Sponsor Licence Compliance: Duties and How to Stay Compliant

Overview of Sponsor Duties

When the Home Office grants a sponsor licence, the employer takes on duties that last as long as the licence does — which, since 6 April 2024, is indefinitely: a licence no longer expires and no longer needs renewing. GOV.UK says it “usually stays valid 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 and not renewable.

The duties fall into five main categories: record-keeping, reporting, right-to-work checks, cooperation with the Home Office, and general compliance with immigration law. The full guidance is published in the sponsor duties and compliance guidance on GOV.UK.

Record-Keeping Duties

You must maintain up-to-date records for every sponsored worker. The required records include:

• Evidence of the right to work check, made before the worker started. Appendix D says the check “must be carried out before the worker starts working for you”, and that in most cases it must be an online check using the share code
• A copy of the worker's passport or travel document — the pages showing identity details and any endorsement
• Evidence of the worker's date of entry to the UK, where you sponsored their entry clearance application
• Up-to-date contact details: current address, telephone number and email
• A record of attendance and absences
• A copy of the employment contract
• The worker's National Insurance number, where they have one

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.

Storage can be paper or electronic. What the guidance requires is that “you must be able to make them available to us on request”.

Reporting Duties

Sponsors must report certain events to the Home Office through the sponsorship management system. Reports must be made within specific timeframes:

Within 10 Working Days

• The worker has not started the job within 28 days of the start date on their certificate of sponsorship
• 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
• Sponsorship has stopped for any reason — resignation, dismissal, redundancy, the end of a fixed-term contract
• The worker's core duties, job title, salary or work location has changed
• You know or suspect the worker is breaching the conditions of their permission

Within 20 Working Days

• Changes to the sponsor's own details: name, address, ownership, structure, key personnel
• A merger, a takeover, or a new branch
• The sponsor ceasing to trade or becoming insolvent
• Anyone within the definition of ‘you’ being convicted of a relevant offence

GOV.UK puts the second deadline plainly: “You must report any significant changes in your own circumstances within 20 working days.” Both deadlines run from the event, not from the date you noticed it.

Right-to-Work Checks

The check comes before the worker starts. In most cases it is an online check using the share code the worker generates: GOV.UK says biometric residence permits and cards can no longer be accepted, and to ask for a share code instead. A share code is valid for 90 calendar days.

A sponsor owes this duty for anyone it sponsors, whether or not it employs them directly. Where the worker is employed by a related organisation, Appendix D says the sponsor must either obtain and keep a copy of that organisation’s check, or make its own.

A follow-up check is due before the worker’s permission expires. Where the excuse rests on a Positive Verification Notice from the Employer Checking Service, it lasts 6 months and the check is repeated on that cycle. The right-to-work checking guidance on GOV.UK provides the full process.

Compliance Visits

The Home Office can visit your premises at any time to check compliance. Visits may be:

• Pre-licence: Before the licence is granted, to verify the business is genuine
• Post-licence (announced): Scheduled in advance, giving you time to prepare
• Post-licence (unannounced): No advance warning, to see your day-to-day compliance

During a visit, the compliance officer will typically check your sponsored workers' files, interview key personnel, verify that workers are performing the roles described on their Certificates of Sponsorship, and inspect your HR systems and processes.

You must cooperate fully. Obstructing or refusing to cooperate with a visit is itself a ground for licence action.

Key Personnel

Every sponsor must appoint key personnel who are responsible for managing the licence:

• Authorising Officer: The most senior person responsible for the licence, typically a director or senior manager
• Key Contact: The main point of contact with the Home Office
• Level 1 User: the person who carries out the day-to-day activity in the sponsorship management system. There can be more than one, but only once the licence holds an A-rating

There can be only one authorising officer and one key contact at any time. The key contact has no system access unless also appointed a Level 1 User. The optional Level 2 User role closed to new appointments on 9 September 2026, and existing Level 2 Users must be converted to Level 1 Users, where eligible, or deactivated by 8 March 2027.

A change of key personnel is a change to the organisation, reportable within 20 working days. Multi-factor authentication became mandatory for system users on 3 September 2026, and the sponsor guidance warns: “You may lose your licence if you do not take action to check and update your SMS Users’ details.” See the licence requirements guide for more on personnel.

Building a Compliance System

The best way to meet your duties is to build systematic processes rather than relying on individual memory:

• Central filing: Maintain a dedicated file (physical or digital) for each sponsored worker containing all required documents
• Compliance calendar: track permission end dates, follow-up right to work check dates, and the working-day clocks on reporting. There is no licence renewal date to track
• Regular audits: Conduct internal audits of your sponsorship records at least quarterly
• Staff training: Ensure HR staff and managers understand their obligations
• Written policies: Document your compliance procedures so they survive staff changes

For small businesses, these systems can be simple. For larger organisations with many sponsored workers, dedicated immigration compliance software may be worthwhile.

Consequences of Non-Compliance

The Home Office has a range of responses to non-compliance:

• Downgrade to a B-rating, with an action plan. The two come together: the plan is what the downgrade obliges you to buy and follow. It costs £1,579, payable within 10 working days of the notification, and runs for a fixed 3 months, during which no new worker can be sponsored. Not paying means revocation. A sponsor can be B-rated twice in a rolling 4-year period; a third time is revocation. See our action plan guide.
• Suspension: no certificates can be assigned while the Home Office investigates, and the sponsor has 20 working days from the written notification to respond in writing. The guidance says there is no oral hearing. See our suspension guide.
• Revocation: the licence ends, and every sponsored worker's permission is shortened, normally to 60 calendar days. A cooling-off period of 12 months applies before a new licence application can succeed, or 24 months after a second revocation. See our revocation guide.

Next Steps

The duties above come from part 3 of the sponsor guidance and from Appendix D, which is the document a compliance officer works from.

Related guides:

• Sponsor Licence: Complete Guide
• Sponsorship Management System (SMS)
• Sponsor Licence Action Plan
• Sponsor Licence Revocation

Questions and answers