UK Sponsor Duties and Compliance 2026: Complete Guide for Employers (Part 3 Guidance Explained)

BECOMING A SPONSOR IS JUST THE BEGINNING

Many UK employers lose their sponsor licence not because they hired the wrong person, but because they failed sponsor duties and compliance checks. If you have a sponsor licence or are applying for one, this is the most important guidance you must understand in 2026.

Holding a UK sponsor licence comes with ongoing responsibilities. Employers must monitor sponsored workers, keep the required records, report relevant changes and comply with UK immigration rules and wider UK law.

The latest Workers and Temporary Workers: Part 3 – Sponsor Duties and Compliance guidance is version 08/26, valid from 28 August 2026 and updated on 2 September 2026.

1. What Are Sponsor Duties?

Sponsor duties are the responsibilities an organisation must follow after receiving a sponsor licence.

According to GOV.UK, these duties include reporting changes, keeping required records, complying with immigration rules and wider UK law, and avoiding behaviour that could undermine the sponsorship system.

The responsibilities begin when the sponsor licence is granted and generally continue until the licence is surrendered, made dormant or revoked.

For each sponsored worker, the sponsor’s responsibilities generally begin when the Certificate of Sponsorship (CoS) is assigned and continue until the sponsorship ends under the circumstances set out in the guidance.

2. Key Sponsor Duties You Must Follow in 2026

Employers must have systems in place to manage sponsored workers properly.

The main duties include:

• Reporting relevant changes to sponsored workers and the organisation.
• Keeping required documents and records.
• Monitoring sponsored workers’ attendance and employment.
• Ensuring workers are doing the job for which they were sponsored.
• Ensuring sponsored workers have the required qualifications, registration or experience.
• Complying with UK immigration rules and sponsor guidance.
• Complying with wider UK law, including employment law.
• Cooperating with UKVI compliance checks.
• Ensuring information provided to UKVI remains accurate.
• Avoiding actions that could create a risk to immigration control.

Sponsors are also expected to ensure that the job, occupation code and job description accurately reflect the role the worker is actually doing.

If the sponsored worker’s role changes, the sponsor may need to report the change or, depending on the circumstances, the worker may need to make a new immigration application.

3. Reporting Duties Explained: What, When and How to Report via SMS

One of the most important sponsor responsibilities is reporting changes to UKVI.

As a general rule, changes affecting a sponsored worker must be reported within 10 working days of the relevant event.

Changes affecting the sponsoring organisation generally have to be reported within 20 working days, unless the guidance specifies a different deadline.

Examples of worker changes that may need to be reported include:

• The worker does not start the sponsored role within the required period.
• The worker is absent without permission for more than 10 consecutive working days.
• The worker has more than four weeks of unpaid or reduced-pay absence in a calendar year, subject to the relevant exceptions.
• The worker’s salary is reduced from the level stated on the CoS.
• There is a significant change to the worker’s employment.
• The worker’s normal work location changes.
• The sponsor stops sponsoring the worker.

Reports are generally made through the Sponsorship Management System (SMS) using the relevant reporting function.

Employers should not assume that only changes to salary or job title matter. Changes to work locations and working arrangements can also create reporting responsibilities.

For example, a permanent or full-time remote working arrangement with little or no requirement to attend the workplace must be reported. Hybrid working does not normally need to be reported simply because the worker works remotely on a regular basis, but changes to the main office or client-site location may still need to be reported.

4. Record Keeping Duties: What Documents Must You Keep?

Record keeping is another major part of sponsor compliance.

Sponsors must maintain the documents required under Appendix D of the sponsor guidance. These records help demonstrate that the organisation is complying with its sponsor duties.

Depending on the worker and route, records can include:

• The worker’s identity and immigration status.
• Right-to-work checks.
• The worker’s recruitment.
• Qualifications and professional registration where applicable.
• The worker’s employment and role.
• Salary and payment information.
• Attendance and absences.
• Work location.
• Documents connected to the sponsorship application and CoS.

Sponsors must also retain relevant information provided as part of their sponsor licence application.

Under Appendix D, documents relating to a sponsored worker generally need to be kept throughout the period of sponsorship and until the earlier of one year after sponsorship ends or the date a compliance officer has examined and approved them, where that examination occurs sooner.

5. Compliance Visits: How UKVI Checks Sponsors

UKVI can conduct compliance checks to determine whether a sponsor is meeting its responsibilities.

These checks may involve:

• Requesting additional documents or information.
• Verifying documents already provided.
• Visiting the sponsor’s premises.
• Conducting digital compliance checks through video conferencing.
• Checking information with other government departments or agencies.
• Considering information received from other sources.

UKVI also carries out regular checks with HMRC to help establish whether workers are being paid appropriately and in accordance with the Immigration Rules and sponsor guidance.

A compliance check can take place before a sponsor licence application is decided or after a licence has been granted.

Visits or interviews can be announced or unannounced.

During a compliance check, officers may inspect records, interview sponsored workers and other employees, verify the organisation’s premises and examine systems used to meet sponsor duties.

Employers must cooperate with UKVI. If sponsored workers work at a third-party site, the sponsor must ensure that the third party understands that UKVI may conduct checks there and that the necessary cooperation is provided.

6. Important 2026 Changes Sponsors Should Know

The August 2026 version of Part 3 introduced or reflected several important changes.

These include the phasing out of Level 2 Users, changes concerning inactive sponsor licences, and the introduction of mandatory multi-factor authentication for SMS Users from 3 September 2026.

The guidance also includes changes relating to right-to-work arrangements for relevant employment commencing on or after 1 October 2026.

Employers should therefore ensure that their HR and sponsorship systems are kept up to date and that the people responsible for sponsorship understand the latest SMS and right-to-work requirements.

7. Consequences of Non-Compliance

Failure to meet sponsor duties can result in compliance action.

Depending on the circumstances, UKVI may:

• Reduce the sponsor’s CoS allocation.
• Set the CoS allocation to zero.
• Downgrade the sponsor licence.
• Suspend the sponsor licence.
• Revoke the sponsor licence.
• Cancel the immigration permission of sponsored workers.
• Refer suspected criminal or civil offences to the relevant authorities.

A sponsor that is downgraded to a B-rating must follow an action plan and cannot assign CoS to new workers until the required improvements have been made and the A-rating is restored.

The action plan is normally limited to 3 months. A sponsor can generally be B-rated and subject to an action plan a maximum of twice during a rolling four-year period.

If a sponsor licence is revoked, sponsored workers can also be affected. Their permission may be cancelled or shortened depending on the circumstances.

After revocation, a sponsor generally cannot apply for another sponsor licence until at least 12 months have passed, although the cooling-off period can be longer in certain circumstances.

8. Common Mistakes That Can Cause Sponsor Problems in 2026

Failing to report changes on time

A change in a worker’s salary, role, location or sponsorship status can create a reporting obligation.

Poor record keeping

Missing documents can make it difficult for an employer to demonstrate compliance during a UKVI check.

The actual job does not match the CoS

The worker should carry out the role represented by the occupation code and job description on the CoS. A significant mismatch can lead to serious compliance action.

Ignoring attendance issues

Sponsors have responsibilities when workers are absent without permission for more than 10 consecutive working days.

Failing to monitor remote working arrangements

Permanent or full-time remote working can create reporting responsibilities where the worker has little or no requirement to attend the workplace.

Passing prohibited sponsorship costs to workers

The guidance includes circumstances where asking a sponsored worker to pay or reimburse certain sponsor licence fees, administrative costs or other prohibited costs can result in compliance action.

9. How to Stay Compliant: Practical Checklist for Sponsors

Employers can reduce compliance risks by putting a clear sponsorship management process in place.

A practical checklist includes:

• Keep the latest sponsor guidance available to HR and relevant staff.
• Monitor the SMS regularly.
• Maintain accurate records for every sponsored worker.
• Track visa and permission expiry dates.
• Record attendance and absences.
• Monitor salaries against sponsorship requirements.
• Keep recruitment evidence.
• Check that workers remain qualified or registered where required.
• Make sure the actual job matches the CoS.
• Monitor changes to work locations and working arrangements.
• Report relevant changes within the required deadlines.
• Keep right-to-work records up to date.
• Train HR staff and SMS users on sponsor responsibilities.
• Prepare for announced or unannounced compliance checks.
• Review the organisation’s sponsorship processes regularly.

It is also important to remember that sponsor guidance can change. Employers should regularly check GOV.UK to make sure they are following the latest requirements.

Key Takeaways

• A sponsor licence comes with ongoing responsibilities.
• Worker-related changes generally need to be reported within 10 working days.
• Organisation-related changes generally need to be reported within 20 working days.
• Sponsors must maintain the records required by Appendix D.
• UKVI can conduct announced or unannounced compliance checks.
• Compliance checks can include document reviews, interviews, site visits and digital checks.
• Sponsors must ensure sponsored workers are performing the role for which they were sponsored.
• Non-compliance can result in reduced CoS allocations, a B-rating, suspension or revocation.
• The latest Part 3 guidance is version 08/26, valid from 28 August 2026 and updated on 2 September 2026.

Conclusion

Having a UK sponsor licence is not a one-time approval. Employers must continue meeting their responsibilities throughout the life of the licence and while they sponsor workers.

Good record keeping, timely reporting, accurate employment information and proper monitoring of sponsored workers are central to maintaining compliance.

Employers should also regularly review the latest GOV.UK sponsor guidance because requirements can change.

Frequently Asked Questions

1. How long do sponsors have to report changes to a sponsored worker?

As a general rule, changes to a sponsored worker’s circumstances must be reported within 10 working days of the relevant event. Some circumstances have specific reporting requirements, so sponsors should check the applicable section of the guidance.

2. How long do sponsors have to report changes to their organisation?

Organisation changes generally need to be reported within 20 working days, unless a different deadline applies to the specific change.

3. Can UKVI visit a sponsor without notice?

Yes. UKVI compliance checks involving visits or interviews can be conducted on either an announced or unannounced basis.

4. What happens if a sponsor fails a compliance check?

Depending on the circumstances, UKVI can take different forms of compliance action, including reducing a CoS allocation, downgrading the licence, suspending the licence or revoking it.

5. What records must a sponsor keep?

Sponsors must keep the documents required under Appendix D, along with other records required by the sponsor guidance. The exact documents depend on the route and circumstances of the sponsored worker.

Official Guidance

Official guidance: GOV.UK Workers and Temporary Workers: Part 3 – Sponsor Duties and Compliance

The official GOV.UK guidance provides detailed information for employers and organisations holding Worker and Temporary Worker sponsor licences, including sponsor duties, reporting requirements, compliance checks and the action UKVI can take when a sponsor breaches or is suspected of breaching its duties.

GOV.UK Workers and Temporary Workers: Part 3 – Sponsor Duties and Compliance

The current guidance is version 08/26, valid from 28 August 2026, and was updated on 2 September 2026.

Disclaimer

Information verified from official GOV.UK Workers and Temporary Workers Guidance Part 3 as of September 2026. This is for information only, not legal advice. Always refer to the official guidance and seek legal advice where appropriate.