Employer Responsibilities When Sponsoring Workers
Holding a sponsor licence comes with significant obligations. Employers must maintain records, report changes, and ensure compliance. Failure to meet these responsibilities can result in licence revocation, affecting all sponsored workers. This guide covers the key duties.
- Section
- Employers & Sponsors
- Reading time
- 9 min
- Last checked
- 14 February 2026
- Source
- The published Immigration Rules and GOV.UK guidance, linked throughout this guide.
- Rowan does not
- Look at your own case, tell you which route to choose, or say what the Home Office will decide. This guide shows the published rules and where to read them.
In short
- 10 working days to report a change affecting a worker; 20 for a change to the organisation.
- The right to work check happens before the worker starts, and cannot use a biometric residence permit.
- Keep a sponsored worker's documents throughout sponsorship and for a year after it ends.
- A B-rating means a £1,579 action plan, payable within 10 working days, running for 3 months.
- Revocation shortens the permission of every worker being sponsored, normally to 60 days.
A sponsor keeps records, reports changes on a deadline, checks the right to work before employment starts, and cooperates with compliance visits. The deadlines are 10 working days for a change affecting a worker and 20 for a change to the organisation. Failing them can mean a B-rating, which costs £1,579 for an action plan, or revocation, which shortens the permission of every worker being sponsored.
The Sponsor Licence Framework
A sponsor licence carries duties in four groups: preventing illegal working, keeping records, reporting changes on a deadline, and monitoring that sponsored workers keep to the conditions of their permission. Since 6 April 2024 a licence does not expire and does not need renewing; it stays valid, in GOV.UK’s words, “as long as you continue to meet the eligibility requirements”. A licence to sponsor Scale-up Workers or UK Expansion Workers is the exception, lasting 4 years.
Record-Keeping Duties
Appendix D of the sponsor guidance lists what a sponsor keeps for each sponsored worker:
- Evidence of the right to work check. In most cases that is an online check using the worker’s share code — biometric residence permits and cards can no longer be accepted
- A copy of the worker’s passport or travel document, and evidence of their date of entry where you sponsored their entry clearance application
- Up-to-date contact details: address, telephone number, email
- Attendance and absence records
- The employment contract, with terms matching the certificate of sponsorship
- The worker’s National Insurance number
Appendix D sets the retention period: documents relating to a sponsored worker are kept throughout the sponsorship and until whichever comes first — one year after the sponsorship ended, or the date a compliance officer has examined and approved them. Right to work evidence is kept longer for illegal-working purposes: the whole of the employment and 2 years after it ends. The documents supplied with the licence application are kept for as long as the licence is held.
Reporting Duties
Reports go through the sponsorship management system. Within 10 working days, for a change affecting a worker:
- The worker has not started the job within 28 days of the start date on their certificate of sponsorship
- Sponsorship has stopped, for any reason
- The worker has been absent from work without your permission for more than 10 consecutive working days
- The worker has been absent without pay, or on reduced pay, for more than 4 weeks in total in any calendar year
- The job title, core duties, work location or salary has changed
- You know or suspect the worker is not complying with the conditions of their permission
Within 20 working days, for a change to your own organisation: GOV.UK says “You must report any significant changes in your own circumstances within 20 working days” — key personnel, address, structure, a new branch, insolvency, a merger or takeover.
The worker’s contact details are a record-keeping duty rather than a reporting one: they must be current in your files, not reported each time they change.
Compliance Visits
The Home Office conducts compliance visits to sponsor premises. They may be arranged in advance or unannounced, and they can happen before a licence is granted as well as after. What an officer looks at is the material the duties require:
- The Appendix D records for each sponsored worker, which the guidance says you “must be able to make available to us on request”
- Whether sponsored workers are doing the job described on their certificate, at the work location it names
- Whether the HR systems behind the reporting duties actually work
- The key personnel, who may be interviewed
Consequences of Non-Compliance
- B-rating and an action plan. The licence is downgraded and an action plan is issued. It costs £1,579, payable within 10 working days of the Home Office giving notice of the downgrade, and runs for a fixed 3 months. Not paying means losing the licence. While B-rated, a sponsor cannot assign certificates to sponsor new workers, though it can still assign them to workers it already employs who are extending their permission
- A limit on second chances. A sponsor can be B-rated twice in any 4-year rolling period. A third time and the licence is revoked rather than downgraded
- Revocation. The licence ends and the Home Office shortens the permission of every worker being sponsored, normally to 60 calendar days
- Civil penalties: Fines for employing workers illegally. See our civil penalty guide
For Workers
If your employer loses their licence, your visa may be curtailed. See our guides on the 60-day rule and curtailment of leave. For more on employer duties, see our sponsor duties guide and CoS assigning guide.
What the Guidance Requires You to Have in Place
- Named key personnel. One authorising officer, one key contact, and at least one Level 1 User. The key contact has no system access unless also appointed a Level 1 User
- Records you can produce on request. Appendix D allows paper or electronic storage, but says you must be able to make the documents available to the Home Office on request
- A way of meeting the deadlines. The duties are measured in working days from the event: 10 for a worker, 20 for the organisation
- Current system user details. Multi-factor authentication became mandatory on 3 September 2026, and the guidance says a licence may be at risk if user details are not kept up to date
Further Resources
For the full sponsor guidance, visit GOV.UK. See also our guides on employing EU nationals, CoS fees, and right to work.
You may also find our UK Visa Fees: Complete Guide andImmigration Health Surcharge helpful.
Questions and answers
What are the main responsibilities of a sponsor employer?
Sponsors must keep accurate records of sponsored workers, report changes to UKVI (such as workers leaving or changes in job details), ensure workers comply with their visa conditions, conduct right-to-work checks, and cooperate with Home Office compliance visits. Failure to meet these responsibilities can result in licence downgrade or revocation.
What must employers report to the Home Office?
A change affecting a worker goes in within 10 working days: not starting the job within 28 days of the start date, an absence from work without permission of more than 10 consecutive working days, absence without pay or on reduced pay of more than 4 weeks in total in a calendar year, sponsorship ending, and changes to the role, work location or salary. A change to the organisation itself goes in within 20 working days.
What happens during a Home Office compliance visit?
A compliance officer visits your premises to check that you are meeting your sponsor duties. They review records, interview staff, check that sponsored workers are performing the roles described in their CoS, and verify your HR processes. Visits may be announced or unannounced.
Can an employer lose their sponsor licence?
Yes. Licences can be downgraded (from A-rating to B-rating) or revoked entirely for serious breaches. This affects all sponsored workers, who may have their visas curtailed. Common reasons include failure to report, employing workers in different roles than their CoS states, and failure to maintain records.
This guide is general information about published immigration rules. It is not advice about an individual application under s.82 Immigration and Asylum Act 1999, and Rowan is not regulated by the Immigration Advice Authority. Immigration rules change several times a year. For advice on a particular situation, contact an adviser authorised by the Immigration Advice Authority or an immigration solicitor. Always check GOV.UK for the authoritative current rules.