Managing Work Locations on a Sponsor Licence has become a defining aspect of modern compliance for UK employers. In today’s landscape of flexible and hybrid working, where teams are often spread across offices, client sites and home setups, the way sponsors manage work locations is as important as the work itself. This topic isn’t just about geography — it’s about governance, oversight and accountability within a changing workplace culture.
Understanding how to align your internal processes with sponsor duties ensures your business runs smoothly while staying fully compliant. From recording office sites to documenting home-working patterns, each step builds the foundation of a resilient sponsor management system — one that keeps your operations adaptive, transparent and audit-ready.
Why work-location rules matter?
When applying for and maintaining a sponsor licence — whether under the Skilled Worker route or another Labour Market route — sponsors have a continuing obligation to notify the UK Home Office of any changes to the locations where sponsored workers carry out their duties. The official guidance, Workers and Temporary Workers: Guidance for Sponsors – Part 3: Sponsor Duties and Compliance, explicitly sets out this requirement.
Failure to meet these reporting obligations can have serious consequences, including the downgrading, suspension, or revocation of your licence. With hybrid working arrangements — encompassing office, home, and client sites — now the norm, sponsors must ensure their internal policies and record-keeping processes for managing work locations are comprehensive and up to date.
The latest policy position
To clarify the current position on hybrid working and multi-site operations under a sponsor licence:
- The Home Office guidance, version 11/25, recognises hybrid working as an established and accepted practice.
- According to the recent updates, sponsors are no longer required to report when a sponsored worker adopts a hybrid working pattern — that is, a mix of home or remote working combined with regular attendance at an office or client site, provided the worker’s main office or workplace and client sites remain the same.
- However, notification to the Home Office remains mandatory where:
- the worker’s main office or work location changes to a branch or site not currently listed on your licence;
- the worker will be working entirely remotely, with little or no requirement to attend your premises or a client site; or
- a new client site (over which you exercise control or oversight) is added and not yet recorded.
- Routine or occasional home working, or ad-hoc attendance at other branches, does not need to be reported. Only a substantive change to a worker’s regular working pattern or normal place of work must be notified.
Recording primary/secondary sites, client sites and home-working patterns
To ensure compliance under the “sponsor licence work location rules”, you should have in place clear policies and forms to record:
a) Primary/Secondary Sites
- Primary site (main office): The address recorded on the Certificate of Sponsorship (CoS) as the normal work location.
- Secondary sites/branches: Additional offices, satellite locations or branches inside your business where the worker will spend “regular” work time (for example, one day per week). These should be captured on your internal record sheet.
- For each secondary site, confirm whether the site is listed on your licence (and thus declared to the Home Office). If not, consider whether you need to make a change notification.
b) Client Sites
- If your sponsored worker will perform duties at a client’s premises (third-party site), those client sites should be documented, including address, client name, nature of work and estimated frequency/duration of visits.
- Determine whether you have “control” of the client site (for example, you supply supervision/monitoring of work) or if the worker is effectively “loaned” to the client (which may require additional obligations).
- The Home Office expects you to treat “working at a different … client’s site, not previously declared on the CoS” as reportable.
c) Home-working/Hub-working Patterns
- Define whether the worker will have remote working from home (or a co-working hub) as part of their routine.
- If they are working from home on a hybrid model (i.e., part-time home, part-time office/client) then you do not need to notify — but you must still keep properly documented records of the pattern (e.g., 3 days home / 2 days office) and how supervision/monitoring will be achieved.
- If the worker will be working entirely remotely (with minimal or no attendance at your premises or a client site) then this must be notified as a change of work location.
A Checklist (A Guidance)
| Field | Description |
| Worker Name & CoS No. | Unique identifier matching your SMS record |
| Main Work Location Address | As per CoS |
| Additional Branch/Site Addresses | All offices/branches where the worker will regularly attend |
| Client Site Addresses | Any third-party client premises where the worker will work |
| Home-working details | Days per week, address of remote hub/home, frequency of attendance at main site |
| Supervision/Monitoring Arrangements | How performance/supervision will be maintained for remote/home work |
| Change Notification Requirement | Flag: Yes/No – based on whether home/hybrid vs full remote or new branch/client site |
| Date of last review | For audit and compliance purposes |
What counts as a reportable change under the “sponsor licence work location rules”
Under the current guidance, a change becomes reportable when there is a regulated alteration to a sponsored worker’s normal work location. The following examples illustrate how this applies in practice:
- Transfer between branches: If a worker moves from one registered branch (A) to another branch (B) that is not recorded on the Certificate of Sponsorship (CoS) or sponsor licence, a report is required.
- New client site: If the worker is reassigned to a client site not listed on the CoS or sponsor records, a report is required.
- Fully remote working: If a worker transitions from office-based to entirely home-based work, with little or no requirement to attend your premises or a client site, a report is required.
- Hybrid working model: If a worker moves to a hybrid arrangement (home and office/client site) but the main office or client site remains unchanged, and no new branch or client site is added, no report is required, though monitoring and record-keeping must continue.
- Ad hoc or occasional changes: Day-to-day variations, such as attending a different branch once a month or working from home one day per week, are not reportable.
Timing of Notification
Where a reportable change occurs, sponsors must update the Sponsor Management System (SMS) within 10 working days.
Why It Matters?
Failure to report a qualifying change can place your sponsor licence at risk. The Home Office retains the power to downgrade, suspend or revoke a licence for non-compliance. Sponsors must also be able to demonstrate how they supervise, monitor and record the activities of remote or off-site workers, evidencing adherence to the sponsor duties set out in the official guidance.
Supervision & Monitoring: proving compliance
One of the sponsor’s core duties is to ensure sponsored workers are supervised and perform the duties detailed on the Certificate of Sponsorship. When work takes place at multiple locations or remotely, you need to implement robust oversight. Key steps:
- Document supervision arrangements: For each location (office, client site, home/hub), clarify how supervision will take place: e.g., line-manager check-ins, remote video supervision, site visits, timesheet/location tracking.
- Maintain attendance records: Especially if the worker spends time at different sites or from home/hub, keep records of days present, location-split, and any deviations.
- Review working patterns regularly: At least quarterly, check that the worker’s location splits still align with those recorded when the CoS was issued or updated.
- Update internal records: Any material change (for example, new client site, shift to full remote working) must prompt internal review and, if reportable, external notification.
- Archive evidence: Keep internal forms, records of home-working agreements, client site addresses and visit frequency for at least the minimum retention period specified by the guidance (typically sponsorship records must be kept for 1 year after last reportable action).
Final words!
Multi-site and hybrid working are now permanent features of how sponsored workers operate in the UK, and how sponsors must manage their compliance responsibilities. But the real difference lies in approach: systems, not stress. When your records are accurate, your reporting prompt, and your internal supervision are solid, multi-location working becomes an asset, not a liability.
So, whether your team is spread between a Manchester office, a London client site, or working from home in Leeds, clarity and documentation are what keep your licence strong.
Follow Sponsor Licence Hub for clear, current guidance on UKVI sponsor duties, reporting changes, and managing compliance under the 2025 rules — explained the way sponsors actually work today.
