Sponsor Licence Management & SMS Support
Sponsor Licence Management · IAA-regulated advice in Birmingham and London
Managing your sponsor licence and the SMS
We help UK employers maintain sponsor licence compliance, meet immigration obligations, avoid penalties, and support smooth workforce operations.
Overview
What is Sponsor Licence Management?
Sponsor Licence Management refers to the ongoing compliance work required to keep a sponsor licence active and in good standing with the Home Office. Obtaining a licence is only the beginning. Once granted, your organisation assumes a range of legal duties including maintaining accurate records of sponsored workers, using the Sponsor Management System (SMS) correctly, reporting changes in worker circumstances within strict timeframes, and ensuring that Right to Work checks and recruitment practices meet UKVI requirements.
UKVI conducts compliance audits both remotely and on-site to assess whether sponsors are meeting these obligations. Failures identified during an audit can result in the licence being downgraded to B-rated status, suspended, or revoked, causing significant disruption to the business. V Immigration supports employers across all aspects of their sponsor duties—from day-to-day SMS management through to compliance health checks, staff training and keeping the licence in good standing.
Our Services
Key Sponsor Licence Management Services
Sponsor Management System (SMS) Support
We advise on navigating the SMS, assigning Certificates of Sponsorship, managing user roles, and acting as a Level 1 User if required.
Read moreCompliance Health Checks
We conduct structured reviews of your records, processes, and SMS history against UKVI compliance standards to address gaps before audits occur.
Read moreReporting Duties & Record Keeping
We assist HR teams in meeting their reporting duties within the 10-day window and maintaining systems that satisfy Appendix D requirements.
Read moreSide by side
Compare sponsor licence management duties
A summary of the main duties you take on as a licensed sponsor, when each one is due and where it is done. Check with us if you are unsure how a duty applies to your organisation.
Reporting changes for sponsored workers What it coversTelling UKVI when a worker does not start within 28 days, is absent without permission, has pay reduced, changes role or location, or sponsorship ends. Deadline or frequencyWithin 10 working days of the change, unless the guidance says otherwise Where it’s doneSMS, using the ‘Report migrant activity’ function Key points
- Absence without permission over 10 consecutive working days must be reported
- Report unpaid or reduced-pay absence over 4 weeks in a calendar year
- Suspected breach of visa conditions: tell UKVI as soon as reasonably practicable
Reporting changes to your organisation What it coversChanges such as a new address, new branches or sites, a merger or takeover, insolvency, a relevant conviction, or (for Worker sponsors) organisation size or charitable status. Deadline or frequencyUsually within 20 working days of becoming aware of the change Where it’s doneSMS; a change of circumstances form if no Level 1 User has access Key points
- Send the submission sheet and any documents within 5 working days
- A new owner without the right licence must apply within 20 working days
- Size or charitable status changes affect licence fees and the Immigration Skills Charge
Assigning certificates of sponsorship What it coversAssigning a certificate to each worker you sponsor, for a role that meets the route’s rules and matches the job they will actually do. Deadline or frequencyEach time you sponsor; the worker must apply within 3 months Where it’s doneSMS; defined certificates for overseas Skilled Workers need a separate request first Key points
- Fee: £525 per certificate on Worker routes, £55 on Temporary Worker routes*
- Skilled and Senior or Specialist Workers: Immigration Skills Charge is usually due too
- You must not pass the Immigration Skills Charge on to the worker
Record keeping (Appendix D) What it coversKeeping the documents listed in Appendix D for each sponsored worker, including right to work, recruitment, salary and absence records and contact details, and producing them on request. Deadline or frequencyDuring sponsorship and up to 1 year after it ends Where it’s doneInternal records, kept on paper or electronically Key points
- Retention ends earlier if a compliance officer examines and approves the records
- Keep your licence application documents for as long as you hold the licence
- Other laws, such as right to work rules, may need longer retention
Right to work checks What it coversChecking that every worker you sponsor or employ has the right to work in the UK and to do the work in question. Deadline or frequencyBefore work starts; repeat by the date time-limited permission ends Where it’s doneManual, online share code or digital provider check; copies kept internally Key points
- Civil penalties of up to £60,000 per illegal worker
- Keep copies for the length of employment plus 2 years
- From 1 October 2026, also covers many worker’s contracts and sub-contractors
Key Personnel and SMS users What it coversHaving an eligible Authorising Officer, a Key Contact and at least one Level 1 User, and keeping their details up to date. Deadline or frequencyAt all times for the Authorising Officer and a Level 1 User Where it’s doneSMS, by a Level 1 User; change of circumstances form if none Key points
- No new Level 2 Users can be appointed from 9 September 2026
- Upgrade or deactivate any existing Level 2 Users by 8 March 2027
- Without an Authorising Officer and Level 1 User, the licence will be revoked
Role, pay and co-operating with UKVI What it coversMaking sure sponsored workers do the job on their certificate, are paid correctly and hold any required registration, and co-operating with UKVI compliance checks. Deadline or frequencyOngoing; UKVI checks can be announced or unannounced Where it’s doneInternal HR systems; UKVI visits and regular HMRC pay checks Key points
- Working outside the certificate’s role or occupation code is a mandatory revocation ground
- You must give UKVI staff full access to your premises on demand
- Wider UK law applies too, including minimum wage and working time rules
*International Sportsperson certificates for 12 months or less cost £55. Fees are Home Office fees from 8 October 2026. Immigration Skills Charge figures are for small or charitable / medium or large sponsors, for the first 12 months.
Summary of the Immigration Rules and GOV.UK guidance as at 9 October 2026. Rules change often; this is general information, not advice on your case.
Eligibility
Sponsor Licence Management Eligibility Requirements
To maintain a valid Sponsor Licence, employers must satisfy strict compliance rules set by UKVI. Based on official guidelines, the main conditions include the following:
1. Sponsor Management System (SMS) & Reporting
The SMS is the central tool through which sponsors discharge many of their core duties and update corporate or worker information.
Core Obligations & Timeframes:
- Assign Certificates of Sponsorship (CoS), update organisational details, and respond to UKVI messages.
- At least one Level 1 User with full SMS access must be in place at all times.
- Sponsors must report changes in a sponsored worker’s circumstances within 10 working days:
- Significant changes to job title or core duties, or a reduction in salary
- Absence without permission for more than 10 consecutive working days
- Termination of employment or changes of work location
Compliance Risk: Errors in SMS management—including misclassifying CoS types or failing to report changes within the required window—are among the most common compliance failures identified during UKVI audits.
Record Keeping Requirements
Appendix D of the sponsor guidance sets out specific documents and information that sponsors must retain for each sponsored worker.
Required Documentation:
- Copies of passports and visa documentation.
- Evidence of compliant Right to Work checks.
- Up-to-date worker contact details.
- Company payslips and records of any absences.
Retention Policy: Records must generally be retained for one year after the sponsorship of the individual ends. UKVI expects to be able to access these records during a compliance visit.
Right to Work Checks
All UK employers—whether or not they hold a sponsor licence—are required to carry out Right to Work checks before employment begins.
Expected Procedures:
- Perform checks thoroughly before any employment or work activity starts.
- Maintain ongoing records during employment and repeat checks before existing documentation expires.
- Ensure clear copies are dated and saved securely in client HR files.
Statutory Excuse: Failure to conduct compliant Right to Work checks removes the statutory excuse against a civil penalty and constitutes a breach of sponsor duties.
Licence Validity & UKVI Audits
Licences are bounded by clear expiration timeframes and are subject to active verification by official inspectors.
Key Operational Indicators:
- Most sponsor licences stay valid for as long as you continue to meet the eligibility requirements, so there is no routine renewal. Scale-up and UK Expansion Worker licences are valid for 4 years, and another licence for those routes can’t be obtained.
- UKVI conducts both remote and on-site compliance visits to assess whether sponsors are meeting duties.
- During a visit, inspectors review SMS records, HR files, Right to Work check documents, and internal processes.
Enforcement Action: Where issues are identified, the licence may be downgraded to B-rated status—preventing the issue of new CoS—or suspended pending investigation.
All criteria above reflect official UKVI rules. Most sponsor licences stay valid for as long as you continue to meet the eligibility requirements, so there is no routine renewal. Scale-up and UK Expansion Worker licences are valid for 4 years, and another licence for those routes can’t be obtained. V Immigration helps clients keep their licence in good standing. Proactive internal compliance reviews significantly reduce the risk of adverse findings.
How we help
Our Sponsor Licence Management Services
We offer complete end-to-end support for UK employers managing the lifecycle of their sponsored workforce, securing corporate compliance, and mitigating operational risks.
Day-to-day oversight of your Sponsor Management System, including CoS assignments, user permissions, and responding to UKVI correspondence.
Read more →Compliance Health ChecksStructured mock audits of your licence management processes, records, and HR systems against current UKVI expectations.
Read more →Reporting Duties SupportAssistance meeting the 10 working day reporting window for changes in sponsored worker circumstances, including unauthorised absences of more than 10 consecutive working days, salary reductions, and terminations.
Read more →Record Keeping GuidanceAdvice on maintaining Appendix D-compliant records for all sponsored workers, including document retention periods and filing requirements.
Read more →Right to Work ChecksReview and guidance on your Right to Work check processes to ensure they meet the required standard for sponsored roles.
Read more →Licence Lifecycle ManagementWe keep track of your licence and your sponsor duties so it stays valid and operational. Scale-up and UK Expansion Worker licences last 4 years, and we track those dates for you.
Read more →CoS Allocation RequestsAssistance preparing and submitting annual undefined CoS allocation requests, including supporting justification where required.
Read more →Level 1 User ServiceSubject to Home Office rules, we can act as a Level 1 User on your licence and manage the SMS directly.
Read more →Bespoke Compliance TrainingTargeted training for Authorising Officers and HR teams on sponsor duties, reporting obligations, and common compliance errors.
Read more →Crisis & Remediation SupportStrategic advice for employers who have identified past compliance failures and need to address them before a UKVI audit or action.
Read more →Employer Advisory ServicesOngoing immigration advice for UK employers managing the full lifecycle of their sponsored workforce.
Book a consultation →Licence Suspension SupportGuidance for sponsors whose licence has been suspended: what the letter means, the deadline and your options. Written representations are outside our Level 1 scope, so we refer them to a solicitor or higher-level adviser.
Read more →Good to know
Frequently Asked Questions
What are a sponsor’s ongoing duties after a licence is granted?
Once a licence is granted, employers must actively manage the SMS, report changes in sponsored worker circumstances within 10 working days, maintain Appendix D-compliant records, conduct ongoing Right to Work checks, and ensure that sponsored roles remain genuine and appropriately paid. These duties apply for the full duration of the licence.
What happens if we fail a UKVI compliance audit?
Depending on the findings, the licence may be downgraded to B-rated status which prevents the issue of new Certificates of Sponsorship until an action plan is completed or suspended or revoked in more serious cases. Revocation results in curtailment of existing sponsored workers’ leave. Taking prompt remedial action before an audit significantly reduces this risk.
Can we outsource our sponsor licence management?
The day-to-day administrative management of the licence including SMS management can be handled by an external adviser. However, the Authorising Officer must always be a paid member of staff or office holder within the organisation and retains ultimate responsibility for the licence. This cannot be outsourced.
What is the difference between a Defined and Undefined Certificate of Sponsorship?
A Defined CoS is used for Skilled Worker applicants applying from outside the UK. An Undefined CoS is for those applying from within the UK, or on certain other routes. Assigning the wrong type is a common error with compliance implications and may require the worker to make a fresh application.
What is a Level 1 User and why does it matter?
A Level 1 User has full access to the SMS and can carry out all day-to-day licence management tasks. UKVI requires that at least one Level 1 User is active on the account at all times. If the sole Level 1 User leaves the organisation without a replacement being set up, the employer’s ability to manage the licence is immediately affected.
How long must we keep records for sponsored workers?
Documents must generally be retained for one year after sponsorship of the individual ends, or until they have been examined and approved by a UKVI compliance officer, whichever is earlier. The specific records required are set out in Appendix D of the sponsor guidance.
What is a compliance health check?
A compliance health check is an internal review of your sponsor licence management processes, records, and SMS history, carried out against the standards UKVI applies during a compliance visit. V Immigration conducts these reviews for clients to identify gaps and address them before enforcement action is taken.
When must a licence be renewed?
Most sponsor licences stay valid for as long as you continue to meet the eligibility requirements, so there is no routine renewal. Scale-up and UK Expansion Worker licences are valid for 4 years, and another licence for those routes can’t be obtained. V Immigration tracks these dates for clients and helps keep every licence in good standing.
What happens to sponsored workers if our licence is revoked?
If a licence is revoked, the Home Office will curtail the leave of all workers sponsored under it, typically allowing a short period currently 60 days to find an alternative sponsor or make arrangements to leave the UK. This makes revocation one of the most serious enforcement outcomes for a business.
How can V Immigration help with sponsor licence management?
We provide end-to-end sponsor licence management support from SMS management and reporting duties through to compliance health checks, staff training, licence lifecycle management, and crisis support. We advise UK employers of all sizes and are available in Birmingham, London and Manchester.
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Sponsor licence compliance is not a one-time task. The obligations that come with a licence require consistent, accurate management and the consequences of getting it wrong can be severe, both for the business and for the workers it sponsors.