International recruitment is central to workforce planning. Employers rely on overseas talent to fill skills gaps and to drive growth across global markets. In the UK, access to international talent is controlled through the sponsorship system, which governs how organisations recruit and manage non-UK workers. For employers with global mobility programmes, understanding and managing sponsorship obligations is vital to long-term compliance and workforce efficiency.
This guide explains the sponsorship system from an employer perspective, covering sponsor licence applications, ongoing compliance, the role of Certificates of Sponsorship, and the wider impact on global mobility.
The UK Sponsorship System Explained
The sponsorship framework sits within the UK’s points-based immigration system. Employers cannot hire most overseas nationals without holding a sponsor licence (sometime referred to as a ‘PBS licence‘ under the old points-based rules). Once approved, the organisation is added to the official UK sponsor list, often referred to as the Register of Licensed Sponsors UK. Jobseekers also search for a list of companies that can sponsor visa in UK before deciding where to apply.
Applications are submitted online through the Home Office portal (which is different to the UK visa application login system), and employers must follow the detailed Home Office sponsor guidance.
For mobility managers, sponsorship is more than a visa process. It is a compliance regime that links into tax, employment law and corporate governance, making it a critical to responsible global workforce management.
Sponsor Licence Application and Categories
Employers must apply for sponsor licence status before they can lawfully employ most overseas staff. Applications must be supported by documents listed in Appendix A to prove trading status and demonstrate that HR and compliance systems are robust enough to meet immigration requirements.
The most widely used category is the skilled worker sponsor licence. High-growth firms may qualify for a scale up sponsor licence, while overseas companies looking to establish a UK base can use the UK expansion worker sponsor licence.
While third party or umbrella company visa sponsorship UK arrangements exist in practice, they attract Home Office scrutiny and often breach guidance if used improperly.
The process involves significant costs. Employers must pay the sponsor licence application fee, and, where applicable, the immigration skills charge for each Skilled Worker they recruit. Some businesses consider alternatives such as the self sponsorship visa UK route, but where a company holds the licence, the compliance burden falls directly on the employer.
Employers often ask how long does it take to get a sponsorship licence in UK. Standard processing times run into several weeks, although the sponsor licence application priority service offers a faster turnaround for urgent recruitment needs.
Employers may also come across references to the Tier 2 sponsor list, a legacy term that still appears in some contexts.
Certificates of Sponsorship
Once licensed, employers can assign a Certificate of Sponsorship (CoS) to an eligible worker. The certificate is an electronic record that confirms the role details and the employer’s sponsorship. Without a valid CoS, a Skilled Worker visa application cannot proceed.
Employers are given an annual allocation of undefined CoS and can also apply for defined CoS where the role requires it. In urgent cases, businesses may need to use the CoS allocation priority service to secure certificates quickly. Mismanagement of allocations or errors in issuing CoS are among the most common compliance breaches.
All sponsorship activity is managed through the sponsor management system. Access is controlled by SMS login and limited to nominated staff such as the authorising officer. To reduce the risk of mistakes, employers should ensure users receive formal training such as SMS level 1 & 2 user training.
Employers must also be able to provide their sponsor licence number when required. Applicants may ask for confirmation that a sponsor licence application is valid and approved before accepting a role. Transparency in this process helps reassure candidates and avoids disputes later in the recruitment cycle.
Compliance and Enforcement
Compliance sits at the heart of the UK sponsorship regime. A licence is granted on the condition that employers meet strict duties designed to protect the immigration system. Although licences are typically valid for ten years, meaning there is no longer as sponsor licence renewal requirement, the licence must remain compliant at all times.
Failure to meet these duties exposes organisations to enforcement action, reputational damage and disruption to their workforce.
Record-keeping duties
Employers must retain specific documents for each sponsored worker, such as passports, biometric residence permits, right to work evidence, contracts of employment, payslips and current contact details. Where relevant, copies of professional qualifications or accreditations must also be held. All records must be stored in line with Appendix A and be available for inspection at any time.
Reporting duties
Certain events must be reported through the sponsor management system, often within 10 working days. These include a worker’s resignation, unauthorised absence of more than 10 consecutive working days, or changes to job title, salary, duties or work location. Structural changes within the organisation, such as mergers, acquisitions or new sites, must also be reported using the sponsor change of circumstances form.
Monitoring duties
Sponsors must track attendance, monitor that workers are performing their sponsored role and confirm they are paid the salary recorded on the Certificate of Sponsorship. Employers are also expected to conduct ongoing right to work checks, ensuring the individual continues to hold valid permission.
Wider compliance duties
Organisations must comply with wider legal obligations, including employment law and tax law. Sponsored workers must not be exploited, underpaid or employed in non-compliant roles. The rules on sponsor duties and compliance and wider sponsor licence compliance guidance are designed to ensure fair treatment and safeguard the integrity of the sponsorship system.
Cooperation with UKVI
Employers must cooperate with the Home Office and allow access to premises and records during a UKVI compliance visit. Visits can be announced or unannounced, and officers will expect to see that HR systems are being followed consistently.
Consequences of non-compliance
Where duties are not met, sanctions range from being sponsor licence downgraded to a B-rating, to full sponsor licence suspension or revocation. Employers may also be placed on the revoked sponsor licence list or the Tier 2 sponsor licence suspended list. In some cases, applications are sponsor licence refused.
Sponsored employees are also directly affected. Many ask can my sponsor cancel my visa in UK; if employment ends, the employer must report this to UKVI, which usually results in visa curtailment.
Maintaining assurance
Employers can use tools such as the daily licence checker to monitor their status and identify issues early. Building internal controls and embedding them across HR, payroll and mobility teams is the best way to demonstrate readiness for audits and reduce the risk of enforcement.
Sponsorship and Global Mobility
A well-managed licence is the engine of a compliant mobility programme. The global mobility sponsor licence enables lawful intra-group moves, but immigration controls have to align with payroll, tax and HR operations. When processes diverge, projects stall and risk rises. Mobility leaders should own the policy, with HR, finance and legal each accountable for their part of the control framework.
External advisers can add value by stress-testing systems and keeping you current on rule changes. Use experienced sponsor licence solicitors or a sponsor licence lawyer to review documentation, escalation routes and SMS use. Ultimate accountability remains with the employer, so knowledge must be retained in-house and reflected in policy and training.
Licence health depends on the people who run it. Appoint capable individuals into the key personnel sponsor licence roles and define cover for absence. Build a single source of truth for sponsored workers, CoS allocations and reporting history so audits can be satisfied quickly.
Other practical measures for compliance include:
Governance and planning
Embed sponsorship obligations into HR policy and workflows so managers understand when to involve mobility. Maintain a live diary for reporting events, CoS allocations and review points. When time pressures threaten delivery, use targeted services such as the post licence priority service guidance to expedite decisions while keeping documentation complete and consistent.
People, training and systems
Train all SMS users and line managers on the rules that govern the wider sponsorship visa UK landscape and your organisation’s approach to sponsorship. Align HR and payroll data with SMS entries to avoid discrepancies on job title, location or salary. Run periodic file checks against your policy and the sponsor guidance to catch issues early.
Operational controls
Require written statements of purpose for each trip or assignment and map activities to permitted rules. Mandate escalation where work falls outside visitor or sponsored scope. Keep invitation letters, itineraries, right to work evidence and funding confirmations together in an audit-ready pack. Use dashboards to track day counts, visa expiry and CoS usage so managers can adjust plans before risk thresholds are reached.
Conclusion
Sponsorship underpins fast and lawful access to international talent. Treat the licence as a live compliance asset, owned by trained people and supported by clear processes. Keep records aligned with the SMS, plan for pressure points with priority services and integrate immigration controls with HR and finance. That approach delivers a mobility programme that is quick, compliant and resilient, supporting growth while standing up to scrutiny.
Author
Anne Morris is the founder and Managing Director of DavidsonMorris. A highly experienced lawyer, she is recognised by Chambers & Partners and the Legal 500 UK as a trusted adviser to multinationals, large corporates and SMEs, delivering strategic immigration and global mobility advice. Anne is also an active commentator on UK immigration and employment law matters.
- Anne Morrishttps://www.hrhype.co.uk/author/anne-morris/
- Anne Morrishttps://www.hrhype.co.uk/author/anne-morris/