Sponsor Licence Duties: Staying Compliant When You Employ Visa Workers

What does a sponsor licence let you do?

A sponsor licence lets a UK employer sponsor non-UK and non-Irish workers for jobs you cannot fill from the resident labour market. GOV.UK puts it plainly: "You'll usually need a sponsor licence to employ someone to work for you from outside the UK."

The most common route is the Skilled Worker visa. The Home Office describes it as allowing "UK-based employers to recruit overseas workers to fill a wide range of skilled vacancies in the UK." To sponsor someone on it, the job must sit at the right skill level, the worker must meet the English language requirement, and the salary has to clear the threshold. The general Skilled Worker salary floor is £41,700 a year or the going rate for the occupation, whichever is higher.

The licence itself is long-lived. Since 6 April 2024, the old four-yearly renewal application and fee no longer apply. A granted licence is now "valid indefinitely, unless we revoke it or you surrender it before then," with limited exceptions for the UK Expansion Worker and Scale-up routes. That removes one admin burden, but it does not reduce your day-to-day duties. An indefinite licence means open-ended compliance obligations, and the Home Office can check on you at any point.

What are the ongoing sponsor duties?

Holding a licence puts four broad duties on you, set out in the Home Office sponsor guidance (Part 3: sponsor duties and compliance). The guidance frames them around preventing abuse of immigration laws and monitoring compliance with the Immigration Rules.

First, record-keeping. You must keep specified documents for each sponsored worker. The guidance confirms "the documents can be kept in paper or electronic form," and Appendix D of the guidance lists what to retain and for how long.

Second, monitoring. You are expected to track your sponsored workers' attendance, contact details and immigration status, and to act when something changes.

Third, reporting. Changes get reported to the Home Office through the Sponsorship Management System (SMS), an online portal, within fixed deadlines covered in the next section.

Fourth, not employing anyone who has no right to work. That duty applies to sponsored and non-sponsored staff alike.

These duties exist precisely because the licence is granted on trust. The Home Office can run a compliance check "on an announced or an unannounced basis," so the records and processes need to be ready before anyone knocks, not assembled after.

What changes must you report on the SMS, and by when?

Reporting is where compliant-on-paper employers slip up, because the deadlines are short and the list is long. Two clocks run, depending on whether the change concerns a worker or your organisation.

For changes about a sponsored worker, you have 10 working days. The guidance says you must report changes to a sponsored worker's circumstances "within 10 working days of the relevant event occurring." That covers a worker who does not turn up for their first day, absences without permission, a job that ends early, a salary cut, or a change of work location.

For changes about your own organisation, the window is wider. The guidance states that, unless otherwise stated, you must report these changes "within 20 working days of the relevant event occurring." Think mergers, a change of address, or selling part of the business.

What is a Certificate of Sponsorship and how do you assign it?

A Certificate of Sponsorship (CoS) is the electronic record you assign to a worker so they can apply for their visa. It is not a paper certificate. It is a reference number generated through the SMS. The Skilled Worker guidance is direct: "You must assign a valid Certificate of Sponsorship to the worker for the job you wish to sponsor them for."

For the Skilled Worker route there are two kinds, and you need to know which you are dealing with. The guidance tells sponsors to "understand the difference between a 'Defined CoS' and an 'Undefined' CoS." A defined CoS is for someone applying from outside the UK and is requested case by case through the SMS. An undefined CoS covers workers already in the UK switching or extending, and comes from your annual allocation.

Assigning a CoS is not a formality. You are confirming the job is genuine, meets the skill and salary rules, and that you intend to employ that person on those terms. If a compliance check later shows the role did not match the CoS, that is a breach. Treat each CoS as a declaration you will have to stand behind.

Do you still need right to work checks for sponsored workers?

Yes. Sponsorship does not replace a right to work check. The sponsor guidance is explicit: you must carry out a right to work check on any worker you are sponsoring, "regardless of the nature of the employment relationship," and the check must happen before employment begins.

The check gives you a statutory excuse against a civil penalty. The illegal working Code of Practice states: "You will have a statutory excuse if you have correctly carried out the prescribed right to work checks before employment commences." You establish it one of three ways: a manual document check, identity verification through a certified Identity Service Provider, or the Home Office online checking service using the worker's share code.

There is a trap sponsored employers must not miss. A sponsored worker's permission is time-limited, so the statutory excuse is time-limited too. The Code requires repeat right to work checks for temporary permissions to retain the statutory excuse, which means a follow-up check before that permission expires. Miss the follow-up date and your statutory excuse lapses, even though the original check was perfect.

What happens if you get it wrong?

Two separate consequences run in parallel: losing your licence, and being fined for illegal working.

On the licence, the Home Office can suspend or revoke it. The sponsor guidance allows suspension where sponsors breach duties or pose a risk to immigration control, and revocation for serious breaches. Suspension is broad: "If your licence is suspended, it is suspended in all routes in which you are licensed." Revocation is harsh and final, with "no right of appeal." Lose the licence and your sponsored workers can lose their permission to stay.

On illegal working, the civil penalty bites whether the breach was deliberate or an administrative slip. Since 13 February 2024, the maximum is £45,000 per worker for a first breach and £60,000 per worker for repeat breaches within three years. The public GOV.UK page summarises this as a penalty of "up to £60,000 for each illegal worker." Knowingly employing someone without the right to work is a criminal offence on top: "You can be sent to jail for 5 years and have to pay an unlimited fine."

Where this advice has limits

This post covers the core duties that apply across the Worker and Temporary Worker sponsorship system, but it is not a substitute for the full guidance or legal advice.

The rules shift often. The Skilled Worker salary thresholds changed in 2025, and the sponsor guidance is reissued every few months. The Part 3 compliance guidance referenced here is version 05/26, published 20 May 2026, and the Skilled Worker guidance is version 04/26 from 8 April 2026. Always check the version date on GOV.UK before you rely on a figure, because a number that is right today can be superseded by a Statement of Changes.

Some duties also carry route-specific or job-specific detail this post does not cover, such as reduced salary thresholds for new entrants or PhD-relevant roles, and the genuineness and going-rate tests for particular occupation codes. If your situation is unusual, or you are facing a compliance visit, get advice from a qualified immigration adviser. I am a software engineer and founder, not an immigration adviser, and the authority here comes from the primary sources cited, not from me.