Sponsor compliance · Reporting duties

Sponsor reporting duties: the 10-day and 20-day deadlines that decide whether your licence stays A-rated.

Direct answer

UK sponsors must report defined events through the Sponsor Management System (SMS). The Home Office uses two main deadlines: 10 working days for most worker-related changes (worker fails to start, worker is absent without permission for more than 10 working days, salary reduction, change of duties, change of work location), and 20 working days for most sponsor-organisation-level changes (significant change in the size or type of the organisation, branch additions, ownership or key personnel changes). Missing these deadlines is one of the most common causes of licence downgrade, suspension, or revocation.

Who this applies to: UK employers holding a sponsor licence — and the Authorising Officer, Key Contact, Level 1 User, or HR lead who is operationally responsible for keeping SMS up to date.

Regulated by the Immigration Advice Authority

Why this matters

Why reporting deadlines now matter more than they used to.

The end of the 4-year licence renewal cycle for standard Worker routes did not mean the end of compliance scrutiny — it means the Home Office now relies on continuous monitoring through SMS reporting and unannounced compliance visits instead. The reporting deadlines you meet (or miss) on a monthly basis are now the single most important signal of your licence health.

→SMS reporting is the Home Office's primary visibility into a sponsor between compliance visits

→Missed reports are routinely identified during visits — they form a documented compliance breach trail

→A pattern of late or missed reports is a leading cause of B-rating downgrades

→Repeated breaches can lead to licence suspension or revocation — outcomes that can stop sponsorship of every worker on the licence

→There is no automatic warning or grace period — the clock runs from the date of the event, not from when you remember to log in to SMS

The 10-day events

Worker events you must report within 10 working days.

Worker fails to start

Report through SMS within 10 working days after the 28-day post-CoS period in which the worker should have commenced employment.

10 working days

Worker absent without permission

Triggered when a worker is absent without sponsor permission for more than 10 consecutive working days.

10 working days

Absence without pay exceeding 4 weeks

Where a worker is on an unpaid absence longer than 4 weeks (other than statutory permitted absences).

10 working days

Salary reduction

Any reduction in the worker's salary, including reductions caused by reduced hours, must be reported.

10 working days

Change of duties / role

From the effective date of the change. Significant role changes may also require a change-of-employment application by the worker.

10 working days

Change of work location

Including moving the worker to a different registered branch of the sponsor.

10 working days

Worker leaves the sponsorship

Resignation, dismissal, end of contract, or any other cessation of the sponsored employment.

10 working days

Deadlines as set out in the Workers and Temporary Workers: Guidance for Sponsors at the time this page was last reviewed. Always verify against the current Home Office guidance before relying on a specific deadline.

The 20-day events

Sponsor-organisation events you must report within 20 working days.

Change in size or type of organisation

Any significant change — including changes that affect whether you qualify as a small/charitable sponsor or a medium/large sponsor for ISC purposes.

20 working days

Adding a new branch

Request a branch addition within 20 working days of the date a worker started working for that branch.

20 working days

Change of Authorising Officer

The Authorising Officer is the senior person ultimately accountable for sponsor compliance — changes must be reported promptly.

20 working days

Change of Key Contact or Level 1 User

The day-to-day SMS operators. Treat as a high-priority report — your SMS access depends on these being current.

20 working days

Change of company name, address, or ownership

Including mergers, acquisitions, sale of the business, and group restructures that change the sponsoring legal entity.

20 working days

Significant change to the nature of the business

For example, ceasing trading in the activity for which workers are sponsored, or a fundamental change of business model.

20 working days

Sponsor-level deadlines are set out in the Workers and Temporary Workers: Guidance for Sponsors. Some events also require supporting evidence and may trigger a fresh compliance review — take advice before reporting a major structural change.

Record-keeping

What you have to keep on file — and for how long.

Reporting through SMS is only half the duty. Sponsors must also keep a defined set of records for each sponsored worker, on file, retrievable on request. The detailed list is set out in Appendix D of the Workers and Temporary Workers: Guidance for Sponsors. The principles are simple — the practice is where most compliance failures sit.

→Worker-specific records for every sponsored worker — passport, visa, RTW check evidence, contact details, contract, attendance records, salary records

→Evidence of recruitment activity where this was required for the role

→Records must typically be kept while the sponsorship is in force and for a defined retention period after it ends (see Appendix D for the current retention rules)

→Records can be paper or digital — but they must be retrievable on request, including during an unannounced compliance visit

→A common compliance visit finding is that records exist but cannot be produced for the named worker within the visit window

Co-operation

The duty to co-operate with the Home Office.

Beyond the listed events, sponsors have a continuing duty to co-operate with the Home Office and its officials. This sits underneath every other duty and is its own breach if ignored.

→Respond to Home Office requests for information within the deadline they set

→Provide reasonable access for unannounced or pre-arranged compliance visits

→Make key personnel available for interview during a visit where reasonable

→Produce sponsor records on request — paper or digital — within the visit window

→Failure to co-operate is treated as a sponsor-duty breach in its own right, on top of any underlying issue

Consequences

What happens when reporting duties slip.

The Home Office uses a graduated set of responses. Most sponsors who run into a problem find it starts as a B-rating downgrade — but ratings can move fast in either direction once a compliance visit is in motion.

→A-rating — the default. Full ability to assign CoS on most routes.

→B-rating — restricted. You cannot assign CoS to new applicants and must complete a Home Office-approved action plan within a defined timeframe to get back to A-rated.

→Suspension — your sponsor licence is suspended pending Home Office investigation. CoS assignment is paused. Workers already in the UK are affected.

→Revocation — your sponsor licence is removed. Sponsored workers' permission to be in the UK is curtailed, typically with 60 days to find another sponsor or leave.

→Civil penalty — a separate financial penalty (currently up to £60,000 per illegal worker) where right-to-work breaches are identified during the same review.

→Scale-up Worker and Seasonal Worker sponsors can only assign CoS while A-rated — a B-rating effectively pauses sponsorship under these routes.

What goes wrong

The five reporting-duty mistakes we see most often.

→Treating the 10-day clock as starting when someone notices the event — it starts on the date of the event itself

→Reporting the easy events (start, end) and missing the medium ones (duty changes, location moves, salary changes that are not headline pay cuts)

→Letting SMS user access lapse when a Level 1 User leaves the business — meaning there is no one able to report the next event in time

→Keeping records but not being able to produce the named worker's file within the window of a compliance visit

→Assuming a compliance breach has been forgotten because no Home Office response has arrived — visits routinely surface 12-month-old reporting gaps

How Harveys helps

What we do for sponsors who want to keep the licence A-rated.

Sponsor reporting duties are the single most operational part of holding a licence — and the part most often handled by an HR generalist with too many other priorities. The Harveys Legal Audit-Ready Sponsor Compliance retainer is built around making sure these deadlines are not the thing that takes a licence down.

→Audit-Ready Sponsor Compliance retainer — monthly check-in covering recent reportable events, SMS hygiene, record-keeping spot-checks, from £295/month + VAT

→Sponsor compliance health-check — one-off diagnostic of your current reporting record, record-keeping, and SMS user setup

→Mock audit — structured pre-visit run-through of the records, users, and timeline a Home Office compliance officer will examine

→Suspension / revocation defence — urgent regulated response when an enforcement action has already started

→All work delivered under IAA Level 1 regulation — Regulation No. F202537009

Common questions

Questions employers ask us.

The 10-working-day window applies to most worker-related events — failure to start, unauthorised absence over 10 working days, salary reduction, change of duties, change of location, end of sponsorship. The 20-working-day window applies to most sponsor-organisation-level events — significant change in size or type of business, branch additions, change of Authorising Officer / Key Contact / Level 1 User, and change of company name, address, or ownership.

From the date of the event itself, not from the date someone in your business notices it. This is the single most common cause of late reports. If a worker leaves on a Wednesday, the 10-working-day clock starts on that Wednesday — not when the HR team gets round to processing the exit.

There is no automatic penalty or grace period. Missed reports are typically identified during a Home Office compliance visit or during a routine SMS check. A single late report rarely causes immediate enforcement action, but a pattern of late or missed reports is a leading cause of B-rating downgrade. Once a compliance visit is in motion, the Home Office can move quickly to suspension or revocation.

In the Workers and Temporary Workers: Guidance for Sponsors — Part 2 (general information on sponsoring a worker) and Part 3 (sponsor duties and compliance), with the record-keeping detail in Appendix D. These are the documents a Home Office compliance officer works from. We recommend you take advice before relying on any third-party summary, including this page.

Digital records are acceptable, but they must be retrievable on request — including during an unannounced compliance visit. A common visit finding is that records exist but cannot be produced for the named worker within the visit window, which is treated as a record-keeping failure in its own right.

Often, yes — but the recovery is on the Home Office's terms. A B-rated sponsor must complete a Home Office action plan within a defined timeframe and meet specific compliance milestones. Failure to recover within the action-plan period typically leads to revocation. Take regulated advice immediately if your licence is downgraded — this is a critical sponsor-licence event.

Related services & resources

IAA

Regulated immigration advice

Harveys Legal is regulated by the Immigration Advice Authority.

Firm Reg No. F202537009. Verify on the IAA register before engagement.

If you are not sure your reporting is current, find out before the Home Office does.

Book a consultation. We will walk through your last 12 months of reportable events, the state of your SMS user setup, and the most likely findings a compliance officer would surface today — and tell you plainly whether you need a one-off health-check or a monthly retainer. Harveys Legal supports immigration applications, sponsor compliance preparation and related legal processes. Final decisions remain with the Home Office or relevant decision-maker.

Book a Consultation →See our compliance retainer

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