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Employer guide

Sponsor compliance duties

The five groups of duties a licensed sponsor keeps, from reporting and records to wider UK law, with Home Office guidance references.

Written by SkilledJobs from the Home Office sponsor guidance. General information, not legal advice. Checked against GOV.UK

A sponsor licence comes with duties. The Home Office sets them out in Part 3 of its guidance for sponsors, "Sponsor duties and compliance". The version we read is 08/26, valid from 28 August 2026. This guide summarises the duties and points to the paragraphs they come from.

It explains the published rules. It does not assess any organisation's position. If you are unsure how a rule applies to you, speak to a regulated adviser about your circumstances.

When the duties start and end

Your duties as a sponsor start on the day the licence is granted (Part 3, C1.8). They continue until you surrender the licence, the Home Office makes it dormant, or the licence ends through revocation.

Your responsibility for each worker starts when you assign them a Certificate of Sponsorship (CoS) (C1.10). It ends when, for example, the CoS is withdrawn before use, the worker's permission expires, or you tell the Home Office you have stopped sponsoring them.

The guidance is clear that a licence is held at the Home Office's "broad discretion" and "creates no property or other enforceable right" (C1.4). It also says that sponsorship "is a privilege not a right" (C1.5).

The five groups of duties

Paragraph C1.11 lists the duties as:

  • reporting duties
  • record-keeping duties
  • complying with immigration law, including all parts of the sponsor guidance
  • complying with wider UK law
  • not behaving in a way that is not conducive to the public good

Licensed sponsors must also read all parts of the guidance and keep up with changes to it (C1.3). Changes are announced on the sponsorship management system (SMS) message board (C1.2).

Reporting

Changes about a sponsored worker must usually be reported within 10 working days. Changes about your organisation must usually be reported within 20 working days (C1.13). You must also tell the Home Office, as soon as reasonably practicable, if you know or suspect a worker has breached their conditions of stay (C1.14).

Our guide to sponsor reporting duties and deadlines covers the list in detail.

Records

You must keep the documents listed in Appendix D for each worker you sponsor, and give the Home Office relevant documents when asked (C1.37 and C1.38). See our guide to record keeping for sponsors.

Immigration law

Paragraph C1.42 sets out what complying with immigration law means for a sponsor. It includes:

  • sponsoring only workers who are qualified, registered or experienced for the job, and keeping copies of the evidence
  • carrying out right to work checks on any worker you sponsor or employ
  • assigning a CoS only for a role that meets the route's criteria and the glossary definition of "eligible role"
  • making sure the actual job matches the occupation code and job description on the CoS
  • not letting an SMS user assign a CoS to themselves, a close relative or a partner
  • not recovering sponsorship fees or associated costs from a worker where the guidance prohibits it

Part 3 says that a sponsored worker found in a role that does not match the occupation code or job description on the CoS, where the change is not permitted, is a mandatory ground for revocation (C1.45). The role check shows the published rules for an occupation code.

Wider UK law

Sponsors must also comply with UK law beyond immigration (C1.53). The guidance names employment law, including National Minimum Wage, the Working Time Regulations and pension enrolment where required. It also names holding any registration or licence your sector needs to operate, and carrying out DBS checks where a role requires one.

Public good

Paragraph C1.54 says the Home Office will not license organisations whose behaviour is not conducive to the public good. Its examples include fostering hatred, glorifying terrorism and discrimination on protected grounds.

Systems the Home Office expects

GOV.UK's summary says sponsors must have HR systems that let them monitor workers' immigration status, keep copies of documents, track attendance, keep contact details up to date and report problems. An example it gives is a worker who stops coming to work.

Part 1 adds that the Home Office assesses whether an applicant can carry out these duties before granting a licence, and may run a compliance check first (Part 1, L3.3).

What happens if duties are not met

If the Home Office reasonably suspects a sponsor is failing its duties, C1.12 lists the sanctions it may use:

  • reducing the CoS allocation, or setting it to zero
  • downgrading the licence rating
  • suspending the licence while it investigates
  • revocation of the licence
  • reporting the sponsor to the police or other authorities

Our guides on B-ratings and action plans, suspension and revocation explain each step. The printable sponsor compliance checklist lists the duties with their paragraph references.

Common questions

Do the duties apply if we are not sponsoring anyone right now?

The licence duties start when the licence is granted and run until it is surrendered, made dormant or ends through revocation (C1.8). Part 3 invites sponsors who are not sponsoring any workers to consider surrendering (section C5).

Can a client or contractor take on the duties?

Part 3 places the duties on the sponsor (C1.11). Where sponsored workers are based at a client's premises, the sponsor must still secure that client's co-operation with compliance visits (C7.10). Speak to a regulated adviser about your circumstances.

Where do route-specific duties sit?

Part 3 applies to all Worker and Temporary Worker sponsors. Each route also has its own guidance with extra duties (C1.1 and C1.36).

Can we talk to someone about our situation?

Yes. You can tell us about your situation and we will reply. We do not assess cases or help with forms.

Sources

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