Answer · Sponsor duties

What are sponsor duties for UK employers?

Direct answer

Sponsor duties are the ongoing legal responsibilities a licensed UK sponsor must meet throughout the life of its sponsor licence. They cover four main areas: keeping records of sponsored workers, reporting specific changes to the Home Office through the Sponsorship Management System (SMS), monitoring sponsored workers' attendance and compliance with their visa conditions, and ensuring the right people inside the business — Authorising Officer, Key Contact, and Level 1 User — carry out their roles properly. Failure to meet these duties can lead to licence downgrade, suspension, or revocation.

Who this applies to: UK employers with an active sponsor licence, HR and operations teams responsible for sponsored worker administration, and key personnel named on the licence.

Regulated by the Immigration Advice Authority

Duty 1 — Record keeping

What records sponsors must keep.

Sponsors must maintain accurate, up-to-date records for every sponsored worker. The records must be available for inspection by the Home Office, in a format that can be retrieved quickly during a compliance visit.

→Right to work checks — completed before employment begins, retained for duration of employment plus 2 years

→Contact details — current UK address, telephone number, and personal email

→Contract of employment or written terms of engagement

→Job description, salary, hours, and work location records

→Attendance and absence records — including unauthorised absences

→Records of any changes in role, salary, location, or other material details

→Records of recruitment activity (where applicable for resident labour evidence)

Duty 2 — Reporting

What sponsors must report to the Home Office.

Certain changes must be reported through the SMS within 10 working days. Late or missed reporting is a common compliance failure.

→Sponsored worker does not start their role on the agreed date

→Sponsored worker is absent without authorisation for 10 or more consecutive working days

→Sponsored worker's employment ends (resignation, termination, end of contract)

→Material change in the worker's role, salary, working hours, or work location

→Changes to the sponsor organisation — ownership, structure, key personnel, contact details

→Suspected breach of visa conditions by the sponsored worker

→Significant changes to the business that may affect the genuine vacancy assessment

Duty 3 — Monitoring

Active monitoring of sponsored workers.

Sponsors must actively monitor their sponsored workers — not just employ them. Monitoring is what allows the sponsor to identify reportable issues and meet their duty to the Home Office.

→Confirming sponsored workers are actually carrying out the sponsored role on the sponsored terms

→Tracking attendance and identifying patterns of unauthorised absence

→Confirming workers continue to hold the right to work and visa conditions are met

→Monitoring salary payments to ensure they meet the agreed CoS salary

→Reviewing role changes that could affect sponsorship (promotion, restructure, location change)

→Ensuring sponsored workers are not being used as a workaround for non-genuine roles

Duty 4 — Key personnel

Who is responsible inside the organisation.

Every sponsor licence requires named individuals to take on specific roles. These roles cannot be ceremonial — the Home Office expects each person to know their duties and carry them out.

→Authorising Officer — most senior person responsible for the licence. Must be a UK-based employee or office holder. Accountable for compliance overall.

→Key Contact — main point of contact between the sponsor and the Home Office. Often the same person as the Authorising Officer in smaller organisations.

→Level 1 User — operates the SMS day-to-day. Assigns CoS, makes reports, manages worker records. Must be a UK-based employee.

→Level 2 User (optional) — restricted SMS access, useful where multiple people need access without the ability to assign CoS.

→All key personnel must be vetted before being named on the licence — including criminal record and immigration history checks.

What goes wrong

Most common sponsor duty failures.

→No clear ownership inside the business — assumed to be HR, but no one is actively running it

→Records stored across multiple systems, formats, or individuals — slow or impossible to retrieve during a visit

→Reports made late or missed entirely — most often role and salary changes

→Salary paid below the CoS rate after a pay restructure, without amendment or report

→Key personnel changes (e.g. Level 1 User leaves the company) not updated on SMS

→Worker continues sponsored role on paper while actually doing something materially different

Why this matters

What happens if duties are not met.

The Home Office can take a range of compliance actions depending on the severity of the failure. Not all action is graduated — serious or repeated breaches can lead straight to revocation.

→Action plan — formal requirement to fix specific issues within a set period (often 3 months)

→Licence downgrade from A-rating to B-rating — restricts ability to issue new CoS until remediated

→Licence suspension — pauses all sponsorship activity while the Home Office investigates

→Licence revocation — complete loss of sponsorship rights, affecting existing sponsored workers

→Cooling-off period before reapplication is possible (typically 12 months minimum)

Common questions

Questions employers ask us.

The Authorising Officer is the most senior individual named on the licence and is ultimately responsible. However, in practice, day-to-day compliance is usually carried out by HR or operations teams under the AO's oversight. Responsibility cannot be delegated to a third party — it stays with the sponsor.

Some duties continue beyond the end of the worker's visa — for example, retaining right to work and HR records for the required period after employment ends. Record retention is typically 2 years from the end of sponsorship.

Operational support for compliance can be provided by external advisers (such as Harveys Legal), but the legal responsibility remains with the sponsor. The Home Office holds the sponsor — not the adviser — accountable for breaches.

Through compliance visits — both announced and unannounced. Inspectors review records, interview key personnel, observe operations, and check that what is documented matches what is happening in practice.

Ongoing — not annually. Compliance is a continuous responsibility, not a periodic project. Most sponsors benefit from quarterly internal reviews and ongoing advisory support, particularly when growing the sponsored workforce.

Related services & resources

Need help meeting sponsor duties day to day?

Book a consultation. We will review your current compliance setup, identify where duties are at risk of slipping, and put practical processes in place to keep your licence secure.

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Harveys Legal supports immigration applications, sponsor compliance preparation and related legal processes. Final decisions remain with the Home Office or the relevant decision-maker.