Sponsor licence duties: what a UK employer owes after approval

Most of the attention goes to the application. An HR team spends weeks assembling supporting documents, pays the fee, waits for the decision, and treats the grant letter as the finish line. It is the starting line. From the day the licence is granted, a set of continuing obligations attaches to the organisation, and they are enforced by a department that can end your ability to sponsor anyone without a right of appeal.

This article sets out what those obligations are: who you must appoint and what each person does, how certificates of sponsorship work, what the Immigration Skills Charge now costs after the increase that took effect on 16 December 2025, which deadlines apply to which events, what you must keep and for how long, and what happens to the people you sponsor if the licence goes. Every figure and rule is quoted from the Home Office guidance, GOV.UK or the regulations, with the version or in-force date named.

Sponsorship fails on the small things: a start date nobody reported, a work location that changed, an absence that passed a threshold while the file sat with a manager. If you want these obligations on a visible track with an owner and a date rather than in somebody's inbox, see how New Dynamics workflows handle a process that has to produce the same record every time.

What a sponsor licence is, and what it covers

GOV.UK's overview for employers opens with the trigger: "You'll usually need a sponsor licence to employ someone to work for you from outside the UK. This includes citizens of the EU, Iceland, Liechtenstein, Norway and Switzerland who arrived in the UK after 31 December 2020." It adds a line that surprises charities: "This includes unpaid work, like running a charity."

You do not need a licence for everyone. The same page excludes Irish citizens, people with settled or pre-settled status under the EU Settlement Scheme, and people with indefinite leave to remain. And a licence is not a guarantee of anything: "Sponsoring someone does not guarantee that they'll get a visa to work for you in the UK."

Licences come in two families. A Worker licence covers skilled or long-term employment, split into Skilled Worker, Senior or Specialist Worker, Minister of Religion and International Sportsperson. A Temporary Worker licence covers specific temporary categories including Scale-up Worker, Creative Worker, Charity Worker, Religious Worker, Government Authorised Exchange, International Agreement, Seasonal Worker and the remaining Global Business Mobility routes. You can hold one or both.

Most licences have no expiry. GOV.UK states that "Your licence usually stays valid for as long as you continue to meet the eligibility requirements." The exceptions are Scale-up Worker and UK Expansion Worker licences, which last four years, and for which "You will not be able to apply for another licence to sponsor these types of workers."

The fees, by organisation size

As the GOV.UK licence fee table stood on 6 November 2026, a Worker licence costs £611 for a small or charitable sponsor and £1,682 for a medium or large one. A Temporary Worker licence is £611 whatever your size. Adding a Worker licence to an existing Temporary Worker licence costs £1,071 for a medium or large sponsor and nothing for a small or charitable one.

You are "usually a small sponsor if at least 2 of the following apply: your annual turnover is £15 million or less, your total assets are worth £7.5 million or less, you have 50 employees or fewer." Charitable status is defined by registration rather than by self-description.

One sentence on that page deserves to be read out loud in a kick-off meeting: "You must pay the licence fee yourself. Your licence may be revoked if you ask the sponsored worker to pay the fee or any costs linked to your application." Most applications are decided in under eight weeks, and an extra £750 buys a decision within ten working days for a limited number of applications each day.

The five duties behind every other rule

Everything in the rest of this article is a consequence of a short list. Paragraph C1.11 of Part 3 of the sponsor guidance names five duties: reporting duties, record-keeping duties, complying with immigration law and all parts of the sponsor guidance, complying with wider UK law, and "not engaging in behaviour or actions that are not conducive to the public good".

Paragraph C1.8 says they start "on the day we grant your licence" and continue until you surrender it, the Home Office makes it dormant or it is revoked. Paragraph C1.4 sets the tone for how they are enforced: a licence "is held at the broad discretion of the Home Office and can be terminated at any time", and "A licence creates no property or other enforceable right."

The key personnel you must appoint

Part 1 of the sponsor guidance, version 08/26, valid from 28 August 2026, requires three nominated roles at application. It describes them plainly.

The Authorising Officer is "a senior person within your organisation who has overall responsibility for your activity as a licensed sponsor". Paragraph L4.33 is more demanding than most organisations assume: this must be "the most senior person in your organisation responsible for the recruitment of all sponsored workers and ensuring you meet all of your sponsor duties". They must be a paid member of staff or an office holder, you can only have one, and the guidance recommends that they check the certificates assigned to workers "at least once a month". If you do not have a suitable Authorising Officer in place, or you fail to report a change of one, the Home Office says it will normally revoke the licence.

The Key Contact is "your main point of contact with UKVI", used for queries about the application, the documents and the fees. You can have only one, and it may be a paid member of staff, an office holder or a UK-based representative.

The Level 1 User is "a person within your organisation who is responsible for your day-to-day activity as a licensed sponsor, including assigning and requesting Certificates of Sponsorship (CoS) and reporting worker activity or changes to your organisation". This is the role that actually works the sponsorship management system, and you can have several. At least one Level 1 User must be an employee, partner or director and a settled worker.

Two structural points matter. Paragraph L4.6 states: "You must have an eligible Authorising Officer and at least one Level 1 User throughout the life of your licence. If you do not, we will revoke your licence." And the Authorising Officer and Key Contact have no automatic access to the system; if they need it, they must also be appointed as a Level 1 User.

The Level 2 User role is being withdrawn. GOV.UK says you can no longer appoint them, existing ones must be converted to Level 1 or deactivated before 9 March 2027, and "Level 2 user accounts will be deactivated automatically after 8 March 2027."

Certificates of sponsorship: defined, undefined and allocation

A certificate of sponsorship is not a document. GOV.UK describes it as "an electronic record, not a physical document", with a number the worker uses to apply. Once assigned, "they must use it to apply for their visa within 3 months".

There are two kinds, and the split is about where the worker is.

Defined certificates are "for people applying on a Skilled Worker visa from outside the UK". You cannot hold a stock of them. Part 2 of the guidance is explicit: "You cannot have an annual allocation of Defined CoS." You apply for each one through the system, and GOV.UK says applications "are usually approved within one working day".

Undefined certificates are "for Skilled Workers applying from inside the UK, and applicants on all other visas". These come from an annual allocation you estimate when you apply for the licence. Asking for more usually takes up to 12 weeks, or five working days if you pay.

Mixing them up is not a filing error. Part 2 says the Home Office "will normally revoke your licence" if you assign a Defined certificate for a job other than the one described in the application for it, or an Undefined certificate where a Defined one is required.

Each certificate carries a fee: £525 for a Worker licence certificate and £55 for a Temporary Worker one. As with the licence fee, "Your licence may be revoked if you ask the sponsored worker to pay the fee or any costs linked to your application."

The Immigration Skills Charge after 16 December 2025

This is the figure most often quoted wrongly, because it changed less than a year ago and the old numbers are everywhere.

The Immigration Skills Charge (Amendment) Regulations 2025 were made on 15 December 2025 and came into force on 16 December 2025. The explanatory note states the effect in one line: "Regulation 2(3) of these Regulations increases the amounts of charges payable by sponsors by 32%."

The current amounts, as GOV.UK publishes them and as the Schedule to the regulations sets them out, are £480 for the first 12 months for a small or charitable sponsor and £1,320 for a medium or large sponsor, then £240 or £660 for each additional six months. Over a maximum five-year sponsorship that is £2,400 or £6,600. Part 2 of the sponsor guidance names the old figures for comparison: £364 and £182 for small sponsors, £1,000 and £500 for large ones, "where the CoS was assigned before 16 December 2025".

The charge applies when you assign a certificate to a Skilled Worker or a Senior or Specialist Worker who is "applying from outside the UK for entry clearance (a visa) for a period of 6 months or more" or "applying from within the UK for permission to stay of any duration, including for less than 6 months". It is not payable for dependants. You pay in one go when you assign the certificate, and GOV.UK warns that if you do not pay or pay the wrong amount, "You'll have 10 working days to pay the charge" and "the worker's visa application will be refused if you do not."

Part 2 also forbids recovering it: "You must not pass on any of the ISC to, or attempt to recoup it from, any of your sponsored workers. If we find out that you have done so, we will normally revoke your licence."

One place where the regulations and the guidance do not match

The exemptions are worth checking rather than assuming, because two official sources currently differ.

Regulation 4(a) of the Immigration Skills Charge Regulations 2017, as substituted on 16 December 2025, exempts twelve occupation codes. Nine are the familiar research and higher education codes (2111 to 2119, 2161, 2162 and 2311). The 2025 amendment added three more: "2463 (clergy)", "3431 (sports players)" and "3432 (sports coaches, instructors and officials)".

The GOV.UK Immigration Skills Charge page, as it stood on 6 November 2026, lists only the original nine. So does paragraph S5.9 of Part 2 of the sponsor guidance, version 10/26, valid from 8 October 2026.

The regulations govern. They are made under section 70A of the Immigration Act 2014, and Part 2 itself says the amount payable "is specified in the Schedule to the Immigration Skills Charge Regulations 2017". The guidance is a summary of them, and on this point the summary has not caught up. If you are sponsoring in one of those three codes, do not simply withhold payment on the strength of a blog post: put the question to the Home Office Business Helpdesk in writing and keep the answer on file.

Where the Skilled Worker thresholds currently sit

Skill and salary are a condition of the certificate you assign, so they are your problem before they are the worker's.

The current structure dates from 22 July 2025, the date the Immigration Rules themselves use as the dividing line for transitional cases. Appendix Skilled Worker, as published on 29 October 2026, sets the main salary requirement as a salary that "equals or exceeds both: £41,700 per year; and the going rate for the SOC 2020 occupation code". Lower options sit at £33,400: for a relevant STEM PhD at 80% of the going rate, for a job on the Immigration Salary List at the full going rate, and for a new entrant at 70% of the going rate.

On skill, GOV.UK tells applicants that a code "listed as a 'higher skilled' job" qualifies, while a "medium skilled" code only works if the job is on the Immigration Salary List, on the Temporary Shortage List, or is a prison officer extension or switch. The Temporary Shortage List itself is time limited: paragraph SW 6.1A applies it only where the certificate was issued "before 31 December 2026".

Going rates are per occupation code and they move. Read them off the current going rates table on GOV.UK on the day you build the offer, not from a spreadsheet somebody saved last year.

Volumes have moved too, which changes how often an HR team touches this process. The Home Office accredited official statistics published on 27 August 2026 report "234,841 visas issued (including dependants) in all work categories in the YE June 2026, of which 158,722 were to main applicants and 76,119 were to dependants", a fall of 18% on the previous year. Refusal rates rose as well: for the Skilled Worker and Health and Care Worker routes combined, "15% in the YE June 2026 compared with 7% in the YE December 2023". More of our wider figures are in the HR statistics hub.

Reporting duties, and the two deadlines that matter

Part 3 of the sponsor guidance, sponsor duties and compliance, version 08/26 published on 28 August 2026, sets two clocks running at paragraph C1.13. Changes to a sponsored worker's circumstances must be reported "within 10 working days of the relevant event occurring". Changes to your organisation must be reported "within 20 working days of the relevant event occurring", and paragraph C2.3 counts that from "the date you became aware of the change".

The worker list at C1.15 is the operational one. You must report when a sponsored worker does not start the role within 28 days, is absent without permission for more than 10 consecutive working days, is absent without pay or on reduced pay for more than four weeks in total in a calendar year, has their pay reduced below the level on the certificate, changes job role or title or core duties within the same occupation code, changes their normal work location, or stops being sponsored by you for any reason.

Two of those hide traps. On absence, the duty to report unauthorised absence applies "even if you intend to continue sponsoring the worker", and the report is due "by no later than 10 working days after the 10th day of absence". On location, hybrid working does not need reporting, but C1.24 requires you to report any worker who is "working entirely remotely, with little or no requirement to attend your premises or a client site", and warns that the Home Office then "reserve the right to ask you to explain why you need to sponsor the worker to come to the UK".

The organisation list at C2.4 covers replacing your Authorising Officer or Key Contact, changing your name, address or branches, losing a registration or accreditation you are legally required to hold, going into an insolvency procedure, a merger or takeover, a relevant criminal conviction, and a change in your organisation's size or charitable status. That last one is quietly expensive: your size determines both your licence fee and the level of Immigration Skills Charge you pay, and paragraph S5.6 says that if you fail to report a change within 20 working days, "we may take compliance action against you".

Separately, and with no fixed deadline, C1.14 requires you to tell the Home Office "as soon as reasonably practicable" if you know or suspect a sponsored worker has breached their conditions of stay, and to give the police anything suggesting a sponsored worker may be involved in terrorism or criminal activity.

Record keeping: what to keep, and for how long

Appendix D to the sponsor guidance, version 10/26, valid from 8 October 2026, is the list. It covers record-keeping duties in five headings: evidence of right to work and date of entry checks, evidence of recruitment, evidence of salary, evidence of skill level, and additional evidence such as contact details and absence records.

Retention is shorter than most people expect, and it is a window rather than a floor. Unless stated otherwise, documents must be kept throughout the sponsorship and until the earlier of "one year after the date on which your sponsorship of the worker ended" or "the date on which a compliance officer has examined and approved them". Your own licence application documents are different: "You must keep this information for as long as you hold a sponsor licence."

Format is up to you. "Documents can be kept either as paper copies or in an electronic format. There is no prescribed method for storing the documents but you must be able to make them available to us on request."

Two warnings sit alongside that. Appendix D notes that some of these documents must be kept longer for other purposes, "for example, to comply with legislation on preventing illegal working", so the one-year sponsorship window does not override the employment plus two years retention that right to work evidence carries. And paragraph C1.41 of Part 3 reminds sponsors of their obligations "under the Data Protection Act 2018 and the General Data Protection Regulation (GDPR)". Sponsorship files fill up with immigration detail about identifiable people, so put them in your retention schedule with a defined period and a deletion step. Our employee data protection guide sets out how to write that down.

Sponsorship also sits on top of the right to work duty rather than replacing it. Paragraph C7.28 says a sponsor "must still carry out a right to work check" on any sponsored worker "regardless of the nature of the employment relationship". Our post on the share code right to work check covers that process and the statutory excuse it produces. The sponsorship duties in this article are a separate and additional set, and doing one well does not discharge the other.

Cooperating with the Home Office, including unannounced visits

Compliance is not an event you can schedule. Paragraph C7.9 of Part 3 says checks may happen "at any time, including before we make a decision on your licence application or after your licence has been granted", and that where a check involves visiting or interviewing you, "this can be on an announced or an unannounced basis."

The cooperation duty at C7.10 is broader than your own offices: "You must co-operate with us and allow our staff full access to any premises or sites under your control on demand." If your sponsored workers work at a client's site, "it is your responsibility to ensure that the third party is aware we may carry out an unannounced visit to, and conduct checks at, their premises. You must ensure their full co-operation. If any such third party is uncooperative, we will take action against you." That sentence should be in your client contracts if you place sponsored staff.

A visiting officer may verify what you said in your licence application, including by taking photographs of your premises, speak to sponsored workers and to colleagues involved in their recruitment, inspect records and systems against Appendix D, and check right to work compliance on workers you do not sponsor. Checks can also be digital, conducted "via remote video conferencing facilities". Paragraph C7.7 adds that the Home Office "will also make regular checks with HMRC to ensure you are paying your workers appropriately". If your payroll and your certificates disagree, that will surface without anyone visiting.

If you use sponsored workers through an intermediary rather than employing them directly, the duty does not transfer with the arrangement. Our pieces on what an employer of record is and on working with international recruitment agencies cover where responsibility actually sits.

Ratings, suspension, revocation, and your workers

A successful application produces an A-rating, which lets you assign certificates and puts you on the public register of sponsors.

A B-rating is a downgrade for what Part 3 calls "relatively minor breaches of the sponsorship scheme that we believe can be resolved by issuing an action plan". While B-rated you cannot sponsor new workers, though you can still assign certificates to existing workers extending their stay. You pay £1,579 for the action plan, within 10 working days of being told about the downgrade, or you lose the licence. All action plans run for a fixed three months, and you can be B-rated at most "twice during any 4-year rolling period in which you hold a sponsor licence". A third qualifying failure means revocation.

A suspension stops you assigning any certificate while the Home Office investigates, and your entry comes off the public register. You get 20 working days to respond in writing, and there is no oral hearing. Existing workers with valid permission "will not be affected, unless or until we decide to revoke your licence".

Revocation is the end of it. Paragraph C10.3 states: "There is no right of appeal against the decision and you will not be eligible to apply again for a sponsor licence until at least 12 months have passed since the date of revocation", rising to 24 months for a repeat. Any certificates you have already assigned "automatically become invalid", so pending entry clearance applications based on them are refused.

The consequence for the people you sponsor is the part to understand before you take a shortcut. Where a worker was not knowingly involved in the reasons for revocation, the Home Office says it "will normally cancel (shorten) their permission so they have only 60 calendar days' left", and they must leave or apply on another route they qualify for. Where a worker was complicit, it "will normally cancel all of their remaining permission", meaning they "will have to leave the UK immediately or face enforced removal". A sponsor's filing failure becomes somebody's 60 days.

Illegal working sits alongside this. Paragraph C7.30 lists a civil penalty "of up to £60,000 for each illegal worker" and adds that if one is issued, "we are likely to revoke your licence", with no new licence for at least 12 months after the penalty is paid in full, and up to five years for more than one penalty.

Running sponsor duties as a process, not as goodwill

The guidance tells you what compliance is. It does not tell you how to make it happen across four sites and three managers who have never read it. That part is yours.

Give every reportable event an owner and a trigger. A 10 working day clock that starts when a line manager notices something is not a clock, it is a hope. The events that matter are mostly already visible to HR somewhere: a start date that moved, four weeks of unpaid leave, a pay change, a resignation, a site move. Connect those records to the person who holds the Level 1 User account instead of relying on them to ask.

Diarise the Authorising Officer's monthly check. The guidance recommends reviewing assigned certificates at least once a month, and that review is also your best chance of catching a wrong occupation code before a visa decision does.

Write down who may assign a certificate. Assigning the wrong type is a normal revocation ground. Keep the list of Level 1 Users short, trained and current, and deactivate accounts the day somebody leaves.

Keep size and charitable status under review. It drives both your licence fee and your Immigration Skills Charge, it has a 20 working day reporting deadline, and it is the duty most likely to be nobody's job.

Record recruitment at the time, not in reconstruction. Appendix D expects evidence of recruitment, salary and skill level per worker, and paragraph C1.38 lets the Home Office ask for "details of your recruitment practices". Our recruitment and selection guide covers keeping that evidence as a by-product of hiring rather than as an archaeology project.

Jurisdiction and limits

Immigration is not devolved, so sponsorship works the same way in England, Scotland, Wales and Northern Ireland. The Immigration Skills Charge (Amendment) Regulations 2025 say so in terms: "These Regulations extend to England and Wales, Scotland and Northern Ireland."

This article describes an employer's duties as a licensed sponsor. It is general information rather than legal or immigration advice, it is not a substitute for the guidance it quotes, and it does not advise any individual on their immigration position. Take proper advice on your own circumstances, and particularly before you act on anything affecting a sponsored worker's status.

This area changes repeatedly. Part 1 and Part 3 of the sponsor guidance were reissued on 28 August 2026, Part 2 and Appendix D on 8 October 2026, and the Immigration Skills Charge changed on 16 December 2025. Work from the current versions on GOV.UK rather than from a saved PDF, an internal wiki page or this article.

Frequently asked questions

What are my sponsor licence duties?

Paragraph C1.11 of Part 3 of the sponsor guidance lists five: reporting duties, record-keeping duties, complying with immigration law and all parts of the Worker and Temporary Worker sponsor guidance, complying with wider UK law such as employment law, and not engaging in behaviour or actions that are not conducive to the public good. They start on the day the licence is granted and continue until you surrender it, it is made dormant or it is revoked.

How quickly must a sponsor report a change?

There are two deadlines. Changes to a sponsored worker's circumstances must be reported within 10 working days of the event. Changes to your organisation must be reported within 20 working days of the day you became aware of them. Some duties have no fixed window at all: you must tell the Home Office as soon as reasonably practicable if you know or suspect a sponsored worker has breached their conditions of stay.

How much is the Immigration Skills Charge now?

For a certificate assigned on or after 16 December 2025, it is £480 for the first 12 months if you are a small or charitable sponsor and £1,320 if you are medium or large, plus £240 or £660 for each additional six months on the certificate. The Immigration Skills Charge (Amendment) Regulations 2025 increased the previous amounts by 32%. Over a five-year maximum the total is £2,400 or £6,600. You must pay it yourself and must not recoup it from the worker.

What is the difference between a defined and an undefined certificate of sponsorship?

Defined certificates are for people applying on a Skilled Worker visa from outside the UK. You cannot hold an allocation of them, so you apply for each one through the sponsorship management system, usually approved within one working day. Undefined certificates are for Skilled Workers applying from inside the UK and for applicants on all other routes, and they come from an annual allocation you estimate when you apply for the licence. Assigning the wrong type is a ground on which the Home Office says it will normally revoke a licence.

Can the Home Office visit without warning?

Yes. Part 3 says compliance checks may happen at any time and that a visit or interview can be announced or unannounced. You must allow staff full access to any premises or sites under your control on demand, and where your sponsored workers work at a third party's site you are responsible for making sure that third party knows an unannounced visit is possible and cooperates with it.

What happens to sponsored workers if a licence is revoked?

Certificates you have already assigned become invalid, so pending entry clearance applications based on them are refused. For workers already in the UK who were not knowingly involved in the reasons for revocation, the Home Office says it will normally shorten their permission to 60 calendar days, within which they must leave or apply on a route they qualify for. Where a worker was complicit, it will normally cancel all remaining permission. There is no right of appeal against revocation and no new licence for at least 12 months.

Your next step: turn five duties into five owned tasks

1. Write down, on one page, who holds each key personnel role today, and check the Authorising Officer really is the most senior person responsible for sponsored recruitment. If they are not, change it and report the change.
2. List every reportable worker event from paragraph C1.15 against the HR record that would reveal it, and name the person who checks that record.
3. Put the Authorising Officer's monthly certificate review in the calendar as a recurring task with a written output.
4. Pull one sponsored worker's Appendix D file end to end and time yourself. Fix whatever is missing before someone else looks for it.
5. Re-test your organisation size and charitable status against the £15 million, £7.5 million and 50 employee thresholds, and diarise that test annually.

For the retention and data protection half of this, read and download our employee data protection guide. The guide is free to read, and the PDF uses our short download form.

Want reporting deadlines, record checks and named owners to live on the same visible track as the rest of your people process? Book a New Dynamics demo and bring your current sponsorship checklist. You can also email contact@new-dynamics.com.