Holding a sponsor licence is not a one-off process. It comes with a continuous set of obligations that must be met for as long as the licence is held. These include maintaining accurate records for every sponsored worker, reporting specified changes to the Home Office within defined timeframes, carrying out right-to-work checks, monitoring sponsored workers' attendance and contact details, and ensuring that the terms of employment remain consistent with the Certificate of Sponsorship under which the worker was sponsored. Failure to meet these duties is the most common reason sponsors face compliance action.
The records a sponsor must hold are set out in Appendix D of the Home Office sponsor guidance and cover a wide range of documentation including identity documents, right-to-work evidence, employment contracts, payslips, and contact details. Right-to-work checks are now primarily conducted through eVisa verification for non-UK nationals following the transition away from physical Biometric Residence Permits. Sponsors must also be aware of which changes in a worker's circumstances require a report to the Home Office and which changes require a new CoS or a change of employment application.
NARA Solicitors advises sponsors on the full scope of these duties in plain terms, conducts compliance reviews of existing systems and records, and helps businesses put in place the processes and documentation they need to meet their obligations. We also advise on specific scenarios that arise in practice, such as how to handle a sponsored worker who changes role, moves to a different working location, or takes an extended absence.
