Sponsoring overseas workers under the UK’s Global Business Mobility (GBM) routes is a powerful way for employers to bring talent into their organisation — but it comes with significant compliance responsibilities. These duties aren’t just bureaucratic boxes to tick; they reflect the UK government’s expectations that licensed sponsors support the integrity of the immigration system and uphold employment and immigration law throughout the sponsorship relationship.
Here’s a practical guide to the key compliance obligations employers face when sponsoring workers under GBM routes — including reporting, monitoring, and preparing for audits.
Sponsorship Is a Privilege, not a Right
Before exploring the duties themselves, it’s important to understand the broader context:
A sponsor licence gives an organisation the right to sponsor workers — including those on GBM routes such as Senior or Specialist Worker, Graduate Trainee, UK Expansion Worker, Service Supplier, and Secondment Worker — but this comes with ongoing responsibilities.
These duties start from the day the licence is granted and continue until the sponsor formally ends sponsorship for a particular worker or surrenders their sponsor licence.
Failure to meet these duties can lead to serious consequences, including licence downgrading, suspension, or revocation.
- Core Compliance Obligations for GBM Sponsors
- Reporting Duties
Sponsors must report a range of events and changes to the Home Office, typically within specified timeframes, using the Sponsor Management System (SMS). These include:
Changes affecting sponsored workers, such as changes to job title, work location, absences without pay or on reduced pay, or if a worker stops working or is absent without permission. These must be reported within 10 working days of the event.
Changes to the sponsor organisation, including changes to trading address, restructures, mergers, changes to Key Personnel, or insolvency procedures. These must be reported within 20 working days of the event.
Timely reporting helps maintain compliance and demonstrates that the sponsor is actively managing their duties.
Record‑Keeping Duties
Sponsors must maintain and retain specific records for each sponsored worker, including documentation showing:
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How the worker was recruited.
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Copies of passports and immigration documents.
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Evidence that the role offered matches the job conditions set out in the Certificate of Sponsorship (CoS).
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Any professional qualifications or licences required for the role.
These records must be maintained throughout the period of sponsorship and retained until at least one year after sponsorship ends, or until they have been examined and approved by a Home Office compliance officer, if this occurs sooner.
Monitoring and Right to Work Checks
Sponsoring organisations are expected to monitor their workers’ ongoing compliance with immigration conditions, including:
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Ensuring workers are doing the job detailed in their CoS and paid at the correct rate.
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Conducting regular right to work checks to confirm that the worker retains valid UK immigration status.
This monitoring supports compliance with immigration and helps identify potential issues before they escalate.
Complying with UK Law and Sponsorship Guidance
Sponsors must comply with:
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All relevant immigration law and the Workers and Temporary Workers sponsor guidance (Parts 1, 2, and 3).
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Wider UK law, such as employment rights, National Minimum Wage, and Working Time Regulations.
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Not engaging in behaviour that is not conducive to the public good (for example, actions that could harm the integrity of the immigration system).
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Non‑compliance with such laws — even outside immigration-specific duties — can trigger sanctions against the sponsor.
Preparing for Compliance Checks and Audits
Sponsors should treat compliance monitoring as an ongoing priority — not just something to worry about when the Home Office visits.
Home Office Compliance Visits
UK Visas and Immigration (UKVI) may carry out compliance checks, including on‑site visits, to assess whether a sponsor is meeting their duties. These can be triggered if:
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UKVI has reasonable grounds to believe duties are not being met.
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There are discrepancies in reporting or record‑keeping.
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The organisation has a history of non‑compliance.
Sponsors should be ready to produce records, explain their monitoring processes, and demonstrate consistent reporting.
Internal Compliance Audits
Many responsible employers conduct regular internal audits of their sponsorship processes. These audits can help ensure that:
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Reporting is timely and accurate.
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Records are complete and stored securely.
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Staff understand their roles in the sponsorship system.
This proactive approach reduces risk and creates a culture of compliance.
Sponsoring GBM workers can be highly beneficial for an organisation — but it also brings long‑term obligations that extend far beyond assigning a Certificate of Sponsorship. Effective sponsors approach compliance with the same rigour as they do core HR and legal processes:
✔ Report changes within the required deadlines and accurately.
✔ Keep meticulous records and make them audit‑ready.
✔ Monitor their sponsored workers continuously.
✔ Stay up to date with immigration and employment law requirements.
By embedding these practices into your operational workflows, you not only protect your licence but also support your GBM talent confidently and compliantly.
Maintaining compliance under the GBM routes requires more than reacting to Home Office requests — it demands robust systems, well-trained staff, and ongoing oversight. At Migrate UK, we help sponsors embed compliance into their day-to-day operations and reduce the risk of licence action.
We can support you through:
HR Department Training
Tailored training for HR and key personnel on sponsor duties, reporting obligations, right to work checks, and record-keeping requirements, ensuring everyone understands their role in maintaining compliance.
Immigration Compliance Support
Ongoing advisory support to help you manage reporting duties, respond to Home Office queries, and stay aligned with evolving sponsorship guidance.
Immigration Compliance Audits
Proactive audits of your sponsor licence processes and records to identify gaps, address risks, and ensure you are fully prepared for a Home Office compliance visit.
It is also important to note that requests for further information following an allocation request or the reporting of changes to an organisation’s details often indicate that the Home Office is carrying out a targeted compliance check. These “clarification” requests may form part of a wider assessment of your sponsor duties, making it essential that records are accurate, consistent, and audit-ready at all times.
If you would like support with training, compliance monitoring, or a pre-emptive audit of your sponsor licence, please contact Migrate UK to discuss how we can help safeguard your licence and support your GBM workforce with confidence.
