Managing your Sponsor Management System (SMS): best practice for UK employers

Managing your Sponsor Management System (SMS): best practice for UK employers

The Sponsor Management System (“SMS”) is the Home Office’s online platform through which licensed sponsors manage their day-to-day sponsorship activities. From assigning Certificates of Sponsorship (“CoS”) to reporting changes in worker or organisational circumstances, the SMS sits at the heart of sponsor licence compliance. Failing to manage it properly can lead to compliance action – including sponsor licence revocation. It is important to note that the duties of the sponsor begin from the day the Home Office grants a sponsor licence and ends when either the licence is (1) surrendered, (2) revoked or (3) an organisation takeover has occurred.

This blog sets out the key obligations UK employers must meet when using the SMS, and offers practical guidance on best practice.

What is the SMS used for?

Once a sponsor licence is granted, the key personnel are given access to the SMS. The system is used to:

• manage the sponsor licence;
• create and assign CoS to workers;
• report changes to sponsored workers’ circumstances (e.g., changes to role, salary, or absences); and
• report changes to the sponsor’s own circumstances (e.g., change of address, ownership, or Key Personnel)

Reporting duties: deadlines and triggers

Sponsors are required to report certain events through the SMS within prescribed timeframes. We have set out some of the key changes which must be reported to the Home Office. The two main categories are:

1. Change of the worker’s circumstances (generally within 10 working days):

• a sponsored worker fails to commence employment within 28 days of the start date stated on their CoS;
• unauthorised absence of more than 10 consecutive working days;
• a sponsored worker is absent from work without pay, or on reduced pay, for more than 4 weeks in total in any calendar year;
• changes to the worker’s job role, title, core duties, or salary;
• a sponsored worker’s normal work location changes;
• the sponsor stops sponsoring a worker for any reason.

2. Change to your organisation (generally within 20 working days):

• changes to Key Personnel (Authorising Officer, Key Contact, Level 1 Users or Level 2 User) – please note the organisation must have an eligible Authorising Officer in place throughout the life of its sponsor licence, and the sponsor guidance expressly rules out the general 20-working-day reporting period for replacing an Authorising Officer or Key Contact;
• change of name, address, contact details or head office details;
• change of organisation size;
• change in structure, such as additional branches or sites or new linked entities;
• change in the status of any registration or accreditation you are legally required to hold to operate or trade in the UK;
• change in ownership, mergers, or takeovers; or
• insolvency, cessation of trading, or conviction of the relevant offence.

Record-keeping duties

Alongside reporting, sponsors must comply with record-keeping obligations, such as:

• maintaining current contact details for all sponsored workers;
• retaining evidence of right-to-work checks; and
• keeping copies of documents relating to the worker’s immigration status, qualifications, and employment.

Records must be kept securely and made available to the Home Office on request – including during compliance visits.

Compliance visits: what the Home Office checks

The Home Office may carry out announced or unannounced compliance visits to assess whether a sponsor is meeting its obligations. During these visits, officers will typically check that:

• reporting and record-keeping systems are robust and functioning;
• SMS users do not share passwords;
• changes to Key Personnel, addresses, and organisational structure have been reported through the SMS;
• sponsored workers are employed in the role and at the salary specified on their CoS; and
• Key Personnel are permanently based in the UK.

Consequences of non-compliance

Failure to comply with reporting, record-keeping, or wider sponsor duties can result in compliance action by the Home Office. This ranges from issuing an action plan to downgrading the licence rating, suspending the licence, or, in the most serious cases, revoking the licence entirely. Loss of the sponsor licence means all existing sponsored workers’ permission will be curtailed, creating significant operational disruption.

Frequently Asked Questions

What is the Sponsor Management System (SMS)?

The Sponsor Management System (SMS) is the Home Office’s online platform used by licensed sponsors to manage their sponsor licence. Employers use the SMS to assign Certificates of Sponsorship (CoS), report changes relating to sponsored workers and update information about their organisation.

How quickly must changes relating to sponsored workers be reported?

Changes to a sponsored worker’s circumstances generally need to be reported through the SMS within 10 working days. This can include changes to their role, salary or normal work location, certain absences and situations where the employer stops sponsoring the worker.

How quickly must changes to a sponsoring organisation be reported?

Certain organisational changes generally need to be reported within 20 working days. These can include changes to the organisation’s name, address, size or structure, as well as changes involving ownership, mergers or takeovers. Different requirements may apply to particular changes, including changes to Key Personnel.

What records must a sponsor keep for sponsored workers?

Sponsors must maintain appropriate records for their sponsored workers. These include current contact details, evidence of right-to-work checks and relevant documents relating to the worker’s immigration status, qualifications and employment. Records must be kept securely and made available to the Home Office when requested.

What happens if an employer fails to comply with its sponsor duties?

Failure to meet reporting, record-keeping or other sponsor duties can result in Home Office compliance action. Depending on the circumstances, this may include an action plan, downgrading or suspension of the sponsor licence or, in serious cases, revocation. Revocation can also affect the immigration permission of existing sponsored workers.

How Gherson can assist

Gherson’s Corporate Immigration team advises UK employers on all aspects of sponsor licence management and compliance. Whether you need help setting up internal reporting processes, preparing for a compliance visit, or resolving an issue flagged by the Home Office, please do not hesitate to contact our team.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

This article was first published in 2023 and has been updated in September 2026. 

©Gherson 2026