Holding a UK sponsor licence in 2025 comes with a fair share of responsibility, but it doesn’t have to feel daunting. Think of it as a partnership between your organisation and the Home Office, where clear communication and careful record-keeping keep everything running smoothly. At the heart of this relationship is the Sponsorship Management System (SMS), your online control panel for all things sponsorship. It’s where you update details, track changes, and make sure every step follows the rules.
In this guide, we’ll walk through the key duties that every licence holder needs to know, from timely reporting to organised record-keeping and keeping an eye on immigration status. And because things don’t always go to plan, we’ll also look at what can happen if those responsibilities are overlooked — and how staying on top of them can keep your licence, and your recruitment plans, in good standing.
Sponsorship Management System (SMS)?
The SMS is an online platform provided by UK Visas and Immigration (UKVI) that allows sponsor licence holders, whether in education or employer routes, to manage day-to-day sponsorship tasks such as creating Certificates of Sponsorship (CoS), Confirmations of Acceptance for Studies (CAS), and reporting changes in a migrant’s circumstances.
Core Duties of a UK Sponsor Licence Holder Under 2025 Rules.
UK sponsor licence holders must adhere to multiple layers of UK sponsor compliance rules, including reporting, record-keeping, and monitoring. These steps ensure both UK immigration safety and organisational accountability.
1. Mandatory Reporting Duties
Sponsors have a legal obligation to report various types of changes immediately via SMS to maintain compliance. Key areas include:
- Changes to sponsored migrant’s details: If a worker or student’s circumstances change—e.g., delayed entry, absence, or employment role modifications—sponsors must report via SMS without delay.
- Sponsorship withdrawal: If sponsorship ends prematurely, this must be updated in SMS via “report migrant activity,” available to Level 2 users for the CoS they assigned.
- Changes to sponsor’s own circumstances: Licence details—such as address, key personnel (Authorising Officer or Key Contact), ownership, or site changes—must be reported via SMS using correct functions, with some changes requiring supporting evidence.
Failure to report such changes accurately or promptly may constitute a breach of UK sponsor compliance rules, exposing sponsors to enforcement action.
2. Record-keeping Obligations
Sponsors are also required to maintain detailed records for all sponsored migrants:
- Right-to-work checks, contracts, salary evidence: For worker sponsors, this includes conducting and retaining proof of right-to-work checks, employment contracts, and salary documentation as required under immigration and employment law.
- For student sponsors, documents—enrolment records, CAS-related documents, and living arrangements for child students—must be retained until at least one year after sponsorship ends or until approval by a compliance officer
- Document retention periods: Education providers must keep all records relating to students throughout sponsorship and for the period specified (e.g., one year after sponsorship ends or when examined by compliance teams)
Robust record-keeping supports audit responses, compliance reviews, and protects sponsors from non-compliance findings.
3. Monitoring Immigration Status
Ongoing monitoring is essential to ensure migrants continue to meet visa conditions:
- Sponsors should verify that sponsored individuals maintain a valid immigration status throughout sponsorship.
- Regular checks—including confirming continued UK presence, valid visa permissions, and job role alignment—are vital.
- Any concerns—such as suspicious conduct or visa breach—must be handled by reporting via SMS and cooperating with UKVI as needed.
4. Using the SMS: Practical Steps and Roles
To successfully manage responsibilities via SMS, sponsors must understand both functionality and user roles:
a) User Roles and Access Levels
- Level 1 users manage core licence settings, including personnel changes and licence details.
- Level 2 users enable routine tasks—assigning CoS/CAS, reporting migrant activity—but only for CAS/CoS created by them.
b) Performing Key SMS Actions
- Assigning CoS/CAS: Navigate the SMS menus by relevant manuals.
- Reporting changes: Use the “report migrant activity” screen to notify UKVI of employment or study changes. Though it’s not the sole method for reporting all employment or study changes. It is primarily used for reporting sponsored migrant activity, specifically by Tier 2 and 5 sponsors. Other changes related to employment or study, especially for non-sponsored individuals, might require different reporting procedures.
c) Managing CoS/CAS Allocations
- Sponsors are responsible for monitoring their allocated Certificate of Sponsorship (CoS) or Confirmation of Acceptance for Studies (CAS) quotas, and they can manage renewals and increases, either manually or automatically, through the Sponsorship Management System (SMS).
Real-World Examples: Consequences of Non-Compliance.
Even a small compliance slip can have serious consequences for sponsors. The following real-world style examples show how simple oversights, often administrative, can lead to downgrades or even the loss of a sponsor licence.
| Example | Scenario | Outcome |
| 1 | A UK employer failed to report a sponsored worker’s absence via SMS. An immigration compliance visit uncovered the breach. | Licence downgraded from A-rated to B-rated, restricting the ability to issue new Certificates of Sponsorship (CoS). |
| 2 | A student sponsor did not retain documents for students who had completed their course over one year ago. | The compliance audit resulted in the revocation of their student sponsor licence. |
| 3 | A sponsor updated their Authorising Officer’s details in SMS but failed to submit the required submission sheet. UKVI kept the change marked as “Pending” and later took action. | Licence revoked due to prolonged inaccuracy in records. |
Key Duties in UK Sponsor Compliance Rules
To meet all legal requirements under the latest 2025 rules, sponsor licence holders must:
1. Report changes promptly
a) Worker/student details: absences, role changes, visa issues.
b) Licence changes: key personnel, address, organisational structure.
2. Maintain comprehensive records
a) Right-to-work checks, contracts, and salary documentation.
b) Student documents, CAS assignments, living arrangements.
c) Retain records for the duration of sponsorship and the required period thereafter.
3. Monitor immigration status
a) Ensure the validity of permission to work or study
b) Identify and report breaches or suspicious conduct
4. Use SMS effectively
a) Assign and manage CAS/CoS responsibly.
b) Manage users and licence settings via appropriate SMS manuals
c) Apply for renewed or additional allocations proactively
Failure to perform these duties may trigger sanctions, including downgrades, suspensions, or revocations.
Take Away!
Navigating the Sponsor Management System (SMS) isn’t just about ticking boxes; it’s about safeguarding your licence, maintaining trust with UKVI, and ensuring vulnerable migration routes aren’t abused. By understanding and fulfilling core duties, reporting, record-keeping, monitoring, and leveraging SMS effectively, sponsor licence holders can remain compliant under the UK sponsor compliance rules and build resilient, responsible organisations.
If you want to stay one step ahead of the rule changes (and avoid any “wish I’d known that sooner” moments), make the Sponsor Licence Hub your regular stop. It’s where the latest updates, practical tips, and need-to-know insights on sponsor compliance land first, so you’re always in the know before the knock on the door.
