On March 6th 2026, the Home Office has released updated sponsor guidance for UK employers, introducing several changes that sponsor licence holders should be aware of.
The updates affect record keeping duties, reporting obligations, right to work responsibilities, and how Certificates of Sponsorship are managed within the sponsorship system.
While some of the changes are technical clarifications, others signal a stronger focus on compliance and oversight of licensed sponsors.
Below is a summary of the key updates and what they mean for organisations that sponsor overseas workers:
New record keeping requirement on employment rights information
Section 5(l) of the Workers and Temporary Workers: guidance for sponsors – Appendix D record keeping duties has been updated to introduce a new requirement.
Sponsors must now retain evidence that they have provided sponsored workers with information about their employment rights in the UK.
Examples of acceptable evidence may include:
- Written information provided to workers about their employment rights
- References to employment rights within employment contracts
- Records of training or awareness sessions provided to sponsored workers
This requirement is linked to section L2 of Part 1 of the sponsor licence application guidance.
Sponsors should ensure that this information is clearly documented and that evidence is retained as part of their compliance records.
Updated wording on sponsor licence status and Home Office discretion
Section L2.2 of the Apply for a Licence guidance has also been updated.
The guidance now explicitly states that participation in the sponsorship system is voluntary and that membership is subject to strict terms contained within the sponsor guidance.
It also reiterates that:
- The granting of a sponsor licence is at the discretion of the Home Office
- The Home Office may refuse an application or revoke an existing licence if it has reasonable concerns about a sponsor’s suitability
- A sponsor licence does not create a property right or other enforceable entitlement
This wording reinforces that sponsor licences are granted at the discretion of the Home Office, and it increases the risk of licences being refused or revoked where the Home Office suspects non-compliance. For sponsors, this raises the importance of maintaining strong compliance processes and accurate records at all times.
Clarification on eligible roles for sponsorship
The updated guidance provides further clarification on how eligible roles are defined for sponsorship.
Sponsors are now directed to a new glossary document which sets out the definition of an eligible role and the criteria that must be met when assigning a Certificate of Sponsorship.
Employers should ensure that roles being sponsored clearly meet the eligibility requirements set out in this glossary.
Accuracy of job descriptions on Certificates of Sponsorship
The guidance places greater emphasis on the importance of accurate job descriptions when assigning a Certificate of Sponsorship.
The role described on the CoS must reflect the actual job that the worker will perform.
If the role changes after immigration permission has been granted, sponsors must consider whether:
- A new immigration application is required, or
- The change must be reported through the Sponsor Management System
Where reporting is required, the change must be recorded on the SMS within 10 working days. Failure to report changes may lead to compliance action from the Home Office.
Right to Work responsibilities in third party arrangements
The updated guidance clarifies that Right to Work obligations may still apply even when the sponsor is not the direct employer of the worker.
This is particularly relevant for organisations operating through:
- Contract based arrangements
- Labour supply chains
- Third party working arrangements
Sponsors should carefully review their Right to Work procedures where sponsored workers are deployed to client sites or engaged through complex contractual structures.
Clarification on CoS status within the Sponsor Management System
The guidance also includes a useful technical clarification regarding the status of Certificates of Sponsorship within the Sponsor Management System.
A Certificate of Sponsorship will now show as “Used” only once a decision has been made on the associated immigration application, rather than when the application is submitted.
This clarification may help sponsors better track the status of CoS allocations within the system.
What these changes mean for sponsors
These updates reinforce the Home Office’s continued focus on compliance, reporting accuracy, and sponsor oversight.
Employers that sponsor overseas workers should review their internal processes to ensure that they:
- Maintain clear documentation of employment rights information provided to workers
- Accurately record job roles on Certificates of Sponsorship
- Report role changes promptly through the SMS
- Understand their Right to Work obligations in third party arrangements
Ensuring that these processes are properly documented will help reduce the risk of compliance action and protect sponsor licence status.
Need help reviewing your sponsor compliance processes?
The UK sponsorship system continues to evolve, and staying compliant with sponsor guidance is essential for organisations employing international talent.
If you would like support reviewing your sponsor compliance processes or understanding how these updates may affect your organisation, get in touch with the team at Centuro Global.
