UK sponsor licence duties: the reporting clocks and the file
Two reporting clocks, seven categories of record, and a compliance visit that can compare sponsored salaries against payroll. This page sets out what the duties actually are and how licences are actually lost.
Last reviewed 2026-09-04 · SponsorReady, Harmony Future Holdings Limited, Dublin
What this page is
A plain-English reading of the sponsor duties in the Home Office Workers and Temporary Workers: guidance for sponsors (Parts 1–3) and Appendix D. It is free, and it is the same corpus our paid pack is built from.
It is not legal advice, and it is not an immigration service within the meaning of the Immigration and Asylum Act 1999 — it does not advise on any individual’s immigration status or application. UK guidance changes frequently: verify current guidance before relying on any deadline, and take regulated immigration advice for case-specific questions.
The two reporting clocks
Everything reportable falls into one of two windows, and the difference is whether the event concerns a worker or the sponsor.
| Window | Covers | Basis |
|---|---|---|
| 10 working days | Worker events: non-attendance, non-compliance, absence without permission, significant changes to the worker’s employment (role, salary outside permitted changes, location), early termination | Part 3: sponsor duties, reporting duties |
| 20 working days | Changes to the sponsor’s own circumstances: name, ownership (mergers, takeovers), size classification, key personnel, address | Part 3: sponsor duties, reporting duties |
The clock starts at awareness, not at the event
Both windows run from the day the sponsor becomes aware. And the sponsor is aware when any responsible person is — not when the Level 1 User finally hears about it. A line manager who knew about an absence three weeks ago has already been running your clock.
What counts as a working day
‘Working day’ excludes weekends and bank holidays (England and Wales, per the guidance glossary — verify for the specific case).
A limit in our own calculator, stated plainly
Our free calculator and our paid pack both exclude weekends only. They do not know your bank holidays. Where a bank holiday falls inside the window, the true deadline is later than the date we show — so the date we show is always safe, never late. Verify bank holidays for the specific deadline if you are close to the wire.
The eight reportable events
| Event | Working days | The part people get wrong |
|---|---|---|
| Worker does not turn up for their first day | 10 | The clock starts the day you become aware, not the day the contract said they would start. |
| Worker absent without permission for more than 10 consecutive working days | 10 | The clock starts on the tenth day of unauthorised absence — so the monitoring has to catch it before then. |
| Employment ends early — resignation, dismissal or redundancy | 10 | Report the actual leaving date, not the date the paperwork closed. |
| Significant change to the role, salary or work location | 10 | Some changes need a new certificate of sponsorship rather than a report — check which before assuming a report is enough. |
| Worker’s circumstances change so they no longer meet the route | 10 | Includes losing a required registration or qualification. |
| Sponsor changes name, ownership or size classification | 20 | Mergers and takeovers start this clock even when nothing changes for the sponsored workers. |
| Key personnel change — Authorising Officer, Key Contact, Level 1 or 2 User | 20 | A vacancy in a mandatory role is itself an exposure: report the change and fill the role. |
| Sponsor’s address or trading address changes | 20 | Including adding or closing a site where sponsored workers are based. |
Key personnel
A licence must maintain an Authorising Officer, a Key Contact and at least one Level 1 User. The Authorising Officer is responsible for the actions of all SMS users (Part 1: apply for a licence, key personnel).
Two failure modes follow from this and both appear on the list below: a single Level 1 User with no deputy who happens to be on leave when a 10-working-day clock starts, and key personnel who left the business and were never removed from the licence.
Appendix D: the records a visit asks for
- Right-to-work check evidence for every sponsored worker, dated before employment started.
- Contact details kept current: address, telephone, mobile.
- Absence records covering unauthorised absence monitoring.
- Evidence of recruitment activity: adverts, applications, interview notes justifying the hire.
- Salary evidence: contracts and payslips matching the certificate of sponsorship.
- Evidence of qualifications and registrations required for the role.
- History of reportable events with SMS report references and dates.
The right-to-work check, in order
- Establish which check applies: a manual document check, an online check using a share code, or an Identity Service Provider check for valid British and Irish passport holders.
- Carry out the check before employment starts. A check dated after the start date does not establish the statutory excuse — and that date is the first thing a visit reads.
- For a manual check: see the original document, check it in the holder’s presence (in person or by live video), and be satisfied it is genuine and belongs to them.
- Keep a dated copy in the worker’s file, filed the same day.
Salary reconciliation, checked from records
Compliance activity has intensified through 2025–26, including checks of sponsored salaries against payroll data. If the salary on the payroll does not match the salary on the certificate of sponsorship, that discrepancy is visible without anyone visiting your office. Reconcile before someone else does.
What we deliberately do not assert
Enforcement statistics change quarterly, so we do not quote them. The duty set above is the stable core, and it is what the pack is built on.
How licences are actually lost
- A right-to-work check dated after the employment start date. It is the first document a compliance visit asks for, and the date is what it reads.
- Salary on the payroll that does not match the certificate of sponsorship. Salary-to-payroll reconciliation is a check that can be made from records alone.
- An event reported inside the window with no record of when the sponsor became aware — leaving no way to prove it was in time.
- Line managers who knew for three weeks before the Level 1 User heard. The sponsor is aware when any responsible person is, so the clock had already been running.
- Contact details captured at hiring and never refreshed.
- Recruitment evidence discarded after probation, so the hire cannot be justified at a visit.
- A single Level 1 User with no deputy, on leave when a 10-working-day clock starts.
- Key personnel who left the business and were never removed from the licence.
What happens when it goes wrong
Licence action is graded: a compliance visit can end in guidance, a downgrade to a B-rating with a mandatory action plan (chargeable, and public), suspension, or revocation.
Revocation does not only land on you
Revocation curtails the permission of the workers you already sponsor. The cost lands on them as well as on the business. The specific outcome for a specific breach is a Home Office decision and we do not predict it.
The file that survives a compliance visit
The free calculator gives you one deadline. The pack gives you the Appendix D file structure, the reporting calendar, the duties matrix, a per-worker completeness matrix and a mock-audit walkthrough.
Get the pack — €490