A medium-sized care provider in Yorkshire lost their sponsor licence in 2025. They had held it for three years. They had sponsored 34 workers. Their care quality was rated Good by CQC. They were, by every visible measure, a well-run organisation.
The reason for revocation was not fraud, exploitation, or deliberate non-compliance. It was a series of administrative failures in the Sponsor Management System (SMS): unreported changes of circumstance, expired Key Personnel details, certificates of sponsorship assigned with incorrect job descriptions, and — most critically — a failure to report that two sponsored workers had stopped attending work more than 10 working days earlier.
The Home Office compliance team that conducted the audit described the organisation's SMS management as "insufficient." The care provider described it as "something nobody had time to deal with properly." Both statements were accurate.
The Sponsor Management System is the portal through which every licensed sponsor in the UK manages their sponsorship obligations. It is the mechanism for assigning Certificates of Sponsorship, reporting changes, and demonstrating compliance with the conditions of the licence. And it is, by widespread acknowledgement, not intuitive — a government system designed for precision rather than usability, managed by people whose primary job is running a business, not navigating immigration bureaucracy.
This guide covers what the SMS is, what you must do in it, what you can do in it, and how to avoid the administrative failures that are driving the surge in licence revocations.
What the SMS is
The Sponsor Management System is the Home Office's online portal for organisations that hold a sponsor licence under the UK's points-based immigration system. It is the primary interface between sponsors and the Home Office for all sponsorship-related activities.
Through the SMS, sponsors can:
- Assign Certificates of Sponsorship (CoS) to workers they wish to sponsor
- Report changes to the sponsored worker's circumstances (job role, salary, absences, departure)
- Report changes to the sponsor organisation (address, ownership, key personnel)
- Request additional CoS allocations when their existing allocation is insufficient
- Manage key personnel — the people authorised to use the SMS on behalf of the organisation
- View compliance-related communications from the Home Office
The SMS is accessed at www.points.homeoffice.gov.uk/gui-sms-jsf. Access is restricted to authorised users — the key personnel named on the sponsor licence.
Key personnel: who does what
Every sponsor licence must have at least three named key personnel roles. Understanding these roles is essential because the Home Office holds these individuals — not just the organisation — accountable for compliance.
Authorising Officer
The Authorising Officer is the most senior person responsible for the licence. They are personally accountable for the organisation's compliance with its sponsor duties. This must be a senior employee: an owner, director, or member of the senior management team. The Authorising Officer does not need to use the SMS day to day, but they are responsible for ensuring that the organisation meets its obligations.
If the Authorising Officer leaves the organisation or changes role, this must be reported to the Home Office via the SMS within 10 working days. Failure to update the Authorising Officer is a compliance failure that can trigger licence action.
Key Contact
The Key Contact is the Home Office's primary point of communication with the sponsor. They receive notifications, compliance correspondence, and requests for information. The Key Contact should be someone who monitors communications regularly and can respond promptly. An unmonitored inbox or an individual who is frequently unavailable creates a risk of missed correspondence — which the Home Office treats as non-cooperation.
Level 1 User
Level 1 Users are the people who operate the SMS on a day-to-day basis: assigning Certificates of Sponsorship, reporting changes, and managing records. An organisation can have multiple Level 1 Users, and in practice, it is advisable to have at least two to ensure continuity if one is absent or leaves the organisation.
A common mistake: Organisations name the same person for all three roles. While this is technically permitted, it creates a single point of failure. If that person leaves, is absent for an extended period, or simply loses track of the SMS obligations, the entire compliance framework collapses. Distributing the roles across at least two — ideally three — individuals provides resilience.
What you must report — and when
The reporting duties attached to a sponsor licence are extensive, time-sensitive, and non-negotiable. Failure to report is one of the most common triggers for compliance action and, ultimately, licence revocation.
Under Sponsor Guidance Appendix D, sponsors must report the following events through the SMS:
Worker-related reporting (within 10 working days)
- The worker does not start employment on the expected date — if a sponsored worker does not arrive or does not begin work as planned, you must report it
- The worker is absent from work for 10+ consecutive working days without permission — unexplained absences must be reported
- The worker's employment ends — whether through resignation, dismissal, redundancy, or any other reason
- There is a significant change in the worker's role — a change in job title, core duties, salary, or working location that differs from what was stated on the CoS
- The worker's salary drops below the required threshold — for any reason, including reduced hours, unpaid leave, or restructuring
- You have reason to believe the worker is breaching the conditions of their visa — for example, working hours that exceed their permitted limit
Organisation-related reporting (within 20 working days unless stated otherwise)
- Change of address — registered office, trading address, or any site where sponsored workers are based
- Change of ownership or control — mergers, acquisitions, change of directors
- Change of key personnel — Authorising Officer, Key Contact, or Level 1 User (10 working days)
- Cessation of trading — if the business stops operating or enters insolvency
- Any criminal proceedings — against the organisation or key personnel
The reporting deadlines are strict. A change that occurs on Day 1 must be reported by Day 10 (or Day 20 for organisational changes). Not Day 11. Not "when we get round to it." The Home Office treats late reporting as evidence of non-compliance, even if the content of the report is accurate.
Common mistakes in SMS management
The Home Office's own data on licence revocations reveals consistent patterns of SMS mismanagement. Here are the most frequently cited failures.
Not reporting worker departures
When a sponsored worker leaves — resigns, is dismissed, or simply stops attending — the sponsor must report this through the SMS within 10 working days. Many organisations fail to do this, either because the SMS is not integrated into their HR process, because the person responsible for SMS reporting is not informed of the departure in time, or because the departure is ambiguous (the worker "might come back").
The consequence: the Home Office's records show the worker as still employed by the sponsor, when in reality they have left and may be working illegally elsewhere. This reflects poorly on the sponsor's compliance and can trigger a compliance visit.
Wrong CoS category or job details
When assigning a Certificate of Sponsorship, the sponsor must accurately describe the role: job title, SOC code, job description, salary, working hours, and work location. Errors in any of these fields — a wrong SOC code, a salary that does not match the actual offer, a generic job description that does not reflect the real role — are compliance failures.
These errors are often made in haste. The HR team is under pressure to get the CoS assigned quickly so the worker can submit their visa application. Accuracy is sacrificed for speed. But the Home Office audits CoS records against actual employment conditions, and discrepancies are treated seriously.
Stale key personnel records
Key personnel change. People leave, are promoted, move departments, or go on extended leave. When the Authorising Officer named on the licence left the company two years ago and nobody updated the SMS, the licence is technically non-compliant. When the Key Contact's email address has not been monitored for six months, critical Home Office correspondence goes unseen.
Updating key personnel records is a simple administrative task that is routinely neglected because it is not urgent — until a compliance visit reveals that the named Authorising Officer has not worked at the organisation for 18 months.
Not requesting CoS allocations in time
Sponsors are assigned a CoS allocation — a set number of certificates they can issue. When the allocation runs out, the sponsor must request more through the SMS. This request takes time to process (typically a few working days, but potentially longer). If the request is not made until the allocation is exhausted and a new hire is waiting, the hiring process stalls.
Planning CoS usage and requesting additional allocations proactively — before you run out — avoids this bottleneck.
How to keep SMS in good shape
Managing the SMS effectively is not complicated, but it requires discipline and routine. Here is a practical framework.
Monthly SMS review
Set a monthly calendar reminder to review the SMS. Check:
- Are all key personnel records current?
- Are there any outstanding reporting obligations?
- Is the CoS allocation sufficient for planned hiring?
- Are there any Home Office messages or correspondence that need a response?
This review takes 30 minutes and prevents the accumulation of compliance debt that leads to problems during audits.
Integrate SMS reporting with HR processes
The most common SMS failures happen because the SMS exists outside the normal HR workflow. A worker's departure is processed in the payroll system but not reported in the SMS. A role change is agreed and documented in the HR file but not updated on the CoS.
Make SMS reporting a mandatory step in every HR process that affects a sponsored worker: hiring, role changes, salary changes, absences, and departures. The person responsible for SMS reporting should be notified automatically whenever a relevant HR event occurs.
Maintain a sponsored worker tracker
Outside the SMS itself, maintain a spreadsheet, database, or compliance system that tracks every sponsored worker: name, CoS reference, visa expiry date, role, salary, and any reporting events. This tracker is your early warning system for upcoming visa expiries, unreported changes, and CoS allocation needs.
This is where visa expiry tracking becomes critical. A sponsored worker whose visa expires without a follow-up action — either a new CoS for extension or a departure report — creates a compliance gap that the Home Office will identify.
Prepare for compliance visits
Home Office compliance officers can conduct unannounced visits to verify that the information in the SMS matches reality on the ground. Are the sponsored workers actually doing the jobs described on their CoS? Are they being paid the stated salary? Are they working at the stated location? Are there workers on site who should have been reported as having left?
The best preparation for a compliance visit is a well-maintained SMS and a sponsored worker tracker that matches reality. If the records in the SMS accurately reflect what is happening in the organisation, the visit is straightforward. If they do not, it is a problem.
Technology to support SMS compliance
The SMS itself is a government system with limited functionality. It does not send proactive alerts, it does not integrate with HR software, and it does not provide the kind of dashboard view that modern compliance management requires.
Certifyd's Right to Work Portal complements the SMS by providing the tracking, alerting, and audit trail capabilities that the SMS lacks. Visa expiry tracking with automated alerts, centralised records for every sponsored worker, and a compliance dashboard that gives you real-time visibility of your sponsorship obligations. When a compliance officer arrives, you can demonstrate not just that your SMS records are accurate but that you have a systematic process for keeping them that way.
For businesses with a sponsor licence, explore how Certifyd supports sponsor compliance.