Home Office Sponsor Licence Holders: Reporting Duties

A Guide to Complying with Home Office Sponsor Duties for Employers

As a UK business holding a Home Office sponsor licence, you have critical responsibilities to ensure compliance with immigration laws. Among these is the duty to report specific changes or events to the Home Office via the Sponsor Management System (SMS). Failing to meet these requirements can lead to penalties, including suspension or revocation of your sponsor licence.

This guide provides an overview of reporting duties for sponsor licence holders, reflecting the latest Home Office requirements in 2025.

Reporting via the Sponsor Management System (SMS)

The Sponsor Management System (SMS) is the primary portal for communicating with the Home Office about your sponsorship activities. It’s where you update the Home Office about changes affecting your business or your sponsored employees.

Who is responsible?

  • The Authorising Officer, Key Contact, or an assigned Level 1 User must ensure reports are submitted accurately and on time.
  • Ensure key personnel are aware of their duties to maintain compliance.

Events to Report Within 10 Working Days

These events must be reported to the Home Office promptly to avoid non-compliance penalties.

Sponsored Employee Changes

  • Failure to Start Work:

    • The sponsored employee does not turn up for their first day.
    • Their start date is delayed by more than 28 days from the date stated on the Certificate of Sponsorship (CoS), visa approval notification or visa start date - whichever is the latter. 
  • Termination of Employment:

    • The worker resigns or is dismissed before the end date on their CoS.
    • Include the last known address and contact details.
  • Change in Job Role or Duties:

    • A change in job title, promotion, or core duties.
    • A new role falling under a different Standard Occupational Classification (SOC) code (a new CoS and visa application may be required).
  • Unauthorised Absence:

    • The worker is absent without permission for 10 consecutive working days or more.
  • Work Location Changes:

    • Any changes to the normal work location, such as moving to a different office or working from home (where applicable).
  • Salary Adjustments:

    • A reduction in salary below the amount stated on the CoS (excluding temporary reductions allowed under certain Home Office guidelines).

Sponsor Changes

  • Business Status:

    • If the business stops trading, becomes insolvent, or enters administration.
  • Key Personnel Changes:

    • Changes to the Authorising Officer, Key Contact, or other key personnel named on your sponsor licence.
  • Change in Trading Name:

    • Updates to your operating or trading name.

Events to Report Within 20 Working Days

Some events allow more time for reporting but are equally important to ensure compliance.

Sponsored Employee Changes

  • Transfer Under TUPE or Similar Arrangement:
    • If a sponsored worker is transferred to another sponsor due to a business reorganisation, such as a merger or acquisition.

Sponsor Changes

  • Mergers, Acquisitions, or Takeovers:

    • Full or partial takeovers, mergers, or acquisitions must be reported. Ensure details of the new ownership and the impact on sponsorship arrangements are included.
  • Change of Organisation Name:

    • Any updates to the legal name of your organisation.
  • Ceasing to Trade:

    • If the business permanently ceases trading, you must inform the Home Office.

Key Points to Remember

Accuracy is Critical: Always double-check the information before submitting reports. Errors can result in compliance breaches.

  • Timeliness Matters: Meeting the reporting deadlines (10 or 20 working days) is non-negotiable.
  • Documentation: Maintain thorough records of all reports submitted via the SMS. These may be required during a Home Office compliance audit.
  • Consequences of Non-Compliance
  • Failing to meet your reporting duties can have serious repercussions, including:

    • Suspension or revocation of your sponsor licence.
    • Civil penalties or fines.
    • Inability to sponsor new employees.

    Practical Tips for Compliance

    1. Assign Roles Clearly: Ensure that your Authorising Officer, Key Contact, and Level 1 Users are fully trained and understand their responsibilities.
    2. Monitor Changes Regularly: Establish processes to track changes affecting your business or sponsored employees.
    3. Use Technology: Consider software tools that help manage sponsorship duties and send reminders for reporting deadlines.
    4. Seek Professional Support: Engage with immigration specialists to audit your processes and ensure ongoing compliance.
  • Where to Find More Information

    The Home Office publishes detailed guidance for sponsor licence holders. Always refer to the most recent documentation to ensure compliance with evolving requirements.

    For additional support or advice, consider consulting experts in sponsor licence compliance to minimise risks and maintain your ability to hire international talent.

    Stay Compliant, Stay Confident

    Managing a Home Office sponsor licence can be complex, but our compliance experts are here to help. From reporting and updates to audits and comprehensive support, we ensure your business meets Home Office requirements at every step. Let us take the stress out of compliance—get in touch today to safeguard your sponsor licence.

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