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UK Updates Sponsor Duties and Compliance Guidance for Workers and Temporary Workers Routes

🇬🇧 United KingdomEmployer Sponsorship1 recorded versionLast change 28 Aug 2026
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Current rules

The updated guidance introduces changes to how sponsors manage their sponsorship licences and comply with the Home Office's administrative requirements. Sponsors must continue to keep their sponsorship systems active and properly managed, while the Home Office is introducing new requirements around SMS access, inactive accounts and user roles. The Level 2 User role is being phased out as part of the wider changes to the Sponsorship Management System. Sponsors will no longer be able to appoint new Level 2 Users from 9 September 2026, and the role is scheduled to be abolished after 8 March 2027. Sponsors therefore need to make sure that they have appropriate alternative SMS users who can continue carrying out sponsorship responsibilities. The guidance also introduces clearer arrangements for inactive sponsor licences and inactive SMS user accounts. Sponsors that no longer need their licence are encouraged to surrender it rather than retain an unused licence indefinitely. The Home Office has also clarified how inactive SMS users can affect sponsor compliance and enforcement. Sponsors should therefore ensure that their SMS users remain active and that there are enough authorised people able to manage the organisation's sponsorship responsibilities. The updated guidance also reflects the introduction of mandatory multi-factor authentication (MFA) for SMS users. MFA is scheduled to become mandatory from 3 September 2026, meaning sponsor users will need to complete an additional authentication step when accessing the Sponsorship Management System. This is intended to strengthen the security of sponsor accounts and reduce the risk of unauthorised access. The guidance also updates sponsors' right-to-work compliance responsibilities ahead of changes applying to certain employment arrangements beginning on or after 1 October 2026. Employers should therefore review their right-to-work checking procedures before that date to ensure that they are using the correct process for the workers they employ. The existing sponsor duties remain in place. Sponsors must continue reporting relevant changes involving sponsored workers, maintaining required records, monitoring sponsored employment and complying with UK immigration and wider legal requirements. Where a sponsor fails to meet these duties, the Home Office can take enforcement action, including reducing its Certificate of Sponsorship allocation, setting the allocation to zero, downgrading or suspending its licence, or ultimately revoking the licence.

Overview

On 28 August 2026, UK Visas and Immigration (UKVI) released an updated version (08/26) of the guidance for sponsors, specifically 'Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance'. This new publication replaces the previous version (05/26) and details the obligations and compliance requirements for organisations that hold a sponsor licence under the Worker and Temporary Worker immigration routes in the UK. Sponsors must now adhere to the latest instructions to ensure they meet their duties and avoid breaching immigration rules.

Who is affected by the latest change

  • UK employers holding Worker sponsor licences
  • UK employers holding Temporary Worker sponsor licences
  • Organisations applying for or keeping sponsor licences
  • Authorising Officers
  • Key Contacts
  • Sponsorship Management System (SMS) Users
  • Employers sponsoring Skilled Workers
  • Employers sponsoring Global Business Mobility workers
  • Employers sponsoring Temporary Workers
  • Sponsors employing workers under other Worker and Temporary Worker routes
  • Employers responsible for right-to-work checks

What changed in the latest version

Before

Sponsors already had to do certain things: * report changes about sponsored workers; * report changes to their organisation; * keep specific records; * obey immigration law; * obey wider UK law; * make sure sponsored workers are employed as their sponsorship states; and * work with the Home Office during checks for compliance. Sponsors usually have 10 working days to report relevant changes about sponsored workers. They have 20 working days to report specific organisation changes. This applies unless a different deadline is given. The previous version of the guide was 05/26. It was published on 20 May 2026.

After

The updated guide changes how sponsors manage their sponsorship licences. It also changes how they meet the Home Office's administrative rules. Sponsors must keep their sponsorship systems active and well-managed. The Home Office is adding new rules for access to the Sponsorship Management System (SMS), inactive accounts, and user roles. The Level 2 User role is being removed. This is part of bigger changes to the Sponsorship Management System. Sponsors will not be able to name new Level 2 Users from 9 September 2026. This role is planned to end after 8 March 2027. Sponsors therefore need to make sure they have other suitable SMS users. These users must be able to continue doing sponsorship duties. The guide also sets out clearer rules for inactive sponsor licences and inactive SMS user accounts. Sponsors who no longer need their licence are asked to give it up. They should not keep an unused licence for a long time. The Home Office has also made it clear how inactive SMS users can affect sponsor compliance and enforcement. Sponsors should therefore make sure their SMS users stay active. They should also make sure there are enough authorised people to manage the organisation's sponsorship duties. The updated guide also includes the new rule for mandatory multi-factor authentication (MFA) for SMS users. MFA is planned to become mandatory from 3 September 2026. This means sponsor users will need to complete an extra step to prove their identity when they access the Sponsorship Management System. This aims to make sponsor accounts more secure. It will also reduce the risk of someone getting unauthorised access. The guide also updates sponsors' duties for right-to-work checks. This is because of changes to certain employment arrangements starting on or after 1 October 2026. Employers should therefore check their right-to-work checking procedures before that date. They must make sure they are using the correct process for the workers they employ. The current sponsor duties still apply. Sponsors must continue to report relevant changes about sponsored workers. They must also keep required records, check sponsored employment, and obey UK immigration and wider legal rules. If a sponsor does not meet these duties, the Home Office can take action. This includes reducing its Certificate of Sponsorship allocation. It can also set the allocation to zero. It can lower or suspend its licence, or in the end, take away the licence.

These changes will have important practical effects for UK sponsor licence holders and sponsored workers. The rule stopping employers from passing fees to workers will create new financial duties for employers. This will affect their costs for sponsoring Skilled Workers. The ban on personal sponsorship makes it clear who can be a sponsor. It could stop people from misusing the system. Mandatory multi-factor authentication adds a new security rule for all Sponsorship Management System (SMS) Users. They will need to change how they access the system. Inactive sponsors are now asked to give up their licences. This will make administrative tasks simpler. It could also affect their ability to sponsor in the future if they become active again.

Explained simply

Imagine you're managing a club, and you have rules about how members behave. The government has just updated its rulebook for businesses that sponsor overseas workers. This update adds an easy-to-read online version of the rules and says that from 3 September 2026, everyone who logs into the sponsor system must use a special two-step security check (like when you get a code to your phone after entering your password). They're also changing how some older types of user accounts work and suggesting that businesses that no longer sponsor workers should tell the government so their licence can be retired. It's all about making the rules clearer and the system safer.

Frequently asked

Version history

  1. v1Effective 28 Aug 2026EffectiveHigh impact
    UK Updates Sponsor Duties and Compliance Guidance for Workers and Temporary Workers Routes

    UK Visas and Immigration (UKVI) has published the latest version of its guide, 'Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance'. This is version 08/26. It became active on 28 August 2026. This updated guide makes several important changes for licensed sponsors. Employers must not pass Skilled Worker sponsor licence fees or Certificate of Sponsorship fees to sponsored workers by the end of 2024. Employers must also not sponsor workers in a personal way. The guide also explains how Level 2 Users will stop being used. It details that all users of the Sponsor Management System (SMS) must use multi-factor authentication from 3 September 2026. It also asks inactive sponsors to give up their licences.

Timeline

  1. Announced

    28 Aug 2026

    On 28 August 2026, UK Visas and Immigration (UKVI) released an updated version (08/26) of the guidance for sponsors, specifically 'Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance'. This new publication replaces the previous version (05/26) and details the obligations and compliance requirements for organisations that hold a sponsor licence under the Worke

  2. Takes effect

    28 Aug 2026

    The guidance for sponsors on sponsor duties and compliance has been updated to version 08/26, replacing version 05/26. This version reflects changes concerning the prohibition of passing Skilled Worker sponsor licence or Certificate of Sponsorship fees to sponsored workers by the end of 2024 and the prohibition of sponsors sponsoring workers in a personal capacity. It also includes clarifications

Other routes in this country

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