Changes to Sponsor Guidance
The Home Office brought in certain small, but integral changes to sponsor licence guidance on the 6th of March 2026. It is a sponsor’s duty to keep abreast of all changes and to ensure that they continue to meet their duties and responsibilities. Sponsors should always familiarise themselves with new sponsor guidance.
In particular, under Appendix D Record-Keeping Duties, sponsors must now keep evidence that they have told their sponsored employees or workers about their employment rights in the UK. They must have human resources systems in place to demonstrate that this information was provided. This is retroactive and does not only apply to new employees. If this information does not exist for existing employees, a sponsor risks being found non-compliant.
“Eligible Role” also receives a new definition in the guidance. The role or vacancy must exist at the point the CoS is assigned to the worker. It must require the jobholder to perform specific duties and responsibilities, as set out on the CoS, it must meet all of the requirements of the route the worker is being sponsored on, and it must be “appropriate to the business or organisation in light of its business model, business plan and scale”. This is a new basis on which the Home Office can question the genuineness of roles, especially for people looking to attempt self-sponsorship.
The Home Office have also made explicit that if they find a worker doing a role that does not exactly match the description on their certificate of sponsorship, they will revoke the sponsor’s licence. Sponsors must continue to report permitted changes within 10 working days but now, if they do not, they will lose their licence. This is retroactive so sponsors should check all sponsored employees to ensure that all permitted changes have been reported.
Finally, the Home Office have redefined the relationship between themselves and Sponsors. Where this was originally designed as a partnership, they have now explicitly stated in the guidance that sponsors become members of the sponsorship scheme “for their own benefit”. They have also stated that if they have “reasonable concerns as to your [a sponsor’s] suitability to be a licence holder, or a reasonable suspicion that you are not suitable for sponsorship, we will refuse your application (or can revoke your licence if you already have one)”.
By : Cameron Dyer