Reporting Deadlines Cheat Sheet isn’t just a handy phrase — it’s a lifeline for every organisation navigating the intricate world of UK sponsor licence management. Holding a sponsor licence comes with weighty responsibility, and much of it revolves around timing. Each update, notification, or declaration submitted through the Sponsorship Management System (SMS) forms part of a larger compliance story — one that UKVI expects to be precise, traceable, and timely. For many employers, juggling staff management with regulatory duties can feel like balancing on a tightrope: one small delay or missed entry can cascade into compliance breaches, warning letters, or even licence suspension.
But beyond the pressure of deadlines lies an opportunity for structure. The Reporting Deadlines Cheat Sheet is about transforming the complex into the clear — a roadmap for keeping your sponsorship duties running smoothly. It’s not just about ticking boxes or meeting UKVI timelines; it’s about embedding accuracy into your organisation’s day-to-day operations. From understanding how to log non-attendance to ensuring every location or role change is properly documented, it’s this awareness that distinguishes a reactive sponsor from a proactive one.
Table of Events & Deadlines
| Event/circumstance | Deadline (working days) | Evidence to keep (recommended) |
| Sponsored worker does not start the role as agreed (delay more than 28 days) | 10 working days after the 28 days | CoS details, correspondence with worker, new start date justification, SMS submission screenshot |
| The sponsored worker is absent without permission for more than 10 consecutive working days | 10 working days of the event | Attendance records, emails/calls re absence, SMS submission screenshot |
| Sponsored worker absent without pay or reduced pay for more than 4 weeks in a calendar year (or during sponsorship period for Scale-up Worker) | 10 working days | Payroll records, contract, SMS submission screenshot |
| Sponsored worker change’s role title/core duties/promoted (within same occupation code) OR normal work location changes | 10 working days | Contract variation, SOC code mapping, SMS submission screenshot |
| Sponsored worker’s salary paid is less than stated on CoS | 10 working days | Payroll records, original CoS salary, SMS submission screenshot |
| End of sponsorship (worker leaves role, contract terminates or is no longer sponsored) | 10 working days | Final salary record, termination letter, SMS submission screenshot |
| Business ceases trading, becomes insolvent, or there is a merger/takeover | 20 working days | Board minutes, financial statements, SMS submission screenshot |
| Business changes, address or authorising officer changes | 20 working days | Change of address notice, HR records, SMS submission screenshot |
| Business changes the nature of business substantially, or the relationship with overseas business changes | 20 working days | Organisational chart, contract changes, SMS submission screenshot |
Note: These deadlines align with the guidance in “Workers and Temporary Workers: guidance for sponsors – Part 3: sponsor duties and compliance”.
What You Must Report, When and How?
Worker-related changes
Under section C1 of the sponsor guidance, employers are expected to report any relevant changes to a sponsored worker’s circumstances within 10 working days of the event. This includes matters such as delayed start dates, absences, salary adjustments, changes in duties or work location, and early termination of employment. Earlier guidance set specific parameters for reporting delayed starts, while the current framework continues to emphasise timely updates. The “Report migrant activity” function within the Sponsorship Management System (SMS) remains the standard route for such notifications, unless otherwise specified by route-specific instructions.
Sponsor-organisational changes
Section C2 of the sponsor guidance addresses organisational changes, requiring sponsors to report these within 20 working days unless otherwise specified. Such changes may include an alteration of business address, a shift in operations, insolvency or takeover events, and amendments to secondment or contractual arrangements.
Record-keeping requirements
Appendix D of the sponsor guidance outlines the documentation that sponsors are required to maintain in order to fulfil their obligations. This includes records of right-to-work checks, copies of passports or immigration documents, contact information for sponsored workers, as well as detailed wage and absence records.
Mistakes to Avoid – 2025 Audit Pitfalls
Many sponsor licence holders in 2025 have faced compliance checks and audits from UKVI and have been found wanting because of:
- Delayed reporting: Failing to make SMS notifications within the required 10 or 20 working days.
- Poor record-keeping: Missing evidence of checks, attendance logs, proof of pay, and SMS submissions. Appendix D emphasises this.
- Incorrect SOC code mapping: When roles change but sponsors claim the same occupation code improperly, this can trigger investigations.
- Misunderstanding delayed start date rules: After 22 July 2025, only delays beyond 28 days need reporting in some cases.
- Changes in company size thresholds (6 April 2025): Failure to update business classification and report under 20 working-day rules.
To be audit-ready, maintain a compliance file with each SMS submission record, annotated reason for change, and supporting documents. Audit panels in 2025 are focusing more closely on the ‘why’ behind each change and whether the sponsor has systems to monitor and report.
Practical Steps for Compliance
- Map your internal processes: Ensure HR/immigration teams know which changes trigger a report, which SMS path to use, and the deadline.
- Maintain a reporting log: For each change, record the date of the event, date of SMS notification, reference number, and supervise to ensure timely submission.
- Retain evidence: Screenshots of SMS submissions, e-mail trails, attendance logs, contract amendments, and payroll evidence. Keep for at least the retention period specified in Appendix D.
- Train your staff: Ensure all stakeholders (authorising officer, key contact, level 1 user) understand their reporting duties, particularly for “sponsor reporting deadlines UKVI”.
- Audit check-ups: Quarterly reviews of SMS logs, record-keeping, and any delays. Check past anomalies and prepare for a possible UKVI inspection.
- Update your compliance policy: Reflect the 2025 changes.
- Use SMS promptly: The guidance emphasises using “Report migrant activity” unless an alternative route applies.
- Be ready for organisational changes: Not just worker changes, but your own business changes must be reported within 20 working days.
Final Thoughts!
Compliance with sponsor reporting deadlines is more than an administrative requirement — it is a reflection of your organisation’s integrity and commitment to due diligence. While the table above outlines what, when, and how to report within the SMS, the true measure of compliance lies in consistency and care. Each update, record, and process strengthens your organisation’s reputation as a reliable sponsor, capable of meeting UKVI expectations with precision and professionalism.
In the end, maintaining a sponsor licence isn’t about ticking boxes — it’s about building a compliance culture that endures. When your reporting systems run smoothly, your records stay audit-ready, and your communication remains transparent, you not only protect your licence but also enhance your credibility as an employer of choice.
For more guidance, insights, and updates on sponsor duties and reporting best practices, follow Sponsor Licence Hub — your trusted partner in navigating the UK sponsorship landscape with confidence and clarity.
