If a Sponsored Worker Changes Role? It’s one of those moments that can quietly transform from routine HR admin into a serious compliance matter. Titles evolve, responsibilities shift, promotions happen, but for UK employers holding a sponsor licence, even small changes can carry big implications. What looks like progress on paper can, in immigration terms, trigger fresh obligations and renewed scrutiny. In a system built on precision and accountability, understanding how role changes fit within sponsorship rules isn’t just advisable — it’s essential.
Understanding When a “Role Change” Requires Action
For a sponsored worker, any change to their employment can trigger immigration consequences. The key question is whether the change amounts to a “material change” in the terms under which the sponsorship was granted.
What counts as a material change?
A role change might require action if it involves one or more of the following:
- A move to a different SOC (Standard Occupational Classification) code or job title that significantly alters the nature of the role.
- A change in duties that moves beyond the original role for which the CoS was issued.
- A different salary, working hours or work location that was not anticipated in the original CoS.
- A change of employer altogether (which often triggers a new sponsorship process).
- One employer to another (or via a TUPE transfer) where immigration permission must be reviewed.
When a New Certificate of Sponsorship (CoS) is Required?
The Certificate of Sponsorship is the cornerstone of the sponsorship process. Whether a new CoS is required depends on the nature of the change.
When you must issue a new CoS
- If the worker is changing employer (the new employer must hold a valid sponsor licence).
- If the worker’s existing CoS does not cover the duties of the new role (different SOC code or substantially different role).
- If the switch involves a new job with a different salary or working requirements that fall outside the original CoS arrangements.
- If the worker is applying for a visa to permit the change (for example, changing employer or changing job within the same employer). The guidance states: the sponsor must assign a new CoS, and the worker must apply to update their visa for the new role.
When you may not need a new CoS
- Where changes are minimal and the role remains essentially the same: same employer, same SOC code, same salary/grade band.
- Where the change falls under the same CoS’s allowances (e.g., minor change of duties, unchanged employer, same salary). But the sponsor must still monitor and ensure compliance with all requirements.
Processes for assigning the new CoS
Once it is clear a new CoS is required:
- The employer issues a new CoS under the Skilled Worker route for the worker’s new role.
- The worker must apply (or update) their visa to reflect the change. The gov.uk site emphasises that the worker must apply before starting the new job unless the change falls under permitted absences or minor variations.
- The employer must update their records, keep evidence of the job offer, salary, duties, start date, and ensure all sponsor duties are met.
Reporting Duties for the Sponsor Licence Holder
As a licence-holder, employers bear ongoing responsibilities when a sponsored worker changes role. Failure to meet these duties can result in sanctions, including revocation of the sponsor licence.
Key reporting obligations
- Notify UKVI of significant changes: If there is a change that affects sponsorship (job role, duties, salary, work location, employer insolvency, or cessation of the worker’s employment), the sponsor must report it within specified timescales.
- Maintain accurate records: The employer must keep records of the worker’s role, start date, duties, salary, and work location. These records should evidence compliance in case of audits.
- Ensure the worker has valid immigration permission: If the worker must apply for an updated visa due to their role change, the employer must not allow them to start the new role until permission is granted. The guidance warns: a sponsored worker changing jobs or employer without permission can breach the immigration rules.
- Ensure salary and employment conditions remain compliant, especially given the updated thresholds in 2025. If the salary drops below the required threshold or job duties change significantly, the sponsor must check compliance.
- Manage continuity of sponsorship for settlement purposes: If the worker is aiming for settlement (indefinite leave to remain), changes must not disrupt continuous leave and compliant sponsorship. Failure to keep compliant may affect the worker’s settlement eligibility.
Implications of the 2025 Rule Changes on Role Changes
Recent updates to the immigration rules mean that sponsors must be especially vigilant when a sponsored worker changes role.
Higher skill and salary thresholds
From 22 July 2025, the skill level required for many roles increased to RQF 6 (degree level) and the general salary threshold for the Skilled Worker route rose to £41,700. For role changes, this means:
- If a sponsored worker moves to a position that falls below the new thresholds, the sponsor must ensure the worker either retains legacy permissions (if eligible) or apply for a compliant role.
- Many roles at RQF 3-5 are now only eligible if listed on the Temporary Shortage List (TSL).
- Sponsors must check whether the worker’s role change remains within eligibility or requires a fresh start with a new compliant role and visa.
Transitional protections
Workers already on the Skilled Worker route before 22 July 2025 benefit from transitional protections — meaning they may continue under older rules for some purposes. However, when changing roles, sponsors should verify which rules apply (legacy vs new), and whether the job change triggers the new rules.
Risk of non-compliance and enforcement
Given the heightened scrutiny, any failure to issue a new CoS when required, or to report changes in a timely fashion, exposes the sponsor to licence revocation, civil penalties and reputational risk.
Scenario Examples
Here are a few practical examples to illustrate how role changes should be handled:
Example A: Same employer, minor change
An engineer sponsored under the SOC code XYZ receives a slight change in duties (e.g., new project duties but same job title, salary unchanged). The employer reviews and determines that no new CoS is needed, but records the change and monitors compliance.
Example B: Same employer, different role
A data analyst sponsored under the SOC code ABC is promoted to a managerial role with a new SOC code and salary uplift. This is a material change; the employer must issue a new CoS, and the worker must apply to update their visa before starting a new role.
Example C: Change of employer
A software developer sponsored by Company A wants to join Company B (which holds its own sponsor licence). A new CoS is required from Company B, and the worker must apply for a visa update. Company A must report the end of employment, and Company B must record the start.
Checklist for Employers When a Sponsored Worker Changes Role
- Review proposed new role: SOC code, duties, salary, location.
- Determine if the change is “same role” or “material change.”
- If a material change: assign a new CoS and advise the worker about visa update.
- Monitor whether the worker can start the new role (only when visa permission is granted).
- Update sponsor records and UKVI reporting (employment end, start, change of role).
- Ensure salary and working conditions meet the current rules.
- Retain documentation: job offers, contracts, emails with workers, payroll records.
- Assess settlement-path implications (continuous leave status, eligibility for ILR).
- Stay updated with UKVI and Home Office guidance.
Conclusion!
Navigating a role change for a sponsored worker is one of the riskiest areas of sponsorship compliance. Employers must approach the process with care, deciding whether a new CoS is required, monitoring the worker’s immigration status, and fulfilling reporting obligations. With the 2025 rule changes raising the bar for skill level and salary thresholds, the importance of diligent review and documentation has never been greater.
By understanding when material changes apply, issuing a new CoS where required, keeping thorough records, and reporting all necessary changes to UKVI, sponsors can reduce risk and maintain compliant operations.
For further insight, updates, and practical guidance on maintaining and renewing your sponsor licence, stay tuned to Sponsor Licence Hub — your essential resource for UK sponsorship compliance.
