Guidance

Lead sponsor guidance: named community sponsorship and refugee study routes (accessible version)

Published 29 October 2026

Version 1.0

About this guidance

This guidance sets out the roles and responsibilities for lead sponsors participating in the named sponsorship and refugee study routes.

The government’s Restoring Order and Control policy statement set out reforms to refugee sponsorship, giving voluntary and community sector (VCS) organisations a greater role in refugee resettlement through three new sponsorship routes: named community sponsorship, refugee study and refugee work. This guidance will be updated to include information on the refugee work route ahead of the route opening.

The routes enable community groups, universities and employers to identify and sponsor refugees for resettlement in the UK, while supporting their integration into local communities. The routes operate through a lead sponsorship model, through which the Home Office enables approved UK-based VCS organisations, to provide advice, support and assurance to sponsors and act as the primary point of contact between sponsors and the Home Office.

These routes operate separately from and alongside the existing UK Resettlement Scheme (UKRS), providing complementary pathways alongside government-led resettlement.

Organisations wishing to become a lead sponsor can apply online at: Apply to be a lead sponsor for refugees.

Further information about the routes is available at: Policy guidance: refugee sponsorship routes.

Terminology used in this guidance

Throughout this guidance:

• ‘lead sponsors’ refers to the VCS organisations approved by the Home Office to support and oversee sponsorship arrangements, provide support and assurance to sponsors, and act as the primary point of contact between sponsors and the Home Office

• ‘sponsors’ refers to the community groups, universities and employers participating in the named sponsorship, refugee study and refugee work routes.

References to ‘refugees’ in this guidance include:
- individuals who meet the definition of a refugee in Article 1 of the 1951 Refugee Convention; and - individuals who are within UNRWA’s mandated area, are Palestinian and cannot access referral through UNHCR’s established resettlement process but whose protection needs have been assessed through an alternative process established by the Home Office

The use of this term does not alter the United Kingdom’s position on refugee status under the Refugee Convention.

Publication

Below is information on when this version of the guidance was published:

• version 1.0
• published for lead sponsors on 29 October 2026

Introduction

The UK government has introduced three new refugee sponsorship routes that enable community groups, universities and employers to play a direct role in supporting refugees to come to the UK and rebuild their lives. The routes are:

• named community sponsorship, which enables community groups to identify refugees they wish to sponsor
• refugee study, which enables universities to sponsor refugees to study in the UK, working with specialist VCS organisations to identify suitable students
• refugee work, which enables employers to sponsor and provide refugees jobs, working with specialist VCS organisations to identify suitable refugees

What is refugee sponsorship?

These refugee sponsorship routes enable community groups, universities and employers to identify refugees in need of protection and support them to come to the UK and rebuild their lives.

Previous comparable UK sponsorship schemes include the Community Sponsorship Scheme.

Under these routes, eligible sponsors can refer refugees for consideration and commit to supporting them after their arrival in the UK. Sponsors are responsible for delivering practical and integration support to help refugees resettle in the UK, while lead sponsors provide oversight, support and assurance throughout the sponsorship arrangement.

Unlike the Community Sponsorship Scheme, where refugees are referred through established UNHCR referral mechanisms, the named community sponsorship, refugee study and refugee work routes enable sponsors to identify a specific refugee they wish to sponsor. Any individual referred under the routes must meet applicable identity, security and eligibility requirements. The Home Office will continue to work in partnership with UNHCR to confirm that individuals meet the relevant refugee or protection requirements.

What does a lead sponsor do?

Lead sponsors are organisations approved by the Home Office to help deliver refugee sponsorship. They support sponsorship arrangements by providing advice, oversight and assurance, and act as the main link between sponsors and the Home Office.

Lead sponsors play a key role in helping sponsorship arrangements succeed. They work with sponsors throughout the sponsorship period, helping them understand their responsibilities, assessing proposed sponsorship arrangements and providing ongoing support and oversight. They help ensure sponsorship arrangements are safe, sustainable and capable of meeting refugees’ needs, while maintaining consistent standards across the routes and identifying and addressing any concerns at an early stage.

To become a lead sponsor, organisations must successfully complete the application process and demonstrate they have the capability, governance arrangements and expertise required to fulfil the role.

Lead sponsors are initially accredited for a three-year period and are subject to ongoing monitoring during that time. The Home Office will review accreditation three months before the end of the accreditation period and decide whether it should continue.

What does a sponsor do?

Sponsors are community groups, universities or employers that provide direct support to refugees arriving through the sponsorship routes.

Sponsors play a vital role in helping refugees integrate into their local communities and contribute to life in the UK. They provide the practical and integration support needed to help refugees settle into their local communities, access opportunities and progress towards independence, enabling them to contribute to their communities and wider society. Depending on the route, this may include providing accommodation, financial support, pastoral support, access to education or employment, and assistance to access local services and build local connections.

Sponsors work closely with lead sponsors throughout the sponsorship arrangement.

What training and support is available?

Training and support will be available from the Home Office or training provider to lead sponsors and sponsors to help them fulfil their responsibilities under the route, deliver sponsorship arrangements safely and effectively and support positive outcomes for refugees. Training and support will cover topics such as:

• sponsorship responsibilities and route requirements
• safeguarding and risk management
• supporting integration and progression towards self-sufficiency
• working with local authorities and other partners
• reporting, monitoring and compliance requirements
• managing sponsorship breakdowns and sponsor withdrawal

The Home Office will provide onboarding support and guidance to help lead sponsors understand their role and prepare to deliver the routes effectively.

Lead sponsors will, in turn, support sponsors through introductory training and preparation activities, helping them understand their responsibilities and prepare to deliver sponsorship arrangements safely and effectively.

Lead sponsors will also be expected to ensure that sponsors complete any necessary training and have access to appropriate guidance and support throughout the sponsorship arrangement.

Further information on training requirements, available resources and support arrangements will be published in due course.

The role of lead sponsors

This section provides an overview of the role and responsibilities of lead sponsors participating in the named community sponsorship and refugee study routes.
Lead sponsors will coordinate activity between the Home Office and sponsors. The lead sponsor role is to build and support a network of sponsors while providing assurance to the Home Office, local authorities and communities that sponsorship arrangements are being delivered safely, consistently and in accordance with route requirements.

Sponsorship arrangements

Lead sponsors are expected to provide ongoing support and oversight throughout the sponsorship period.

Under the named community sponsorship route, formal sponsorship arrangements will last for one year. However, sponsors should generally ensure that suitable accommodation is available for two years. This may depend on the type of accommodation provided. For more information, see Accommodation.

Under the refugee study route, formal sponsorship arrangements are expected to continue for the duration of the refugee’s course of study. For information on accommodation requirements under the study route, see Accommodation – study route.

Lead sponsors may choose to continue supporting sponsors after the sponsorship arrangement has ended. Any support provided after the sponsorship period is voluntary and sits outside the formal sponsorship arrangements established under the route. Responsibility for any ongoing support sits with the lead sponsor and sponsor, and not with the Home Office or local government. The nature and duration of any such support is for the lead sponsor, sponsor and refugee to agree and will depend on individual circumstances.

Lead sponsor responsibilities

Lead sponsors are responsible for:

• engaging, onboarding and supporting sponsors
• completing an assessment of proposed sponsorship arrangements and submitting applications to the Home Office
• considering whether refugee referrals appear consistent with published eligibility criteria
• monitoring sponsorship arrangements and compliance with route requirements
• maintaining accurate records and meeting reporting requirements
• identifying and escalating safeguarding, welfare and compliance concerns
• supporting the management of changes to sponsorship arrangements
• engaging with local authorities and the Home Office
• completing monitoring and assurance activity
• maintaining accreditation requirements

The Home Office retains responsibility for the route’s policy, refugee eligibility decisions and lead sponsor accreditation.

Sponsor engagement and onboarding

Lead sponsors help prospective sponsors prepare to participate in the routes. This includes engaging with prospective sponsors, supporting them through onboarding activities, helping them understand how the routes operate and what will be expected of them before they begin delivering sponsorship.

Sponsor engagement and onboarding may occur in a range of ways. Some lead sponsors may proactively build relationships with community groups, employers and universities, while others may be approached by organisations they already work with or by others seeking support for the first time.

Lead sponsors can choose which sponsors they work with, provided they meet route requirements. Decisions on whether to onboard and support a prospective sponsor may take account of factors such as their own capacity and priorities, as well as whether the proposed sponsorship arrangement appears suitable and capable of delivering the support required under the route.

Where a lead sponsor decides not to work with a prospective sponsor because of concerns about their suitability to participate in the route, the lead sponsor must notify the Home Office and provide details of those concerns.

Lead sponsors should apply their onboarding processes consistently and fairly. Where a lead sponsor decides not to work with a prospective sponsor, it should explain the reasons for that decision and, where appropriate, identify any steps the prospective sponsor could take to address the concerns raised.

Assessing sponsorship arrangements and completing applications

Lead sponsors play an important role in helping sponsors develop strong and sustainable sponsorship arrangements.

They are responsible for submitting sponsorship applications to the Home Office on each sponsor’s behalf. Before doing so, lead sponsors will be required to review the information and evidence provided by sponsors and undertake an assessment of the proposed arrangement. Applications should include details of the lead sponsor’s assessment, together with any supporting information required by the Home Office. Where further information or evidence is requested, the lead sponsor must coordinate and provide that information on the sponsor’s behalf.

As part of this process, based on the application and evidence provided, lead sponsors should consider whether the sponsor appears to meet the relevant eligibility requirements and whether the proposed sponsorship arrangement is capable of providing safe and effective support throughout the sponsorship period.

This includes considering:

• accommodation arrangements
• financial resources
• safeguarding arrangements
• plans to support integration into local communities or (for the refugee study route) participation in student life
• progression towards self-sufficiency
• any additional requirements applicable to the relevant route

Under the named community sponsorship route, sponsors will normally identify the refugee, and any eligible dependants, they wish to sponsor and provide the lead sponsor with the information and evidence required to assess the proposed sponsorship arrangement. Where a sponsor has not identified a specific individual, lead sponsors may work with the sponsor to identify a suitable refugee for sponsorship.

There are separate arrangements for identifying and matching refugees under the study route.

Lead sponsors should only complete and submit an application to the Home Office where, based on the information and evidence available, the proposed sponsorship arrangement appears to meet the requirements of the route and is ready to be formally considered by a Home Office decision-maker.

The Home Office remains responsible for deciding whether the requirements of the route have been met and whether a proposed sponsorship arrangement should be approved. The Home Office may request further information or supporting evidence where necessary.

Checking refugee eligibility

Lead sponsors should familiarise themselves with the published eligibility requirements for the relevant route.

Lead sponsors should review the information provided by the sponsor about the refugee and check that it appears complete and consistent with those published requirements. Where information is incomplete or appears inconsistent, lead sponsors should seek clarification from the sponsor before proceeding with an application.

Lead sponsors do not determine whether a refugee meets the eligibility requirements of the route and must not provide immigration advice, such as advising on the likelihood of a successful application, recommending immigration routes or providing advice based on an individual’s personal circumstances. Their role is limited to drawing attention to the published route requirements, referring sponsors to official guidance, reviewing information provided by the sponsor and identifying any missing or potentially inconsistent information.

Where information provided by the sponsor appears incomplete or inconsistent with the published route requirements, the lead sponsor should not proceed with the sponsorship application. The lead sponsor should explain the reasons for its decision, including any missing information, inconsistencies or concerns identified, to the sponsor group.

For further information on the distinction between providing general information and regulated immigration advice, see the Immigration Advice Authority’s guidance on immigration assistance.

Support for sponsors

Lead sponsors provide support to sponsors throughout the sponsorship arrangement. Before arrival, they help sponsors prepare for sponsorship by ensuring they understand their responsibilities, route requirements, have appropriate support plans and safeguarding arrangements in place and complete any required training and preparation activities.

Following arrival, lead sponsors provide ongoing advice, guidance and support to help sponsors deliver sponsorship effectively and respond to any challenges that arise. This includes helping sponsors to meet their responsibilities and support refugees to settle and integrate successfully in the UK. Lead sponsors may also signpost sponsors to relevant services and resources, including English for Speakers of Other Languages provision and other support available to help refugees progress towards integration and self-sufficiency.

Lead sponsors are expected to support sponsors through significant changes to sponsorship arrangements that may affect their suitability or sustainability. This may include helping sponsors identify potential solutions, notifying the Home Office of significant issues where required, and supporting efforts to resolve concerns where appropriate. For further information see Intervention and escalation.

Home Office engagement

Lead sponsors act as the primary point of contact between sponsors and the Home Office throughout the sponsorship arrangement. This includes sharing information that must be reported under the route, responding to requests for information and helping to ensure that required reports and notifications are submitted in a timely manner.

Lead sponsors should have appropriate processes in place to keep informed about sponsorship arrangements, identify issues that may need to be reported or escalated, and communicate relevant information to the Home Office when required.

Engagement with local authorities

While sponsors are responsible for providing accommodation and day-to-day integration support, local authorities will also play an important role in supporting the integration of refugees into local communities and delivering key statutory services.

Lead sponsors should support engagement with relevant local authorities where this is needed to support the delivery of a sponsorship arrangement. This may include helping sponsors understand local authority services and facilitating information sharing where appropriate. The extent of engagement will depend on the circumstances of the arrangement and the role of the local authority.

Where a safeguarding, homelessness or other concern falls within a local authority’s statutory responsibilities, the lead sponsor must ensure that an appropriate referral is made without delay in line with local procedures. Where required under this guidance, the Home Office should also be notified. Referral to the relevant statutory body and notification to the Home Office may take place in parallel.

While local authorities do not approve individual sponsorship arrangements, they will be made aware at an early stage of prospective sponsorship arrangements in their area. Further guidance will be provided in due course.

Monitoring and assurance

The Home Office retains overall responsibility for monitoring the operation and delivery of the routes and assuring itself that route requirements continue to be met. This may include reviewing information provided by lead sponsors, seeking further information where necessary and undertaking its own assurance activity.

Lead sponsors contribute to the Home Office’s monitoring and assurance of the routes through their oversight of the sponsorship arrangements they support.

This includes monitoring how arrangements are progressing, identifying and addressing concerns at an early stage, keeping appropriate records, and reporting or escalating issues where required.

Lead sponsors should maintain regular contact with the sponsors they support throughout the sponsorship arrangement. The frequency and nature of contact should be proportionate to the circumstances of the sponsorship arrangement and any risks or concerns identified.

For further information, see the section Monitoring and assurance.

Related external links

Immigration Advice Authority’s guidance on immigration assistance

The role of refugee study route lead sponsors

This section sets out the additional responsibilities of lead sponsors operating under the refugee study route. These responsibilities apply alongside those set out in the role of lead sponsors and reflect the specialist nature of higher education sponsorship.

Study route lead sponsors work with university sponsors to identify and support refugees, oversee sponsorship arrangements and help ensure that refugees receive the academic, practical and integration support required throughout their studies.

Working with university sponsors

Study route lead sponsors are responsible for engaging and working with university sponsors participating in the routes.

In doing so, study route lead sponsors should have regard to the sponsor suitability considerations set out in the section on Requirements applicable to all sponsors, alongside the additional requirements set out below.

Before working with a prospective university sponsor, the lead sponsor should satisfy itself that the university:

• is a recognised UK university with degree awarding powers. Evidence of this may be found through the relevant higher education regulator, register or government authority in England, Wales, Scotland or Northern Ireland, including:

  • The OfS Register - Office for Students (universities in England)

  • Register of Higher Education Providers - Medr (universities in Wales)

  • Universities - gov.scot (universities in Scotland) or

  • Higher Education Policy - Department for the Economy (universities in Northern Ireland).

• holds a Student Sponsor - Track Record licence. A full list of universities with this licence can be found here: Register of licensed sponsors: students - GOV.UK
• can offer suitable courses to prospective refugees
• has appropriate accommodation and welfare arrangements, including pastoral and student mental health support, in place including outside academic term time where required
• has sufficient staffing and resources to support refugees throughout the sponsorship period, including outside academic term time

Further information on degree awarding powers can be found here: Check if your university or college can award a degree: Overview - GOV.UK

University sponsors must provide the integration support required under the route but can deliver that to refugees in the way they consider most appropriate. This may include signposting refugees to university societies and events, facilitating buddy schemes, or establishing student volunteer networks, helping to ensure that integration is a two-way process between the refugee and the wider student community.

Universities of Sanctuary provides examples of integration initiatives, good practice and resources that may assist university sponsors in supporting positive integration outcomes.

University sponsors should be the refugee’s primary point of contact for routine support, including outside academic term time. This does not prevent refugees from raising concerns directly with the lead sponsor, Home Office or relevant statutory authority where appropriate.

Study route lead sponsors should maintain ongoing relationships with university sponsors and provide advice, guidance and oversight throughout their participation in the route.

Identifying and matching refugees

Study route lead sponsors may identify refugees and match them to suitable university sponsors. University sponsors may also identify refugees directly and refer them to a study route lead sponsor.

Where a study route lead sponsor identifies the refugee, it should undertake an assessment to support effective matching between the refugee and a suitable university sponsor. This assessment should consider whether the refugee is likely to meet the relevant route and university requirements of an appropriate course before a match is proposed.

As part of this assessment, study route lead sponsors should consider whether:

• the proposed course appears appropriate to the refugee’s educational background, skills and future aspirations
• the refugee appears likely to be able to access, participate in and successfully complete the proposed course
• the refugee appears broadly capable of meeting any relevant English language requirements
• any identified support needs or vulnerabilities can be appropriately supported
• the proposed university sponsor is likely to be able to provide an appropriate course and support package for the refugee’s circumstances

The university sponsor remains responsible for admissions decisions and for determining whether a prospective refugee meets its academic, English language and course entry requirements.

Where the university sponsor decides to offer the prospective refugee a place on a suitable course, the lead sponsor must assess the wider sponsorship arrangement before it is submitted to the Home Office.

An application may only be submitted to the Home Office once a university offer, either conditional or unconditional, has been made. The Home Office will determine whether the route requirements have been met and make the relevant immigration, identity, security and suitability decisions.

An offer of a university place does not guarantee resettlement or permission to enter the UK. The refugee must not travel until the Home Office has made the relevant decisions and confirmed that travel may proceed.

Supporting university and student finance applications

Study route lead sponsors are responsible for supporting refugees and university sponsors through the application process.

This includes supporting refugees to apply to universities, whether directly or through UCAS, as well as assisting with applications for student finance, scholarships or other financial support where required. As a university offer must be obtained before a sponsorship application is submitted to the Home Office, some support may be provided before a referral is made while the prospective refugee remains overseas. This support may be provided remotely and in collaboration with overseas academic partners, and may include helping individuals understand application processes, prepare supporting documents and submit applications within the applicable timescales. Support may also include helping individuals access essential equipment, such as laptops, to submit applications from.

Student finance approval is not a requirement for the Home Office to make an immigration decision. However, before the refugee travels, the study route lead sponsor must be satisfied that sufficient funding is available to cover tuition fees, living costs and other relevant costs for the required period. This may include student finance, scholarships, tuition fee waivers or other confirmed funding.

Where required, study route lead sponsors must also support refugees to obtain any additional approvals necessary before travel, such as an Academic Technology Approval Scheme (ATAS) certificate. Certain approvals, including ATAS certificates, must be obtained before a visa can be issued and entry clearance granted to refugees.

Study route lead sponsors are responsible for confirming with the university sponsor that the refugee has been registered for university enrolment on their arrival in the UK, to ensure the refugee will be able to access student finance.

Long-term sponsorship and integration support

Study route lead sponsors are responsible for working with university sponsors to maintain oversight of sponsorship arrangements throughout the refugee’s studies and support progression towards postgraduate education where appropriate, employment and long-term integration and self-sufficiency.

University sponsors will be required to provide refugees with the standard post-graduation support available to their wider student population, including support relating to employment and further study opportunities.

Additional support following completion of studies may be provided at the university sponsor’s discretion. For further information see Oversight of sponsorship arrangements.

Study route lead sponsors must monitor whether the university sponsor continues to meet the applicable requirements and is able to support the refugee throughout their studies. Where concerns arise about a university sponsor’s ability to deliver the sponsorship arrangement and how that might limit the refugee’s ability to continue studying or access support, the lead sponsor should work with the university sponsor and refugee to identify appropriate action and notify the Home Office if the continued viability of the sponsorship arrangement may be affected.

Study suspension and withdrawal

Refugees are expected to remain engaged with their studies throughout the sponsorship period. Any suspension of studies must be considered by the university sponsor in accordance with its interruption of studies policies and should normally be limited to exceptional circumstances. Examples of exceptional circumstances may include serious illness, significant mental health concerns, bereavement, family emergencies, or other circumstances accepted by the university under its published policies.

If a refugee decides to suspend their studies, the university sponsor must notify study route lead sponsors and the Home Office without delay and explain the steps taken to support the refugee back into study or progress towards other agreed pathways.

Where a refugee suspends their studies, study route lead sponsors must work with the university sponsor, refugee and relevant support services to:
- understand the circumstances leading to the suspension or withdrawal - assess any impact on accommodation, financial support, welfare and the wider sponsorship arrangement - ensure that appropriate support remains available - facilitate a return to study where possible - support progression towards an appropriate alternative education, training or employment pathway where a return to study is not realistic

The lead sponsor must continue to oversee the sponsorship arrangement and keep the Home Office informed of significant developments, including any concerns about its continuing viability.

Further information on notification, monitoring and assurance requirements relating to study suspension is set out in the section on Monitoring and Assurance.

In the event that a refugee chooses to withdraw from their course, there will be no impact on their refugee status, immigration permission and route to settlement.

Contextual admissions and academic access

Responsibility for making contextual admissions decisions rests with the university sponsor. Any contextual offer made under the route must be made in accordance with the university’s existing admissions and widening participation policies.

Study route lead sponsors should obtain confirmation that the university has applied its published admissions policies but are not expected to assess the academic merits of an offer themselves.

Universities have existing widening participation schemes where they ease entry requirements for those from lower socio-economic backgrounds to access university with reduced offers and additional support. University sponsors can only offer contextual admissions to refugees in line with existing widening participation schemes to consider the barriers that refugees face. These offers may allow for a limited reduction in academic grade requirements, for example, by one grade, however these offers must not alter English language proficiency requirements.

Related external links

Register of licensed sponsors: students - GOV.UK

Universities of Sanctuary

Eligibility criteria for lead sponsors

This section sets out the eligibility requirements organisations must meet to become an accredited lead sponsor. Information on how to evidence the eligibility requirements are set out in the Accreditation process for lead sponsors section.

To be accredited as a lead sponsor, organisations must demonstrate that they:

• are a registered UK Charity or Community Interest Company (CIC), registered for a minimum of one year
• have the capability, resources and networks required to fulfil the lead sponsor role
• are able to support multiple sponsorship arrangements
• have a governance board where the majority of members are British or Irish citizens
• have required policies and procedures in place

Charity or CIC registration

Organisations based in England or Wales must be registered as a charity with the Charity Commission or be registered as a CIC with Companies House.

For organisations based in Scotland, organisations must be registered as a charity with the Office of the Scottish Charity Regulator (OSCR) or as a CIC with Companies House.

For organisations based in Northern Ireland, organisations must be registered as a charity with the Charity Commission for Northern Ireland or as a CIC with Companies House.

To be accredited as a lead sponsor, organisations must have been registered and operating for a minimum of one year prior to application.

Lead sponsors must be based and operating in the UK. The role requires organisations to support sponsors, assess sponsorship arrangements and maintain oversight of sponsorship activity across the UK. As these functions require ongoing engagement with sponsors and oversight of sponsorship arrangements, organisations cannot undertake the role entirely remotely.

Capability, resources and networks

Organisations must demonstrate that they have the capacity and capability to fulfil the role effectively. This must include evidence of:

• relevant experience and expertise
• organisational resources, capacity and networks
• appropriate policies and procedures
• monitoring and assurance arrangements
• identified individuals to undertake the key contact, authorising officer and safeguarding lead functions
• consortium arrangements (where applicable)
• refugee study route capability (where applicable)

Support for multiple sponsorship arrangements

Lead sponsors should be able to support multiple sponsorship arrangements while providing effective support and oversight. To be accredited, organisations are expected to commit to working towards supporting a minimum number of sponsorship arrangements during the initial three-year accreditation period and must demonstrate that they have the capacity and capability to support and oversee multiple sponsorship arrangements at the same time.

For the purposes of this requirement, a sponsorship arrangement involving a refugee and any eligible dependants will be counted as a single sponsorship arrangement. For example, a lead sponsor supporting a sponsorship arrangement for a family of five would count as one sponsorship arrangement rather than five.

Governance board

Organisations must have a governance board where more than 50% of members are British or Irish citizens. This includes individuals who hold British or Irish citizenship in addition to another nationality. This requirement helps ensure that organisations carrying out key sponsorship functions have a strong understanding of the UK context in which the routes operate.

Related external links

Charity Commission

Companies House.

Office of the Scottish Charity Regulator (OSCR)

Charity Commission Northern Ireland

Applying to become a lead sponsor

This section explains how organisations can apply to become a lead sponsor and the evidence they will be required to provide as part of the accreditation process.

To be accredited as a lead sponsor, organisations must meet the eligibility requirements.

Checks on organisations and personnel

As part of the accreditation process, the Home Office will conduct checks on organisations applying to become lead sponsors and on individuals connected with the application. This may include checks in relation to key personnel, board members and consortium partners.

These checks will be carried out when considering an application and may be repeated during the period of lead sponsor accreditation where necessary. Before repeating checks on key personnel, the Home Office will contact the lead sponsor’s key contact to confirm that the individuals concerned remain in their role.

The Home Office may use information provided as part of an application, together with information lawfully obtained from government departments, public authorities and other relevant bodies, where necessary to assess whether an organisation and associated individuals connected with the application are suitable to undertake the lead sponsor role.

Information required as part of the application

As part of their application, organisations will be required to provide the following information:

• name and UK-based address of organisation
• charity or organisation number
• information about key personnel
• information about board members
• details of partner organisations (if applying as part of a consortium)
• a statement of capability setting out how the organisation will fulfil the lead sponsor role

Organisations should ensure they have gathered all required information and supporting documentation before beginning the application process, as the online application form cannot be saved once started.

Name and address of organisation

Charities applying to become lead sponsors must provide the name of the organisation exactly as it appears on the relevant charity register.

CICs applying to become lead sponsors must provide the name of the organisation exactly as it appears on Companies House.

The address provided on the application form must be a UK-based address; this must be the registered address for the organisation.

Charity or organisation registration number

Organisations must provide their charity registration number or Companies House registration number, as applicable. Charity registration numbers and Companies House Registration numbers are usually 8-10 characters.

Key personnel

Organisations must nominate individuals to undertake the following key roles:

• key contact

• authorising officer

• safeguarding lead

One individual may hold more than one position within the organisation; however, a single individual must not hold all three positions.

Organisations will be required to provide the following details for each individual nominated as a member of key personnel:

• full name and any previous names they have been known by
• date of birth
• nationality
• passport or driving licence (including uploading an image of the document)
• email address

If any members of key personnel do not hold a passport or driving licence, the Home Office will contact them to request alternative forms of identity documentation.

Lead sponsors must keep their key personnel information up to date throughout the duration of the lead sponsor agreement. They must notify the Home Office as soon as reasonably practicable of any changes to the key contact, authorising officer or safeguarding lead. The Home Office may request updated information, identity documentation or other evidence in relation to new personnel.

Key contact

The key contact should be the individual responsible for the organisation’s relationship with the Home Office and the day-to-day delivery of the lead sponsor role. This may include overseeing sponsor engagement and onboarding, managing relationships with sponsors, overseeing sponsorship activity, coordinating the assessment of sponsorship applications or coordinating staff and volunteers involved in sponsorship. In addition, this individual will act as the main point of contact with the Home Office.

Authorising officer

The authorising officer must be a senior individual within the organisation with overall accountability for its delivery of the lead sponsor role. They must have authority to make decisions on behalf of the organisation, approve key sponsorship activities and commit organisational resources where required, including financial decisions.

The authorising officer will be responsible for ensuring the organisation complies with the requirements of the route and will be the individual accountable to the Home Office for the organisation’s performance as a lead sponsor.

Safeguarding lead

The safeguarding lead should have appropriate safeguarding knowledge and a thorough understanding of the organisation’s safeguarding policies and procedures.

The safeguarding lead is responsible for supporting sponsors to understand and comply with safeguarding requirements, reviewing proposed safeguarding arrangements as part of the sponsor assessment process and promoting good safeguarding practice throughout the sponsorship arrangement. Responsibility for day-to-day safeguarding within a sponsorship arrangement remains with the sponsor, and relevant statutory agencies retain their safeguarding responsibilities.

Where safeguarding concerns arise, the safeguarding lead must ensure that they are identified, recorded and addressed appropriately. This may include recommending additional support, training or oversight, notifying the Home Office where required and making referrals in accordance with local safeguarding arrangements.

The safeguarding lead is responsible for ensuring that appropriate Disclosure and Barring Service (DBS) checks, or the Devolved Government equivalents, are considered and completed for staff, volunteers or other individuals who will provide support to refugees. This includes ensuring appropriate records are maintained and that sponsors understand and comply with any safeguarding and DBS check requirements applicable to their role. Further information of which DBS check is right for those directly supporting the resettled individuals can be found at: Find out what type of DBS check you can get - GOV.UK.

Board members

Organisations must provide the following information for all board members:

• full name
• date of birth
• nationality
• passport number (where held)

Where a board member does not hold a passport, the Home Office may request alternative documentation to verify their nationality.

Consortium members

If applying as part of a consortium, the organisation acting as the lead sponsor must provide details of all consortium members, including the name of each organisation and a description of its role within the consortium.

Where an application is made by a consortium, the lead sponsor eligibility criteria apply only to the organisation acting as the lead sponsor. Other consortium members are not required to meet all of the lead sponsor eligibility criteria.

The organisation acting as the lead sponsor remains responsible for fulfilling the lead sponsor requirements and for ensuring that any activities carried out on its behalf by consortium members are delivered in accordance with the route requirements.

Statement of capability

The statement should clearly demonstrate how the organisation intends to meet its responsibilities as a lead sponsor, including evidence of its experience and expertise, resources and networks, policies and procedures, monitoring and assurance arrangements, and any other information relevant to the delivery of the lead sponsor role.

Further information on the evidence that should be included in the statement of capability is available in the section Statement of capability.

Related external links

Find out what type of DBS check you can get - GOV.UK

Statement of capability

This section explains the information organisations should include in their statement of capability.

The statement of capability forms a key part of the lead sponsor accreditation process and will be used by the Home Office to assess whether an organisation has the capability, resources and networks required to fulfil the lead sponsor role.

Organisations must submit a statement of capability outlining how they will deliver the lead sponsor role and meet the accreditation criteria set out in this guidance.

The information below provides a non-exhaustive list of the types of evidence organisations may wish to include within the statement of capability. Organisations should focus on providing evidence that best demonstrates their ability to fulfil the lead sponsor role.

Statements of capability will be assessed against the accreditation criteria set out in this guidance. Organisations should provide information demonstrating how they will meet those criteria.

Statements of capability must be submitted as a single document and must not exceed 7MB in size. Organisations should aim for around 1,000 words per section; however, this is not a hard limit. Where further detail is required to evidence the criteria, organisations can exceed 1,000 words. Statements of capability are not required to be fully composed of text, and organisations can include links and images as part of their submissions.

The statement must address each of the following:

• experience and expertise
• resource and networks
• policies and procedures
• monitoring and assurance
• consortiums (if applicable)
• study route requirements (if applicable)

Experience and expertise

Organisations should provide evidence of any relevant experience that demonstrates their ability to fulfil the lead sponsor role. This may include experience of refugee resettlement, community sponsorship, integration support, safeguarding, volunteer management or supporting vulnerable individuals.

Organisations with previous experience of refugee resettlement or community sponsorship may wish to include information such as:

• the number of refugees supported to resettle in the UK

• integration outcomes achieved, such as employment, English language progression, education outcomes or sustained accommodation

• case studies demonstrating the support provided to refugees, including the plans put in place to address identified needs and support successful integration

• formal or informal training undertaken

Organisations without prior experience of refugee resettlement should explain the processes, expertise and partnerships they will use to deliver the lead sponsor role effectively. In addition, they should demonstrate how they will address any gaps in experience and ensure they have access to the knowledge and support required to fulfil the role. They may include information about transferrable knowledge and skills including:

• volunteer management
• support for vulnerable populations
• experience of education or housing
• community development

For organisations who are new to delivering community sponsorship, partnering with other organisations as part of a consortium can support delivery of the lead sponsor role by reducing the direct impact on the organisation. For further information see Consortiums.

If a lead sponsor intends to work with particular sponsors or refugee groups (e.g., groups which support specific diasporas or LGBTQIA+ refugees), it may include evidence of its experience and understanding of those groups as part of its evidence of experience and expertise.

Study route lead sponsors must have specialist expertise in refugee education and a demonstrable history of delivering support in this area.

Resources and networks

Organisations should explain the staffing, financial resources, partnerships and organisational capacity available to support delivery of the lead sponsor role. This should demonstrate how the organisation is equipped to onboard, support and oversee sponsors and manage multiple sponsorship arrangements.

Organisations should also describe their network of partners and stakeholders, including any relationships with community groups, charities, local authorities, Strategic Migration Partnerships (SMPs) and other organisations involved in integration support. This may include evidence of relevant partnerships, referral pathways and community connections that will enable sponsors and refugees to access accommodation, safeguarding support, education, healthcare, employment, integration services and other support where required.

Organisations may wish to include information such as:

• the number of staff and/or volunteers available to deliver the lead sponsor role, including a breakdown of full-time or part-time roles and their responsibilities or recruitment plans to increase resource
• the geographical areas in which the organisation operates and how staff and resources are distributed across those locations. If the organisation will be supporting sponsors remotely, evidence of how it will support and oversee geographically dispersed sponsors
• details of the organisation’s networks including relationships with other charities or organisations, community groups, local authorities, SMPs and other relevant partners
• details of any existing partnerships with sponsor groups or other organisations involved in refugee resettlement, integration or sponsorship activity
• evidence of the organisation’s capacity to engage, support and oversee sponsors, including an assessment of the number of sponsorship arrangements the organisation could reasonably support at any one time and the assumptions underpinning that assessment, taking account of available staffing, resources, governance arrangements, partnerships and anticipated demand
• details of the organisation’s arrangements for delivering sponsor onboarding and preparatory activities, including how it will ensure sponsors complete any Home Office-required onboarding and preparatory activities, understand their responsibilities under the route and have access to appropriate guidance and support throughout the sponsorship period

The Home Office recognises that named community sponsorship and refugee study are new routes and that some prospective lead sponsors may have limited previous experience of sponsorship. As a result, organisations may not be able to accurately predict the number of sponsorship arrangements they will ultimately deliver, due to circumstances outside an organisation’s control.

Assessment will focus not only on organisational capacity, but also on whether an organisation has the knowledge, expertise, partnerships, referral pathways and community networks required to support sponsors and refugees effectively and consistently across multiple sponsorship arrangements.

Study route lead sponsors are required to have access to overseas academic networks who will support study route lead sponsors to identify suitable refugees with the required academic qualifications and English language ability to access university courses in the UK.

Policies and procedures

The organisation should describe the policies and procedures it has in place to support delivery of the lead sponsor role and sponsors. These policies should demonstrate how the organisation will manage risk, support sponsors and safeguard refugees. Organisations are not required to provide copies of policies in their statement of capability.

The relevant policies and procedures include:

• safeguarding policy – organisations should explain how their safeguarding policies support the delivery of sponsorship arrangements, including how safeguarding concerns will be identified, escalated and managed, and how refugees will be supported safely throughout the sponsorship process.
• complaints procedure – organisations should explain how complaints and concerns raised by sponsors, refugees or other stakeholders will be received, recorded, considered and responded to in a fair, transparent and timely manner, including how complaints routes will be communicated to sponsors and refugees.
• data protection and information handling procedures – organisations should explain how personal data relating to sponsors and refugees will be collected, stored, shared and protected in accordance with relevant data protection legislation.
• anti-modern slavery and trafficking policies – organisations should explain the arrangements they have in place to identify, prevent and respond to risks of modern slavery, trafficking or exploitation affecting refugees. This should include how sponsors will be expected to identify and escalate concerns
• anti-fraud policies – organisations should explain how they will ensure that sponsorship arrangements are not designed for profit
• Indemnity and liability insurance – organisations should explain the relevant policies they have in place when working with volunteers, community groups or partner organisations. This could include public liability, employer’s liability or professional indemnity insurance, where relevant
• conflicts of interest arrangements – organisations should have appropriate arrangements to identify, manage and record actual, potential or perceived conflicts of interest, particularly where these could affect the organisation’s oversight, assurance or decision-making functions as a lead sponsor

Organisations should outline how these policies and procedures will be applied in practice to support sponsors and refugees.

Monitoring and assurance

Organisations must explain how they will monitor sponsorship arrangements and provide ongoing assurance that sponsors are meeting their responsibilities under the route. The statement of capability should set out the systems and processes the organisation will use to monitor sponsorship outcomes, including any quantitative or qualitative information required.

Organisations should also explain how they will identify and address concerns, provide additional support to sponsors where required, and evaluate the overall effectiveness of sponsorship arrangements, including how the organisation would plan to put in place contingencies in cases of sponsorship breakdown.

The Home Office does not require organisations to use any specific monitoring methodology. However, organisations must demonstrate that they have robust arrangements in place to monitor sponsorship arrangements and identify concerns.
Organisations may wish to include information on how they plan to monitor:
- whether refugees continue to have access to suitable accommodation - whether refugees are being supported to access key services, such as healthcare, education, welfare support and employment - progress towards integration and self-sufficiency - compliance with safeguarding requirements - sponsor performance and adherence to route requirements - the effectiveness and sustainability of sponsorship arrangements - attendance, academic progression, retention, study completion and graduate outcomes for refugees participating in the Refugee Study route

For more information, see section Monitoring and assurance.

Consortiums

Where several organisations are applying as part of a consortium, one organisation must be nominated as the lead sponsor. The designated lead sponsor must complete the application form. The organisation nominated as the lead sponsor must meet all eligibility requirements for the role of lead sponsor. Other consortium members are not required to meet lead sponsor eligibility requirements.

If organisations are applying as part of a consortium, they must provide details of the functions that each organisation will be responsible for and explain how the consortium will work together to deliver the lead sponsor role.

The statement of capability should outline how the consortium will work together to deliver the lead sponsor role, by explaining how the combined skills, experience, networks and resources of consortium members will support the delivery of the lead sponsor role and provide assurance that responsibilities are clearly defined and appropriately managed.

Information relating to key personnel, governance board members and governance arrangements should be provided for the designated lead sponsor organisation. The designated lead sponsor will remain accountable to the Home Office for delivery of the lead sponsor role and compliance with the requirements of the route.

Study route

Organisations applying to become study route lead sponsors will need to demonstrate how they meet additional evidence pertaining to how they will deliver the study route lead sponsor role. Study route lead sponsors will need to demonstrate their ability to undertake specialised roles including evidence of:

• their overseas academic networks to assess qualifications and the suitability of refugees to access higher education
• details of overseas partners used in the assessment of refugee capability to access study
• how the organisation will work with university sponsors to match refugees to suitable courses
• their ability to assess qualification equivalency and English language proficiency in order to identify suitable university courses and support refugee referrals
• their ability to support refugees with university, student finance and other required applications, such as ATAS applications
• their ability to meet funding gaps in student funding (such as those typically faced by taught master’s students) through philanthropic partners or scholarships from university sponsors
• their ability to support refugees in securing housing outside of student accommodation
• their ability to support refugees through study and postgraduate employment
• their ability to integrate refugees into UK society
• previous experience of working in and/or delivering refugee education and/or refugee education sponsorship

How will the Home Office process applications for approval as a lead sponsor?

This section explains how applications to become a lead sponsor will be assessed and how organisations will be notified of the outcome.

Once an application has been submitted, the Home Office will assess whether the organisation meets the requirements to be accredited as a lead sponsor.

Where further information is required before a decision can be made on the application, the Home Office will contact the key contact named in the application to request additional evidence or clarification.

Successful application

If an application is successful, the Home Office will notify the organisation by email and invite it to enter into a contract before it can begin operating as a lead sponsor.

Contract

Before an organisation can begin operating as a lead sponsor, it must enter into a contract with the Home Office. The contract will outline:

• the respective roles and responsibilities of the Home Office and the lead sponsor throughout the period of accreditation
• monitoring, reporting and assurance requirements
• processes for managing and escalating issues
• arrangements for reviewing performance and compliance
• circumstances in which accreditation may be suspended or terminated
• data sharing arrangements and agreement

The contract will include a data sharing protocol (DSP) setting out how data will be used, stored and secured. The DSP will set out the purpose of the data collected and the responsibilities of each party for handling and storing that data in accordance with UK data protection legislation.

The contract must be signed by authorised representatives of both the Home Office and the lead sponsor. An organisation may only operate as a lead sponsor once the contract has been signed by both parties. The date that the contract is signed by both parties will be the date that the organisation will commence operating as a lead sponsor.

Contract term and review

The contract between the Home Office and the lead sponsor will initially be in place for a period of three years. Three months before the stated expiry of the contract, the Home Office will review the organisation’s performance, compliance with the requirements of the route and ongoing capability and suitability to operate as a lead sponsor.

Following this review, the Home Office may extend the agreement for a further period, with or without amendments, where it is satisfied that the lead sponsor continues to meet the requirements of the route. Lead sponsors will not ordinarily be required to submit a new application for accreditation to extend the term of the agreement.

Throughout the term of the agreement, lead sponsors will be subject to ongoing monitoring and assurance activity by the Home Office.

Lead sponsors must notify the Home Office of any significant changes which may affect their ability to fulfil the lead sponsor role. This includes changes to key personnel, governance arrangements, organisational structure, financial circumstances or any other material change relevant to their accreditation.

Publication of approved lead sponsors

Details of approved lead sponsors will be published on GOV.UK.

Unsuccessful application

Applications will be refused where an organisation does not meet the accreditation criteria set out in this guidance. Refusal decisions cannot be appealed.

Where an application is refused, the Home Office will explain the reasons in writing for the decision. Organisations may submit a new application three months after the date of the refusal decision, provided they have addressed the issues identified in that decision. A previous refusal does not prevent an organisation from applying again.

Where an application is refused due to concerns relating to fraud, dishonesty, misconduct or other integrity issues, the organisation will not be eligible to submit a further application for a period of two years from the date of the refusal decision. Any future application must demonstrate that the concerns identified by the Home Office have been fully addressed.

The Home Office reserves the right to refuse to consider a further application where it is not satisfied that the organisation is suitable to fulfil the lead sponsor role.

Eligibility criteria for sponsors

This section explains how lead sponsors should assess whether a proposed sponsor meets the requirements of the route before a sponsorship arrangement is submitted to the Home Office.

Assessing sponsor eligibility

Lead sponsors must assess whether a proposed sponsor meets the requirements of the route and appears capable of delivering its responsibilities throughout the sponsorship period.

Lead sponsors should gather and document sufficient information and evidence to support their assessment that the proposed sponsor appears to meet the requirements of the route. They should provide the Home Office with a summary of their assessment and the evidence considered as part of the sponsorship application.

Requirements applicable to all sponsors

Lead sponsors must consider the sponsor’s overall suitability to participate in the route.

The Home Office may set additional requirements in due course, if this becomes necessary to ensure the safe operation of the scheme. If any new requirements are added, this policy document will be updated accordingly, and Lead Sponsors will be notified.

Safeguarding and background checks

Lead sponsors should satisfy themselves that the sponsor is suitable to participate in the route and capable of fulfilling its responsibilities. This should include consideration of information obtained through sponsor engagement, onboarding activities, interviews, references and any other checks undertaken by the lead sponsor. Where concerns arise regarding a sponsor’s suitability, lead sponsors should take appropriate steps to resolve those concerns before endorsing a sponsorship arrangement.

Lead sponsors should ensure that individuals involved in sponsorship activity are suitable to undertake their role and that any DBS checks, or Devolved Government equivalents, required for the role have been completed before the Home Office approves the sponsorship arrangement.

Training requirements

Lead sponsors should be satisfied that the sponsor understands and is willing to comply with any training requirements associated with the route.

Location and local knowledge

Lead sponsors should consider whether the sponsor has a sufficient understanding of the local area and the services, support networks and opportunities available to support refugees. This may include whether the sponsor is based in, or has a clear connection to, the community in which the refugee will be living. This supports effective integration and access to local support networks and services.

Additional requirements for named community sponsorship

For sponsors applying under the named community sponsorship route, lead sponsors must ensure that the sponsor group is comprised of a minimum of five named members who will hold key roles in delivering the sponsorship arrangement. This helps ensure sufficient capacity and resilience to deliver sponsorship responsibilities throughout the sponsorship period and reduces reliance on any single individual.

The Home Office may publish additional requirements relating to sponsor group membership and the individuals undertaking key sponsorship roles in due course. Lead sponsors will be notified of any such requirements and this guidance will be updated accordingly.

How to assess proposed sponsorship arrangements

This section explains the role of lead sponsors in completing an assessment of whether proposed sponsorship arrangements appear to meet the requirements of the route.

When assessing a proposed sponsorship arrangement, lead sponsors should consider whether the sponsor understands and is capable of fulfilling its responsibilities.

Lead sponsors must provide details of their assessment, and supporting evidence where requested, to the Home Office as part of the sponsorship application. The Home Office will consider the lead sponsor’s assessment and determine whether the requirements of the route have been met.

Assessing sponsor capability

When assessing whether a sponsorship arrangement is suitable, lead sponsors should satisfy themselves that the sponsor understands and is capable of fulfilling its responsibilities. This includes considering whether the sponsor can:
- identify and propose refugees or demonstrate a willingness to work with the lead sponsor to identify suitable refugees to sponsor - secure suitable accommodation - secure sufficient financial resources to support the refugee - develop and deliver an integration, participation and progression plan appropriate to the route - comply with safeguarding, reporting and performance requirements - engage with local authorities and relevant partners where required - complete any mandatory training and guidance required by the route

Assessing sponsorship arrangements

Before submitting an application, lead sponsors must assess whether the proposed sponsorship arrangement appears to meet the requirements of the route and is capable of providing the support the refugee requires.

As part of this assessment, lead sponsors should consider whether the sponsor has made appropriate preparations for the refugee’s arrival and initial relocation in the UK. They should also consider whether appropriate arrangements are in place to provide support from the point of arrival and help the refugee access essential services and begin integrating into their new community.

This includes assessing the sponsor’s:

• accommodation arrangements

• financial resources

• safeguarding arrangements

• plans to support integration, participation and progression, including initial settlement, longer-term self-sufficiency, or successful participation in higher education where relevant

• ability to provide a suitable university place (refugee study route only)

Where concerns are identified

During the assessment process, lead sponsors may identify concerns regarding a proposed sponsorship arrangement or determine that they do not have sufficient capacity to support the arrangement.

Where concerns are identified, lead sponsors should consider whether those concerns can reasonably be addressed through the provision of further information, clarification or amendments to the proposed arrangements.

Sponsors should be given an opportunity to provide additional information or address concerns identified during the assessment process, where appropriate.

If, following assessment, a lead sponsor considers that the proposed sponsorship arrangement does not meet the requirements of the route, is capable of providing the support required by the refugee, or the lead sponsor does not have sufficient capacity to support the arrangement, the lead sponsor should not submit the sponsorship arrangement to the Home Office.

Where a lead sponsor decides not to proceed with a proposed sponsorship arrangement, it should clearly explain the reasons for that decision to the sponsor.

Where a lead sponsor decides not to work with a prospective sponsor because of concerns about their suitability to participate in the route, the lead sponsor must notify the Home Office and provide details of those concerns.

Accommodation

Lead sponsors must assess whether the sponsor has suitable accommodation in place, or a credible and deliverable plan to secure suitable accommodation, for the required period before the refugee arrives in the UK.

Suitable accommodation is a critical component of a successful sponsorship arrangement. Lead sponsors should obtain sufficient information and evidence to satisfy themselves that any accommodation provided under a sponsorship arrangement is safe, secure, affordable, sustainable and appropriate to the refugee’s needs throughout the sponsorship period.

Accommodation does not need to be secured at the point a sponsorship arrangement is initially proposed. However, lead sponsors must be satisfied that the sponsor has a realistic and credible plan to secure suitable accommodation before the refugee arrives in the UK.

Before a refugee is granted permission to travel to the UK, lead sponsors must confirm to the Home Office that suitable accommodation has been secured, assessed and is available for occupation. Further guidance on suitable accommodation will be published in due course.

Accommodation not yet secured

When considering whether a plan to secure accommodation is credible, lead sponsors should consider factors such as:

• the sponsor’s proposed accommodation model
• evidence of available housing options and local market conditions
• identified funding sources and affordability
• contingency arrangements should the preferred accommodation not become available
• the sponsor’s previous experience of securing accommodation, where relevant

Accommodation must be secured and confirmed within a timeframe specified by the Home Office. Where accommodation has not been secured or confirmed by that deadline, the application will be refused, and a new application will be required once the sponsor has a credible plan in place for accommodation.

Further information, including on the applicable timeframe, will be published in due course.

Accommodation – named community sponsorship

Lead sponsors must review the information and evidence provided about the proposed accommodation and undertake an assessment of whether it appears to meet the accommodation requirements of the route. Lead sponsors may decide how this assessment is carried out, taking a proportionate and risk-based approach. This may include undertaking checks directly or obtaining relevant information and evidence from local authorities or property management companies.

Suitable accommodation should generally be available for a minimum of two years from the refugee’s arrival in the UK, although this may vary depending on the type of accommodation being provided. Lead sponsors should therefore satisfy themselves not only that accommodation is suitable at the point of arrival, but also that there are realistic and sustainable arrangements in place to meet the accommodation requirement throughout that period.

When assessing accommodation, lead sponsors should consider factors such as:

• whether the accommodation is of an appropriate size for the refugee or family who will occupy it
• the condition, security and state of repair of the property, including whether it is well maintained, free from serious hazards and whether external doors and windows can be secured
• whether the property contains appropriate furnishings, facilities and amenities necessary for daily living
• the safety of the property. Lead sponsors should satisfy themselves that any relevant legal and safety requirements have been met, for example by checking that relevant certificates and inspections are up to date. Lead sponsors are not expected to undertake statutory inspections or assessments, such as fire safety checks, themselves. Sponsors can submit copies of safety and property information to the lead sponsor
• the accessibility of the property and whether any known accessibility needs have been identified and whether adaptations or other arrangements may be required to accommodate them
• whether the accommodation will be affordable and sustainable throughout the sponsorship period, including the expected duration, stability and security of any tenancy, licence or occupancy arrangement
• the location of the accommodation, including access to public transport, education, healthcare and other essential services
• the wider location and surrounding area, including whether there are any known safety, safeguarding or community cohesion concerns which could affect the refugee’s wellbeing, integration or sense of security

The evidence required will depend on the accommodation being provided but may include tenancy or licence agreements, proof of ownership, property inspection reports, safety certificates, photographs of the accommodation, confirmation of affordability, or other documentation demonstrating that the accommodation is suitable and available for occupation.

Accommodation should comply with all relevant housing, landlord, tenancy, licensing and property safety requirements, including any legal obligations that apply to the accommodation type being provided. Housing suitability should be assessed against any standards, guidance or requirements specified by the relevant local authority or Devolved Government.

Lead sponsors should be satisfied that the accommodation is suitable for the refugee’s circumstances, capable of meeting any known accessibility or support requirements identified through the sponsorship process, and capable of supporting their integration and progression towards independence.

Accommodation – study route

The accommodation requirements under the study route differ from those under the named community sponsorship route, reflecting the role of university sponsors and the use of university-managed accommodation.

Study route lead sponsors are responsible for carrying out accommodation checks to ensure accommodation for refugees provided by university sponsors is suitable, including that it is safe and secure, capable of meeting any known accessibility or support needs and appropriately located to enable access to study, healthcare and other essential services.

Study route lead sponsors will need to confirm that either:
- accommodation is available for the first academic year for undergraduate students including outside academic term time or - for the full twelve months of the course for taught master’s students as refugees will not have alternative accommodation available outside academic term time

Study route lead sponsors must conduct a minimum of one check prior to the refugee’s arrival to ensure the property is prepared and of a suitable standard. Lead sponsors may choose to check-in with the refugee in person or remotely to do a follow up check if they feel it is required after the individual has had sufficient time to settle in. This is to ensure the refugee is not having any issues with the property. If there are issues, study route lead sponsors must manage and resolve any concerns/issues directly with the university sponsor. Study route lead sponsors should use their discretion in deciding how many further checks they should do.

Following the first year of undergraduate study, refugees will normally secure accommodation outside of university halls to support their integration and independence. Study route lead sponsors, alongside university sponsors, must support undergraduate refugees to identify and secure suitable alternative accommodation.

This support should include practical advice on:

• tenancy agreements,
• renters’ rights and responsibilities
• utility bills and household costs
• budgeting
• accessing accommodation in the private rented sector
• navigating shared living arrangements

Financial resources

Lead sponsors must assess whether sponsors have sufficient financial resources to support the refugee throughout the sponsorship period. Sponsors should provide evidence of available funds and, where applicable, any plans to raise additional funding.

Lead sponsors should obtain sufficient information and evidence to satisfy themselves that the sponsor has the resources necessary to meet the costs associated with the sponsorship arrangement. Evidence may include bank statements, evidence of pledged donations, grant funding agreements, fundraising plans, or other documentation demonstrating that sufficient resources are available.

Sponsors are not required to hold all funding at the point a sponsorship arrangement is initially proposed. However, lead sponsors must be satisfied that the sponsor has a realistic and credible plan to secure any additional funding required before the refugee arrives in the UK. Any funding required under the sponsorship arrangement must be secured and confirmed before a visa can be granted.

Sponsors must not seek personal or business loans to fund sponsorship arrangements.

Sponsors must not charge refugees to access resettlement pathways or profit financially from sponsorship arrangements. If a lead sponsor suspects that a sponsor intends to charge refugees fees, seek reimbursement of sponsorship costs, or derive a financial benefit from facilitating sponsorship arrangements, the lead sponsor should report this to the Home Office.

Before a refugee is granted permission to travel to the UK, lead sponsors must confirm to the Home Office that sufficient funding is in place to support the refugee throughout the sponsorship arrangement.

Financial resources not yet secured

When considering whether a plan to source funding is credible, lead sponsors should consider factors such as:
- identified funding sources and the likelihood of those funds being secured - evidence of previous fundraising activity or grant funding, where relevant - the sponsor’s contingency arrangements should anticipated funding not materialise - the sponsor’s previous experience of supporting refugees or delivering comparable activities, where relevant

Funding must be secured and confirmed within a timeframe specified by the Home Office. Where sufficient funding has not been secured or confirmed by that deadline, the application will be refused, and a new application will be required once the sponsor has a credible plan in place for securing sufficient funding. Further information on the applicable timeframe will be published in due course.

Financial resources

Lead sponsors are responsible for determining what level of funding is required for each sponsorship arrangement. This assessment should take account of the specific circumstances of the proposed sponsorship and the anticipated support needs of the refugee, and the lead sponsor should explain the basis for that assessment when submitting the application to the Home Office.

When assessing financial resources, lead sponsors should consider factors such as:

• whether the sponsor is supporting an individual or a family
• the location of the sponsor arrangement
• the expected cost of accommodation in the locality
• the ability of the refugee to secure employment
• whether the refugee has additional or complex needs requiring additional support
• the anticipated cost and availability of transport
• the refugee’s anticipated support requirements, including any additional or complex needs
• the likely costs associated with supporting integration, education and access to employment
• any other foreseeable costs associated with the sponsorship arrangement

Lead sponsors should ensure that sponsors have sufficient funds available to meet costs incurred before arrival and during the initial six months following arrival.

Sponsors must be able to provide financial support for the duration of the sponsorship arrangement. Sponsors should therefore demonstrate both:

• sufficient funds available upfront to cover anticipated costs before arrival and during the initial six months following arrival; and
• a credible plan and sufficient resources to sustain support throughout the sponsorship period.

As a guide, sponsors supporting a family may typically be expected to demonstrate access to between £9,000 and £15,000. Lead sponsors may determine that a higher or lower amount is appropriate depending on the circumstances of the case. Where a sponsor is supporting an individual rather than a family, the level of funding required is likely to be lower.

Funding should be sufficient to cover accommodation costs, living expenses and any supplementary support required to enable successful integration.

Financial resources – study route

Study route lead sponsors must satisfy themselves that sufficient funding is available to meet the costs associated with study and living in the UK for the duration of the sponsorship arrangement. This includes course fees, accommodation costs where applicable, living expenses and any other support required to enable the refugee to participate successfully in their course.

Where refugees cannot immediately access home fee status and student finance upon arrival or where student finance does not cover all costs (for example taught master’s students), study route lead sponsors are responsible for ensuring course fees and living costs are fully covered for the duration of study.

Study route lead sponsors, alongside university sponsors, may determine how such costs are met. Options include, but are not limited to, study route lead sponsors securing philanthropic funding, the university sponsor waiving course fees and the university sponsor granting fully funded and verified scholarships which cover course fees and living costs.

Safeguarding arrangements

Lead sponsors must assess whether appropriate safeguarding arrangements are in place, or planned, for the proposed sponsorship arrangement. This includes considering the nature of the support that will be provided, the individuals involved in delivering that support and any risks to refugees.

As part of this assessment, lead sponsors should consider whether the sponsor has:

• identified any risks that may arise from the sponsorship arrangement and plans to put appropriate measures in place to manage those risks
• clear processes for identifying, reporting and escalating safeguarding concerns to the appropriate safeguarding lead, statutory authority, lead sponsor or other relevant body, as appropriate, including allegations or concerns relating to staff, volunteers or other individuals involved in delivering support
• arrangements in place to ensure refugees know how to raise concerns or seek support
• arrangements to ensure that individuals providing support to refugees are aware of safeguarding risks, reporting procedures and any relevant safeguarding responsibilities
• appropriate arrangements for supporting or supervising individuals providing support to refugees
• arrangements for sharing safeguarding information appropriately and maintaining confidentiality
• appropriate expectations and boundaries for individuals providing support to refugees
• identified a named individual responsible for safeguarding matters within the sponsor organisation or group

Assessing safeguarding risks

Lead sponsors should review how the sponsor has identified and assessed any safeguarding risks associated with the proposed sponsorship arrangement and whether appropriate measures are in place or will be in place before support is provided to a refugee, to mitigate those risks. This may include reviewing any safeguarding policies, procedures or plans provided by the sponsor and considering whether they are appropriate and proportionate to the nature of the sponsorship arrangement.

When assessing the proposed sponsorship arrangement, lead sponsors should also consider whether there are any safeguarding risks arising from the sponsor, sponsorship model or proposed support arrangements. This may include considering:

• whether the sponsor has the capacity and capability to deliver support safely and appropriately
• whether roles and responsibilities are clearly defined and understood
• whether the proposed support arrangements could create inappropriate dependency on individual sponsors or volunteers
• whether there is sufficient oversight, supervision and accountability
• whether any aspects of the proposed accommodation or support arrangements create additional safeguarding risks that require mitigation
• whether there are any known concerns regarding the sponsor’s conduct, governance, behaviour or previous delivery of sponsorship, where relevant

Lead sponsors should also consider whether there are any safeguarding risks associated with the individuals involved in delivering the sponsorship arrangement and whether any additional safeguards or mitigations are required before submitting an application to the Home Office. This may include considering:

• the nature and extent of contact with refugees
• whether individuals will provide unsupervised support
• whether appropriate supervision, boundaries and accountability arrangements are in place
• whether any concerns have been identified regarding an individual’s conduct, suitability or behaviour
• whether individuals have received appropriate safeguarding training and understand their safeguarding responsibilities
• whether any personal, financial or family relationships could create safeguarding concerns, conflicts of interest or inappropriate dependency

Where risks are identified, lead sponsors should ensure that the sponsor has proposed appropriate mitigation measures and should assess whether those measures appear sufficient before submitting the sponsorship arrangement to the Home Office. This may include requiring additional training, enhanced supervision or oversight, changes to support arrangements, or restricting particular individuals from undertaking certain roles.

The lead sponsor must provide the Home Office with details of the risks identified, the proposed mitigation measures and its assessment of those measures. The Home Office will consider this information when determining whether the proposed sponsorship arrangement meets the requirements of the route.

Safeguarding checks and record keeping

As part of this assessment, lead sponsors must ensure that DBS checks, or the Devolved Government equivalents, for individuals who will provide support to refugees have been identified and will be completed before support is provided to refugees. Where individuals will be interacting directly with refugees, an enhanced DBS check should be undertaken. For example, under the refugee study route, this may include university staff who provide pastoral support, safeguarding functions or unsupervised support to refugees. Where such checks are required, lead sponsors should ensure they have been completed before sponsorship arrangements proceed.

Lead sponsors should maintain appropriate records of safeguarding assessments, safeguarding checks undertaken, and any mitigation measures identified. Lead sponsors must be able to provide this information and any supporting evidence to the Home Office on request. The Home Office will review safeguarding information as part of its consideration of the sponsorship application and whether the proposed sponsorship arrangement is suitable.

Proportionate approach

The safeguarding arrangements required will vary depending on the nature of the sponsorship arrangement, the roles being undertaken and the needs or vulnerabilities of the refugee(s). Lead sponsors should take a proportionate approach when assessing safeguarding arrangements and ensure that any identified risks are appropriately managed.

Integration and self-sufficiency plan

Sponsors must provide a credible integration and self-sufficiency plan setting out how they will support the refugee throughout the sponsorship period.

Under the named community sponsorship route, this should focus on settlement, integration into the community and progression towards long-term self-sufficiency.

Under the study route, this should focus on successful participation in higher education, student wellbeing, integration into the local community and progression to employment, further study or long-term self-sufficiency following completion of study.

All sponsors are expected to provide a core package of support regardless of route or location. This should include support to access accommodation, healthcare, education and other essential services, opportunities for English language learning and community participation and support to progress towards greater independence and self-sufficiency.

The plan should be tailored to the refugee’s circumstances, strengths, needs and aspirations. Where possible, sponsors should support refugees to play an active role in identifying their goals, priorities and longer-term aspirations, recognising that successful integration is most effective when refugees are able to shape their own support and development.

All sponsors are expected to provide support relating to initial settlement, access to essential services, English language learning, community participation, and progression towards education, training or employment, unless clearly not applicable to the circumstances of the refugee.

Arrival and initial settlement support

The integration plan should explain how the sponsor will prepare for the refugee’s arrival and support them during the initial stages of the sponsorship arrangement. Lead sponsors should be satisfied that sponsors have considered the practical, welfare and integration needs that may arise before arrival and during the initial resettlement period following arrival in the UK.

The Home Office’s overseas delivery partner will support operational delivery of the routes overseas, including health assessments, document handling, travel arrangements and other pre-departure processes required before an individual can travel to the UK.

Lead sponsors should recognise that the period immediately before and following arrival may present increased welfare, safeguarding and practical risks. Sponsors should be able to demonstrate that they have considered these risks and put appropriate arrangements in place to manage them.

When assessing these arrangements, lead sponsors should consider whether the sponsor has identified:

• how the refugee(s) will be met and supported on arrival, including arrangements for travel from the airport, port or other arrival location to their accommodation
• arrangements for ensuring accommodation is ready for occupation, that the refugee(s) has access to essential household items and necessities upon arrival, and that they are supported to understand the accommodation, local area, transport options and practical aspects of daily life
• any immediate welfare, health, safeguarding, accessibility, language or communication needs that may require support, including arrangements for interpretation or translation where required
• how the refugee(s) will access food, clothing, toiletries and other essential items and services required during the initial settlement period
• how the sponsor will support the refugee(s) to establish initial contact with relevant services, which may include registering with a GP, accessing education, engaging with local authority services, opening a bank account, accessing welfare support where eligible, or obtaining any documentation required to access services
• arrangements for helping the refugee(s) understand the support available to them, including how to raise concerns, seek assistance and access support independently of the sponsor where necessary
• how sponsors will identify, monitor and respond to concerns arising during the initial settlement period, including arrangements for maintaining contact during the first 72 hours, escalating safeguarding or welfare concerns, and making referrals where additional support is required
• contingency arrangements should travel plans change, accommodation become unavailable, or other urgent issues arise shortly before or after arrival, including arrangements for responding to emergencies outside normal contact arrangements

The plan should demonstrate that sponsors have considered the actions required before arrival and during the initial settlement period, and that appropriate arrangements are in place to provide a safe, supported and well-managed transition into life in the UK and the sponsorship arrangement.

Delivering integration support

Sponsors must provide evidence demonstrating how the proposed support will be delivered in practice. This may include information on local services that have been identified, existing relationships with community organisations, planned referrals to relevant support services, arrangements for English language provision, information on local employment, training and education opportunities and healthcare providers or other support services that are expected to contribute to the refugee’s integration, participation and progression towards self-sufficiency.

For named community sponsorship arrangements, this should focus on supporting refugees to establish themselves in the community, access services, build social connections and progress towards independence and self-sufficiency.

For refugee study route arrangements, this should also explain how the refugee will be supported to access, participate in and succeed in higher education, including support with academic integration, student wellbeing, work placements, careers advice, progression to employment and further study where appropriate.

Lead sponsors must assess whether the proposed arrangements are realistic, tailored to the needs of the refugee or family and capable of supporting successful integration and progression towards self-sufficiency. In doing so, lead sponsors should consider whether:

• appropriate local services, support networks and community connections have been identified and the sponsor has considered how engagement with those services will take place where appropriate
• the sponsor has demonstrated an understanding of the circumstances of the refugee or family, aspirations and longer-term integration needs
• any specific needs or vulnerabilities of the refugee have been identified and appropriately addressed within the support arrangements
• realistic arrangements are in place to support sustained access to accommodation, healthcare, education, training, employment and other services that support long-term integration
• where children are included in the sponsorship arrangement, appropriate arrangements are in place to support access to education, including engagement with local schools, school admissions processes and any additional educational support that may be required
• opportunities have been identified to support English language learning, skills development, education, volunteering or employment, as appropriate
• opportunities have been identified to help the refugee build social connections, participate in community life and develop independent support networks
• the proposed support is achievable and sustainable throughout the sponsorship period
• the plan includes clear measures to support the refugee to develop independence, confidence and self-sufficiency over time
• the sponsor has considered how support will adapt as the refugee’s circumstances change and reliance on sponsorship reduces
• the plan provides a credible pathway towards long-term integration, stability and self-sufficiency in the UK

Progression towards self-sufficiency

Sponsors should demonstrate how support will evolve over the course of the sponsorship arrangement to promote increasing independence and reduce reliance on the sponsor over time. The level and type of support required may change as refugees become more familiar with life in the UK and develop confidence in accessing services, opportunities and support independently.

Lead sponsors should consider whether the sponsor has identified realistic opportunities to support the refugee to develop the knowledge, skills, resources and connections required to live independently and participate fully in society.

Lead sponsors should assess whether:

• the plan identifies realistic outcomes and milestones to support progression towards independence
• support is designed to empower the refugee rather than create long-term dependency
• realistic opportunities have been identified to support progression towards education, training, employment and financial independence
• the proposed support will help the refugee develop the confidence, skills and social networks needed to access services and opportunities independently

Study route and ability to provide a suitable university place

When assessing a proposed study route sponsorship arrangement, study route lead sponsors should consider whether the proposed university place and wider sponsorship arrangements are appropriate to the refugee’s circumstances and capable of supporting successful participation in higher education.

As part of this assessment, study route lead sponsors should consider whether:

• the course is appropriate to the refugee’s educational background, skills and future aspirations

• the refugee’s academic qualifications, prior study and experience meet the entry requirements, including those required under contextual offers, of the proposed course

• the refugee is likely to be able to access, participate in and successfully complete the proposed course

• any subject-specific requirements set by the university sponsor are met

• the refugee will have access to the accommodation, pastoral, welfare and academic support required to participate successfully in the course

Study route lead sponsors should take a holistic view of the refugee’s circumstances when undertaking this assessment. This should include consideration of the refugee’s educational background, support needs, personal circumstances and ability to engage successfully with higher education in the UK.

The university sponsor’s admissions process should provide assurance that the refugee meets the institution’s academic, English language and course entry requirements. Where a university sponsor has assessed a refugee against those requirements, study route lead sponsors should rely on that assessment and are not expected to undertake a separate assessment.

Study route lead sponsors must work closely with university sponsors to ensure that refugees are matched to courses for which they are suitably qualified and capable of successfully participating, and that appropriate accommodation, pastoral, welfare and academic support arrangements are in place throughout the sponsorship period.

Application for a sponsorship arrangement

This section explains the application that lead sponsors must complete and submit to the Home Office on behalf of sponsors seeking to sponsor a refugee and, where applicable, their dependants.

Lead sponsors should only submit an application where they have completed an assessment of the proposed sponsorship arrangement and consider that it appears to meet the requirements of the relevant route.

Information included in the application

The application must include information about:

• the sponsor and proposed sponsorship arrangements
• the refugee(s) to be sponsored, and any eligible dependants
• the route under which the refugee is being sponsored
• any supporting evidence required by the Home Office

Under the named community sponsorship route, details of the sponsor will include the names and details of the five key members who will hold key roles in delivering the sponsorship arrangement.

Lead sponsors are responsible for ensuring that information submitted to the Home Office is accurate, complete and supported by appropriate evidence.

Lead sponsor assessment

As part of the application, lead sponsors must provide a summary of their assessment of the proposed sponsorship arrangement. The summary should explain how the lead sponsor has reviewed the information and evidence provided, the factors it considered and the basis on which it considers the arrangement appears to meet the published requirements of the route. The summary should also identify any concerns, risks or issues identified during the assessment process and explain any steps taken, or proposed, to address them.

The Home Office will consider the lead sponsor’s assessment and determine whether the requirements have been met.

The assessment summary should include consideration of the suitability of the sponsor and the suitability of the proposed sponsorship arrangement.

Lead sponsors must be able to provide supporting evidence relating to their assessment if requested by the Home Office.

Information not required

Lead sponsors are not required to include detailed information regarding a refugee’s reasons for fleeing their country of origin or seeking international protection. Assessments of protection needs will be undertaken by the United Nations High Commissioner for Refugees (UNHCR) or, where applicable, another organisation responsible for assessing protection needs for the relevant caseload. Information relating to the refugee’s protection claim does not need to be included as part of the sponsorship application.

Ongoing oversight of sponsorship arrangements

This section explains the activities lead sponsors are expected to undertake as part of their ongoing oversight of sponsorship arrangements to ensure sponsors continue to meet their responsibilities, refugees receive appropriate support, and sponsorship arrangements remain suitable, sustainable and effective throughout the sponsorship period.

Monitoring and assurance

The Home Office retains overall responsibility for monitoring the operation and delivery of the routes and assuring itself that route requirements continue to be met. This may include reviewing information provided by lead sponsors, seeking further information where necessary and undertaking its own assurance activity.

Lead sponsors contribute to the Home Office’s monitoring and assurance of the routes through their oversight of the sponsorship arrangements they support.

They should establish monitoring and assurance arrangements that are proportionate to the nature and risks of the sponsorship arrangement and provide assurance that sponsors continue to meet the requirements of the route and that refugees are receiving appropriate support.

Lead sponsors should ensure there are regular opportunities for refugees to raise concerns independently of the sponsor. This should include direct contact with the refugee within the first month following arrival and periodic contact throughout the sponsorship period.

As part of their monitoring and assurance activity, lead sponsors should assess whether:

• sponsors continue to meet the requirements of the route
• refugees continue to have access to suitable accommodation and necessary support
• appropriate safeguarding arrangements remain in place
• sponsorship arrangements are supporting integration and progression towards independence
• emerging risks, disputes, welfare concerns or safeguarding concerns are identified and addressed promptly
• sponsorship arrangements remain sustainable and capable of meeting the needs of the refugee

Where concerns arise, lead sponsors should work with sponsors and refugees to address issues through additional support, facilitated discussions or other appropriate interventions. For further information, see Intervention and escalation.

Lead sponsors must maintain appropriate records of their monitoring and assurance activity and provide information to the Home Office when requested, in accordance with any reporting requirements set out in the lead sponsor agreement.

Lead sponsors may be asked to participate in Home Office evaluation activities, such as interviews or focus groups, and should engage with these activities where possible. Lead sponsors should support Home Office monitoring and evaluation activity by promoting participation in the voluntary Resettlement Outcomes Over Time Survey of refugees, when relevant.

Accommodation

Lead sponsors should have arrangements in place to monitor whether accommodation remains safe, suitable and sustainable throughout the sponsorship period.

Monitoring arrangements should consider:

• whether accommodation remains suitable for the refugee’s needs
• whether any safety, maintenance or affordability concerns have arisen
• whether any accessibility or support needs are not being met
• whether any issues with landlords, hosts or other occupants require intervention
• whether accommodation arrangements remain sustainable over the longer term

Where accommodation concerns are identified, lead sponsors should work with sponsors to ensure appropriate action is taken and consider whether additional oversight or intervention is required.

Integration and wellbeing

Lead sponsors should monitor whether sponsorship arrangements are delivering the support set out in the integration, participation or progression plan, as applicable, and supporting refugees to achieve the objectives of the relevant route.

Integration outcomes will vary between refugees and should be assessed against individual circumstances, needs and aspirations rather than uniform expectations.

Lead sponsors should use information gathered through monitoring and assurance activities to assess whether refugees:

• are receiving the support identified within their integration plan
• are able to access relevant services and opportunities
• are making progress towards greater independence
• are experiencing barriers to integration, wellbeing or self-sufficiency

Where barriers or unmet needs are identified, lead sponsors should work with sponsors to identify appropriate support, monitor progress and provide additional oversight where necessary.

Risks, concerns and sponsorship breakdowns

Lead sponsors should have arrangements in place to identify, monitor and assess risks and concerns relating to sponsors, refugees and sponsorship arrangements throughout the sponsorship period.

Early identification of issues can help prevent concerns from escalating, improve outcomes for refugees and reduce the likelihood of sponsorship arrangements ending prematurely.

Concerns may be identified through routine monitoring activities, engagement with sponsors and refugees, accommodation monitoring, safeguarding processes, reports from third parties or other relevant sources.

Potential indicators that a sponsorship arrangement is at risk of breakdown may include:

• repeated accommodation-related concerns, including suitability, affordability or sustainability issues
• unresolved disputes between sponsors and refugees
• a deterioration in relationships between sponsors and refugees
• repeated failures to deliver agreed support
• safeguarding concerns or welfare issues
• disengagement from support services, education, employment or other agreed activities
• significant financial difficulties affecting the sponsor’s ability to meet its commitments
• concerns regarding a sponsor’s capacity, capability or ongoing ability to fulfil its responsibilities
• repeated complaints from refugees or third parties
• risks of homelessness, sponsorship withdrawal or other circumstances that may place the continuation of the sponsorship arrangement at risk.

Where concerns are identified, lead sponsors should work proactively with sponsors and refugees to understand the issues and agree appropriate support or interventions. This may include additional support, enhanced monitoring, accommodation solutions, referrals to specialist services or other measures designed to prevent sponsorship arrangements from breaking down.

Lead sponsors should maintain records of identified risks, actions taken and outcomes achieved.

Where concerns cannot be resolved, or where there is a significant risk to refugee welfare, safeguarding or the continuation of a sponsorship arrangement, lead sponsors should escalate the matter in accordance with the intervention and escalation procedures, including notifying the Home Office where required.

Additional requirements for study route lead sponsors

Study route lead sponsors are responsible for ongoing monitoring and assurance of university sponsors to ensure that sponsorship arrangements align with the objectives of the refugee study route, including delivery of positive integration outcomes.

Study route lead sponsors must conduct appropriate assurance and compliance reviews of university sponsors and assess university sponsors against the following Home Office compliance measures:

• continuing to meet university sponsor eligibility requirements
• delivering the support commitments set out in their agreement with study route lead sponsors
• providing appropriate student welfare and pastoral support
• maintaining appropriate safeguarding arrangements
• supporting refugees to access accommodation, student finance, and other relevant services, where applicable
• monitoring attendance, academic progression, retention and course completion
• identifying and escalating concerns relating to study suspension, course withdrawal, welfare or safeguarding issues in a timely manner
• cooperating with data collection, monitoring and assurance requirements
• supporting refugees towards successful integration, self-sufficiency and progression into further study or employment

Study route lead sponsors must provide the Home Office with confirmation that reviews have been completed, a summary of findings and information on any actions taken to address non-compliance or improve delivery. This information must be provided in accordance with any reporting requirements set out in the lead sponsor agreement.

Study route lead sponsors should also maintain appropriate records and be able to demonstrate the steps being taken to support the refugee. This may include engagement with university welfare, pastoral or student support services, referrals to mental health or wellbeing support, measures to address accommodation or financial difficulties, academic support arrangements, and a documented plan setting out the support being provided and any anticipated timescales for return to study or progression towards alternative education, training or employment pathways.

Where concerns are identified, study route lead sponsors should agree and monitor appropriate action with the university sponsor. This may include additional support, increased oversight, a follow-up review or an improvement plan. Serious or unresolved concerns must be escalated in accordance with guidance set out in Escalation and intervention. The Home Office may also take account of course retention and completion outcomes when considering a university sponsor’s ongoing participation in the route.

Record keeping and reporting

Lead sponsors must maintain records relating to sponsorship arrangements, monitoring and assurance activity, concerns raised, interventions undertaken and communications with the Home Office.

This should include records relating to accommodation concerns, safeguarding matters, sponsorship breakdowns, support provided to sponsors and any actions taken to address identified risks.

Records must be retained for the period specified in the lead sponsor agreement.

Lead sponsors may be required to provide the Home Office with information on sponsorship outcomes, monitoring activity, identified concerns and actions taken, in accordance with the reporting requirements set out in the lead sponsor agreement.

Home Office assurance and performance monitoring of lead sponsors

The Home Office will undertake monitoring and assurance activity in relation to lead sponsors. This may include regular reporting requirements, performance reviews, reviews of sponsorship arrangements, spot checks and requests for information, records or evidence relating to delivery of the lead sponsor role.

The Home Office may also undertake visits, meetings with lead sponsor staff and engagement with sponsors and refugees as part of its assurance activity.

The Home Office will conduct periodic assurance and performance reviews of lead sponsors in accordance with the lead sponsor agreement. Lead sponsors will be notified in advance of scheduled reviews, and the Home Office will provide information on any reporting or evidence requirements associated with those reviews.

Lead sponsors must cooperate with any reasonable request for information, records or evidence from the Home Office relating to their delivery of the lead sponsor role.

Where concerns arise regarding a lead sponsor’s performance or compliance, the Home Office may require improvements to be made, impose additional monitoring requirements, issue an improvement notice, suspend sponsorship activity or withdraw lead sponsor accreditation where appropriate. For further information see Suspension or removal of a lead sponsor.

Intervention and escalation

This section explains the actions lead sponsors should take where concerns arise regarding a sponsor, refugee or sponsorship arrangement, including when concerns should be escalated to the Home Office or relevant local authority.

Lead sponsors are expected to take a proportionate approach to intervention and escalation. In most circumstances, lead sponsors should work with sponsors to resolve concerns at the earliest opportunity. However, where there is a safeguarding concern, risk of homelessness, suspected criminality or fraud, or any other significant risk to a refugee, lead sponsors must escalate the matter immediately as set out in this guidance.

Lead sponsors should not delay escalation where the circumstances described in this guidance apply. Early identification and escalation of concerns will be regarded as evidence of effective monitoring and oversight. Failure to escalate significant concerns, or attempts to conceal concerns, may be taken into account as part of Home Office assurance and performance monitoring activity.

Where this guidance requires notification to the Home Office, lead sponsors should provide sufficient information to explain the concern, actions taken, ongoing risks and any further support or intervention identified or required. Lead sponsors should keep the Home Office informed of significant developments until the matter is resolved.

Notification to the Home Office enables the Home Office to maintain oversight of sponsorship arrangements, monitor how significant concerns are being managed and consider whether any additional action is required in relation to the operation of the route.

Lead sponsors must maintain records of concerns raised, actions taken and outcomes achieved and provide information to the Home Office when requested.

Identifying and responding to concerns

Lead sponsors are expected to identify concerns through their ongoing monitoring and assurance activities and take appropriate action to prevent issues from escalating. Where concerns arise, lead sponsors should engage with the sponsor to understand the issue, provide advice and support and agree appropriate action in response.

Concerns may include:

• failures to meet sponsorship responsibilities, such as failing to maintain regular contact with the refugee or deliver agreed support
• accommodation becoming unsuitable or unavailable, for example because of eviction, overcrowding or significant disrepair
• safeguarding concerns
• financial difficulties affecting delivery of the sponsorship arrangement, such as loss of funding or an inability to meet agreed financial commitments
• breakdowns in the relationship between the sponsor and refugee(s)
• fraud, misconduct or other integrity concerns
• study related concerns, including poor attendance or engagement with study

Where concerns are identified, lead sponsors should take proportionate action to address them at the earliest opportunity. This may include:

• facilitating discussions between relevant parties
• agreeing actions to address identified concerns
• providing additional guidance, training or support
• increasing monitoring or oversight
• agreeing an improvement plan with the sponsor
• temporarily declining to support or submit new sponsorship arrangements until concerns have been addressed

Where a sponsor is experiencing difficulties in meeting its responsibilities, lead sponsors should work with the sponsor to understand the reasons and agree appropriate corrective action. Lead sponsors should monitor progress and provide additional support where appropriate.

Refugee concerns

Lead sponsors must ensure that refugees are given clear and accessible information about how to raise concerns or make a complaint about their sponsorship arrangement, including:

• how to contact the sponsor and lead sponsor
• how to raise concerns independently of both the sponsor and lead sponsor
• how to report urgent safeguarding concerns or other significant risks
• how to access interpretation, translation or other accessibility support

The lead sponsor should normally be the primary point of contact for concerns relating to the sponsorship arrangement. However, refugees must not be required to raise concerns through the sponsor or lead sponsor where the concern relates to that organisation or individual, or where they do not feel safe or able to do so. Sponsors and refugees may raise concerns about the conduct, decisions or actions of a lead sponsor directly with the Home Office via contact details that will be provided.

Concerns involving safeguarding issues, a risk of homelessness, risks to a refugee’s ability to continue their studies, serious misconduct, fraud or any other significant risk to a refugee must not be treated solely as complaints and should be escalated in accordance with the procedures set out in this guidance.

Escalation to the Home Office

Lead sponsors should take reasonable steps to resolve concerns before escalating them to the Home Office, unless the nature of the concern requires immediate escalation.

The circumstances set out below require immediate notification and must not be held for inclusion in a routine monitoring or periodic assurance return.

Lead sponsors must notify the Home Office immediately where:

• there is a safeguarding concern involving a refugee
• there is a risk of homelessness
• a sponsorship arrangement is at risk of breaking down or has broken down
• a sponsor is unwilling or unable to address significant concerns raised by the lead sponsor
• a sponsor or any of its members should be suspended or removed from participation in the route
• financial difficulties may affect the sponsor’s ability to support the sponsorship arrangement
• a refugee has suspended their studies, withdrawn from their course or is at risk of being unable to continue their studies
• there are concerns regarding fraud, criminality or serious misconduct
• there is any other issue which may present a significant safeguarding, operational or reputational risk

Safeguarding concerns

Where there are concerns about the safety or wellbeing of a refugee, lead sponsors must take immediate action to safeguard the individual and notify the Home Office. This includes concerns relating to children, vulnerable adults, exploitation, abuse neglect or other safeguarding risks.

Where concerns fall within the statutory responsibilities of a local authority, including concerns involving children or vulnerable adults, lead sponsors must ensure that an appropriate referral is made without delay in accordance with local safeguarding procedures. The Home Office must also be notified. These actions may take place in parallel.

Lead sponsors should support sponsors to manage safeguarding concerns appropriately, including ensuring concerns are recorded, appropriate referrals are made and immediate risks are mitigated where possible.

Where a safeguarding concern cannot be resolved, or additional statutory intervention is required, the Home Office and relevant local authority will determine whether any further action is necessary.

Accommodation concerns

Where accommodation becomes unsuitable, unavailable or is at risk of being lost (for example due to eviction, overcrowding, relationship breakdown within the household or significant disrepair), lead sponsors must work with the sponsor to identify solutions and minimise disruption to the refugee. This may include supporting the sponsor to secure alternative accommodation or identifying additional sources of support.

Where there is a risk that a refugee may become homeless or be left without suitable accommodation, lead sponsors must ensure that the relevant local authority is contacted at the earliest opportunity and that any appropriate referral is made. The Home Office must also be notified. These actions may take place in parallel.

Sponsor non-compliance

Where a sponsor is unwilling or unable to address significant concerns, or where non-compliance continues despite intervention by the lead sponsor, the lead sponsor must notify the Home Office and provide details of the concerns identified, the actions taken and the sponsor’s response.

Examples of non-compliance may include:

• repeated failures to provide agreed support
• failure to engage with monitoring and assurance activities
• failure to maintain suitable accommodation arrangements
• failure to implement agreed actions following concerns raised by the lead sponsor

Where serious concerns arise, a lead sponsor may temporarily decline to support or submit further sponsorship arrangements from that sponsor while the concerns are considered. Serious concerns may include safeguarding concerns, criminality, fraud, serious misconduct, or other issues that could pose a risk to refugees, the integrity of the route or public confidence.

The lead sponsor must notify the Home Office as soon as reasonably practicable. The Home Office will consider the information provided and determine whether the sponsor should be subject to any formal restriction, suspension, additional requirements or removal from participation in the route.

Financial difficulties

Where a sponsor experiences financial difficulties that may affect their ability to meet their responsibilities under the route, such as a loss of funding, unexpected costs or reduced fundraising income, lead sponsors must work with the sponsor to understand the nature and extent of the issue and identify options to maintain the sponsorship arrangement. This may include reviewing available resources, identifying additional sources of funding or support or agreeing other measures to mitigate the impact on the refugee.

For study route sponsorship arrangements, this may also include circumstances where tuition fees, maintenance funding, scholarships or other financial support arrangements are no longer available or are insufficient to enable the refugee to continue their studies. Study route lead sponsors should work with the university sponsor and the refugee to identify alternative sources of funding or support where possible.

Where financial difficulties may affect the sponsor’s ability to provide accommodation, financial support or agreed integration support, lead sponsors must notify the Home Office immediately.

Where it becomes clear that the sponsor is unable to meet its responsibilities and the situation cannot be resolved, lead sponsors must notify the Home Office and provide details of the actions taken, the reasons the issue could not be resolved and any risks arising. The Home Office will consider whether any action is required in relation to the sponsorship arrangement or participating organisations.

Study suspension

Where a study route refugee suspends their studies, withdraws from their course or is at risk of being unable to continue their studies, study route lead sponsors must notify the Home Office immediately.

Study route lead sponsors must provide details of the actions taken to understand the reasons for the suspension or withdrawal, the support being provided to the refugee and any proposed next steps. Where appropriate, this should include information on plans to support the refugee’s return to study or progression towards alternative education, training or employment pathways.

Fraud, misconduct and integrity concerns

Lead sponsors must notify the Home Office immediately where there are concerns regarding fraud, criminality, serious misconduct or other integrity issues involving a sponsor, refugee or member of the lead sponsor itself.

Examples may include:

• misuse of funds
• deliberate misrepresentation in an application
• undeclared conflicts of interest
• concerns that a sponsorship arrangement is being used for an improper purpose

Lead sponsors should preserve relevant records and evidence and cooperate with any enquiries undertaken by the Home Office or other relevant authorities. Where appropriate, lead sponsors should take steps to mitigate any immediate risks while enquiries are ongoing.

Sponsorship breakdown

A sponsorship arrangement may be at risk of breaking down where concerns cannot be resolved, relationships between sponsors and refugees deteriorate significantly, or the sponsor is no longer able to meet its responsibilities under the route.

Where a sponsorship arrangement is at risk of breaking down, lead sponsors should take reasonable and proportionate steps to understand the issues and support resolution wherever possible.

This may include:

• facilitating discussions between sponsors and refugees
• providing additional guidance, support or oversight
• agreeing actions to address concerns
• identifying additional sources of support
• implementing an improvement plan
• exploring alternative sponsorship arrangements where appropriate

Lead sponsors must notify the Home Office where a sponsorship arrangement is at risk of breaking down, including details of any support or alternative arrangements being considered.
Where concerns relate to matters falling within a local authority’s statutory responsibilities, including safeguarding concerns involving children or vulnerable adults, lead sponsors should engage with the relevant local authority in accordance with local procedures.

Where a sponsorship arrangement breaks down, or it becomes clear that the situation cannot be resolved, lead sponsors must notify the Home Office immediately, take reasonable steps to identify and mitigate any immediate risks to the refugee and consider whether alternative sponsorship arrangements could be identified to provide ongoing support.

Where the breakdown creates risks relating to homelessness, safeguarding or other matters that fall within a local authority’s statutory responsibilities, lead sponsors should engage with the relevant local authority without delay and make any appropriate referrals in accordance with local procedures. Lead sponsors should not assume that a local authority will assume responsibility for matters that fall outside its statutory duties.

Where a sponsorship breakdown affects a refugee study route refugee, study route lead sponsors should assess any impact on course participation, accommodation, financial support and welfare arrangements.

Study route lead sponsors should work with the university sponsor and refugee to explore appropriate support and, where relevant, consider whether alternative sponsorship or study arrangements may be available.

The Home Office will consider what, if any, further action is required in light of the circumstances of the case.

Sponsor withdrawal

A sponsor may decide that it is no longer able or willing to continue with a sponsorship arrangement.

Where a sponsor is considering withdrawal, it should notify the lead sponsor at the earliest opportunity to allow sufficient time for alternative arrangements to be explored. Lead sponsors should engage with the sponsor as soon as possible to understand the reasons for withdrawal, determine whether concerns can be resolved and assess whether the sponsorship arrangement can continue or whether alternative arrangements may be required. This may include providing additional support, guidance or other measures to help address the issues identified.

Where a sponsor confirms that it intends to withdraw, the lead sponsor must notify the Home Office immediately and assess the impact of the withdrawal, including whether alternative sponsorship arrangements could be identified to support the refugee. Where the withdrawal creates risks relating to accommodation, safeguarding, financial support or refugee welfare, lead sponsors must take reasonable steps to identify and mitigate any immediate risks while alternative arrangements are explored.

The Home Office will consider the circumstances of the withdrawal and determine whether any further action is required in light of the circumstances of the case, including whether alternative arrangements are necessary to support the refugee.

Where a sponsor withdraws after a visa has been granted but before travel, the lead sponsor must notify the Home Office immediately and identify an alternative sponsor or sponsorship arrangement to support the refugee. Refugees should not travel to the UK until suitable sponsorship arrangements are in place and the Home Office has confirmed that travel may proceed.

Suspension or removal of a lead sponsor

This section explains the circumstances in which the Home Office may suspend or withdraw an organisation’s accreditation as a lead sponsor.

When accreditation may be suspended or withdrawn

Lead sponsor accreditation may be suspended or withdrawn where the Home Office is no longer satisfied that an organisation is capable of fulfilling the requirements of the lead sponsor role or where there are concerns regarding its conduct, governance or compliance with the requirements of the route.

The Home Office may consider suspension or withdrawal where, for example:

• the organisation no longer meets the eligibility requirements for accreditation
• there are serious or repeated compliance failures
• safeguarding concerns have not been appropriately managed
• the organisation fails to cooperate with Home Office monitoring, assurance or information requests
• there are concerns regarding fraud, misconduct or other integrity issues
• significant organisational changes have occurred which affect the organisation’s ability to deliver the lead sponsor role
• the organisation ceases to operate, becomes insolvent or experiences serious financial difficulties

Review and decision-making

Before deciding whether to suspend or withdraw accreditation, the Home Office will normally notify the lead sponsor in writing of the concerns identified, the action under consideration and the reasons for considering that action. The Home Office may request further information, records or evidence from the lead sponsor and, where appropriate, provide an opportunity for the concerns to be addressed through an improvement plan or other corrective action.

The lead sponsor will normally be given an opportunity to respond in writing before a final decision is made. The notification will specify the period within which representations must be submitted. The Home Office will consider any representations and supporting evidence received within that period before making its decision.

Where the Home Office considers that immediate action is necessary to protect refugees, maintain the integrity of the route or manage another serious risk, it may temporarily restrict or suspend some or all new sponsorship activity while the concerns are considered. The Home Office will notify the lead sponsor in writing of any interim measures, the reasons for them and the activities affected. Interim measures do not constitute a final decision to withdraw accreditation.

The Home Office will notify the lead sponsor in writing of its final decision, the reasons for the decision, the date on which it takes effect and any conditions or transitional arrangements that apply.

Managing existing sponsorship arrangements

Where interim restrictions are imposed or accreditation is suspended or withdrawn, the Home Office will determine the arrangements required to ensure that existing sponsorship arrangements continue to be appropriately supported and managed. This may include enhanced oversight by the Home Office, transferring oversight of sponsorship arrangements to another accredited lead sponsor or implementing other transitional arrangements.

Lead sponsors must cooperate with any transitional arrangements requested by the Home Office and provide relevant information to support the continuity of support for sponsors and refugees.

Reapplying following withdrawal of accreditation

Where an organisation’s accreditation has been withdrawn, it may not submit a further application to become a lead sponsor for a period of 12 months from the date of withdrawal. Where accreditation was withdrawn due to serious or repeated non-compliance, fraud, safeguarding failures, misconduct or other integrity concerns, that period will be extended to two years.

Following this period, the Home Office may consider a further application where the organisation can demonstrate that the issues leading to withdrawal have been fully addressed and appropriate corrective action has been taken.

The Home Office reserves the right to refuse to consider further applications where it is not satisfied that the organisation can effectively deliver the lead sponsor role.