Managing an Existing UK Sponsor Licence: A Guide for HR Teams 

Introduction: Taking Over Sponsorship Responsibilities

Taking over responsibility for a UK sponsor licence can be more complicated than it first appears. A HR manager might inherit sponsorship duties following a resignation, a change in HR leadership, an internal restructure or the departure of the employee who originally managed the organisation’s licence.

The problem is that sponsorship responsibilities do not disappear when the person responsible for them leaves. Your organisation remains accountable for meeting its Home Office sponsor duties, even if the relevant records are incomplete, the login details have been lost or nobody is entirely sure which employees have been sponsored.

Before making changes or assigning new Certificates of Sponsorship (CoS), it is worth carrying out a structured review of the licence, its users and the organisation’s existing sponsorship records.

This guide explains how to take over a sponsor licence, regain access to the Sponsor Management System (SMS), identify potential compliance issues and establish a reliable process for managing sponsorship going forward.

1. Check Who Has Access to the Sponsor Management System

The first step when taking over a sponsor licence is to establish whether you can access the Home Office’s Sponsor Management System.

The SMS is the online system through which licensed sponsors manage their licences, report relevant changes, request Certificates of Sponsorship and maintain their sponsorship arrangements.

You should establish:

• Who currently has SMS access.
• Whether the organisation has an active Level 1 User.
• Whether the Authorising Officer (AO) listed on the licence is still employed by the organisation and able to fulfil the role.
• Whether the Key Contact details are current.
• Whether the login credentials and registered email addresses are accessible.
• Whether the organisation has any external legal representatives linked to its licence.

Why an active Level 1 User matters

A Level 1 User is responsible for carrying out key functions on the SMS. These include managing users, requesting changes to licence details and undertaking important sponsorship administration.

If the only Level 1 User has left the organisation, you may find that nobody internally can make the changes needed to keep the licence up to date. This can affect routine administration as well as the organisation’s ability to respond promptly to changes or future recruitment requirements.

The position of the Authorising Officer is equally important. The AO is the senior person responsible for the organisation’s activities as a licensed sponsor and must meet the relevant eligibility requirements. The AO is not simply a name that needs to appear on a form: the role carries responsibility for the organisation’s sponsorship arrangements.

If your organisation no longer has an eligible, active AO, or has no functioning Level 1 User, treat this as a priority. An unresolved gap in key personnel can create difficulties in demonstrating that the organisation is managing its licence appropriately and can prompt Home Office scrutiny.

Do not assume that the licence is being managed simply because sponsored employees continue to work for the organisation or because the licence has not been suspended.

2. What If the Previous HR Manager Has Left and Nobody Has the Login Details?

This is a common problem when sponsorship responsibilities are transferred between employees.

You may know that the organisation holds a sponsor licence but have no access to the previous manager’s email account, no record of the username and no working password.

The correct approach depends on which details are missing.

If you have the username but have forgotten the password

Use the SMS login page and follow the available password-reset process. You will generally need the username and access to the relevant registered email account to complete the process.

If the reset email goes to an account that the organisation can no longer access, or the password-reset process does not work, you will need to contact the Home Office Business Helpdesk.

Do not assume that creating a new SMS account is an alternative to recovering access to the existing licence.

If you have lost the username or cannot access the registered email account

Start by checking your internal records. The original licence application, correspondence from the Home Office, previous HR handover documents and emails relating to Certificates of Sponsorship may help establish which accounts were used.

If these searches do not resolve the problem, contact the Home Office Business Helpdesk:

Email: BusinessHelpdesk@homeoffice.gov.uk

Telephone: 0300 123 4699

Explain that you are trying to recover access to an existing sponsor licence and that the previous person responsible has left. Have the organisation’s details and sponsor licence reference available if you know it.

The Business Helpdesk can advise on the appropriate recovery process. It is important to distinguish between recovering login details and formally changing the people responsible for the licence: these are separate issues.

What if the previous Authorising Officer or other key personnel have left?

Where the organisation needs to replace its AO, Key Contact or other relevant personnel, a formal change may be required through the Home Office’s prescribed process.

If you cannot access the SMS to make the change, you may need to submit a manual change of circumstances form. This is particularly relevant where the organisation has lost access because its previous key personnel have moved on.

Follow the current Home Office instructions for the form and supporting information required. A manual notification should not be treated as an automatic restoration of SMS access, nor as confirmation that the Home Office has accepted every proposed change.

Keep a copy of the submission and any acknowledgement or correspondence received. If the change is urgent, make sure you understand what remains outstanding rather than assuming that the licence details have already been updated.

The important point is to establish a documented route back to effective control of the licence, rather than allowing the problem to remain unresolved.

3. Consider Appointing a Legal Representative as a Level 1 User

One practical way to improve continuity is to appoint an appropriate immigration legal representative as a Level 1 User on the organisation’s sponsor licence, where permitted under the current rules.

This can be particularly valuable for businesses where HR staff change regularly, the organisation has a small internal HR team or sponsorship is only one part of a wider people-management role.

An appropriately appointed representative can help maintain access to the SMS and support the organisation with routine sponsorship administration. If an HR manager leaves, the organisation is less likely to find that all practical knowledge of the licence has disappeared with them.

The arrangement can also provide a consistent point of contact for questions about sponsorship duties, reporting changes and requesting CoS allocations.

However, appointing a legal representative does not transfer the organisation’s sponsor duties to that representative. The organisation remains responsible for its compliance, and the AO must continue to fulfil the responsibilities attached to the role.

It is also important to distinguish between having a representative linked to the licence and having a clear service arrangement defining what that representative will actually do. Access alone does not guarantee that changes will be reported, visa expiry dates will be monitored or records will be maintained.

A useful arrangement should specify who is responsible for each task, how instructions are given, what needs to be escalated and how the organisation retains oversight.

For organisations that rely on a small HR team, this can provide an additional layer of continuity without requiring every sponsorship task to sit with one employee.

4. Review the Licence Summary Page Before Making Changes

Once you have access to the SMS, do not immediately start assigning Certificates of Sponsorship or submitting change requests. First, establish what the licence currently says.

The licence summary page is a useful starting point. Compare the details recorded on the SMS against the organisation’s current structure and internal records.

Check the following:

• Authorising Officer: Is the named individual still employed and eligible to hold the role?
• Key Contact: Are the contact details correct?
• Level 1 Users: Are the users still authorised to access the system, and are their details current?
• Organisation details: Is the registered name, address and other relevant information accurate?
• Licence routes: Does the organisation hold the appropriate routes for its current and anticipated recruitment needs?
• Branches and linked entities: Are the relevant locations and organisational arrangements correctly recorded?
• Certificate of Sponsorship allocation: How many undefined CoS remain available, and when does the allocation expire?
• SMS messages: Are there outstanding messages, requests or notifications that require attention?

Remember that the Authorising Officer and Key Contact do not automatically have SMS access simply because they are named on the licence. They must also be appointed as SMS users if they need to log in.

Check whether your organisation needs undefined Certificates of Sponsorship

If your organisation expects to sponsor further workers, check the available undefined CoS allocation.

Undefined CoS are generally used for Skilled Workers applying to extend or switch their permission from within the UK, and for workers sponsored under other relevant work routes. Defined CoS are used for Skilled Workers applying for entry clearance from outside the UK.

If the organisation needs more undefined CoS than are currently available, a Level 1 User can submit an in-year allocation request through the SMS.

You should also check when the existing allocation expires and whether an annual allocation request will be needed for the next allocation period.

It is better to identify a shortfall before a recruitment deadline becomes urgent. Remember that a request for additional CoS is subject to Home Office consideration; submitting a request does not guarantee approval.

Check whether the organisation’s size needs updating

The organisation’s size classification is another detail worth checking, particularly if it has grown, been acquired or undergone a restructure since the licence was granted.

Where the relevant sponsorship rules require the organisation to be classified as a small or medium-sized enterprise or a large organisation, make sure the classification is correct.

For a company, the statutory small-company definition generally considers three criteria:

• Annual turnover.
• Balance sheet total.
• Average number of employees.

A company will generally need to meet at least two of the three applicable statutory thresholds to qualify as small, subject to the detailed rules and exclusions. A parent company may also need to consider whether its group qualifies as a small group.

Do not assume that a business is small simply because it has a relatively small HR department, operates from one office or employs fewer than 50 people. Equally, do not assume that an organisation is large merely because it forms part of a wider group without checking the applicable rules.

The relevant financial thresholds and treatment of group companies should be checked against the current statutory definition and the applicable sponsor guidance.

Why does this matter? An incorrect classification can affect the accuracy of licence information and the way certain sponsorship-related fees or requirements are assessed. If the organisation’s circumstances have changed, establish whether an update is required and follow the appropriate reporting process.

5. Check Whether You Have an Authorising Officer in Place Before Approaching the Home Office

If you discover that the previous Authorising Officer has left and no replacement has been appointed, this should be treated as a priority.

The Home Office requires sponsors to have an eligible Authorising Officer and at least one eligible Level 1 User throughout the life of the licence. Failing to maintain these key personnel can put the licence at risk, including the possibility of revocation.

There is an important distinction between identifying a problem and knowing how to resolve it. An organisation that has lost its AO, cannot access the SMS and has no reliable sponsorship records may need to address several issues together.

Before approaching the Home Office about a wider compliance problem, undertake a prompt internal review of the records and processes available. This is not about delaying a required notification or concealing a problem. It is about ensuring that you understand the position, can answer questions accurately and are prepared to demonstrate that the organisation takes its obligations seriously.

What if the Home Office carries out a compliance inspection?

The Home Office can conduct compliance checks, including visits, digital checks and requests for documents or information. These checks may take place without advance notice.

If the organisation has no active AO, or has experienced a significant breakdown in the management of its licence, it should not assume that the issue will be treated as a minor administrative oversight. The Home Office may wish to establish who is responsible for sponsorship and whether the organisation has adequate systems to comply with its duties.

Before making an approach about an unresolved licence problem, prepare to explain:

• Who is currently responsible for immigration compliance.
• Who is proposed as the replacement AO and why they are suitable.
• Whether the organisation can access its SMS and how it intends to restore or maintain access.
• Which employees are currently sponsored and what checks have been carried out on their immigration status.
• Whether relevant worker changes have been reported.
• Whether the organisation has retained the required sponsorship records.
• How right to work checks are conducted, recorded and monitored.
• What action is being taken to correct any identified gaps.

You should be able to demonstrate a robust right to work process, including how initial checks and any required follow-up checks are completed and recorded.

If records are missing or a reporting deadline has been missed, be clear about the position and the steps being taken to address it. Do not recreate records in a way that suggests checks were performed when they were not.

Where there are significant compliance concerns, obtaining advice from an immigration specialist before submitting a detailed explanation to the Home Office can help you understand the issues, identify the appropriate corrective action and communicate accurately.

The objective is not to guarantee that an inspection will be avoided. It is to ensure that the organisation can demonstrate responsible management of its licence and a credible plan for putting any deficiencies right.

6. Identify Every Employee Who Has Been Sponsored by the Organisation

One of the biggest risks when taking over sponsorship responsibilities is assuming that the list of sponsored workers is complete.

The HR team may have records of current Skilled Workers but no clear picture of former employees, previous visa extensions or Certificates of Sponsorship assigned by a predecessor.

Start with the SMS, but do not rely on it alone.

Use the SMS to search for Certificates of Sponsorship

The SMS includes a search function for Certificates of Sponsorship. An advanced search can help you identify CoS assigned from a particular date, making it easier to investigate historical sponsorship activity.

Where available, use the advanced search options to set an appropriate date range and review the results. This can help you identify workers whose records may not be included in the current HR handover.

Review the results against the organisation’s employee records, payroll information and recruitment documentation.

Be careful not to treat every CoS record as proof that a person started employment or remained employed for the full period stated. A CoS records an intended sponsorship arrangement; you will need to establish what happened in practice.

Check HR files for anyone who holds or has held a visa

Review employee files for evidence of immigration permission, including:

• Right to work check records and relevant follow-up dates.
• Copies or records of immigration status checks.
• CoS references and sponsorship correspondence.
• Visa or eVisa information, where relevant to the organisation’s records.
• Employment contracts and changes to employment terms.
• Start dates, termination dates and payroll records.
• Records of absences or changes to working arrangements where relevant.
• Correspondence about extensions, switching immigration routes or changes of employer.

You should also check whether any employees who were sponsored have moved to a different immigration route. Someone who originally held a Skilled Worker visa may subsequently have obtained another form of permission, meaning the organisation’s current responsibilities need to be considered in light of their present status.

The aim is to build a reliable record of both current and historical sponsorship activity, rather than simply creating a list of employees whose visas are still valid.

Check that former sponsored workers were reported correctly

Where a sponsored worker left employment before the end of the period covered by their permission, check whether the organisation reported the relevant cessation of employment to the Home Office.

Sponsors generally have a duty to report when a sponsored worker stops working for them, including where employment ends earlier than expected. The applicable reporting deadline is normally 10 working days for a worker ceasing employment, subject to the precise circumstances and current guidance.

Review the actual departure date, the relevant CoS record and any report made through the SMS. If a report appears to be missing, establish the facts and obtain advice on the appropriate next step.

Also check for other reportable changes, such as significant changes to a sponsored worker’s role, salary or working arrangements. Not every change requires the same action, so assess the circumstances against the current guidance rather than assuming that all changes are treated identically.

A historic reporting failure does not necessarily mean that every aspect of the licence is non-compliant. However, it should not be ignored simply because the employee has already left.

7. Check Your Record-Keeping Against Appendix D

Once you have identified current and former sponsored workers, check whether the organisation holds the documents required by the Home Office.

Appendix D of the sponsor guidance sets out the records that Worker and Temporary Worker sponsors must retain. The precise documents required depend on the worker and the circumstances, so it is important to review the applicable requirements rather than rely on a generic checklist.

Typical records include relevant evidence of immigration status and right to work, employment details, salary and payment records, contact details, and other documents specified in the applicable guidance.

The organisation must be able to make relevant records available to the Home Office when requested.

How long must sponsor records be retained?

As a general rule, documents relating to a sponsored worker must be kept throughout the sponsorship period and until the earlier of:

• One year after the date on which sponsorship ended; or
• The date on which a compliance officer has examined and approved the documents, if that happens sooner.

There are important qualifications. Some records may need to be retained for longer under other legal requirements, including right to work record-retention rules and wider employment, tax or data protection obligations.

Documents submitted as part of the original sponsor licence application must also be retained for as long as the organisation holds the licence.

For that reason, do not automatically delete an employee’s immigration records one year after they leave. Check whether another legal retention requirement applies and make sure the organisation can justify its retention arrangements.

What if records are missing?

If a previous HR manager maintained the records on a personal drive, used a system that has since been decommissioned or failed to hand over the relevant files, you should establish which documents are missing and whether they can be recovered.

Use legitimate existing records to reconstruct the available history, clearly distinguishing original documents from later notes or explanations. Do not backdate documents or imply that a check was carried out if there is no evidence that it was.

A documented audit is useful because it establishes what the organisation knows, what remains uncertain and what remedial action is needed.

It can also help you establish a more consistent approach to storing sponsorship records, with controlled access and a clear process for retaining and disposing of personal information.

8. Establish a Reliable Sponsorship Compliance Process

Once the immediate handover issues have been addressed, the next step is to prevent the same problems from recurring.

Sponsorship compliance should not depend on one person remembering every reporting deadline or keeping all the relevant information in their inbox.

A sustainable process should cover:

• Ownership: Identify the AO, the internal Level 1 User and the person responsible for day-to-day sponsorship administration.
• Access: Maintain appropriate SMS access, keep user details up to date and remove access when people leave or are no longer authorised.
• Monitoring: Review visa expiry dates, upcoming extensions and CoS allocation deadlines.
• Reporting: Ensure relevant worker and organisational changes are assessed and reported within the applicable deadlines.
• Record-keeping: Maintain a consistent file structure for sponsored workers and retain documents in accordance with Appendix D and other applicable requirements.
• Right to work: Ensure checks are completed correctly, with follow-up checks where required, and that evidence is retained.
• Training: Make sure the people involved understand their responsibilities and know when to seek specialist advice.
• Oversight: Periodically review the licence and the activity undertaken through the SMS.

The Home Office recommends that Level 1 Users access the SMS regularly, with monthly access recommended in its guidance. This is a sensible minimum for a routine review of licence information and messages, although individual organisations may need more frequent checks.

Remember, too, that SMS access is subject to security requirements, including multi-factor authentication. Keep user details accurate and ensure that each user accesses their own account rather than sharing passwords or authentication codes.

A written handover process is particularly useful when HR responsibilities change. It should record the current licence position, outstanding CoS requests, sponsored workers, visa expiry dates, unresolved reporting issues and any upcoming deadlines.

9. How Migrate UK Can Help You Manage Your Sponsor Licence

Taking over a sponsor licence is an opportunity to establish a more reliable approach to immigration compliance. However, many HR teams do not have the time or specialist knowledge to monitor every sponsorship obligation alongside their wider responsibilities.

Migrate UK offers an annual sponsor licence compliance service designed to support organisations in maintaining their sponsorship arrangements proactively.

For a low annual fee, the service provides ongoing access to immigration specialists and assistance with routine sponsor licence administration. It is designed to give HR teams a consistent point of contact and reduce the risk of important administrative tasks being overlooked.

What is included in our sponsor licence compliance service?

Our service includes:

1. Immigration enquiries

We respond to relevant immigration enquiries relating to the operation of your sponsor licence, where the question falls within the scope of the service and does not require a separate substantive legal instruction.

2. Annual Certificate of Sponsorship requests

We assist with requests for the organisation’s annual CoS allocation, helping you plan ahead for anticipated recruitment and extensions.

3. In-year CoS allocation requests

If recruitment requirements change during the year, we can assist with requests for an increased CoS allocation.

4. Change of circumstances notifications

We assist with notifications relating to live and used Certificates of Sponsorship, where these fall within the agreed scope of the service.

5. Changes to key personnel and organisation details

We support the reporting of changes to key personnel and organisational details through the SMS, helping to maintain accurate licence information.

6. Visa expiry monitoring and renewal reminders

We track visa expiry dates for relevant visa holders and provide reminders three months before expiry to help HR teams plan for extensions or other appropriate immigration arrangements.

7. Free sponsorship compliance webinars

Clients receive access to at least two free webinars each year covering sponsorship compliance and relevant developments.

8. Monthly immigration and sponsorship newsletter

Our monthly newsletter provides updates on immigration rules, sponsorship requirements and compliance developments relevant to employers.

9. Migrate UK experts linked as Level 1 Users

Our experts are linked to your sponsor licence as Level 1 Users, subject to the applicable eligibility requirements and appointment process. This helps maintain continuity of SMS access and provides a consistent point of contact when your internal HR team changes.

Conclusion: Make Your Sponsor Licence Handover an Opportunity to Improve Compliance

Taking over a sponsor licence can reveal problems that have developed gradually: outdated key personnel, inaccessible SMS accounts, incomplete worker records or reporting obligations that were overlooked during a previous handover.

The priority is to establish control of the licence, identify any gaps and put a reliable process in place. Start with SMS access and the licence summary, review your CoS allocation, identify current and former sponsored workers, and check that the organisation’s records and reporting history are complete.

If the organisation has lost its Authorising Officer or Level 1 User, or you discover potentially significant compliance issues, take the time to understand the position and obtain appropriate advice. Do not assume that an inactive licence user or an incomplete handover is merely an administrative inconvenience.

A structured handover, clear ownership and regular compliance monitoring can make a substantial difference to the way an organisation manages its sponsorship responsibilities.

If your HR team needs ongoing support, Migrate UK’s sponsor licence compliance service provides practical assistance with routine SMS administration, CoS allocation requests, change notifications, visa expiry reminders and access to immigration specialists.

Contact Migrate UK to discuss how our annual compliance service could support your organisation.

Further reading

For the latest official requirements, consult the Home Office guidance:

• Workers and Temporary Workers: guidance for sponsors — Part 1: Apply for a licence
• Workers and Temporary Workers: guidance for sponsors — Part 3: Sponsor duties and compliance
• Appendix D: Record-keeping duties
• Sponsor Management System user manuals

Immigration rules and sponsor guidance can change. Always check the current version before taking action.