Workers and Temporary Workers - guidance for sponsors part 1: apply for a licence (accessible)

Question 1

About this guidance

Accepted Answer

This document provides information for employers and other organisations on how to apply for authorisation (a licence) to sponsor an overseas national on the Worker and Temporary Worker immigration routes.

For sponsorship purposes, the ‘Worker’ routes are:

Skilled Worker
Global Business Mobility – Senior or Specialist Worker
T2 Minister of Religion
International Sportsperson

For sponsorship purposes, the ‘Temporary Worker’ routes are:

Charity Worker
Creative Worker
the following Global Business Mobility (GBM) routes:
- Graduate Trainee
- UK Expansion Worker
- Service Supplier
- Secondment Worker
Government Authorised Exchange
International Agreement
Religious Worker
Scale-up
Seasonal Worker

This document forms part of the guidance collection ‘Workers and Temporary Workers: guidance for sponsors’ (or ‘sponsor guidance for employers’ for short). The guidance is structured as follows:

3 main parts
appendices
route-specific guidance

You should read all parts of the guidance to ensure that you understand your duties and responsibilities as a licensed sponsor.

If you are new to sponsorship, you may find it helpful to read the relevant route- specific guidance first.

You can find all documents on the ‘Guidance for employers and educators’ page on GOV.UK.

This guidance is subject to change. If you have printed or downloaded a copy of this guidance, check the version number and date against the current version published on GOV.UK to ensure you are referring to the most up-to-date version.

You can find previous versions of the sponsor guidance on the National Archives website.

Main parts

The 3 main parts are:

Part 1 (this document): tells you how to apply for a sponsor licence, the requirements you must meet, how we consider your application, and what happens if we refuse your application
Part 2: Sponsor a worker – general information: tells you about the processes you must follow to sponsor a worker once you have obtained your sponsor licence
Part 3: Sponsor duties and compliance: tells you about your duties and responsibilities as a sponsor and the action we will take if you breach, or are suspected of breaching, these duties, including if you act in a manner that is not conducive to the public good

Appendices

The relevant appendices are:

Appendix A: this tells you the documents you must submit to support your sponsor licence application
Appendix B: this is a list of immigration offences we will take into account when considering your suitability to hold a sponsor licence
Appendix D: this tells you about your record-keeping duties as a licensed sponsor

Route-specific guidance

These documents contain detailed information on sponsoring workers on specific routes:

Contacts

If you think the guidance has factual errors or broken links, you can email the Business Helpdesk.

If you have any queries about the application process, you can call us on 0300 123 4699, or email the Business Helpdesk.

Version number and publication

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

version 04/25
published on 9 April 2025

You can view previous versions of this guidance on the National Archives website.

Changes to this guidance

This version replaces version 12/24 (published on 31 December 2024). The guidance has been updated to:

reflect a commitment in the Written Ministerial Statement of 28 November 2024 to prohibit sponsors from passing on sponsorship fees and associated administrative costs to their sponsored workers – this was implemented for the Skilled Worker route on 31 December 2024 and is now being extended to sponsors on other routes
reflect amendments made to Appendix A to the sponsor guidance
make some other minor amendments and clarifications

Details of the changes are set out below. Paragraph numbers in brackets refer to the previous version of this guidance where the number was different:

About this guidance: reference to the Youth Mobility Scheme deleted
L3.1, Annex L1(k), Annex L1(l): minor drafting amendments
L3.2, L6.27 (L6.26), L8.2: cross-references to section L7 deleted and, where necessary, amended to Appendix A, as section L7 has now been deleted
L6.7, L6.11, Annex L3(c): updated to reflect that the organisation formerly known as the Office of the Immigration Services Commissioner is now known as the Immigration Advice Authority
L6.9, L6.10: minor drafting amendments and clarification
L6.12: subheading above amended to read ‘Sponsorship fees’; reference to priority services added
L6.14: clarification that we will reject a sponsor licence application if the application fee is not paid in full
L6.15, L6.16: order of paragraphs reversed and reference to the pre-licence priority service added
L6.17: updated to reflect the new prohibition on seeking to recoup the sponsor licence and associated administrative costs from a sponsored worker for all routes from 9 April 2025 (or 31 December 2024 in the case of Skilled Worker sponsors); and the CoS fee and associated administrative costs for specified routes from 9 April 2025 (or 31 December in the case of Skilled Worker)
L6.18: new paragraph clarifying what we mean by ‘associated administrative costs’; subsequent paragraphs in this section renumbered accordingly
L6.29 (L6.28): clarification that supporting documents can include information available online
L7: section deleted as this information is now contained in the revised version of Appendix A being published at the same time
L8.20, L8.21, L8.28: clarification that in a pre-licence compliance check, we may not assess a prospective sponsor against all of the listed criteria
L10.3: clarification that only Scale-up and UK Expansion Worker licences expire
Annex L1(j): reference to ‘validating’ a licence application removed, since an invalid application would be rejected rather than refused
Annex L2(f): amended to allow for refusal where a person coming under the definition of ‘you’ has been named as Key Personnel at an organisation whose licence application has been refused within the last 6 months
Annex L2(l): link added to relevant section of guidance
other minor housekeeping changes

Question 2

Glossary

Accepted Answer

The glossary below contains a list of terms and phrases commonly used across all parts of the sponsor guidance for employers, and their definitions.

Certificate of Sponsorship (CoS)

An electronic document with a unique reference number issued by you (the sponsor) to a worker via the Sponsorship Management System, which confirms the details of the job for which you will be sponsoring the worker.

If you are a ‘PB1 sponsor’ (a Government Authorised Exchange (GAE) sponsor taking part in the initial roll-out phase of the new sponsorship service, Sponsor UK), any reference to a CoS should be read to include the process of sponsoring a GAE worker via the Sponsor UK service. See Annex GA1 of Sponsor a Government Authorised Exchange worker for further details.

The worker must have a valid CoS before they can make a successful application for entry clearance, permission to enter or permission to stay.

Cancellation of permission (formerly ‘curtailment of leave’), and derived terms

This is when the Home Office cancels or shortens a person’s entry clearance or permission such that they will have a shorter period of, or no, permission remaining.

This could happen, for example, if the person breaches their conditions of stay, is convicted of a criminal offence, or you fail to comply with your sponsor duties.

Permission may be shortened to expire within a specified period of time (usually so that the person has 60 days’ permission remaining) or, in more serious circumstances, cancelled entirely.

Compliance check

A check to satisfy us that you are complying with, or if not yet licensed are capable of complying with, your sponsor duties as detailed in Part 3: Sponsor duties and compliance. A compliance check can include, but is not limited to, any of the following:

a compliance visit
a digital compliance inspection
a review of evidence or information from our own records, evidence or information you have previously submitted to us, and any evidence or information we request from you as part of a check

Compliance visit

Where we visit you to perform a compliance check. This includes visiting any branches or sites under your control, or any relevant client site or third party where your sponsored workers will be working.

Digital compliance inspection

Where we carry out a compliance check by verifying your trading presence digitally, and conducting interviews with you using remote video conferencing facilities. This includes interviewing anyone coming under the general definition of ‘you’, or any of your sponsored workers and may involve you having to present evidence prior to, during or after the video conference interview.

Entry clearance

A document which provides evidence of a person’s eligibility to enter the UK. It can take the form of either a visa (when issued to a visa national) or an entry certificate (when issued to a non-visa national); and can be issued as either a vignette sticker in the holder’s passport or travel document, or in digital format (‘eVisa’).

An entry clearance is often commonly referred to simply as a ‘visa’.

For further information, see paragraphs 24 to 30C of the Immigration Rules.

Global Business Mobility (GBM) route

Any of the following routes:

Senior or Specialist Worker
Graduate Trainee
UK Expansion Worker
Service Supplier
Secondment Worker

For further information, see Sponsor a Global Business Mobility worker.

Permission

Means either permission to enter or permission to stay. In everyday usage, this is often referred to as a ‘visa’ but that term has a more technical meaning (see ‘Entry clearance’ above).

Permission to enter

Has the same meaning as ‘leave to enter’ under the Immigration Act 1971.

Permission given to a person to enter the UK – this could be via a valid entry clearance, a grant of permission by an immigration officer, or a grant of permission via an automated ePassport Gate (where the passenger is eligible to use that facility).

Permission to stay

Has the same meaning as ‘leave to remain’ under the Immigration Act 1971 (and includes a variation of leave to enter or remain and an extension of leave to enter or remain).

Permission given to a person who is already in the UK.

Relevant offence

Any offence listed in Annex L4 of this guidance.

Settled worker

See ‘Who needs to be sponsored’ in section S1 of Part 2: Sponsor a worker.

Settlement

Permission given to a person to enter or stay in the UK on a permanent basis. Also known as ‘indefinite leave to remain’.

UKVI

UK Visas and Immigration, an operational command of the Home Office.

Visa national

A person specified in Appendix Visitor: Visa National list as needing an entry clearance (a visa) in advance of travel to the UK for any purpose or duration.

We or Us

The Home Office.

Working days

Any day other than a:

Saturday
Sunday
UK bank holiday

You or Your

The sponsor organisation or prospective sponsor organisation, including any:

owner
director
Authorising Officer
Key Contact
Level 1 User
person recorded on your Companies House listing as a Person with Significant Control
person involved in your day-to-day running

See the ‘Key Personnel’ section for a definition of ‘Authorising Officer’, ‘Key Contact’, and ‘Level 1 User’.

Question 3

L1. Sponsorship: an introduction

Accepted Answer

This section tells you what a sponsor licence is and provides a brief overview of the immigration routes on which you can sponsor workers.

What is sponsorship?

L1.1. If you wish to employ a person who is not a settled worker, or who does not otherwise have immigration permission to work for you in the UK, you will need to be authorised by the Home Office. This authorisation is known as a ‘sponsor licence’, and employers who hold a sponsor licence are known as ‘sponsors’.

L1.2. You do not need a sponsor licence to employ certain categories of person, including:

Irish citizens (with very limited exceptions)
people who have been granted settled or pre-settled status on the EU Settlement Scheme
people with indefinite leave to enter or remain in the UK (also known as ‘settlement’)

L1.3. This is not a complete list. For more information on who does, and does not, need sponsorship, see section S1 of Part 2: sponsor a worker.

L1.4. A worker must have an offer of a job which meets the relevant criteria from an approved sponsor before they can make a valid application to enter or stay in the UK on the Worker or Temporary Worker routes. The sponsor confirms this by assigning a Certificate of Sponsorship to the worker.

L1.5. Sponsorship plays two main roles in a worker’s application for permission to enter or stay in the UK:

it provides evidence that the worker will fill a role for the sponsor in an occupation that’s eligible for the route on which they’re being sponsored
it involves a pledge from the sponsor that it accepts all of the duties of sponsorship

L1.6. Individual persons are not eligible to be recognised as sponsors, unless they are sole traders who wish to sponsor someone to work in their business.

Sponsoring workers in a personal capacity

L1.7. We will not grant you a licence if you intend to sponsor workers in a personal capacity, such as in either of following circumstances:

you are an individual person or household who wishes to employ or engage a worker, or workers, in a personal capacity and you are not otherwise conducting business or providing a service in the UK
the worker, or workers, will be employed by, or engaged for the personal benefit of, an individual who works for your organisation, or a close relative or partner of that individual, and the role is unrelated to your organisation’s wider activities

L1.8. If you have, or are granted, a sponsor licence, you must not use your licence to sponsor workers in a personal capacity as defined above. If we find you have done this, we will normally revoke your licence. If you have previously been permitted to sponsor workers in a personal capacity, you must not assign any further Certificates of Sponsorship to sponsor workers on this basis.

Exception for private servants in a diplomatic household

L1.9. The only exception to the general prohibition on sponsoring workers in a personal capacity is where you meet all of the following:

you are a diplomatic mission, consular post or recognised international organisation
you are licensed, or are applying to be licensed, on the International Agreement route
you are sponsoring, or intend to sponsor, a private servant in the household of either a diplomat or of a member of a recognised international organisation

L1.10. In this scenario, the diplomatic mission, consular post or international organisation must be the sponsor and meet the requirements in Sponsor an International Agreement worker.

Routes on which you can be licensed

L1.11. When you apply for a licence, you will be asked which immigration route, or routes, you wish to sponsor workers on. You can apply to be licensed on as many routes as you feel appropriate for your business or organisation.

L1.12. For convenience, these routes are classified as either ‘Worker’ or ‘Temporary Worker’ routes.

L1.13. There is a brief description of these routes below. For more detailed information, refer to the route-specific guidance.

Worker routes

L1.14. The ‘Worker’ routes are:

Skilled Worker: this allows employers to recruit people to work in the UK in an eligible skilled occupation which meets the salary and going rate requirements
Global Business Mobility – Senior or Specialist Worker: this is for senior managers or specialist employees being transferred by their overseas employer to a branch in the UK
T2 Minister of Religion: this for a person who has a key leading role within their faith-based organisation or a religious order in the UK
International Sportsperson: this for an elite sportsperson or qualified coach who is sponsored in a role where they will make a significant contribution to the development of sport at the highest level in the UK

Temporary Worker routes

L1.15. The Temporary Worker routes are:

Question 4

L2. Sponsorship: your responsibilities

Accepted Answer

This section provides an overview of your duties and responsibilities as a licensed sponsor.

Guiding principles

L2.1. Sponsorship is based on two main principles:

sponsorship is a privilege, not a right – this means that those who benefit most directly from employing migrant workers must:
- play their part in ensuring the immigration system is not abused
- comply with wider UK law
- not behave in a manner that is not conducive to the public good
overseas nationals who apply for permission to enter or stay in the UK to work are eligible, and a trustworthy and licensed employer genuinely wishes to employ and sponsor them

L2.2. When a sponsor is granted a licence, significant trust is placed in them. With this trust comes a direct responsibility to act in accordance with the UK’s immigration laws, all parts of this sponsor guidance, and with wider UK law, including, but not limited to:

L2.3. We have a duty to ensure all sponsors discharge these responsibilities, and we will take compliance action when it is considered that a sponsor has failed to do so, or otherwise poses a risk to immigration control. Part 3: Sponsor duties and compliance contains detailed guidance on your duties as a licensed sponsor and the compliance action we can take if you fail to meet those duties.

Behaviour that is not conducive to the public good

L2.4. There is also a wider responsibility for sponsors to behave in a manner that is consistent with our fundamental values and is not detrimental to the wider public good. The Home Office will not license organisations whose actions and behaviour are not conducive to the public good. Such actions and behaviour include, but are not limited to:

fostering hatred or inter-community division
fomenting, justifying or glorifying terrorism
rejecting the rights of, or discriminating against, other groups or individuals on the basis of their sex, age, disability, gender reassignment, sexual orientation, marital or civil partnership status, race, or religion or belief (including lack of belief)

L2.5. The Home Office will refuse a sponsor licence application or take the appropriate compliance actions if a prospective or existing sponsor is engaging, or has ever engaged, in such behaviour or actions. The compliance action taken will depend on the gravity of the behaviour and actions but could include compliance actions up to and including revocation of your licence.

Safeguarding children

L2.6. Under section 55 of the Borders, Citizenship and Immigration Act 2009, we must have regard to the need to safeguard children and to promote their welfare when exercising immigration functions. The administration of the sponsor licensing regime supports our immigration functions, whilst not itself constituting such a function. We do not consider that section 55 of the 2009 Act imposes a general duty upon us to consider the welfare of children of sponsored migrants when making decisions about licensing. However, we do consider it appropriate to ensure sponsors, and prospective sponsors, have suitable care arrangements in place for any child under 18 who will work for them in the UK, or will otherwise be under their care or supervision. These include arrangements for the child’s:

travel to the UK
reception when they arrive in the UK
arrangements while in the UK, as well as parental consent to these arrangements

L2.7. If we are not satisfied you have suitable arrangements in place (where required), we will refuse your sponsor licence application. If you already hold a licence and we find out you do not have suitable arrangements in place (where required), we will revoke your licence.

L2.8. You must have a Disclosure and Barring Service (DBS) check on any of your workers undertaking a ‘regulated activity’ for children. See the ‘Regulated Activity in relation to Children’ page on GOV.UK for information on this. If your sponsored worker requires a check, they must show you their certificate of good character or criminal record check. If you require a check, you must ensure it is carried out.

Creative Workers below school-leaving age

L2.9. If you are, or intend to, sponsor children below school-leaving age on the Creative Worker route to take part in films, plays, concerts or other paid public performances, or that take place on licensed premises, or paid modelling assignments, you must apply for a child performance licence from the local authority. If you are not responsible for producing or organising the event, you must ensure that the person or organisation responsible for the event has obtained a child performance licence for the child before the event. See ‘Sponsor a Creative Worker’ for further information.

Abuse of sponsorship arrangements

L2.10. UKVI will consider information about abuse of the sponsorship arrangements, including behaving in a manner that is not conducive to the public good, investigate it and, if appropriate, tell the relevant authorities. UKVI will also take action against you (the sponsor). This could include downgrading your licence, suspending your licence, or revoking it. There is more information in Part 3: Sponsor duties and compliance.

L2.11. We treat any allegation of abuse of the sponsorship system in the strictest confidence. Anyone with information can contact us by emailing the Business Helpdesk. Immigration offenders can also be reported via the ‘Report an immigration crime’ page on GOV.UK.

Question 5

L3. How sponsor licensing works

Accepted Answer

This section provides an overview of the requirements you must meet to be eligible for a sponsor licence, how we consider applications, and what you must do to keep your licence.

Applying for your licence

L3.1. You apply for your licence by completing the online application form and submitting the supporting documents specified in Appendix A to the sponsor guidance. You must pay a fee for your application. The amount you pay depends on the type of licence you are applying for, the size of your organisation, or whether you have charitable status. For further information on the application process, see section L6 of this guidance.

L3.2. Before you apply, you should:

read this document and the relevant route-specific guidance to ensure you understand and will be able to meet the requirements
decide which routes you wish to be licensed under – see section L1 of this document for a general overview of the various routes available, and the route-specific guidance for more detailed information
appoint an Authorising Officer to manage your application and nominate a Level 1 User – see section L4 of this guidance for guidance on Authorising Officers, Level 1 Users and other Key Personnel
if you have multiple branches or sites, decide which branches of your organisation you would like to employ and sponsor workers at and whether you want individual branches to hold their own licence – see section L5
decide how many workers you are likely to sponsor in your first year – this will determine how many Certificates of Sponsorship (CoS) you will need
ensure you will be able to send all relevant supporting documents listed in Appendix A of the sponsor guidance within 5 working days of submitting your application

Considering your application

L3.3. Before we can grant you a sponsor licence, we need to establish that you:

are a genuine organisation operating lawfully in the UK – to prove this, you must provide certain documents or information specified in Appendix A of the sponsor guidance (note that if you are applying on the UK Expansion Worker route, you must not have an existing active trading presence in the UK but must have a UK ‘footprint’ – see section GBM3 of Sponsor a Global Business Mobility worker for details)
are honest, dependable, reliable, and are not engaging and have not engaged in behaviour or actions that are not conducive to the public good – to judge this, we look at your history and background, the Key Personnel named in your application, and any people involved in your day-to-day running
are capable of carrying out your sponsor duties and evidencing your compliance in a timeframe and manner set out in section C1 of Part 3: Sponsor duties and compliance – we judge this by looking at your current human resources and recruitment practices to make sure you will be able to fulfil your sponsor duties, and we may conduct a compliance check on you before your licence is granted
meet any relevant route-specific requirements – for example, if you are applying under the Skilled Worker route, the Scale-up route or any of the Global Business Mobility (GBM) routes, you must be able to offer genuine employment that meets the skill level and any salary requirements of the route
otherwise meet the eligibility and suitability criteria

Deciding your application

L3.4. Applications may be rejected as invalid, refused, or granted with an A- Rating (or, in the case of the UK Expansion Worker route, a Provisional rating). Section L9 of this guidance has more information about the decision we may make on your application. See Section L8 for information about sponsor ratings.

L3.5. If you do not submit mandatory documents with your application or you do not pay the full fee, your application will be invalid and we will reject it without further consideration.

L3.6. If you do not meet all of the eligibility and suitability criteria, we will refuse your application and you may not be eligible to re-apply for 6 months (longer in certain circumstances) – see ‘Cooling-off period’.

L3.7. If your application is approved, your organisation’s name will be added to the Register of Sponsors on GOV.UK. You will be given access to the sponsorship management system (SMS) and will be able to sponsor workers who meet the relevant criteria by assigning them a CoS.

Maintaining your licence

L3.8. If you are granted a sponsor licence, it will be valid indefinitely, unless we revoke it or you surrender it before then. The only exceptions to this are if you are licensed on either the UK Expansion Worker route or the Scale-up route – you can only be licensed on these routes for a maximum of 4 years. We reserve the right to take action against you if we have reason to believe you pose any risk to immigration control or that you are acting, or have acted, in a way that is not conducive to the public good.

L3.9. If you are granted a UK Expansion Worker licence, you must normally have established a UK trading presence within 2 years of the date the licence was granted and have applied to add at least one other route to your licence. If you have not done so, we will also review whether you are continuing to meet the requirements of that route. If you are not, we may revoke your licence. See section GBM3 of Sponsor a Global Business Mobility worker for further information.

L3.10. As a licensed sponsor, you must meet certain duties, such as telling us if your sponsored workers don’t start their employment or are absent without permission for a significant period. You must keep records for the workers you sponsor, including up-to-date contact details and evidence of their right to work in the UK. You must also give any documents to us, within the timeframe specified, if we request them.

L3.11. We will continually monitor your ability and willingness to comply with your duties. We will make regular checks with HMRC to ensure you are paying your sponsored workers appropriately, and we may also:

set a limit on the number of CoS you can assign (or reduce your allocation to zero)
conduct a compliance check
refer cases for civil penalty action or possible prosecution if we find evidence you may have employed workers illegally

L3.12. If you fail to comply with your duties, or become no longer eligible or suitable to hold a sponsor licence, we may take action against you, including:

downgrading your licence rating – see Sponsor ratings for further information
reducing the number of CoS you can assign (or setting your limit to zero)
suspending your licence while we investigate further
revoking your licence
in serious cases, reporting you to the police or other relevant authorities

L3.13. Part 3: Sponsor duties and compliance has more information about your duties as a licensed sponsor, how to manage your licence, and the action we will take if you breach your sponsorship duties or act in a manner that is not conducive to the public good.

Question 6

L4. Key Personnel

Accepted Answer

This section tells you how to appoint ‘Key Personnel’ to manage your sponsor licence and the requirements they must meet.

Overview

L4.1. When you apply for your sponsor licence, you must nominate certain people to manage your sponsor licence. We call these people ‘Key Personnel’. You must ensure you understand what these roles are and who is suitable and eligible to fill them.

L4.2 In your sponsor licence application form, you must nominate Key Personnel for the following 3 roles:

Authorising Officer – a senior person within your organisation who has overall responsibility for your activity as a licensed sponsor
Key Contact – your main point of contact with UKVI
Level 1 User – a person within your organisation who is responsible for your day-to-day activity as a licensed sponsor, including assigning and requesting Certificates of Sponsorship (CoS) and reporting worker activity or changes to your organisation

L4.3. These roles can be filled by the same person, or a combination of different people, provided they are suitable and eligible for the role. You can only have one Authorising Officer and one Key Contact at any one time. You can nominate more than one Level 1 User in your application, or add more Level 1 Users after your licence has been granted, provided they meet the suitability and eligibility requirements.

L4.4. There is a further optional Key Personnel role, known as the Level 2 User. Your Level 1 User can only add Level 2 Users after you have been granted a licence. A Level 2 User has fewer permissions than a Level 1 User. You do not have to have any Level 2 Users.

L4.5. Level 1 and Level 2 Users carry out their functions by using the sponsorship management system (SMS). Level 1 and Level 2 Users are therefore collectively referred to as ‘SMS Users’. The Authorising Officer and Key Contact do not have access to the SMS, unless they are also appointed as an SMS User. You can do this when you apply for your licence or after it has been granted. For guidance on managing Key Personnel, see SMS Manual 2: manage your sponsorship licence.

L4.6. You must have an eligible Authorising Officer and Level 1 User throughout the life of your licence. If you do not, we will revoke your licence.

If you’re applying under UK Expansion Worker

L4.7. There are different rules for appointing Key Personnel if you’re applying under UK Expansion Worker. See section GBM3 of Sponsor a Global Business Mobility worker for further information.

L4.8. If you are a Government Authorised Exchange ‘PB1 sponsor’ taking part in the initial roll-out phase of the new sponsorship service (Sponsor UK), eligible Key Personnel on your licence will manage some sponsorship functions using the Sponsor UK service. For further information, see Annex GA1 of Sponsor a Government Authorised Exchange worker.

General requirements for Key Personnel

L4.9. Each of your Key Personnel must meet all of the following requirements:

be based in the UK for the period they will fill the role (there is an exception for the UK Expansion Worker route, as set out below)
have a valid National Insurance Number (unless they are exempt from requiring one – if this is the case, you must explain the reason and may need to provide evidence of the exemption)
be from within your organisation, unless an exception set out below applies
not be a contractor or consultant who is contracted to you for a specific purpose
meet the suitability requirements for Key Personnel
meet the specific eligibility requirements for the Key Personnel role they will fill

L4.10. If you nominate Key Personnel who do not meet the requirements in this section, we are likely to refuse your application for a sponsor licence (or revoke your licence if you already have one).

L4.11. In some cases, instead of refusing your application (or revoking your licence), we may:

give you the opportunity to nominate alternative Key Personnel who meet our requirements before we make a decision
limit or reduce your CoS allocation, or set it to zero

L4.12. In all cases, we reserve the right to refuse or revoke your licence without giving you the chance to nominate alternative Key Personnel.

Exception to residence requirement for UK Expansion Worker

L4.13. If you are applying under UK Expansion Worker, and your Authorising Officer (and Level 1 User) will be assigning their own CoS to enable them to apply for a visa to come to the UK, they may be based outside the UK from the time you apply for your licence until they enter the UK with a valid UK Expansion Worker visa.

Key Personnel from outside your organisation

L4.14. Your Key Personnel must normally be a paid staff member or an office holder from within your organisation. Additionally, at least one of your Level 1 Users must be an employee, an owner or a director within your organisation. However, you can appoint Key Personnel from outside your organisation in the circumstances set out below.

L4.15. You must not nominate a contractor or a consultant who has been contracted by you for a specific purpose for any Key Personnel role.

L4.16. You are responsible for anything done by anyone you have set up as an SMS User, including people from outside your organisation. If we are considering taking action against you, we will treat anything done on your behalf by a person from outside your organisation as if it were done by you. You should take precautions by checking the identity of anyone you appoint from another organisation and ensure they are suitable for the role.

UK-based representatives

L4.17. A UK-based representative can fill the following Key Personnel roles:

Key Contact
an additional Level 1 User
a Level 2 User

L4.18. They cannot be your Authorising Officer.

L4.19. You cannot nominate a representative as a Level 1 User when you first apply for your licence. You must first ‘appoint’ them as your representative. When you have been granted a licence, you can then nominate that person as an additional Level 1 User or as a Level 2 User. If you have only one Level 1 User, that person must not be a representative.

L4.20. The representative must be based in the UK – you cannot appoint an overseas-based representative for any Key Personnel role. You should check any representative you wish to appoint is suitably qualified to provide immigration advice or immigration services.

If you outsource your human resources function

L4.21. If you use the services of a third-party organisation to deliver some or all of your human resources function, you can appoint an employee of that organisation to act as:

an additional Level 1 User (they cannot be your primary or sole Level 1 User)
a Level 2 User

Agency staff

L4.22. A temporary staff member supplied to you by an employment business (or ‘temp agency’) can be appointed as a Level 2 User. They cannot fill any other Key Personnel role.

Insolvency practitioners

L4.23. If you go into administration (also known as special administration or administrative receivership) after you have been granted a licence, an insolvency practitioner must be appointed as your Authorising Officer while you remain in administration and they can fill any other Key Personnel role. For further guidance on what to do if you go into administration, see section C3 of Part 3: Sponsor duties and compliance.

Checks we make on your personnel

L4.24. We will always make checks on any Key Personnel you nominate, and may check other people falling under the general definition of ‘you’ or ‘your’. These include checks against our records and the Police National Computer (PNC) database. We will make these checks when considering your sponsor licence application and may repeat them at any time while you hold a sponsor licence. We will also carry out checks if new people are nominated to fill these roles. The outcome of these checks will, or may, influence the decision we make on your application, or the status of your existing licence.

L4.25. We do not routinely make checks on people associated with sponsors who are not Key Personnel or do not fall under the general definition of ‘you’ or ‘your’ but we reserve the right to do so. Such people could include employees in positions of responsibility who are not directors or Key Personnel, and individual financiers involved in the running of your organisation. We may ask you for information on such individuals as part of the application process. Their conduct, where relevant, may be taken into account when deciding your application.

Suitability requirements for Key Personnel

L4.26. We will refuse your sponsor licence application (or will revoke your licence if you already have one) if anyone falling under the definition of ‘you or your’:

has an unspent conviction for an offence listed in Annex L4 of this guidance
has been issued with a relevant civil penalty as described in Annex L1(c) to (g)
is legally prohibited from being a company director (for any reason, including bankruptcy), unless a court has given permission for that person to act as a director, or to promote or form a business, and acting as Key Personnel would not contravene that permission – this applies whether or not the individual is acting, or intends to act, as a director within your organisation

L4.27. We will normally refuse your sponsor licence application (or will normally revoke your licence if you already have one) if anyone falling under the definition of ‘you or your’:

has an unspent conviction for an offence not listed in Annex L4 but which we believe to be of relevance to your ability to meet your sponsor duties or otherwise makes you unsuitable to hold a sponsor licence
has been issued with a relevant civil penalty (other than those listed in Annex L1)
has previously been named as Key Personnel at any sponsor organisation where an application for a licence was refused within the last 6 months or where a licence has been revoked within the last 12 months
is, or has been, an owner, a director or an Authorising Officer of a sponsor licence holder that has been ordered to pay costs to the Home Office in any legal proceedings, and those costs have not been paid
is subject to UK or UN sanctions that would be contravened if you were granted, or allowed to continue holding, a sponsor licence
is acting, or has acted, in a manner that is not conducive to the public good
otherwise poses a risk to immigration control

L4.28. This is not a full list of reasons why your application could be refused. For further information, see:

Annexes L1, L2 and L3 of this guidance
Annexes C1, C2 and C3 of Part 3: Sponsor duties and compliance

Key Personnel roles: eligibility and responsibilities

L4.29. The subsections below explain what each of the Key Personnel roles (Authorising Officer, Key Contact, Level 1 User, Level 2 User) involves and who is eligible to fill them. You should read these subsections carefully before you appoint Key Personnel.

L4.30. Where reference is made below to a ‘partner’, this means an individual who is a business partner within your organisation (if you are a partnership, limited partnership or limited liability partnership).

L4.31. For a definition of the terms ‘employee’, ‘director’ and ‘office holder’, see the Employment status guidance on GOV.UK.

Authorising Officer

L4.32. You must nominate an eligible Authorising Officer when you apply for your licence. If you do not, we will refuse your application.

L4.33. Your Authorising Officer must be a paid member of staff or an office holder within your organisation. You cannot appoint a representative or somebody from another organisation to fill this role. The only exception to this is if you go into administration, in which case an insolvency professional must fill this role. See section C3 of Part 3: Sponsor duties and compliance for further information.

L4.34. Your Authorising Officer must be the most senior person in your organisation responsible for the recruitment of all sponsored workers and ensuring you meet all of your sponsor duties. If you do not recruit the workers you sponsor, this role must be filled by the most senior person responsible for your activity as a licensed sponsor.

L4.35. You can only have one Authorising Officer at any one time. If there is more than one person who could fill this role, you must decide which one to nominate. You are responsible for the actions of your Authorising Officer, so you should ensure you are confident that they understand fully the importance of this role.

L4.36. The Authorising Officer is responsible for deciding how many of your staff need to have access to the SMS and what level of permission they can have. They are responsible for the activities of all SMS users and must comply with our requirements for using the system. If they fail to do this, we will take action against you.

L4.37. The Authorising Officer does not have automatic access to the SMS. If they want to have access, they must also be appointed as a Level 1 (either when you apply for your licence or after it has been granted) or as a Level 2 User (after you have been granted a licence).

L4.38. The Authorising Officer is responsible for the activities of all SMS users, so you must have a system in place to check these activities. We recommend that the Authorising Officer checks the CoS assigned to workers at least once a month.

L4.39. You must have an eligible Authorising Officer in place throughout the life of your licence. The nominated person must always meet the requirements set out in this section. We will normally revoke your licence if we find you either:

do not have a suitable and eligible Authorising Officer in place
fail to tell us of a change of Authorising Officer

Key Contact

L4.40. The Key Contact is usually the person who acts as the main point of contact between you and us. We will contact them if we have any queries about your sponsor licence application, your supporting documents, or the payment of any fees. We may also contact your Authorising Officer.

L4.41. You must nominate an eligible Key Contact in your application. They can be the same person as your Authorising Officer, or a different person, provided they are suitable and eligible.

L4.42. You can only have one Key Contact, who must be one of the following:

a paid member of staff or an office holder within your organisation
a UK-based representative

L4.43. The Key Contact does not have automatic access to the SMS. If they need access to the system, they must also be appointed as a Level 1 User (either when you apply for your licence or after it has been granted) or as a Level 2 User (after you have been granted a licence).

Level 1 User

What a Level 1 User does

L4.44. The Level 1 User is responsible for carrying out your day-to-day sponsorship activities using the SMS, including:

assigning CoS to workers
asking for an increase in the number of CoS you can assign (your CoS allocation)
applying for Skilled Worker Defined CoS
asking for more Level 1 Users and adding Level 2 Users
updating their own details or the details of any active Level 2 Users
deactivating (removing) SMS Users (for example, when they’ve left your organisation)
telling us about changes to your organisation’s details or circumstances (see section C2 of Part 3: Sponsor duties and compliance for further information on reporting organisational changes)
reporting worker activity to us – for example, if a worker is absent without your permission, or if there are changes to the worker’s role or salary (see section C1 of Part 3: Sponsor duties and compliance for further information on reporting duties)
withdrawing CoS
viewing information about your licence activity and Key Personnel
accessing messages we post on the SMS from time to time
applying for premium customer service and tracking the progress of your application

Who can be a Level 1 User

L4.45. The Level 1 User can be the same person as your Authorising Officer, or be another person, or other persons, provided (in all cases) they meet the relevant suitability and eligibility requirements in this section.

L4.46. If you apply for your sponsor licence on or after 31 December 2024, you must nominate at least one Level 1 User (also referred to as your ‘primary’ Level 1 User) who meets both of the following requirements:

they are an employee, a director or a partner within your organisation
they are a ‘settled worker’, as defined section S1 of Part 2: Sponsor a worker (unless an exception set out below applies)

L4.47. If you fail to nominate a Level 1 User who meets both of these requirements, we will refuse your application.

L4.48. If you are granted a licence, you must ensure you have at least one Level 1 User in place throughout the life of your licence who meets the above requirements. If you do not, we will revoke your licence. The only exception to this is if you are in administration, in which case an insolvency practitioner can fill this role. For further information, see section C3 of Part 3: Sponsor duties and compliance.

Appointing additional Level 1 Users

L4.49. You can nominate more than one Level 1 User in your sponsor licence application but any additional Level 1 Users must be a paid member of staff or an office holder within your organisation. You cannot nominate a representative or a person from another organisation at this stage.

L4.50. After your licence has been granted, you can (if you wish) appoint additional Level 1 Users. Additional Level 1 Users must be one of the following:

a paid member of staff or an office holder within your organisation
an employee of an organisation engaged by you to deliver all or part of your human resources function
a UK-based representative

L4.51. It is for you to decide how many Level 1 Users you need. The Authorising Officer is responsible for their conduct, so we recommend that you do not have more Level 1 Users than you really need. You should make sure you have at least enough eligible Level 1 Users to be able to cover periods of absence.

Exceptions to the ‘settled worker’ requirement

L4.52. The requirement to have at least one Level 1 User who is a settled worker does not apply if you are a diplomatic mission, a consular post or an international organisation, and you are licensed (or applying to be licensed) on the International Agreement route.

L4.53. The requirement also does not apply if your Authorising Office is a person with valid entry clearance or permission to stay as any of the following:

a Representative of an Overseas Business
a Tier 1 (Graduate Entrepreneur) migrant
a Tier 1 (Entrepreneur) migrant
a Tier 1 (Exceptional Talent) migrant
a Start-up migrant
an Innovator or Innovator Founder
a Global Talent migrant
a UK Expansion Worker

L4.54. Even if this exception applies, you must ensure you have at least one Level 1 User who is an employee, a director or a partner within your organisation. If your Authorising Officer is later granted permission on a route not listed above, you must appoint a Level 1 User who fully meets the normal eligibility requirements set out at paragraph L4.46 above.

Transitional arrangement for Level 1 Users of existing sponsors

L4.55. If you already hold a valid sponsor licence on or before 31 December 2024, or applied for a licence before that date which was granted, you must have:

at least one Level 1 User who is an employee, a director or a partner within your organisation
at least one Level 1 User who is a settled worker (unless an exception specified above applies)

L4.56. These requirements can be met by a single Level 1 User, or by two separate Level 1 Users.

L4.57. In future, we will likely require all sponsors to have at least one Level 1 User who, on their own, meets both of the above requirements. We will publish further information about this in due in a future update to this guidance. In the meantime, we recommend, as a matter of best practice, you appoint one at least one Level 1 User who can meet both of these requirements.

Different requirements for UK Expansion Worker sponsors

L4.58. If you are applying under UK Expansion Worker, and your Authorising Officer is based overseas at the time of application, that person must be named as your Level 1 User. You can only change your Level 1 User, or add more Level 1 Users, when you have obtained an A-rating for your licence. For further guidance on appointing a Level 1 User on the UK Expansion Worker route, see section GBM3 of Sponsor a Global Business Mobility worker.

Level 2 Users

L4.59. Level 2 Users have fewer permissions than Level 1 Users. Level 2 Users can only perform the following actions in SMS:

create and assign CoS to workers
report worker activity to us relating to CoS they have personally created and assigned, or which have been transferred to them by a Level 1 User

L4.60. Level 2 Users cannot report on CoS assigned by Level 1 Users (unless the CoS has been transferred to the Level 2 User).

L4.61. You can only add Level 2 Users after you licence has been granted. They must be nominated by a Level 1 User.

L4.62. You can decide how many Level 2 Users you need (you do not have to have any). The Authorising Officer is responsible for them, so we recommend that you do not have more Level 2 Users than you really need.

L4.63. A Level 2 User must be one of the following:

a paid staff member or office holder within your organisation
an employee of an organisation engaged by you to deliver all or part of your human resources function
a temporary staff member supplied to you by an employment business
a UK-based representative

L4.64. As part of the transformation of Home Office sponsorship IT, we are making changes to the criteria on who can access the new sponsorship service (Sponsor UK). Level 2 Users will not be invited to register as users. If you want any of your existing Level 2 Users to have access to the new service, you must appoint them as Level 1 Users before you transition to the new service and ensure they can meet the relevant requirements for Level 1 Users.

L4.65. Previously, ‘overarching’ sponsors on the Government Authorised Exchange (GAE) route have been permitted to appoint Level 2 Users who are employed by outside organisations (‘host employers’) taking part in the specific GAE scheme they are licensed for. This provision will not be available to you when you move to the new service. This is because employees of third-party organisations are not permitted to act as Level 1 Users (except in the specific circumstances outlined above under Additional Level 1 Users).

L4.66. If you currently have Level 2 Users from a host employer, you should make alternative arrangements for managing your relationship with that employer before you transition to the new service, as they will no longer be permitted to directly access your sponsor licence. You should not appoint any new Level 2 Users from host employers.

L4.67. For further information about the Sponsor UK service, see Annex GA1 of Sponsor a Government Authorised Exchange worker.

Recording contact details of Key Personnel

L4.68. You must give contact details for your Key Personnel, both when you apply for a licence and if you change any Key Personnel or add new ones after we have granted your licence.

L4.69. The contact address given for each of your Key Personnel must be either your main business address or that of any branch or head office you are including in, or have subsequently added to, your licence. All email addresses you provide for each of your Key Personnel must be secure, personal to, and only accessible by, the named individual.

L4.70 . If you are appointing a Level 2 User who is an employee of another organisation engaged by you to deliver all or part of your human resources function, the address provided must be the main business address of that organisation.

L4.71. If you are appointing a UK-based representative (where eligible), the address must be the representative’s main business address.

Question 7

L5. Organisations with multiple branches

Accepted Answer

This section provides information on how you can apply for a licence if you have multiple branches or sites.

Guiding principles

L5.1. The sponsorship system is based on a direct relationship between a sponsor and the person they are sponsoring to work in the UK. This allows a sponsor to fulfil its sponsorship duties effectively.

L5.2. Organisations have a wide range of corporate structures and collaborative arrangements for delivering business in partnership with others. These are permitted under this guidance, but they must not distort or dilute the relationship between a sponsor and a worker that underpins the effective functioning of the sponsorship system.

L5.3. To ensure the sponsorship system works effectively where there are multiple branches or collaborative arrangements, the relationship between branches and organisations must be open and transparent so that the sponsorship of workers can be monitored effectively.

L5.4. Arrangements or partnerships that circumvent the Immigration Rules or this guidance will be considered to be abuse of the sponsorship system, and compliance action will be taken against the sponsor and/or its partners in such circumstances. If compliance action is taken, this will affect any licence you hold under the Worker or Temporary Worker routes, including all branches and partnerships listed on it.

How you can apply if you have multiple branches

L5.5. If you have a number of different offices, UK-based subsidiaries or entities, locations or campuses, which we call ‘branches’ in this guidance, you can register in a number of ways, including by:

applying for a single licence that includes your head office and all branches in the UK
each branch applying for its own licence
grouping a number of branches under a single licence – for example, a large UK-wide company might find it more convenient to register all of its operations in a particular region under a single licence

L5.6. We may ask for evidence to show that your head office and/or group of branches listed for any Worker or Temporary Worker route are linked by common ownership or control. We assess common ownership or control of branches in the same way we assess it for applications for a licence on the Senior or Specialist Worker or Graduate Trainee route as set out in section GBM2 of Sponsor a Global Business Mobility worker.

L5.7. If you are applying on any of the Global Business Mobility routes, you must also register details of the linked overseas business from whom workers will be assigned. See section GBM2 of Sponsor a Global Business Mobility worker for further information.

L5.8. We will not allow you to add a branch to your sponsor licence in any of the following circumstances:

the branch already holds a sponsor licence and it has been downgraded to a B-rating, or suspended whilst we investigate it
the branch previously held a sponsor licence and it has been revoked within the past 12 months
the branch is unable to offer a genuine vacancy that meets the suitability criteria for the issue of a licence in the relevant route

L5.9. If you have a number of branches that are individually licensed and we revoke the licence from one of those branches or downgrade it to a B-rating, we will not automatically remove or downgrade the licences from the other branches, but we will investigate them.

L5.10. If you are licensed as a ‘head office and all UK branches’ and we revoke your licence or downgrade it to a B-rating, this will apply to all your branches. If we revoke your licence, none of your branches will be able to sponsor workers. If you are sponsoring workers when your licence is revoked, we will normally cancel the permission they have to be in the UK, because they will no longer be working for a licensed sponsor. See Part 3: Sponsor duties and compliance for information on what happens to sponsored workers if we are considering taking action against you, or if we revoke your licence.

L5.11. If any of your branches later apply for their own licence, we will take into account any evidence of previous abuse or non-compliance, and the reasons for it, when considering their application.

Employment agencies and third-party employment

L5.12. If you are an employment agency or employment business, or other third party (intermediary) who supplies workers to a client, you can apply for a sponsor licence but only to sponsor workers who will be employed directly by you in connection with the running of your business. You cannot sponsor a worker and then supply them as labour to another organisation, regardless of any genuine contractual arrangement between the parties involved.

L5.13. If you are an employment agency, employment business or intermediary and we grant a sponsor licence to you on this basis, but later find the workers you are sponsoring have been supplied as labour to another organisation, we will revoke your licence.

L5.14. If you are a sponsor that wants to employ a worker who has been supplied to you by an employment agency, employment business or intermediary, you can only assign a Certificate of Sponsorship to them if you:

have genuine responsibility for deciding all the duties, functions and outcomes or outputs of the job the worker is doing
are responsible for agreeing and paying the worker’s salary

L5.15. See section S1 of Part 2: Sponsor a worker for information on sponsoring workers who are, or will be, working on a contract basis.

Franchises

L5.16. If you have a number of franchises under your control, you can decide whether to apply for a licence as a ‘head office and all UK branches’ or have each franchise licensed individually.

L5.17. If your franchises are separate businesses not under your control (as the parent organisation), each franchise must have its own licence if it wishes to sponsor workers.

Question 8

L6. Application process

Accepted Answer

This section describes the process of applying for a sponsor licence.

L6.1. The information in this section applies to all routes. You must also refer to the route-specific guidance relevant to route, or routes, in which you are applying to be licensed.

How we use your information

L6.2. All sponsorship applications are confidential. However, we may use personal information that you provide to us when you apply for a licence, at any time throughout the period of your licence, or in any other dealings with us, in accordance with the Home Office Personal Information Charter.

L6.3. In certain circumstances, information about you or your employees may be passed to other government departments and agencies, local authorities and fraud prevention agencies, such as HM Revenue and Customs (HMRC), the Department for Work and Pensions (DWP), and Cifas, for immigration purposes, the prevention of fraud and criminality and/or to help them carry out their functions. These bodies may provide the Home Office with information about you and your employees.

Using a representative

L6.4. You must make the application yourself. A representative can help you to fill in your application form (see ‘Choosing a representative’ below) but they must not send it on your behalf. If we find this has happened, we will refuse your application and not refund your fee.

L6.5. You can only appoint a representative at the licence application stage if you also want to appoint them as your Key Contact. You cannot appoint a representative as a Level 1 or Level 2 User at the licence application stage, or as an Authorising Officer at any stage. See the Key Personnel section for further information.

L6.6. If, after being granted a licence, you wish to use the services of a representative, or add them as a Level 1 or Level 2 User, you must appoint them using the sponsorship management system (SMS). We will not deal with any communications from a representative acting on your behalf unless they have been appointed by you.

Choosing a representative

L6.7. If you use the services of a representative – either in connection with your sponsor licence application or in any other dealings with us – they must be based in the UK and, if they will be providing immigration advice or immigration services (as defined in section 82 of the Immigration and Asylum Act 1999 (‘the 1999 Act’)), be authorised to provide such advice or services in accordance with section 84 of the 1999 Act. This means they must be one of the following:

L6.8. If a representative provides immigration advice or immigration services on your behalf without being ‘qualified’ under the 1999 Act, they may be committing a criminal offence.

L6.9. Sponsor licence holders are exempted from the general prohibition on providing immigration advice and immigration services to their sponsored workers and their eligible family members, in connection with their applications for entry clearance or permission to enter or stay on a sponsored work or study route, provided they meet specified conditions in the Immigration and Asylum Act 1999 (Part 5 Exemption: Licensed Sponsors) Order 2022.

L6.10. You cannot use this exemption to provide immigration advice or immigration services where the specified conditions are not met – this includes providing immigration advice or immigration services for other purposes, or to any other persons, or charging a fee for providing immigration advice or services. For further information, see section S6 of Part 2: Sponsor a worker. Anyone who satisfies section 84 of the 1999 Act in this manner must still comply with the IAA Code of Standards.

L6.11. You can find more information about the role of the IAA, and how to find a qualified immigration adviser, on the IAA website.

Sponsorship fees

L6.12. There is a fee for each of the following:

your application for a sponsor licence
in some cases, applying to add routes to your licence
each Certificate of Sponsorship you assign
if you are sponsoring a Skilled Worker or a Senior or Specialist Worker, you will normally need to pay an Immigration Skills Charge for each worker you sponsor, unless an exemption applies – see section S5 of Part 2: Sponsor a worker for further information
any additional premium services or priority services you request after your licence has been granted

L6.13. The fee for a sponsor licence depends on the type of licence you are applying for and the size or status of your organisation. You are eligible to pay the ‘small’ fee if you are any of the following:

are applying for a licence under the Temporary Worker routes only
have charitable status – see Sponsor a Charity Worker for a definition of this term
are subject to the small companies regime as set out in section 381 of the Companies Act 2006
a person who is not a company for the purposes of that section and you employ fewer than 50 people

L6.14. In all other cases, you must pay the ‘large’ fee. If you do not pay the fee in full, your application will be invalid and be rejected without further consideration.

L6.15. The fee is for our consideration of your licence application and will not be refunded if we refuse your licence application or you withdraw it after consideration of it has begun.

L6.16. If you need a faster decision on your sponsor licence application, there is a pre-licence priority service available for certain routes. For the latest information on current sponsorship fees, see UK visa fees on GOV.UK.

L6.17. You are responsible for paying the sponsorship fees listed above. If you are granted a licence, we will normally revoke your licence if you recoup, or attempt to recoup, by any means, the following fees from a worker you are sponsoring:

the Skilled Worker sponsor licence fee (including the fee for adding that route to your existing licence), and any associated administrative costs, where you recoup, or attempt to recoup, that fee or those costs on or after 31 December 2024
the sponsor licence fee on any other route (including the fee for adding that route to your existing licence), and any associated administrative costs, where you recoup, or attempt to recoup, that fee or those costs on or after 9 April 2025
the Certificate of Sponsorship fee, and any associated administrative costs, for a Skilled Worker, where that Certificate was assigned on or after 31 December 2024
the Certificate of Sponsorship fee, and any associated administrative costs, for a worker sponsored on any of the following routes, where that Certificate was assigned on or after 9 April 2025:
- any of the Global Business Mobility routes
- Minister of Religion
- International Sportsperson
- Scale-up
- Seasonal Worker
the Immigration Skills Charge for a Skilled Worker or a Senior or Specialist Worker, where you are required to pay this

L6.18. ‘Associated administrative costs’ means any costs incurred by you to obtain, use or maintain your licence and includes, but is not limited to:

fees for premium services or priority services for sponsor licence applications, changes of circumstances requests, or assigning, requesting or applying for a Certificate of Sponsorship
fees for legal advice related to applying for, using or maintaining your sponsor licence, or assigning, requesting or applying for a Certificate of Sponsorship
immigration advice or immigration services provided by a third party to a sponsored worker where the worker did not have a genuine choice in whether, or how, to obtain such advice or services, or where you provide such advice or services to the worker directly

Completing the online application form

L6.19. You must register your details online by completing the UKVI Online sponsor application registration. Once you have registered, you will be able to log into the UKVI ‘Sponsor application log in’ page. You must then complete the online application form and submit specified documents to prove you are eligible and suitable. These documents are listed in Appendix A of the sponsor guidance.

L6.20. You should make sure you will be able to send all of your documents to us within 5 working days of submitting your application.

L6.21. If you gather all the necessary information before starting, the application should take about 20 to 30 minutes to complete. If you want to keep a copy of it for your records, you must make a note or take a screenshot of what you have included in your application as you complete it because we cannot give you a copy of your licence application.

L6.22. When you complete the online sponsor licence application form, you must choose which routes you wish to be licensed under. You can choose as many routes as you need, provided you are eligible for them. If your application is successful, these will then be the only routes on which you can sponsor workers.

Certificate of Sponsorship allocation

L6.23. The online application form asks you for an estimate of the number of Certificates of Sponsorship (CoS) you may wish to assign in your first year on each route you’re applying to be licensed. You will need to assign a CoS to any worker you wish to sponsor before they can apply for entry clearance, permission to enter, or permission to stay. You will therefore need to think carefully about how many workers you are likely to employ during the year and why. This will determine your annual CoS allocation.

L6.24. If you are applying under Skilled Worker, you will be asked for the number of ‘Undefined’ CoS you will need during your first year as a sponsor. These are CoS assigned Skilled Workers who will be applying for permission to stay from within the UK. There is a different process for requesting and assigning CoS (known as ‘Defined’ CoS) if the worker will be applying for entry clearance from outside the UK. See sections SK11 and SK12 of Sponsor a Skilled Worker for further information.

L6.25. If you are applying under UK Expansion Worker, your maximum CoS allocation will be between 1 and 5, depending on your circumstances – see section GBM3 of Sponsor a Global Business Mobility worker for further information.

L6.26. You must give detailed reasons for the number of CoS you are requesting. If we are not satisfied with your reasons, or we otherwise have concerns, we may either give you a lower CoS allocation than you have requested, or set your allocation to zero. See section S2 of Part 2: Sponsor a worker for detailed guidance on what a CoS is and how we decide your application.

After you have submitted your application

L6.27. Once you have submitted your online application, you must send the following documents (by email) to validate it:

L6.28. You must also tell us in a covering email or letter accompanying your submission sheet if you (under the general definition of ‘you’ or ‘your’):

have been suspended or removed from any sponsor register within the last 5 years
have any criminal prosecutions pending
are aware that an organisation you have been involved with in a similar role has failed to pay value added tax (VAT) or any other form of excise duty

L6.29. You must send all of these documents to us within 5 working days of the date you complete your online application. You should scan or take pictures of your supporting documents and send them to the email address given on the submission sheet. If the relevant information is available online, indicate this in your sponsor licence application and tell us the website address, and any reference or registration number if relevant, so we can do an online check instead. See section 6 of Appendix A for further guidance on how to ensure your supporting documents are in the correct format.

L6.30. If any mandatory items are missing or incorrect, your application will be invalid. We reject invalid applications, return them to you without further consideration, and refund the application fee. If you still wish to apply for a licence, you will need to make a new application and pay the fee.

L6.31. If there are any documents specified in Appendix A, other than mandatory documents, missing from your application, or if we require any more documents or information, we will contact you by email. We will give you 5 working days to send the documents or information we ask for. We must receive all the documents or information by the end of the deadline date. If you are sending anything by post, you must respond to our email request by return email, within the deadline, telling us you have posted the information and providing any postal reference or tracking numbers.

L6.32. If you have not contacted us by the end of the deadline date, we will assume that you have not responded and your application will then be refused. If this happens, your application fee will not be refunded. It is therefore very important your Authorising Officer and Key Contact are available while we consider your application to deal with any requests we may need to make. We will always email the person named as your Key Contact if we need any further information or documents. We may also email your Authorising Officer.

Your duty of honesty

L6.33. You have a duty to act honestly in any dealings with us. This includes not making false statements and ensuring that all essential information is disclosed to us when applying for a sponsor licence or assigning or applying for a CoS while you are a sponsor. You must inform us if there is any change in your circumstances while your licence application is pending or after your licence has been granted – for example, if you cease to be registered with the appropriate regulatory body (where required) or you or any of your Key Personnel are convicted of an offence or have a pending prosecution.

L6.34. If we believe that you have knowingly provided false statements or false information with your application, not provided information you held when required to, you pose a threat to immigration control, or you are acting, or have acted, in a manner that is not conducive to the public good, we will refuse your licence application (or revoke your licence if you already hold one).

Question 9

L7. Supporting evidence

Accepted Answer

This section has been deleted as the information is now contained in Appendix A to the sponsor guidance.

Question 10

L8. How we assess your application

Accepted Answer

This section tells you how we assess applications for a sponsor licence, the circumstances in which we may conduct a compliance check, and how we assign ratings to sponsors.

Eligibility and suitability criteria

L8.1. All applications for a sponsor licence must meet the eligibility and suitability criteria described below.

Eligibility

L8.2. To confirm you are eligible for a licence, you must provide the supporting documents listed in Appendix A to the sponsor guidance and any additional documents we may request. We ask for these documents to make sure you are genuine and have an operating or a trading presence in the UK (or, in the case of UK Expansion Worker, a UK ‘footprint’). We may verify these documents to confirm they are genuine. For further information on the checks we make, see section 6 of Appendix A.

L8.3. If you have no operating or trading presence in the UK (or, in the case of UK Expansion Worker, if you have no UK footprint), we will refuse your application. If we find you have no operating or trading presence in the UK after granting a licence, we will revoke your licence.

Suitability

L8.4. The suitability criteria determine whether we grant or refuse your application, change the sponsor rating of an existing licence, or revoke an existing licence. It may also affect the limits we set for Certificates of Sponsorship (CoS) that you can assign.

L8.5. To assess suitability, we look at whether:

L8.6. We will also consider any evidence which suggests you may be a threat to immigration control or have engaged or are engaging in behaviour or actions that are not conducive to the public good, or evidence from a public body of your lack of compliance with their rules.

Genuine vacancy, salary and skill-level

L8.7. If you are applying under the Skilled Worker, Scale-up or GBM routes, we must be satisfied you can and intend to offer genuine employment that meets the, salary and skill-level criteria of those routes. See the relevant route-specific guidance for information on this.

L8.8. If your business involves using no (or little) physical office space (a ‘virtual business model’), we will consider the type of work a sponsored worker will be doing and where the worker will be carrying out their employment duties. We may need to conduct a compliance check and/or see contracts between you and any third party.

L8.9. Below are two examples of circumstances in which we may not be satisfied you can offer genuine employment that would meet the requirements of the Skilled Worker route. These examples are not intended to be exhaustive.

Example 1

You do not currently employ, or have never employed, anyone in a role which meets the Skilled Worker requirements. This could be if you are a small retail outlet and currently only have people working for you as shop assistants or in other lower-skilled roles.

Example 2

You tell us you require, or have already sponsored, a person in a role which does not appear necessary for your business – for example, you are a small fast food outlet and you tell us you need, or have appointed, a full-time business development manager, HR manager or publicity manager, but there is no credible need for these roles in your business.

Criminal convictions and civil penalties

L8.10. We will automatically refuse your application if anybody falling under the general definition of ‘you’ or ‘your’ has any unspent criminal convictions for a relevant offence. For a definition of ‘relevant offence’, see Annex L4 of this guidance.

L8.11. You can apply for a licence once your conviction has become spent under the Rehabilitation of Offenders Act 1974 (as amended from time to time). However, if you previously applied before the conviction was spent and we refused your application for that reason, and the conviction subsequently becomes spent, you will be subject to a cooling-off period when you reapply, which means you may not be eligible for a licence straightaway.

L8.12. We may also refuse your application if you have been convicted of an offence which is not listed as a ‘relevant offence’ but which we consider to be relevant to your ability to carry out your sponsor duties.

L8.13. If you have a criminal prosecution pending, we will put your application on hold pending the outcome, unless we have other reasons to refuse it, in which case we will refuse it without waiting.

L8.14. If you have previously been issued with a relevant civil penalty or charge, you may be subject to a cooling-off period of between 12 months and 5 years once the penalty has been paid in full, depending on the nature of the civil penalty or charge. We will always refuse your application if the relevant penalty or charge has not been paid in full.

Pre-licence compliance checks

L8.15. We use risk assessments to guide our compliance activity and focus that activity on the areas of highest risk. If we know little about you, are concerned about the evidence you have provided, or if information or evidence otherwise comes to light that causes us concern, we will make further checks. These could include checks with other government departments and/or a compliance check.

L8.16. If we undertake a compliance check, we may visit you, and interview you and any relevant personnel, at your main office address and any other physical addresses where your sponsored workers would be carrying out their employment duties (including their home address, if they normally work from home). If we undertake a digital compliance inspection, we may interview you and any other relevant personnel using remote video conferencing facilities.

L8.17. If you operate a virtual business model (with little or no physical office space), it is highly likely that we will conduct a compliance check with your Authorising Officer, which may include a compliance visit to their physical address, before making a decision on your application for a licence.

L8.18. If there are differences between what you told us and what our compliance officer finds during a compliance check, we will let you know whether we need more information before making a final decision.

L8.19. If we have significant doubts about your ability to fulfil your sponsorship duties after a compliance check, we are likely to refuse your application.

Scoring system if we conduct a compliance check

L8.20. If we conduct a compliance check on you, either before deciding your licence application, or after your licence has been granted, we will assess you against one or more of the criteria in the table below to decide whether to grant your application (or to allow you to keep your licence if you already have one). For each criterion we assess you against, we will give a score of ‘met’ or ‘not met’:

Criterion	How we judge this
Human resources systems	Whether you have systems in place that allow you to know when a sponsored worker has not turned up for work or to identify when their current permission is coming to an end.
Convictions and civil penalties	Whether or not you have an unspent criminal conviction for a relevant offence (as defined in Annex L4) or have been issued with a relevant civil penalty.
Migrant compliance	Whether you are employing any workers, sponsored or not, who are in breach of the conditions of their immigration permission – for example, a Student who is working more hours than they are allowed to.
Employment	Whether you can, and genuinely intend to, offer employment which meets the criteria for the relevant immigration route (such as genuine vacancy, salary and skill-level).

L8.21. We will grant your licence if you meet all of the criteria above we assess you against and there are no other reasons in Annex L1, L2 or L3 to refuse your application. If you do not meet all of the criteria we assess you against, we:

will refuse your application if any of the circumstances listed in Annex L1 arise
will normally refuse your application if any of the circumstances in Annex L2 arise
may refuse your application if any of the circumstances listed in Annex L3 arise

L8.22. For further information on pre-licensing and compliance activity, see:

Sponsor ratings

L8.23. For routes other than UK Expansion Worker, a sponsor licence is rated either ‘A’ or ‘B’. Your licence rating appears on the published register of licensed sponsors on GOV.UK.

L8.24. Subject to the exception for UK Expansion Worker below, an A-rating is awarded when you are first granted a licence on the basis that you have systems in place to be able to meet your sponsor duties and that we trust you to act in a way appropriate to those licensed by us. We will not grant a licence if you are not able to achieve an A-rating.

L8.25. Throughout the validity period of your licence, we will rate you as either A or B, according to our assessment of your ability to comply with your sponsor duties and to act in a way appropriate to those licensed by us. If you are downgraded to a B-rating, you must meet a time-limited sponsorship action plan, for which you must pay and which will set out the steps you need to take to gain or regain an A-rating. If you do not meet the requirements of your action plan within the specified time limit, we will revoke your licence.

Sponsor rating for UK Expansion Worker

L8.26. If you are granted a sponsor licence on the UK Expansion Worker route, you will be given either an ‘A’ or a ‘Provisional’ rating. A ‘Provisional’ rating is awarded if your Authorising Officer (and Level 1 User) is an employee of the overseas business and will be assigning their own Certificate of Sponsorship in order to apply for entry clearance to the UK. You can upgrade to an A-rating once the Authorising Officer has been granted entry clearance and has updated their details on the SMS. See section GBM3 of Sponsor a Global Business Mobility worker for further information.

L8.27. A Provisional rating cannot be downgraded to a B-rating. If you are a Provisional sponsor and you fail to meet your sponsor duties or the conditions for holding a licence, we will normally revoke your licence.

L8.28. You will be given a rating for each type of licence that you have (Worker, Temporary Worker and/or Student). That rating will apply to all routes in which you are licensed that are covered by that type of licence – you cannot have different ratings for individual routes. For example, if you are licensed under Skilled Worker and Senior or Specialist Worker (both of which are Worker routes), and we downgrade you due to failings in respect of only one of those routes, your licence rating will show on the register as ‘Worker (B rated)’.

L8.29. If you have more than one type of licence (Worker, Temporary Worker or Student), your rating will usually be the same for each type of licence you hold. In exceptional cases, if we find you are not meeting your sponsor duties in only one type of licence, we will downgrade that licence to a B- rating but you may be permitted to retain your A-rating for the other types of licence you hold.

L8.30. Part 3: Sponsor duties and compliance has more information on downgrading licence ratings and other action we may take against you.

Question 11

L9. The decision on your application

Accepted Answer

This section tells you how we will notify you of the decision on your sponsor licence application, additional services you may be eligible for if we approve your application, and what you can do if your application is refused.

L9.1. When we have decided your application, we will write to you to tell you:

whether we have approved or refused your application
the reasons for the decision if we have refused your application

L9.2. Decision letters are sent by email to the mailbox of the Authorising Officer stated in the online sponsor application. We will return any original documents you have sent to us by Royal Mail Signed For delivery to the address given for the Authorising Officer in your online sponsor application.

Note: emails from us may be diverted to junk or spam folders, which can be avoided by marking the email domain @homeoffice.gov.uk as trusted in your email settings.

If your application is approved

L9.3. If we approve your licence application, we will tell you in our decision letter:

the maximum number of Certificates of Sponsorship (CoS) you will be allowed to assign – this will be zero if you said in your application that you are unsure whether or when you may need to recruit any overseas workers in the future
your sponsor licence number (SLN) – this is unique to you and you must quote it in all communications with us

Sponsoring workers

L9.4. Once you are ready to sponsor a worker, you must refer to the relevant route-specific guidance and Part 2: Sponsor a worker for information on how to do this.

Additional services you may be eligible for

L9.5. A-rated sponsors may be eligible for additional services – the premium customer service and the priority change of circumstances service. These are described below.

Premium customer service

L9.6. The premium customer service offers an enhanced level of support for A- rated sponsors. A premium customer has their own dedicated account manager who will provide tailored advice and support. The ‘Premium customer service for employers’ page on GOV.UK has full guidance about this service, including the benefits, costs, eligibility criteria, and how to apply.

L9.7. If you successfully apply for premium customer service, this will be indicated on our public Register of sponsors, where your sponsor rating will show as A (Premium) for large employers or A (SME+) for small and medium enterprises.

Priority change of circumstances service

L9.8. The priority change of circumstances service offers a faster consideration of sponsor change of circumstances requests for A-rated sponsors. The ‘Priority change of circumstances service’ page on GOV.UK has full guidance about this service.

If your application is refused

L9.9. If your licence application is refused, you may be able to:

ask us to review the decision through the ‘Error correction request’ process, if you believe there has been a simple caseworking error
apply again – but only after the appropriate ‘cooling-off period’, if applicable, has ended

Error correction request

L9.10. There is no right of appeal against the refusal of an application for a licence. However, if you believe the refusal decision is the result of either:

a caseworker error – for example, if we have incorrectly applied a cooling-off period and you send evidence to us to show that this is the case
evidence sent as part of your application not being considered by us – for example, if we have not considered a specific piece of information and you send evidence to show this was received by us

you can send an ‘Error correction request form’.

L9.11. The request must be sent within 14 calendar days from the date of the refusal decision letter. We aim to reply to you within 28 working days of the receipt of your error correction request form.

L9.12. The pre-licence error correction process does not offer a full reconsideration of a decision to refuse a licence application. We will not consider any additional evidence which was not available at the time of application.

L9.13. If we establish that a simple caseworker error has occurred, or a piece of information sent at the time of application has not been considered, we will write to you inviting you to send a new online sponsor licence application. You will need to pay application fee again but, on receipt of your application, we will refund this. Sending a new application is not a guarantee that a licence will be granted.

L9.14. If we maintain our original decision to refuse your licence application, we will write to tell you. The cooling-off period will continue to apply from the date of the original refusal decision. A refusal decision will not be reviewed a second time under this process.

Cooling-off period following refusal, withdrawal, revocation, surrender, civil penalty or conviction

L9.15. If your application for a sponsor licence is refused, you will not normally be able to make a successful further application until a specified period of time has elapsed since the refusal. This is known as the ‘cooling-off period’.

L9.16. The cooling-off period will also normally apply in any of the following circumstances:

you withdrew your licence application while we were undertaking checks on you and it is likely that we would have refused your application had you not withdrawn it
you previously held a sponsor licence and:
- it was revoked, or
- you surrendered it while we were taking compliance action against you (and it would have been revoked as a result of that compliance action)
you have been issued with a civil penalty or charge specified in the table below
you have an unspent conviction for a relevant offence

L9.17. The length of the cooling-off period depends on the circumstances.

L9.18. If you apply, or reapply, while you are still subject to a cooling-off period, we will automatically refuse your application, even if the reasons that led to the cooling-off period no longer apply.

L9.19. The table below sets out the length of the cooling-off period according to the circumstances. You must also read the notes below the table.

Circumstance	Length of cooling off period
Your application was refused (or would have been refused had you not withdrawn it) because: your application was sent by a representative you did not provide documents or information we requested by a specific deadline for reasons outside your control you applied to be licensed on the Scale- up route and your application was refused solely because you do not meet the definition of a ‘qualifying Scale-up sponsor’	No cooling-off period (you can apply again at any time).
Your previous application was refused (or would have been refused had you not withdrawn it) for any reason not otherwise mentioned in this table	6 months from the date your application was refused (or the date we notified you that we had accepted your withdrawal request, as the case may be).
You previously held a sponsor licence and it was revoked (or it would have been revoked had you not surrendered it)	12 months from the date of the notice informing you that your licence had been revoked (or the date we notified you that we had accepted your request to surrender your licence, as the case may be).
You have been issued with a civil penalty for employing an illegal worker under either: section 15 of the Immigration, Asylum and Nationality Act 2006; or regulation 11 of the Accession of Croatia (Worker Authorisation) Regulations 2013 and that penalty has been paid in full	12 months from the date you paid the penalty in full.
More than one civil penalty has been issued to an owner, a director or an Authorising Officer of your organisation (either individually or collectively) under section 23 or section 25 of the Immigration Act 2014 for authorising occupation of premises under a residential tenancy agreement by an adult who is disqualified because of their immigration status, and those penalties have been paid in full	12 months from the date you paid the penalty in full.
You have been issued with a civil penalty or charge under: section 32 of the Immigration and Asylum Act 1999: carrying clandestine entrants section 40 of the Immigration and Asylum Act 1999: carrying passengers without proper documents section 24 of the Counter-Terrorism and Security Act 2015 or the Authority to Carry (Civil Penalties) Regulations 2015: bringing a passenger to the UK in breach of an authority to carry scheme and that penalty or charge has been paid in full	5 years from the date you paid the penalty or charge in full.
Either: you have been issued with 2 or more civil penalties for employing an illegal worker under: section 15 of the Immigration, Asylum and Nationality Act 2006; or regulation 11 of the Accession of Croatia (Worker Authorisation) Regulations 2013; or 3 or more civil penalties have been issued to an owner, a director or an Authorising Officer of your organisation (either individually or collectively) under section 23 or section 25 of the Immigration Act 2014 for authorising occupation of premises under a residential tenancy agreement by an adult who is disqualified because of their immigration status and those penalties have been paid in full	We may refuse your licence application for up to 5 years after the date you paid the penalty in full – see notes below this table.
You have (or a person mentioned above has) an unpaid civil penalty or charge for any of the offences listed above and you are (or that person is) still liable once your or their objection and appeal rights are exhausted	Indefinite – we will not grant you a licence while you have an unpaid civil penalty or charge.
You have an unspent conviction for a relevant offence	Until the conviction is spent under the Rehabilitation of Offenders Act 1974 If the unspent conviction is recorded against an individual in your organisation, you can reapply for a licence (subject to any other cooling-off period that may apply in this table) before the conviction is spent if that individual: no longer works for you no longer falls under the definition of ‘you’, or does not otherwise have significant involvement in the running or financing of your business For further information, see ‘Checks we make on your personnel’.

Notes on the table above

L9.20. Where more than one cooling-off period is relevant to your circumstances, the longest cooling-off period will apply, as explained in the examples below.

Example 1

Your application was refused because you did not meet all of the requirements of the route in which you were applying (6-month cooling-off period) and because you have recently been issued with a civil penalty for employing an illegal worker, which you are paying off in agreed instalments. In this scenario, you will not be eligible to make a successful licence application until 12 months have elapsed since you have paid the civil penalty in full, as that is the longer cooling-off period.

Example 2

Your application was refused because you did not meet all of the requirements of the route in which you were applying (6-month cooling-off period) and because you have previously been issued with a civil penalty for employing an illegal worker. You paid that penalty in full 10 months ago. In this scenario, the 6-month cooling-off period will apply, as the cooling-off period for the civil penalty will expire in 2 months.

L9.21. Where reference is made to civil penalties issued to “an owner, a director, or an Authorising Officer of your organisation”, this means civil penalties issued to those persons either individually or collectively. For example, if an owner has been issued with one civil penalty, and your Authorising Officer has been issued with another, this will count as two civil penalties against your organisation.

L9.22. Where the table above says that we may impose a cooling-off period of up to 5 years (multiple civil penalties for employing illegal workers or under the right-to-rent scheme), we will take into account a number of factors including, but not limited to:

the number of civil penalties imposed
the number of illegal workers or (as the case may be) disqualified adults involved
the amount of each civil penalty imposed
the extent to which you co-operated with the Home Office or relevant authorities
how soon you paid off the penalty, or penalties, or if you complied with any agreement to pay the penalty, or penalties, in instalments

New application after cooling-off period has expired

L9.23. Before you reapply, you must ensure that the reasons we refused (or would have refused) your previous application, or revoked (or would have revoked) your previous licence, no longer apply. The fact that the cooling-off period has expired does not mean we will grant your application – you must fully meet the requirements set out in this guidance.

L9.24. As part of the application process, a UKVI compliance officer may conduct a compliance check on you. If this happens, the officer will undertake relevant checks to establish that you have the necessary systems and procedures in place to meet your sponsorship obligations. If we are not satisfied that you can fully meet your sponsorship obligations or you otherwise remain unsuitable to hold a sponsor licence, we will refuse your application again and you will be subject to a further cooling-off period.

Question 12

L10. Sponsorship management system

Accepted Answer

This section tells you about the sponsorship management system and how you can use it to report changes or add routes to your licence.

What is the sponsorship management system?

L10.1. Once licensed, you will be given access to the sponsorship management system (SMS). This online function allows you to carry out day-to-day activities and report any changes to us, such as a change of address. You will also use it to:

manage your organisation’s licence or services
create and assign Certificates of Sponsorship (CoS) to workers you wish to sponsor
apply for Defined CoS for Skilled Workers
report changes of circumstances of your sponsored workers, including withdrawal of sponsorship

For further information assigning CoS and your reporting duties, see:

L10.2. The SMS allows users two levels of access – ‘Level 1’ and ‘Level 2’. The level decides the type of access (permissions) the user has to the system and the functions they can perform. See section L4 for more information.

L10.3. Your SMS account is also a source of information about your sponsor licence. You can see details of how many SMS users you have appointed and who they are, the date your licence will expire (Scale-up and UK Expansion Worker only), the number of CoS left to assign, and when your allocation of CoS will expire. Your SMS account also has a ‘message board’ where we post useful messages, such as information about updates to the sponsor guidance.

L10.4. You need to access your SMS account regularly to review and update your licence details and to keep up to date with the latest news, messages, and any changes that may be coming up. We recommend that your Level 1 User accesses your account at least once a month.

L10.5. When we grant your sponsor licence, we set up your SMS account and send the Level 1 User’s ‘user name’ to your Authorising Officer by post. We send the Level 1 User their password by email. Once your Level 1 User has successfully accessed your SMS account, they can perform a number of functions.

L10.6. SMS users must not give their password to anyone else. If they do, we may revoke your licence.

L10.7. See User manuals: sponsorship management system (SMS) on GOV.UK for detailed guidance on how to use the SMS.

Adding routes to your licence

L10.8. Once your licence has been granted, you can apply to add routes to it. For example, if you were originally licensed under Skilled Worker only, you could add Senior or Specialist Worker (or any other route) to your licence, if you meet the relevant requirements.

L10.9. You will have to pay a fee if you:

are a ‘large’ company (that is, you do not meet the definition of ‘small or charitable sponsor’)
were originally licensed under the Temporary Worker routes only; and
wish to add one or more of the Worker routes to your licence

L10.10. The fee will be the difference between the fee for a sponsor licence for the Worker routes and the fee for a sponsor licence for the Temporary Worker routes.

L10.11. There is no additional fee to pay for adding routes if:

you are a small or charitable sponsor
you are already licensed under one or more the Worker routes and you paid the large fee when you originally applied; or
you are licensed under the Temporary Worker routes only and you wish to add other Temporary Worker routes to your licence

L10.12. To add routes to your licence, your Level 1 User must log in to the online sponsor licence application form using your original log-in details or by registering again. They will then fill in a shortened version of the online application form which allows them to apply to add new routes to your licence. The Level 1 User will not be able to change anything else. You must pay the fee (if relevant) and send us any documents specified in Appendix A to the sponsor guidance as mandatory for the relevant route. The Authorising Officer must approve this action, and the Level 1 User must retain the evidence of this approval.

L10.13. You will not be allowed to add routes if your licence is suspended, has a Provisional rating, or is downgraded to a B-rating. See Part 3: Sponsor duties and compliance for information on the circumstances in which we downgrade or suspend licences.

L10.14. There can only be one Authorising Officer and one Key Contact named on a sponsor licence. If you want to apply to add a route to your licence, but you want different people to act as Authorising Officer and Key Contact for that route, you must apply for a new, separate, licence and pay the full application fee.

Question 13

Annex L1: circumstances in which we will refuse your application

Accepted Answer

This annex sets out the circumstances in which we will refuse your sponsor licence application.

Unless otherwise stated, ‘you’ or ‘your’ has the meaning given in the Glossary.

a.

You knowingly send any false document with your application. If this happens, and we believe that a criminal offence has been committed, we will refuse your application and refer your case for prosecution.

b.

You have an unspent conviction for a relevant offence listed in Annex L4 of this guidance.

c.

You:

have been issued with a civil penalty or charge under:
remain liable for the penalty or charge once your objection and appeal rights have been exhausted; and
apply for your licence before 5 years has elapsed since the date the penalty or charge was settled (paid in full)

d.

You:

have been issued with a civil penalty for employing an illegal worker, or illegal workers, under either:
- section 15 of the Immigration, Asylum and Nationality Act 2006; or
- regulation 11 of the Accession of Croatia (Immigration and Worker Authorisation) Regulations 2013; and
remain liable for the penalty once your objection and appeal rights have been exhausted; and
apply for a licence before 12 months has elapsed since the date the penalty was settled (paid in full)

e.

You have not paid an outstanding civil penalty or charge for any of the offences referred to in (c) or (d) above, or any other civil penalty for employing illegal migrant workers, and you are still liable once your objection and appeal rights have been exhausted.

f.

Two or more civil penalties have been issued to an owner, a director or an Authorising Officer of your organisation (either individually or collectively) under section 23 or section 25 of the Immigration Act 2014 for authorising occupation of premises under a residential tenancy agreement by an adult who is disqualified, because of their immigration status, and:

that person was or is (or those persons were or are, as the case may be) still liable once their objection and appeal rights have been exhausted; and
you apply for your sponsor licence before 12 months has elapsed since the date the penalties were settled (paid in full)

g.

An owner, a director or an Authorising Officer of your organisation has not paid an outstanding civil penalty issued for authorising occupation of premises under a residential tenancy agreement by an adult who is disqualified, because of their immigration status, for which they are still liable once their objection and appeal rights have been exhausted.

h.

You have previously held a sponsor licence of any type and that licence was revoked by us, or you surrendered that licence while we were taking compliance action against you, in the 12-month period prior to the date of your application.

i.

Any person who falls under the general definition of ‘you’ is legally prohibited from being, or becoming, a company director, unless a court has given permission for that person to act as a director, or to promote or form a business, and their role within the sponsor organisation would not contravene that permission.

j.

We have asked you to send us any document or information to support your application and you do not send the document or information within the given time limit.

k.

You fail to meet one or more of the requirements of the route, or routes, on which you are applying to be licensed, as set out in the relevant route-specific guidance – for example, if you are applying under Skilled Worker or the Global Business Mobility routes, and we are not satisfied you can, and genuinely intend to, offer genuine employment which meets the skill level or salary requirements of those routes.

If you fully meet the requirements of one route, or some routes, on which you are applying to be licensed, but not others, we will only licence you for the route, or routes, on which you qualify.

l.

You do not have in place the necessary human resources systems or other processes to comply with your sponsor duties. For example, your internal communications may not be good enough for you to know if a sponsored worker has not reported for work.

m.

We have reason to believe you are acting, or will act, as an employment agency or employment business and intend to supply a worker you are sponsoring to a third party as labour.

n.

You are applying on a route other than UK Expansion Worker and you have no operating or trading presence in the UK.

o.

You fail to meet the requirements set out in the safeguarding children section.

p.

Your application is sent by a representative.

q.

You fail to nominate in your online application form an Authorising Officer and at least one Level 1 User who meets our requirements as set out in section L4 of this document.

r.

You have had an application for a sponsor licence refused within the last 6 months for any reason (or would have had it refused had you not withdrawn the application), unless the refusal was for one of the following reasons:

your application was sent by a representative
you did not provide documents or information we requested by a specific deadline for reasons outside your control
you applied to be licensed on the Scale-up route and your application was refused solely because you do not meet the definition of a ‘qualifying Scale-up sponsor’ as set out in section SC2 and Annex SC1 of Sponsor a Scale-up Worker

s.

You are applying as an individual person (who is not a sole trader).

Question 14

Annex L2: circumstances in which we will normally refuse your application

Accepted Answer

This annex sets out the circumstances in which we will normally refuse your sponsor licence application.

Unless otherwise stated, ‘you’ or ‘your’ has the meaning given in the Glossary.

a.

You have provided a false statement or false information, or have not provided, when required, information that you held, to us or any other Government Department.

b.

You have an unspent conviction for an offence other than a relevant offence listed in Annex L4 which we believe to be of relevance to your ability to discharge your sponsor duties or suitability to hold a sponsor licence.

c.

You have been issued with 2 or more civil penalties in the 5-year period immediately prior to your application for employing an illegal migrant worker.

See ‘Cooling-off period’ in section L9 for further information.

d.

Three or more civil penalties have been issued in the 5-year period immediately prior to your application to an owner, a director or an Authorising Officer of your organisation (either individually or collectively) under section 23 or section 25 of the Immigration Act 2014 for authorising occupation of premises under a residential tenancy agreement by an adult who is disqualified, because of their immigration status.

See ‘Cooling-off period’ in section L9 for further information.

e.

You are or have been an owner, a director or an Authorising Officer of a sponsor organisation which has been ordered to pay costs to the Home Office in any legal proceedings, and those costs have not been paid.

f.

You have previously been named as ‘Key Personnel’ at any organisation where either:

that organisation’s sponsor licence (of any type) has been revoked within the last 12 months
that organisation’s application for a sponsor licence (of any type) has been refused within the last 6 months (and an exception in Annex L1(r) of this guidance does not apply)

See below this table for further information on how we consider previous non-compliance.

g.

You are employing a worker (whether sponsored or not) who is subject to immigration control and that person either:

does not have permission to enter or stay in the UK; or
they are working in breach of the conditions of their permission (leave) and you could reasonably have been aware of this breach

We will also refer your case to the relevant Home Office team to consider issuing you with a civil penalty.

h.

The UK Government or United Nations has imposed sanctions on you which will be contravened by giving you a licence.

i.

You engage in actions or behaviours that are not conducive to the public good.

j.

We have reason to believe that you otherwise pose any risk to immigration control.

k.

You fail to co-operate with a compliance check, where required, or delay compliance activity.

l.

You intend to sponsor workers in a personal capacity, as defined in section L1 of this guidance.

Previous non-compliance

Previous non-compliance with the sponsorship system (other than non-compliance which would result in automatic refusal under Annex L1) may result in your application being refused. This could be where it is one of several grounds falling under this Annex or Annex L3, or it is warranted by the actions of any person falling under the general definition of ‘you or your’. We also reserve the right to check individuals involved in your organisation who do not fall under the general definition of ‘you or your’ and to take into account their previous conduct– see ‘Checks we make on your personnel’ for further information.

The action we take will depend on:

the seriousness of the past conduct (including conduct that led to revocation of a licence) and what you have done to improve the situation
how long it is since the conduct took place and any mitigating circumstances
concerns we may have about any of your associated persons or employees, and the role they have within your organisation – in particular, where they have been employed or associated with an organisation that has been removed from the sponsor register for abuse or serious non-compliance within the last 5 years
in the case of previous criminal conduct, whether we believe this has a bearing on your suitability to be a sponsor – note that we will always refuse your application if anyone falling under the general definition of ‘you or your’ has an unspent criminal conviction for an offence listed in Annex L4

Question 15

Annex L3: circumstances in which we may refuse your application

Accepted Answer

This annex sets out the circumstances in which we will consider refusing your sponsor licence application. Generally, we will not refuse your application if only one of these circumstances arises, but we reserve the right to do so, depending on the gravity of the issue. The more of these circumstances that are present, the more likely it is we will refuse your application.

Unless otherwise stated, ‘you’ or ‘your’ has the meaning given in the Glossary.

a.

You have a previous record of non-compliance or poor compliance with the duties of sponsorship. See Annex L1 of this guidance if you have previously had a sponsor licence and it was revoked.

b.

You have previously been asked to provide evidence to allow us to decide whether an organisation you are, or have been, involved with was complying with its sponsor duties and that information was not provided.

c.

You or any organisation that you have been involved with in a similar role has had its authorisation to provide immigration advice or immigration services, as defined by section 82 of the Immigration and Asylum Act 1999, removed by the Immigration Advice Authority (formerly the Office of the Immigration Services Commissioner), or other designated professional body or designated qualifying regulator.

d.

You have, or you are aware that a sponsor organisation you have been involved with in a similar role within the last 5 years has, been issued with a penalty for failure to pay VAT or duty.

e.

You have been issued with any civil penalty not otherwise mentioned in these annexes and we believe this is of relevance to your ability to carry out your sponsor duties or suitability to hold a sponsor licence.

f.

You have been issued with a warning notice (not a civil penalty) under section 15 of the Immigration, Asylum and Nationality Act 2006 (employment of illegal workers) within the previous 5 years.

Question 16

Annex L4: relevant offences

Accepted Answer

This annex lists the unspent convictions that we will take into account, as referenced in Annex L1 of this guidance. Note that we will always refuse your licence application if you have an unspent conviction for any of these offences.

Number	Unspent conviction for
1.	Any offence specified under any of the “Immigration Acts” (as that term is defined in section 61 of the UK Borders Act 2007).
2.	Any offence listed in Appendix B of the guidance for sponsors.
3.	Any offence listed under Class A (homicide, manslaughter and related grave offences) in Annex 1B: List of offences in class order as defined by the Crown Prosecution Service.
4.	An offence under section 4 of the Offences against the Person Act 1861 (soliciting murder).
5.	An offence under section 18 of that Act (wounding with intent to cause grievous bodily harm).
6.	An offence under section 16 of the Firearms Act 1968 (possession of a firearm with intent to endanger life).
7.	An offence under section 17(1) of that Act (use of a firearm to resist arrest).
8.	An offence under section 18 of that Act (carrying a firearm with criminal intent).
9.	An offence of robbery under section 8 of the Theft Act 1968 where, at some time during the commission of the offence, the offender had in his possession a firearm or an imitation firearm within the meaning of the Firearms Act 1968.
10.	An offence under section 1 of the Protection of Children Act 1978 (indecent images of children).
11.	An offence under section 56 of the Terrorism Act 2000 (directing terrorist organisation).
12.	An offence under section 57 of that Act (possession of article for terrorist purposes).
13.	An offence under section 59 of that Act (inciting terrorism overseas).
14.	An offence under section 47 of the Anti-terrorism, Crime and Security Act 2001 (use etc of nuclear weapons).
15.	An offence under section 50 of that Act (assisting or inducing certain weapons-related acts overseas).
16.	An offence under section 113 of that Act (use of noxious substance or thing to cause harm or intimidate).
17.	An offence under section 1 of the Sexual Offences Act 2003 (rape).
18.	An offence under section 2 of that Act (assault by penetration).
19.	An offence under section 4 of that Act (causing a person to engage in sexual activity without consent).
20.	An offence under section 5 of that Act (rape of a child under 13).
21.	An offence under section 6 of that Act (assault of a child under 13 by penetration).
22.	An offence under section 7 of that Act (sexual assault of a child under 13).
23.	An offence under section 8 of that Act (causing or inciting a child under 13 to engage in sexual activity).
24.	An offence under section 9 of that Act (sexual activity with a child).
25.	An offence under section 10 of that Act (causing or inciting a child to engage in sexual activity).
26.	An offence under section 11 of that Act (engaging in sexual activity in the presence of a child).
27.	An offence under section 12 of that Act (causing a child to watch a sexual act).
28.	An offence under section 14 of that Act (arranging or facilitating commission of a child sex offence).
29.	An offence under section 15 of that Act (meeting a child following sexual grooming etc).
30.	An offence under section 25 of that Act (sexual activity with a child family member) if the offender is aged 18 or over at the time of the offence.
31.	An offence under section 26 of that Act (inciting a child family member to engage in sexual activity) if the offender is aged 18 or over at the time of the offence.
32.	An offence under section 30 of that Act (sexual activity with a person with a mental disorder impeding choice).
33.	An offence under section 31 of that Act (causing or inciting a person with a mental disorder to engage in sexual activity).
34.	An offence under section 34 of that Act (inducement, threat or deception to procure sexual activity with a person with a mental disorder).
35.	An offence under section 35 of that Act (causing a person with a mental disorder to engage in or agree to engage in sexual activity by inducement etc).
36.	An offence under section 47 of that Act (paying for sexual services of a child) against a person aged under 16.
37.	An offence under section 48 of that Act (causing or inciting child prostitution or pornography).
38.	An offence under section 49 of that Act (controlling a child prostitute or a child involved in pornography).
39.	An offence under section 50 of that Act (arranging or facilitating child prostitution or pornography).
40.	An offence under section 62 of that Act (committing an offence with intent to commit a sexual offence).
41.	An offence under section 5 of the Domestic Violence, Crime and Victims Act 2004 (causing or allowing the death of a child or vulnerable adult).
42.	An offence under section 5 of the Terrorism Act 2006 (preparation of terrorist acts).
43.	An offence under section 9 of that Act (making or possession of radioactive device or materials).
44.	An offence under section 10 of that Act (misuse of radioactive devices or material and misuse and damage of facilities).
45.	An offence under section 11 of that Act (terrorist threats relating to radioactive devices, materials or facilities).
46.	Any offence, not otherwise listed above, of: trafficking for sexual exploitation espionage terrorism (whether an offence under terrorism legislation or an offence which has a terrorist connection) dishonesty (theft, corruption, deception and fraud) tax or excise duty avoidance bribery proceeds of crime money laundering abuse and neglect of children
47.	Any of the following: an attempt to commit an offence specified in this Annex conspiracy to commit an offence specified in this Annex incitement to commit an offence specified in this Annex an offence under Part 2 of the Serious Crime Act 2007 of encouraging or assisting a crime where the offence (or one of the offences) in question is one that is specified in this Annex aiding, abetting, counselling or procuring the commission of an offence specified in this Annex

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About this guidance

Structure of the sponsor guidance

Main parts

Appendices

Route-specific guidance

Contacts

Version number and publication

Changes to this guidance

Glossary

Certificate of Sponsorship (CoS)

Cancellation of permission (formerly ‘curtailment of leave’), and derived terms

Compliance check

Compliance visit

Digital compliance inspection

Entry clearance

Global Business Mobility (GBM) route

Permission

Permission to enter

Permission to stay

Relevant offence

Settled worker

Settlement

UKVI

Visa national

We or Us

Working days

You or Your

L1. Sponsorship: an introduction

What is sponsorship?

Sponsoring workers in a personal capacity

Exception for private servants in a diplomatic household

Routes on which you can be licensed

Worker routes

Temporary Worker routes

L2. Sponsorship: your responsibilities

Guiding principles

Behaviour that is not conducive to the public good

Safeguarding children

Creative Workers below school-leaving age

Abuse of sponsorship arrangements

L3. How sponsor licensing works

Applying for your licence

Considering your application

Deciding your application

Maintaining your licence

L4. Key Personnel

Overview

If you’re applying under UK Expansion Worker

If you’re a ‘PB1 sponsor’ (Government Authorised Exchange)

General requirements for Key Personnel

Exception to residence requirement for UK Expansion Worker

Key Personnel from outside your organisation

UK-based representatives

If you outsource your human resources function

Agency staff

Insolvency practitioners

Checks we make on your personnel

Suitability requirements for Key Personnel

Key Personnel roles: eligibility and responsibilities

Authorising Officer

Key Contact

Level 1 User

What a Level 1 User does

Who can be a Level 1 User

Appointing additional Level 1 Users

Exceptions to the ‘settled worker’ requirement

Transitional arrangement for Level 1 Users of existing sponsors

Different requirements for UK Expansion Worker sponsors

Level 2 Users

Level 2 Users and sponsorship transformation (Sponsor UK)

Recording contact details of Key Personnel

L5. Organisations with multiple branches

Guiding principles

How you can apply if you have multiple branches

Employment agencies and third-party employment

Franchises

L6. Application process

How we use your information

Using a representative