How to Avoid Common Pitfalls in the UK Sponsor Management System: Compliance Tips for Employers

The UK Sponsor Management System (SMS) requires strict compliance from employers to avoid penalties such as fines, licence suspension, or revocation. Key pitfalls include failure to report changes, inadequate record-keeping, and improper use of Certificates of Sponsorship (CoS), all of which can be mitigated through structured HR policies, staff training, and digital record management.

Common Pitfalls and Compliance Strategies

One of the most frequent compliance failures is delayed or missing reporting of changes. Employers must report worker-related changes—such as role, salary, location, or absence exceeding four weeks—within 10 working days. Organisational changes, including shifts in company size, ownership, or key personnel, must be reported within 20 working days. Implementing automated reminders in HR software can help meet these deadlines consistently.

Inadequate record-keeping remains a leading cause of licence revocation. Sponsors are required to maintain comprehensive records for each sponsored worker, including job descriptions, payslips, right-to-work checks, and proof of qualifications, for the duration of employment plus one year. Integrating Appendix D requirements into HR information systems ensures documentation is collected proactively rather than reactively during audits.

Issuing Certificates of Sponsorship (CoS) for non-genuine or ineligible roles poses another significant risk. Roles must meet the required skill level (RQF Level 3 or above) and salary thresholds—£41,700 for Skilled Worker and £48,500 for Global Business Mobility Senior/Specialist roles. Employers should verify job details against Home Office criteria before CoS issuance to prevent non-compliance.

Right-to-work checks must be conducted online using share codes for all Biometric Residence Permit (BRP) holders, as physical BRPs are no longer valid. Employers must retain evidence of these checks, including the date and name of the person who performed them. Regular training for HR staff ensures ongoing compliance with updated digital verification processes.

Building a Compliant HR Framework

• Establishing clear HR sponsorship policies is critical for maintaining compliance. These should cover recordkeeping, CoS issuance procedures, right-to-work checks, and change reporting timelines. Policies must be easily accessible to all relevant staff and updated regularly to reflect changes in immigration law.
• Designating and training key personnel including the Authorising Officer, Key Contact, and Level 1 Users ensures accountability within the SMS. Background checks on key personnel help maintain organisational integrity, as any criminal record issues can lead to licence refusal or revocation.
• Conducting regular internal or mock audits with external immigration legal support helps identify compliance gaps before official Home Office audits. These audits should review CoS usage, record completeness, and adherence to reporting timelines, enabling proactive corrections.

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