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Sponsor duties, in plain English.

What the Home Office expects from an organisation that sponsors workers: the checks to make, the changes to report, the records to keep, and what happens when they check.

How KivoHR keeps these duties for you

Sponsored workers

Your organisation, 2 October 2026

Example
2 actions before your next inspection Appendix D files complete for 4 of 4

Email me the checklist

Every duty on this page as a line to tick, on paper you can print and keep.

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Right-to-work checks

Every employer must check that a new member of staff can legally work in the UK before their employment starts, not on their first day and not afterwards. A check made properly and on time gives you a statutory excuse: protection from a penalty if it later turns out the person could not work.

  • People with digital immigration status, which now includes eVisas, give you a share code from their UKVI account. You make an online check with the code and their date of birth. A manual check of documents is not acceptable for them.
  • British and Irish citizens can be checked manually from their documents, or through a certified identity service provider.
  • Time-limited permission needs a follow-up check before it runs out, or the protection lapses with it.

Since 13 February 2024 the civil penalty for employing someone without the right to work is up to £45,000 per worker for a first breach and up to £60,000 per worker for a repeat one.

Changes you must report

Changes about a sponsored worker are reported through the Sponsor Management System within 10 working days of the change. The main ones:

  • they do not start work within 28 days of when they were expected to
  • they are absent without your permission for more than 10 consecutive working days
  • they take unpaid or reduced-pay leave of more than four weeks in a year
  • their salary drops below the level on their certificate of sponsorship
  • their job changes significantly: role, title, duties, or a promotion
  • they move to a different work location, including a new branch or permanent home working
  • you stop sponsoring them, for example because they resign or their contract ends early

Changes to your organisation are reported within 20 working days: a change of name or address, new branches, a merger or takeover, insolvency, or stopping trading.

A new authorising officer or key contact is reported straight away. The guidance gives no 20 days for these two (Part 3, C2.3), and your licence must have an authorising officer and a Level 1 user at all times (Part 1, L4.6).

Your SMS users

The Sponsor Management System (SMS) changed in September 2026. What to do now:

  • Level 2 users are ending. No new Level 2 users can be added since 9 September 2026. By 8 March 2027, add each Level 2 user who still needs access as a Level 1 user, then deactivate their Level 2 account. Any Level 2 accounts left are deactivated after that date (Part 1, L4.58 to L4.59).
  • Two-step login is coming to every account. Multi-factor authentication is being switched on in phases from 3 September 2026, and for any licence granted from 9 September 2026. Users get a 6-digit code by text or email; Level 1 users are also asked for their date of birth (Part 1, L4.67 to L4.69).
  • Check your users’ details before it reaches you. Each user needs a current email address, and each Level 1 user a mobile number and the right date of birth on the SMS (Part 1, L4.84). The Home Office emails you two weeks before your accounts are switched over.
  • Never share a password or a code. An SMS user who tells anyone their password or one-time passcode gives the Home Office grounds to revoke your licence (Part 3, Annex C3).
  • Sign in at least once a year. An account nobody has used for 12 months counts as inactive and can be deactivated. If that leaves you with no active Level 1 user, the licence can be suspended (Part 1, L4.72 to L4.78).

Your licence still needs an authorising officer and at least one Level 1 user at all times.

Absence and keeping in touch

You are expected to know whether your sponsored workers are turning up. When someone has been absent without permission for more than 10 consecutive working days, the 10-working-day reporting clock starts.

The report includes the worker’s last known home address, phone number and any personal email address, and what you did to try to contact them. So the contact details you hold need to be current, not the ones from their application.

Records you must keep

Appendix D of the sponsor guidance lists the documents you must keep for every worker you sponsor, including copies of their right-to-work evidence, their contact details and records of absence and salary.

Keep them for as long as you sponsor the worker, then until whichever comes first: one year after the sponsorship ends, or a compliance officer has examined and approved them. Some documents have to be kept longer for other reasons. Right-to-work check records, for example, fall under the illegal working rules as well.

You must also keep the documents you sent with your licence application for as long as you hold the licence.

How the Home Office checks

The Home Office can ask you for documents, verify what you have told it, interview you over video, check with other government departments, or visit you on site, with or without notice.

What happens if it finds problems depends on how serious they are:

  • A B-rating and an action plan for relatively minor issues. You cannot sponsor new workers until you are back to an A-rating.
  • Suspension while it investigates. You cannot assign certificates of sponsorship while suspended.
  • Revocation, with or without suspension first. The workers you sponsor can then be affected too.

Staying ready

Most problems found at a compliance check are not dramatic. They are a missing document, a change reported late, or contact details nobody updated. The organisations that do well keep these in one place, as part of their everyday HR, instead of in a spreadsheet someone remembers to open before a visit.

Stay on top of your sponsor duties.

Right-to-work follow-ups, reports with their deadlines counted and every worker’s file, alongside the rest of your HR.

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