Sponsorship Licence Compliance & Skilled Worker Management
Holding a UK sponsor licence gives you access to global talent, but it also comes with serious compliance obligations.
From the moment your licence is granted, the Home Office places a significant level of trust in your organisation to manage your sponsored workers responsibly and in full compliance with UK immigration law.
At Tann Law Solicitors, we help businesses in Coventry and across the UK confidently meet those obligations, providing guidance on sponsor licence compliance and expert intervention when it matters most.
Are you looking for help obtaining a sponsor licence first? See our Sponsor Licence Application Services.
Your Sponsor Licence Compliance Duties
In exchange for the ability to recruit globally, licence holders are expected to take on a set of ongoing duties. These fall into three core categories:
Record-Keeping
You will need to maintain up-to-date and readily accessible records for every sponsored worker throughout their employment. This includes:
- Copies of passports, visas, and eVisa confirmation showing immigration status and permission to work.
- Evidence of right to work checks conducted before employment commenced.
- Current contact details, including home address and phone number.
- Employment records such as job descriptions, contracts, salary details, and working hours.
- Records of attendance and any absences, including the reasons for them.
Reporting Duties
You are legally required to report certain events and changes to the Home Office via the Sponsor Management System within certain timeframes. Reportable events include:
Within 10 Working Days
- Changes to a sponsored worker’s job title, salary, or work location.
- A sponsored worker’s failure to start their role.
- Repeated or unexplained absences.
- The early termination of employment for any reason, including resignation, dismissal, or redundancy.
Within 20 Working Days
- Significant changes to your organisation itself, such as changes to your business address, ownership structure, mergers, or acquisitions.
- Changes to key personnel managing the licence.
Complying with UK Immigration and Employment Law
Sponsors must ensure that every sponsored worker is carrying out only the work specified on their Certificate of Sponsorship, is being paid at or above the required salary threshold, and is working within the terms of their visa.Â
Since April 2025, sponsors are also prohibited from passing any licence or Certificate of Sponsorship fees on to sponsored workers. Doing so is now a presumptive ground for revocation.
What Is the Sponsor Management System (SMS)?
The Sponsor Management System (SMS) is the mandatory online portal through which all UK sponsor licence holders manage their licence and sponsored workers.
It is the primary interface between your organisation and UK Visas and Immigration (UKVI), and using it correctly is fundamental to staying compliant.
Through the SMS, your organisation will:
- Assign Certificates of Sponsorship (CoS) to prospective overseas employees.
- Report changes in sponsored workers’ circumstances to the Home Office.
- Make changes to key personnel, such as adding or removing Level 1 Users.
- Renew your sponsor licence when required.
The SMS is managed by your nominated key personnel, who are:
- Your Authorising Officer.
- Key Contact.
- Level 1 User(s).
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Getting the right people in these roles and making sure they are properly trained to use the system is critical. Errors or omissions in the SMS are a frequent trigger for Home Office scrutiny.
As of January 2025, at least one Level 1 User must be both an employee, director, or partner of the business and a settled worker.
How Tann Law Supports Sponsor Licence Compliance
Day-to-Day Sponsor Licence Compliance Support
We provide clear, reliable guidance on your sponsor duties as they arise, helping your HR team understand what to report, when to report it, and how to maintain the records the Home Office expects to see.
Sponsor Management System Training and Support
Understanding how to use the Sponsor Management System correctly is one of the most practical, yet most commonly underestimated aspects of holding a sponsor licence. Our Coventry-based solicitors can provide SMS training for your key personnel, helping them learn the system and meet reporting obligations on time.
Level 1 User Services
For businesses that need hands-on SMS management rather than just training, Tann Law can act as your Level 1 User. This means we take direct responsibility for managing your Sponsor Management System, handling reporting obligations, assigning Certificates of Sponsorship, and ensuring timely compliance with all Home Office requirements.
Skilled Worker Visa Applications
Once your licence is in place, we support you and your overseas employees through the Skilled Worker visa application process.Â
Sponsor Licence Renewals
Sponsor licences are subject to a 10-year renewal cycle. We’ll support you through the renewal process when the time comes, ensuring your application is accurate and that your business is well-positioned for a smooth continuation of its licence.
B-Rating Recovery
If your sponsor licence has been downgraded from an A-rating to a B-rating following a compliance visit, prompt action is essential. A B-rating means the Home Office has identified concerns about your compliance, and you will be placed on an action plan to demonstrate improvement within a set timeframe. We work with you to identify and address the specific concerns raised, implement the necessary changes, and support your application to have your A-rating reinstated.
Licence Suspension and Revocation Support
If your sponsor licence has been suspended, or you have received notice that revocation is being considered, you need specialist legal advice as a matter of urgency. Suspension means you cannot assign new Certificates of Sponsorship, and revocation has serious consequences for both your business and your existing sponsored workers.
Ready to hire the talent your business needs?
Sponsor licence compliance is an ongoing commitment that requires knowledge, consistency, and timely action.Â
Our Coventry-based immigration solicitors are here to make that manageable for your business, providing the support you need to hold your licence with confidence.
Frequently Asked Questions
What happens if I miss a 10-day or 20-day reporting deadline?
Missing a reporting deadline is a serious compliance failure. The Home Office may:
- Downgrade your licence from A-rating to B-rating.
- Suspend your ability to assign new Certificates of Sponsorship.
- In serious cases, revoke your licence entirely.
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If you've missed a deadline, report it immediately via your Sponsor Management System, even if late, and seek legal advice as a matter of urgency.
What's the difference between an A-rating and a B-rating?
An A-rating means your compliance is satisfactory and you can operate normally.
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A B-rating means the Home Office has identified compliance concerns. You'll be placed on an action plan and must demonstrate improvement within a set timeframe. During this period, you cannot sponsor new workers in certain circumstances.
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Failure to recover to A-rating can result in revocation.
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Can I manage SMS reporting myself, or do I need a solicitor?
Many businesses successfully manage day-to-day SMS reporting in-house with proper training. However, legal support is valuable for:
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- Initial SMS training for key personnel
- Complex situations (restructures, TUPE, redundancies)
- Compliance visits or audits
- B-rating recovery
- Any suspension or revocation threats
Can I Select a Legal Representative or Law Firm as my Level 1 User?
Yes, you can do this, but generally, you can only add a third party as an additional level 1 user after your licence has been granted.
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During your company's initial application, your level 1 user must either be a paid employee or a company officer.
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Tann Law Solicitors can be appointed as a Level 1 User for your sponsor licence, providing expert management of your Sponsor Management System on your behalf.
This is particularly valuable if:
- You don't have the internal capacity to manage day-to-day SMS reporting.
- Your business is undergoing restructuring or periods of change.
- You want to ensure compliance is handled by immigration law specialists.
- You're concerned about missing reporting deadlines or making SMS errors.
What records must I keep for sponsored workers?
You must maintain:
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✓ Copies of passports, visas, and eVisa confirmations
✓ Right to work check documentation
✓ Current contact details (address, phone)
✓ Employment contracts and job descriptions
✓ Salary and working hours records
✓ Attendance records and absence reasons
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