When a business obtains a UK sponsor licence, the celebration tends to be short-lived. The licence itself is just a permission to sponsor. What comes next is an ongoing, detailed set of compliance obligations that the Home Office expects you to meet every day, every week, every month — indefinitely.
Most sponsors understand the basics: check right to work, keep records, report changes. But the full scope of sponsor duties is broader and more time-sensitive than many realise. The 3,100 businesses that lost their licence last year did not typically fail because of a single dramatic error. They failed because recurring obligations fell through the cracks — a report filed on day 12 instead of day 10, a visa expiry date nobody was tracking, a change of circumstances that never reached the Sponsorship Management System.
This is the compliance calendar most sponsors wish they had received when their licence was granted. It covers every recurring duty, organised by timeframe, with clear ownership guidance.
The 10-working-day obligations
These are the most time-critical sponsor duties. Under Sponsor Guidance Part 3, specific changes must be reported via the Sponsorship Management System (SMS) within 10 working days of the change occurring. Not 10 calendar days. Working days.
Missing these deadlines is one of the top triggers for compliance visits and licence downgrades.
Report immediately when a sponsored worker:
- Fails to start work on the expected date
- Is absent without permission for more than 10 consecutive working days
- Leaves your employment (resignation, dismissal, redundancy, or end of contract)
- Changes job role — any change to duties, job title, salary, or working pattern that differs from what was stated on the Certificate of Sponsorship
- Changes work location — moves to a different site or begins working from a location not previously declared
- Has a change to immigration status — new visa, extension, curtailment, or any change to their conditions of stay
- Is the subject of a disciplinary process that may affect their continued employment
Report immediately when your organisation:
- Changes its address or trading name
- Merges with, is acquired by, or acquires another organisation
- Ceases trading or enters insolvency proceedings
- Has a change to its Authorising Officer, Key Contact, or Level 1 user on the SMS
- Becomes subject to criminal proceedings or is investigated by a regulatory body in connection with immigration offences or related matters
Each of these has a 10-working-day window. In practice, you should aim to report within 5 days to build in a buffer for system access issues, holiday cover, and the time it takes for information to reach the person responsible for SMS reporting.
Who owns this?
Your Key Contact is typically responsible for SMS reporting. But the information that triggers a report — a worker leaving, a role change, an absence — originates with line managers, HR, and payroll. If the communication path between these functions and the Key Contact is unclear, reports will be late.
Action: Establish a documented process. When a sponsored worker's circumstances change, who tells the Key Contact, and by what method? Email? Shared system notification? The process must not depend on someone remembering.
Monthly obligations
Visa expiry monitoring
Every sponsored worker has a visa with an expiry date. Your obligation is to ensure that you conduct a follow-up right to work check before that expiry date — not after, not on the day, but before.
Monthly task: Review the visa expiry dates for all sponsored workers. Identify any expiring within the next 90 days. For those expiring within 30 days, confirm that the follow-up check is scheduled, the worker has been reminded to apply for an extension (if applicable), and the check will be conducted and recorded before the expiry date.
If a visa expires and the worker has not applied for an extension, you have a serious problem. You may be employing someone without the right to work, and your statutory excuse — which only lasts as long as the permission it was based on — has lapsed.
Contact details verification
You are required to hold current contact details for every sponsored worker: home address, personal phone number, and personal email address. These details change more often than most employers track.
Monthly task: Cross-reference your records against any known changes. At minimum, prompt sponsored workers to confirm or update their details quarterly.
Absence monitoring
The Home Office expects sponsors to monitor attendance. If a sponsored worker is absent without authorisation for more than 10 consecutive working days, you must report it via SMS.
Monthly task: Review absence records for all sponsored workers. Identify any patterns of unexplained absence. Ensure that any absence approaching the 10-day threshold is flagged to the Key Contact before the reporting deadline passes.
Quarterly obligations
Record completeness audit
Every quarter, conduct a systematic check of your sponsored worker files. For each worker, confirm you hold:
- Current passport/visa details
- Certificate of Sponsorship reference number
- Evidence of right to work check (date, method, outcome)
- Current contact details (home address, personal phone, personal email)
- Job details matching the CoS (role title, salary, work location, hours)
- Absence records
This is not an optional exercise. It is the internal audit that ensures you can pass an external audit at any time.
Quarterly task: Select a sample of files (or review all of them if your sponsored workforce is small enough). Create a checklist. Document what was checked, what was found, and what was rectified. Keep the audit record — it demonstrates to compliance officers that you take your duties seriously.
SMS system access review
The SMS is your portal for all reporting and Certificate of Sponsorship activity. Review who has access, what level of access they have, and whether those individuals are still the right people for their roles.
Quarterly task: Confirm that your Authorising Officer, Key Contact, and Level 1 users are current. If someone has left or changed role, update the SMS. An outdated SMS user list is a compliance failing in itself and can delay urgent reporting.
Pay and conditions check
For each sponsored worker, verify that their actual salary, role, and working conditions match what was declared on their Certificate of Sponsorship. The Home Office requires that sponsored workers are paid at least the going rate for their occupation code and that their role matches the job description on the CoS.
Quarterly task: Cross-reference payroll data against CoS details. If a sponsored worker's salary has dropped below the threshold (due to reduced hours, for example), or their duties have changed from what was declared, you have a compliance issue that needs to be addressed and, if necessary, reported.
Annual obligations
Certificate of Sponsorship allocation review
If you hold an allocation of unrestricted CoS (for Skilled Worker or other visa routes), review your allocation annually. Are you using your allocations? Do you need to request more? Are any allocated CoS unused and approaching their validity deadline?
Annual task: Review CoS usage and allocation. Request additional allocations if needed via the SMS. Allow sufficient lead time — allocation requests are not instant.
Compliance framework review
Once a year, step back and review your overall compliance framework. This is not about individual worker files. It is about the system itself.
- Is the process for conducting right to work checks documented and followed consistently?
- Is the reporting process from line managers to Key Contact functioning?
- Are visa expiry dates tracked centrally with automated alerts?
- Are records stored securely and accessibly?
- Have there been any near-misses or process failures in the past year?
- Do managers and HR staff understand their specific responsibilities?
Annual task: Conduct a formal review. Document findings. Update processes where needed. Brief the Authorising Officer on the results. This review is your evidence of a well-led compliance function.
Training refresh
People forget. Rules change. New staff join and are not briefed. An annual training refresh ensures that everyone involved in sponsor compliance — from the Authorising Officer to line managers who supervise sponsored workers — understands their role.
Annual task: Deliver training or refresher sessions. Cover: current right to work check requirements, reporting obligations, what to do when circumstances change, and what a compliance visit involves. Keep records of who attended.
The compliance calendar at a glance
| Frequency | Task | Owner | |-----------|------|-------| | As needed (10-day window) | Report changes via SMS | Key Contact | | Monthly | Visa expiry monitoring | HR / Key Contact | | Monthly | Contact details check | HR | | Monthly | Absence monitoring review | Line managers / HR | | Quarterly | Record completeness audit | HR / Compliance lead | | Quarterly | SMS system access review | Authorising Officer | | Quarterly | Pay and conditions check | HR / Payroll | | Annually | CoS allocation review | Key Contact | | Annually | Compliance framework review | Authorising Officer | | Annually | Training refresh | HR / Compliance lead |
The cost of missing deadlines
Sponsor licence compliance is not a system that forgives occasionally being a few days late. The 10-working-day reporting window is absolute. If you miss it, the Home Office records the failure. Multiple late reports compound into a pattern that triggers a compliance visit, a B-rating downgrade, or revocation.
The businesses that maintain their licences year after year are not the ones that never have an issue. They are the ones that have a system — calendar-driven, role-assigned, documented — that catches issues before they become failures.
The businesses that lose their licences are overwhelmingly those that relied on individual memory, informal processes, and the assumption that someone was keeping track. When the Home Office arrived, nobody was.
Certifyd's Right to Work Portal automates the critical elements of sponsor compliance — visa expiry tracking with automated alerts, centralised worker records, and audit-ready reporting. It replaces the manual calendar with a system that never forgets a deadline, never loses a file, and is always ready for the visit that could come tomorrow.