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Compliance

Sponsor Licence Compliance Duties After Approval

Compliance checklist for sponsor licence holders

Getting your sponsor licence approved is the beginning, not the end. From the day your licence is granted you take on a set of legal obligations to the Home Office that run for as long as you hold the licence. Failure to meet them can result in suspension, revocation, civil penalties and in serious cases criminal prosecution. This guide covers every key duty.

The SMS Portal

The Sponsorship Management System (SMS) is the online portal through which you manage your sponsor licence. You use it to assign Certificates of Sponsorship, report changes, and manage your key contacts. Your Level 1 user, who must be an employee or director of the business, not an external contractor, is responsible for day-to-day portal management. SMS access must be used correctly: incorrectly assigned CoS, missed reports and lapsed key contacts are among the most common compliance failures identified during Home Office visits.

The 10-Day Reporting Duty

You must report certain events to UKVI within 10 working days of them occurring. The key events that trigger this duty include: a sponsored worker failing to attend for their first day of work; a sponsored worker being absent without permission for 10 or more consecutive working days; a sponsored worker's employment ending earlier than the end date on their CoS; a significant change in the worker's job role, salary or work location; and a sponsored worker being taken on by a different employer within a group structure.

Missing a 10-day report is one of the most common reasons for compliance warnings and can contribute to a licence suspension if the Home Office identifies a pattern. We track all reporting obligations as part of our Management Retainer service.

Right to Work Records

You must conduct a right to work check for every person you employ before their employment begins, not just sponsored workers. For sponsored workers you must also retain copies of their visa documentation and record their contact details, immigration status and visa expiry date. All records must be kept for the duration of employment plus 2 years after employment ends.

Home Office compliance visits will audit right to work records. Missing records, unchecked workers or expired documents that were not followed up are all grounds for civil penalties or licence action. The civil penalty for employing an illegal worker is up to £60,000 per worker.

Salary Maintenance

You must continue to pay your sponsored workers at least the salary stated on their Certificate of Sponsorship throughout their employment. Any reduction in salary, even with the worker's agreement, that takes their pay below the threshold stated on the CoS or the applicable going rate puts both the worker's visa and your licence at risk. If you need to reduce a sponsored worker's salary for any reason, contact us first.

Key Contact Responsibilities

Your Authorising Officer, Key Contact and Level 1 SMS users must remain suitable throughout the life of the licence. If any of these people leave the business, acquire a relevant criminal conviction, or are otherwise no longer suitable, you must update the SMS immediately. Running a licence with lapsed or unsuitable key contacts is a compliance breach. Annual checks on all key contacts are best practice.

Cooperating with Home Office Visits

UKVI conducts unannounced compliance visits to sponsor licence holders. These visits can happen at any time and inspectors have the right to access your premises, review your records and speak to your staff. The best preparation is to ensure your records are always compliant, not just around a visit you know about. If you receive advance notice of a visit, contact us immediately. We will review your compliance position and prepare you for the inspection.

The Management Retainer

For businesses that find compliance management time-consuming or that want the confidence of professional oversight, our Management Retainer covers all of the above. Monthly compliance management, CoS assignments, SMS portal support, visa expiry tracking, 10-day reporting, and quarterly health checks. Contact us to discuss how the retainer works for your business.

Related Articles and Services

Management Retainer → Compliance Audit → How It Works →
Who Needs This

Is Your Licence
At Risk Right Now?

You need a compliance audit if any of the following apply:

  • Your licence has been active for more than 12 months without a formal review
  • You have had staff changes affecting key contacts or sponsored workers
  • You have received any correspondence from UKVI in the past 6 months
  • Your HR team has changed and handover was informal
  • You have not reviewed your SMS entries since your last CoS assignment
  • You are planning to scale your sponsored workforce significantly

The audit does not stop at the report. We identify the gaps and fix them before we finish. You leave fully compliant.

What We Audit

Every Compliance Area
Covered

  • Sponsor Management System entries and reporting obligations
  • CoS records for all sponsored workers
  • Right to work documentation for every relevant employee
  • HR policies covering recruitment, absence monitoring and contact details
  • Salary compliance against 2026 thresholds (£41,700 minimum)
  • Attendance and tracking records for sponsored workers
  • Key contact appointments and their continued eligibility
  • Previous UKVI correspondence and any account flags
Business compliance review
What You Receive

A Written Report. A Remediation Plan. Fixed Before We Leave.

You receive a written compliance report identifying every gap, risk-rated by severity. A remediation plan with specific actions. A follow-up call to walk through findings. Where gaps exist, we fix them as part of the same engagement not a separate invoice.

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FAQ

Common Questions

Common triggers: a worker leaving without SMS notification, complaints or tip-offs, failure to report a change of address, patterns of CoS assignments in high-risk sectors, and random selection from the licence register.
1 to 2 business days from receipt of your documentation. We work quickly because time matters.
Yes. We attend, ensure you are fully prepared and manage the interaction with UKVI throughout.
Consequences range from a licence downgrade to suspension or full revocation. Workers can have their visas curtailed within 60 days. Civil penalties of up to £60,000 per illegal worker can also apply.
Our fee is confirmed before we start. Contact us for a quote based on your number of sponsored workers and licence history.

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