Sponsor Licence Reporting Deadline: What Must Be Reported in 10 or 20 Working Days?

Introduction: Why Missing a Reporting Deadline Can Cost You Your Licence

Failing to report changes to UK Visas and Immigration (UKVI) can put an employer's sponsor licence at risk, even where the underlying employment arrangements remain compliant with immigration law.

During sponsor compliance checks, UKVI examines whether the information recorded on the Sponsorship Management System (SMS) accurately reflects an organisation's employment practices. Late or missing reports can raise concerns about whether a sponsor has adequate compliance procedures in place, potentially resulting in a licence being downgraded, suspended or revoked.

Every licensed sponsor has mandatory reporting obligations. Most changes affecting individual sponsored workers must be reported within 10 working days, while significant changes to the sponsoring organisation generally have a 20-working-day deadline.

However, these deadlines are not universal. Certain circumstances require earlier action, while others have specific reporting rules that employers must understand.

This guide explains the sponsor licence reporting duties deadlines that UK employers must follow, including which changes must be reported, how to make reports through the SMS, and how to protect your organisation from avoidable compliance breaches.

What Are the Sponsor Licence Reporting Deadlines?

Under the Home Office's Workers and Temporary Workers: Guidance for Sponsors, Part 3, employers holding a sponsor licence must notify UKVI of specified changes affecting their sponsored workers or organisation.

The two principal reporting deadlines are:

Working days generally exclude weekends and bank holidays. However, employers should identify the event that starts the reporting period rather than simply calculating the deadline from when their HR department becomes aware of it.

For worker-related changes, the standard deadline runs from the relevant event. For most organisational changes, paragraph C2.3 specifies 20 working days from when the sponsor became aware of the change, subject to exceptions.

What Must Sponsors Report Within 10 Working Days?

The 10-working-day reporting requirement primarily concerns changes affecting the employment or circumstances of individual sponsored workers.

These reports are generally submitted through the 'Report migrant activity' function within the SMS.

1. A Sponsored Worker Does Not Start Employment

Sponsors must normally ensure that a worker begins their sponsored employment within 28 days of the relevant start date established under the Home Office guidance.

The applicable date depends on factors including the start date recorded on the Certificate of Sponsorship (CoS), the validity date of the worker's immigration permission and when their visa was granted.

If the worker has not started within the permitted 28-day period, the sponsor must either:

• Report the revised start date and explain the reasons for the delay; or
• Withdraw sponsorship if the individual will no longer take up the employment.

This report must be submitted within 10 working days after the end of the 28-day period.

UKVI may accept reasonable explanations for delays, including illness, travel disruption or the need to complete a contractual notice period. However, the Home Office retains discretion to assess the circumstances.

2. Unauthorised Absence Exceeding 10 Working Days

If a sponsored worker is absent from employment without permission for more than 10 consecutive working days, the sponsor must notify UKVI.

The report must be submitted no later than 10 working days after the tenth consecutive working day of absence.

Importantly, this obligation applies even where the employer intends to continue sponsoring the individual.

The sponsor should explain when the absence began, whether the worker has returned, any attempts to contact them, and whether sponsorship will continue.

This is distinct from authorised annual leave, sickness absence or other approved absences, which are subject to different rules.

3. Unpaid Leave or Reduced Pay Exceeding Four Weeks

Sponsors must report where a sponsored worker is absent without pay, or on reduced pay, for more than four weeks in total during a calendar year.

The four-week threshold is assessed against the worker's normal working pattern, and separate periods of absence are added together.

Ordinarily, sponsorship must cease if the threshold is exceeded without an applicable exception.

However, permitted exceptions include sickness absence, statutory maternity or paternity leave, statutory adoption leave, jury service and certain other circumstances recognised by UKVI.

Where an exception applies, the sponsor may continue sponsorship but must still report the qualifying absence.

Employers should therefore distinguish between whether an absence is permitted and whether it needs to be reported. These are separate compliance considerations.

4. Changes to Salary or Employment Duties

A sponsored worker's salary or pay being reduced from the amount recorded on their CoS will generally require reporting within 10 working days.

This includes relevant changes that may affect whether the worker continues to meet the salary requirements of their immigration route.

Salary increases do not normally require reporting, although certain exceptions apply, including where an overseas-qualified nurse or midwife completes professional registration.

Significant changes to employment duties must also be reported where a new immigration application is not required. Examples include:

• A promotion or change in job title.
• A substantial adjustment to core responsibilities.
• A change of role within the same eligible occupation code.
• Certain permitted changes under the Home Office's change-of-employment exceptions.

A critical distinction is that submitting an SMS report does not automatically authorise a worker to undertake a completely different sponsored role.

Where a new occupation code or other material change triggers a change-of-employment application, a new CoS and visa approval may be required before the worker begins the new role.

5. Changes to a Sponsored Worker's Normal Work Location

Employers must report changes to a sponsored worker's normal work location, including movement to another branch, office or client site not previously recorded on the CoS.

The distinction between hybrid and fully remote working is particularly important. Under the current guidance:

• Routine hybrid working between home and an existing office does not, by itself, require an SMS report.
• A change to the worker's main office or regular client site generally requires reporting.
• Permanent, fully remote contractual home working must be reported where the employee has little or no requirement to attend a workplace.

Sponsors must maintain appropriate records of working arrangements, even where an SMS notification is unnecessary.

6. A Sponsored Worker Leaves Employment

Employers must report when they cease sponsoring an individual, including where the worker:

• Resigns or is dismissed.
• Is made redundant.
• Leaves before the end date recorded on their CoS.
• Decides not to take up the sponsored position.
• Obtains indefinite leave to remain or other immigration permission that no longer requires sponsorship.
• Can no longer fulfil their sponsored employment because of the loss of required professional registration.

The report should specify the reason sponsorship has ended and the relevant date.

Where sponsorship is withdrawn, the sponsor must also provide the worker's last recorded residential address, contact telephone number and any personal email addresses held.

Employers should be aware that withdrawing sponsorship may result in UKVI cancelling or shortening the individual's immigration permission.

What Must Sponsors Report Within 20 Working Days?

The 20-working-day reporting deadline generally relates to changes affecting the sponsor organisation rather than an individual worker.

1. Changes to Company Details

Sponsors must notify UKVI of significant changes to their organisation's registered or operational details.

Examples include changes to the:

• Organisation's name
• Main business or head office address
• Contact details
• Branch or site information
• Nature of the organisation's business activities

These details must remain accurate because UKVI relies on them when assessing the sponsor's ongoing suitability and conducting compliance checks.

2. Changes to Company Structure or Ownership

Significant structural changes must also be reported. These include mergers, takeovers, de-mergers, changes in direct ownership and certain corporate reorganisations.

A sponsor licence is not automatically transferable between legal entities.

Depending on the arrangement, an organisation may need to apply for a new sponsor licence, even where the sponsored workers remain in their existing positions.

For mergers, takeovers and similar transactions, the guidance specifically requires notification within 20 working days of the change taking place.

Where sponsored workers transfer under the Transfer of Undertakings (Protection of Employment) Regulations (TUPE) or similar protection, both the transferring and receiving organisations may have obligations.

An acquiring organisation that does not already hold the appropriate sponsor licence must generally apply for one, or extend its existing licence, within 20 working days of the workers transferring.

Failing to take the appropriate action can place those workers' immigration permission at risk.

3. Changes to Organisation Size or Charitable Status

Sponsors must report changes affecting their classification as a small or large organisation, or their charitable status. These changes can affect the fees payable for sponsor licensing and the Immigration Skills Charge. For example, an organisation that no longer qualifies as a small business must update UKVI rather than continuing to rely on its former classification.

4. Changes to Regulatory Registration or Accreditation

Where an organisation must hold a particular regulatory registration, licence or accreditation to operate or qualify as a sponsor, changes to that status must be reported. This may include the loss, suspension or alteration of a required registration. Such changes can directly affect whether the organisation remains eligible to sponsor overseas workers.

5. Insolvency or Cessation of Trading

Sponsors must notify UKVI if they cease trading or enter relevant insolvency procedures, including administration, liquidation or a company voluntary arrangement.

The precise reporting requirement depends on the nature of the procedure. For example, a company entering administration must notify UKVI within 20 working days. Additional requirements apply concerning the appointment of the administrator as Authorising Officer.

Are There Exceptions to the 10- and 20-Working-Day Deadlines?

Yes. Sponsors should not assume that every notification can be made within one of the two standard periods.

Changes to Key Personnel

The Home Office requires sponsors to keep their Authorising Officer, Key Contact and SMS user information accurate.

Importantly, paragraph C2.3 expressly excludes replacement of the Authorising Officer or Key Contact from its usual 20-working-day reporting rule.

These changes should be managed promptly, ideally before an existing appointment ends where practicable.

Sponsors must also retain at least one Level 1 User with the necessary SMS access at all times, unless surrendering their licence.

Suspected Breaches of Immigration Conditions

Where an employer knows or suspects that a sponsored worker has breached their conditions of stay, UKVI must be informed as soon as reasonably practicable.

Employers should not assume that the ordinary 10-working-day deadline authorises them to delay reporting such concerns.

How Do Employers Report Changes Through the SMS?

Most sponsor reporting obligations are fulfilled through the Home Office's Sponsorship Management System.

The process generally involves the following steps:

• Log in to the SMS. An appropriately authorised Level 1 User should access the sponsor's account.
• Select the relevant reporting function. Worker-related changes are generally reported using 'Report migrant activity', while organisational changes are normally submitted through the licence details or user management functions.
• Provide accurate information. Include the relevant dates, circumstances, explanation and supporting details required by UKVI.
• Submit and retain evidence. Keep a record of the submission, including the date and any supporting documentation or subsequent correspondence.

Where an organisation no longer has an active Level 1 User with SMS access, certain changes must instead be submitted using the Home Office's sponsor change of circumstances form.

UKVI provides detailed instructions in SMS Manual 9: Reporting Worker Activity and SMS Manual 2: Managing Your Licence.

What Happens If You Miss a Sponsor Reporting Deadline?

Missing a sponsor reporting deadline constitutes a potential breach of the duties attached to the sponsor licence.

The Home Office has several enforcement options, depending on the nature and seriousness of the non-compliance.

These include:

Not every late report automatically results in revocation. UKVI considers the relevant circumstances, compliance history and seriousness of the breach.

However, repeated failures, inaccurate reporting or evidence of inadequate HR systems can significantly increase the risk of enforcement action.

Where a sponsor discovers that a reporting deadline has already passed, the priority should be to submit the outstanding notification promptly, preserve an accurate record of events and investigate why the deadline was missed.

A late report does not automatically remedy the original breach, but ignoring the matter could create further compliance concerns.

How Can Employers Avoid Missing Reporting Deadlines?

Effective sponsor licence compliance requires clear procedures and communication between HR, payroll, recruitment teams and the individuals responsible for managing the SMS.

Employers should consider implementing the following measures:

• Maintain a central sponsorship register: Record each sponsored worker's immigration permission, CoS details, salary, job title, work location and reporting history.
• Establish internal notification procedures: Ensure managers inform the immigration or HR team promptly when a sponsored worker's circumstances change.
• Monitor absence and payroll records: Identify unauthorised absences, prolonged unpaid leave and changes to remuneration before reporting deadlines are missed.
• Review proposed employment changes: Assess whether promotions, restructures or relocations require an SMS notification or a new visa application.
• Conduct regular sponsor compliance audits: Compare SMS records with contracts, payroll, attendance records and corporate information.

Proactive monitoring is particularly important because reporting deadlines may begin before the individual responsible for managing the licence becomes aware of an event.

Frequently Asked Questions

Does a sponsor need to report every salary increase?

No. Salary increases do not ordinarily need to be reported, although specific exceptions apply. Salary reductions generally require reporting and must be assessed against the applicable immigration requirements.

Does hybrid working need to be reported to UKVI?

Not normally. Moving to a routine hybrid working arrangement does not itself require notification, provided the relevant main office and client-site details remain unchanged. Permanent fully remote contractual arrangements are treated differently.

Do sponsors need to report annual leave?

Ordinary authorised annual leave does not generally require an SMS report. However, employers must retain appropriate absence records and consider the separate reporting requirements for unauthorised absence and extended periods of unpaid or reduced-pay absence.

Can an employer make a late SMS report?

Yes. Employers should submit overdue notifications promptly and retain records explaining the delay. However, late reporting does not remove the possibility of compliance action.

Who is responsible for sponsor licence reporting duties?

The sponsoring organisation remains responsible for meeting its compliance obligations. Although a Level 1 User or appointed immigration adviser may carry out SMS reporting, outsourcing the administrative process does not transfer ultimate responsibility away from the sponsor.

Conclusion: Protecting Your Sponsor Licence Through Timely Reporting

Understanding sponsor licence reporting duties deadlines is essential for every UK employer sponsoring overseas workers.

The principal distinction is straightforward: most reportable worker-related changes must be notified within 10 working days, while most significant organisational changes must be reported within 20 working days.

Nevertheless, employers must recognise the exceptions, including special reporting triggers, earlier notification obligations and additional evidence requirements.

Missing a deadline can have consequences extending well beyond an individual reporting failure, potentially affecting an organisation's ability to recruit, retain and sponsor overseas employees.

How Migrate UK Can Help

At Migrate UK, we support employers with their ongoing sponsor licence compliance obligations, including SMS reporting, changes to sponsored workers' circumstances, corporate restructures and compliance reviews.

Whether your organisation requires assistance with a particular change or broader support managing its sponsor licence, our immigration specialists can help identify the relevant obligations and ensure reporting is completed accurately and within the applicable deadlines.

Contact Migrate UK for guidance on sponsor reporting obligations and ongoing sponsor licence compliance.