working days |
| Unpaid or reduced-pay leave of more than 4 weeks in a year | 10 working days |
| Salary reduced below the level stated on the CoS | 10 working days |
| Significant changes to duties or the normal place of work | 10 working days |
| The business stops sponsoring the worker | 10 working days |
| New Authorising Officer or Key Contact, change of address, name or branches | 20 working days |
| Merger, takeover, change of ownership or insolvency procedure | 20 working days |
Changes to the business’s details can take some time to process: according to GOV.UK, requests can take up to 18 weeks, while the priority service registers a change within 5 working days for £350. This matters when, for example, a business cannot assign an urgently needed certificate until a new Authorising Officer is in place.
In September 2026, the Home Office changed how sponsors access the SMS. Since 3 September 2026, multi-factor authentication has been mandatory for SMS users, and since 9 September 2026 sponsors can no longer add new Level 2 users, as this role is being phased out. Businesses that relied on Level 2 users for reporting should review who has access well in advance, so that reports continue to be submitted on time once older accounts are switched off.
Mandatory records: what to keep under Appendix D
The list of documents a sponsor must keep for each worker is set out in Appendix D to the sponsor guidance. The current version, 08/26, was published on 3 August 2026. Records can be kept on paper or electronically — what matters is that an officer can access them quickly.
The main groups of documents for each sponsored worker are:
- evidence of the right to work check, including the result of the online eVisa status check;
- recruitment records: job adverts showing the date of publication, and details of candidates and interviews where a formal labour market test was carried out;
- the employment contract, payslips and evidence of the amount and frequency of all salary payments;
- evidence of qualifications and professional registration where the role requires them;
- up-to-date contact details: UK address, personal email and phone number, and a history of changes;
- absence records.
Records must be kept for as long as the business sponsors the worker and then until the earlier of two dates: one year after sponsorship ends, or the date a compliance officer has examined and approved them. In practice, the most common gaps are missing copies of job adverts, outdated contact details and payslips that cannot be matched against the certificate.
A well-organised archive shortens inspections and reduces the risk of technical findings. That is why a records audit is usually the first step of compliance support: advisers check each worker’s file against Appendix D and draw up a list of missing documents.
Sponsor compliance
What sponsor licence compliance support includes
SMS reporting
Timely reports of worker and company changes
Staff file audits
Checking worker records against Appendix D
Salary checks
Matching pay to the CoS and salary thresholds
Inspection readiness
Mock audit and briefing for key personnel
The scope of support depends on the size of the business and the number of sponsored workers: one employer may only need a quarterly audit, while another needs an adviser who manages the SMS on an ongoing basis.
Salary requirements for sponsored workers
Pay is one of the most closely checked areas. For the Skilled Worker visa, the general threshold is £41,700 a year or the going rate for the occupation, whichever is higher. Lower salaries are allowed for some groups of applicants, as set out on the Skilled Worker visa page on GOV.UK. Employers must also comply with national minimum wage law.
A sponsor must pay the worker at least the amount stated on the certificate of sponsorship. If the salary goes down — for example, because hours are cut or the worker moves to a different role — this must be reported through the SMS within 10 working days. Pay rises generally do not need to be reported. Importantly, a reduction below the threshold that applies to the worker can call into question whether they still meet the requirements of their visa.
Salary checks go beyond the figure in the contract. An officer compares payslips, bank payments and PAYE records, and the Home Office may work with HMRC to check compliance with the minimum wage. If payroll is run by an external accountant, their figures need to match the terms of the certificates. Bringing these processes together is easier when accounting and payroll services sit with the same team that handles the immigration side.
Home Office inspections: how to prepare for a compliance visit
The Home Office carries out compliance checks both with and without prior notice. A check may take place at the business’s premises or remotely, including by video call. Officers compare the information from the licence application with the actual situation, review records, interview sponsored workers and other staff, and may take photographs of the workplace.
The best approach is to prepare as if an officer were arriving tomorrow:
- update the list of key personnel in the SMS and make sure they understand their duties;
- gather files for all sponsored workers in line with Appendix D;
- check actual duties and salaries against the certificates;
- confirm that every report in recent months was submitted on time;
- prepare workers for questions about their role, working hours and place of work.
Right to work checks are a separate risk. They must be carried out before each worker starts, whatever the employment arrangement. Employing someone without the right to work can lead to a civil penalty of up to £60,000 for each illegal worker, according to GOV.UK, and for a sponsor it is also grounds for revoking the licence.
Licence ratings, downgrades, suspension and revocation
A new licence is granted with an A-rating, which allows the business to assign certificates of sponsorship. If the business stops meeting its sponsor duties, the Home Office may downgrade it to a B-rating. While the B-rating is in place, no new certificates can be assigned, and the business must complete a paid action plan lasting no more than 3 months. The fee must be paid within 10 working days of being told about the downgrade.
According to the GOV.UK page on licence ratings, a business can only have 2 B-ratings while its licence is valid. If problems remain after the second action plan, the licence is revoked. For serious breaches, the Home Office may suspend or revoke the licence straight away, without an interim downgrade.
There is no right of appeal against revocation, and a new application can only be made after at least 12 months. For a business that relies on overseas workers, this means not only a pause in hiring but also the need to deal with existing staff: their permission to stay is usually cut short, and they have to find a new sponsor or switch to another visa. That is why a suspension letter needs a response within days, not at the end of the deadline.
Common sponsor mistakes
Most Home Office findings stem not from deliberate breaches but from routine oversights that build up over the years. Typical situations include:
- a change of office address or a new branch was never reported;
- a worker was moved to a different role or city, but the SMS was not updated;
- pay was reduced during a quiet period and not reported in time;
- the Authorising Officer left and no replacement was appointed in the system;
- the cost of the certificate of sponsorship or the Immigration Skills Charge was deducted from the worker’s pay, even though passing it on is prohibited;
- worker files lack copies of job adverts and evidence of the right to work check.
Each of these mistakes is easy to fix early and hard to explain to an officer after the fact. Regularly comparing SMS data with the real staffing picture closes most of these risks before an inspection.
A consultation is a convenient starting point, but compliance support itself is built step by step, from an initial audit to ongoing help.
How sponsor licence compliance support works: 5 stages
Support follows a cycle: first an assessment of the licence’s current state, then closing the gaps, and after that regular monitoring and inspection preparation.
Initial consultation and licence health check
Document audit and closing compliance gaps
Ongoing SMS reporting and deadline control
Preparing the business for a Home Office visit
Support with new hires and business changes
How long the first two stages take depends on the number of workers and the state of the records. From the third stage onwards, compliance support works as a permanent function of the business that does not have to be restarted each time.
Costs and timescales: government fees for sponsors
The cost of compliance support is calculated individually and depends on the number of sponsored workers and the scope of work. Government fees are paid separately and are set by the Home Office. The main amounts according to GOV.UK at the time of publication are shown below.
| Fee | Small or charitable sponsor | Medium or large sponsor |
|---|---|---|
| Sponsor licence (Worker) | £611 | £1,682 |
| Certificate of sponsorship (Worker) | £525 | £525 |
| Immigration Skills Charge — first 12 months | £480 | £1,320 |
| Immigration Skills Charge — each additional 6 months | £240 | £660 |
The figures come from the GOV.UK pages on applying for a licence, certificates of sponsorship and the Immigration Skills Charge. Most licence applications are decided in under 8 weeks. An extra £750 buys a decision within 10 working days, but places on the priority service are limited.
When planning a budget, it is worth considering indirect costs too: staff time spent preparing for an inspection and, in the worst case, the action plan fee after a downgrade and a pause in hiring. Compared with these losses, regular compliance support usually costs less.
Practical examples: how compliance gaps affect a business
A typical scenario: a restaurant group sponsors several chefs. One of them moves to another restaurant in the same group in a neighbouring town, but nobody reports the change of work location. During an inspection, the officer cannot find the worker at the address on the certificate, and the business has to explain why the SMS data does not match reality.
Another example is an IT company whose director changed. The former director was the Authorising Officer, and after they left the role formally remained empty. When the company needed to assign a certificate to a new specialist urgently, it turned out that the key personnel had to be updated first, which takes time. In both cases, the problem could have been prevented by simple regular checks.
Similar situations come up in Imperial & Legal’s work. Below are real stories of employers and workers who needed help with a sponsor licence after inspections and changes in the business.
Related client stories
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Many employers seek support as early as the licence application — and that is when the habits that later help them pass inspections are formed. One client explained why he chose not to work through the requirements alone.
My business was expanding, so I needed additional staff. One of them was a foreign student studying at a British university. It turned out I had to register as a sponsor to employ him. I got in touch with Imperial & Legal. Their qualified specialists explained to me how to go about it and helped me prepare the necessary documents and obtain my sponsorship licence with a fast-track option.
If a business not only hires directly but also transfers staff from overseas parts of its group, sponsor duties apply to those routes as well — see the overview of Global Business Mobility visas for more detail.
How to keep a sponsor licence in the long term
An indefinite licence changes how sponsorship works: compliance becomes an ongoing process rather than preparation for renewal. The main points:
Key takeaways
- report changes to workers within 10 working days and changes to the business within 20 working days;
- keep Appendix D records throughout sponsorship and after it ends;
- pay at least the amount stated on the certificate and report any salary reduction;
- check the right to work before each worker starts;
- keep key personnel and SMS access up to date following the September 2026 changes;
- remember that a B-rating can only be given twice, and after revocation a new application is possible only after 12 months.
This page is for general information only and does not constitute individual legal advice. Home Office requirements are updated regularly, so decisions in a specific case should take into account the current version of the guidance and the business’s circumstances.
