Rowan

Employer Sponsor Duties: A Complete Checklist

This guide provides a practical checklist of every duty a sponsor employer must fulfil. Use it as a reference to ensure your organisation stays compliant and protects your sponsor licence.

Checked 14 February 20268 min readWritten by the Rowan Editorial Team
Section
Employers & Sponsors
Reading time
8 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

  • Four core duties: monitor, record, report, and prevent illegal employment.
  • The right to work check comes before the first day of work, not on it.
  • 10 working days to report a change affecting a worker; 20 for a change to the organisation.
  • Sponsor licences stopped needing renewal on 6 April 2024 — except Scale-up and UK Expansion Worker licences, which last 4 years.
  • Keep a sponsored worker's documents throughout sponsorship and for a year after it ends.

A sponsor must monitor the workers it sponsors, keep records, report changes and prevent illegal working. The deadlines are what the duties turn on: the right to work check before the first day of work, 10 working days to report a change affecting a worker, and 20 working days for a change to the organisation. Since 6 April 2024 there is no licence renewal to remember.

Before Sponsoring a Worker

  • Ensure your sponsor licence is active and A-rated
  • Check the role against the skill rule. Since 22 July 2025 a new Skilled Worker application must be for a job at skill level RQF 6. A job at RQF 3 to 5 is only sponsorable if the occupation code is on the Immigration Salary List or the Temporary Shortage List, and a Temporary Shortage List role cannot bring dependants
  • Check the salary against both tests: £41,700 a year or the going rate for the occupation code, whichever is higher, with a lower threshold of £33,400 in defined cases
  • Satisfy yourself the vacancy is genuine
  • Assign a CoS with accurate details
  • Pay the fees — £525 for a certificate on a Worker licence, £55 on a Temporary Worker licence, plus the immigration skills charge. None of these may be recovered from the worker

When the Worker Arrives

  • Do the right to work check before their first day of work. Appendix D of the sponsor guidance says the check “must be carried out before the worker starts working for you”. A check made after work has begun gives no statutory excuse
  • In most cases that means an online check using the worker’s share code. Biometric residence permits and cards can no longer be accepted
  • Record the check, and the worker’s date of entry to the UK where you sponsored their entry clearance application
  • Report it if the worker has not started within 28 days of the start date on the certificate of sponsorship
  • Note when their permission ends, so the follow-up right to work check is not missed

During Employment

  • Report an absence from work without your permission of more than 10 consecutive working days, within 10 working days
  • Report absence without pay, or on reduced pay, of more than 4 weeks in total in any calendar year, within 10 working days
  • Report a change to the job duties, title, work location or salary, within 10 working days
  • Keep records updated and available on request
  • Do the follow-up right to work check before the current permission expires
  • Cooperate with any Home Office compliance visit

When Employment Ends

  • Report the worker's departure to UKVI within 10 working days
  • Record the leave date and reason
  • Keep the worker’s documents until a year after the sponsorship ended, or until a compliance officer has examined and approved them, whichever comes first. Right to work evidence is kept longer: the whole of the employment and 2 years after it ends
  • Understand the impact on the worker's visa (60-day rule)

Licence Maintenance

There is no renewal to diarise. The requirement to renew a sponsor licence was removed on 6 April 2024, and GOV.UK now says a licence “usually stays valid as long as you continue to meet the eligibility requirements”. The exception is a licence to sponsor Scale-up Workers or UK Expansion Workers, which lasts 4 years and cannot be renewed. What is left:

  • Report a change to your key personnel — the authorising officer, key contact or a Level 1 User — within 20 working days
  • Report a change to the organisation within 20 working days: address, ownership, structure, a new branch, a merger or takeover, insolvency
  • Keep your system users’ contact details current. Multi-factor authentication became mandatory on 3 September 2026, and the sponsor guidance warns that a licence may be at risk if user details are not kept up to date
  • Convert or deactivate any Level 2 Users by 8 March 2027; the role closed to new appointments on 9 September 2026

Common Compliance Failures

  • Failing to report a worker leaving within 10 working days
  • Not keeping copies of required documents
  • Employing workers in roles different from their CoS
  • Paying below the stated salary without updating the CoS
  • Failing to monitor attendance

For more detail, see our guide on employer responsibilities. For penalties, see our guide on civil penalties. For information on hiring EU nationals, see our guide on employing EU nationals after Brexit.

Further Resources

For the full sponsor duties, visit GOV.UK. See also our guides on curtailment and right to work.

You may also find our UK Visa Fees: Complete Guide andImmigration Health Surcharge helpful.

Questions and answers

What are the four core sponsor duties?

The Home Office defines four categories of sponsor duties: monitoring immigration status and preventing illegal employment, maintaining accurate records, reporting changes to the Home Office, and ensuring sponsored workers comply with their visa conditions. All four must be met at all times.

Do I need to check if my sponsored worker is complying with their visa?

Yes. Sponsors have a duty to monitor compliance. This includes ensuring the worker is performing the role described in the CoS, is being paid the salary stated, and is not working hours that exceed any restrictions. If you become aware of non-compliance, you must report it.

What happens when a sponsored worker leaves?

Report the worker's departure to UKVI within 10 working days using the Sponsorship Management System. Include the leave date and reason. This is a mandatory reporting duty. Failure to report can result in compliance action against your licence.

How often must I renew my sponsor licence?

You do not. The requirement to renew a sponsor licence was removed on 6 April 2024. GOV.UK now says a licence "usually stays valid as long as you continue to meet the eligibility requirements". The one exception is a licence to sponsor Scale-up Workers or UK Expansion Workers, which is valid for 4 years and cannot be renewed.

When must the right to work check be done?

Before the worker starts working for you. Appendix D of the sponsor guidance says the checks "must be carried out before the worker starts working for you". A check made on the first day, once work has begun, does not give a statutory excuse against a civil penalty.

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.