Overview of the Sponsor Management
Effective sponsor management is essential for any UK business that holds a Sponsor Licence. Once a licence has been granted, the organisation must continue to manage its sponsorship responsibilities and maintain appropriate systems for sponsored workers.
The Home Office uses the Sponsorship Management System (SMS) as the main online system through which sponsors manage sponsorship activities.
Businesses should ensure that the people responsible for sponsorship understand their roles and that internal HR procedures support the organisation’s immigration obligations.
What Is Sponsor Management?
Sponsor management involves the day-to-day administration of a business’s Sponsor Licence and sponsored workers.
This can include:
- Managing Certificates of Sponsorship
- Maintaining worker records
- Monitoring sponsored employees
- Reporting changes to UKVI
- Managing SMS users
- Updating business information
- Monitoring compliance
- Managing sponsorship allocations
Good sponsor management helps ensure that the information held by the business, the Home Office and the worker remains accurate.
Sponsorship Management System
The Sponsorship Management System is used by authorised personnel to undertake various sponsorship activities.
A business must control access to the system carefully. Users should only have the access they need and should understand their responsibilities.
Where a person responsible for sponsorship leaves the organisation or is no longer suitable to perform the role, the business should take appropriate steps to update or remove their access.
Key Personnel
Sponsors are required to appoint key personnel to manage sponsorship.
The principal roles are:
Authorising Officer
The Authorising Officer is a senior and competent person responsible for the actions of staff and representatives who use the SMS.
Key Contact
The Key Contact is the main point of contact between the business and UKVI.
Level 1 User
The Level 1 User is responsible for the day-to-day management of the Sponsor Licence using the SMS.
These roles can be filled by the same person or different people, depending on the organisation’s circumstances.
Managing Certificates of Sponsorship
Businesses use the sponsorship system to manage Certificates of Sponsorship.
A Certificate of Sponsorship contains important information about the worker and the job.
The business should ensure that the information provided is accurate and reflects the genuine employment arrangement.
Before assigning sponsorship, employers should check matters such as:
- The occupation
- Job duties
- Salary
- Work location
- Start date
- Working arrangements
- Eligibility of the worker
Monitoring Sponsored Employees
Sponsor management also involves monitoring sponsored workers after they start employment.
Employers should have HR systems that allow them to monitor:
- Immigration status
- Attendance
- Contact details
- Right to work documentation
- Employment information
- Relevant changes
UKVI expects sponsors to maintain appropriate systems for monitoring their sponsored workers.
Managing Changes
Employment arrangements can change over time.
For example, a business may want to change an employee’s:
- Job role
- Duties
- Salary
- Work location
- Working arrangements
Not every change requires an immigration application, but some changes can affect sponsorship and may need to be reported or require the worker to update their immigration permission.
Employers should therefore obtain advice before making significant changes to sponsored employment.
Managing Business Changes
The business itself may also change.
Mergers, acquisitions, restructuring, insolvency, changes to ownership and changes involving connected overseas businesses can create sponsorship considerations.
Sponsors have reporting obligations concerning certain significant business changes, and these should be dealt with within the relevant Home Office timescales.
Internal Sponsor Procedures
Businesses should ideally have written procedures covering sponsorship.
These can explain:
- Who manages the Sponsor Licence
- Who has SMS access
- How sponsored workers are monitored
- How absences are recorded
- How changes are reported
- Where sponsorship records are kept
- Who reviews immigration documents
- How HR and management communicate about immigration matters
Clear procedures can help prevent important reporting deadlines or compliance responsibilities from being overlooked.
Sponsor Licence Changes
Businesses may need to update their Sponsor Licence information when circumstances change.
This can include changes to business details, key personnel and other information relevant to the organisation’s sponsorship arrangements.
Keeping the licence information accurate is part of effective sponsor management.
How We Can Help
SWM Solicitors can advise businesses on the practical and legal aspects of sponsor management.
We can assist with key personnel, Sponsorship Management System issues, Certificates of Sponsorship, sponsored worker changes, business changes and ongoing compliance.
Effective sponsor management is not simply an administrative task. It is an important part of maintaining the organisation’s ability to sponsor workers in the UK.