If you want to employ a person who’s not a ‘settled’ worker, or who doesn’t otherwise have immigration permission to work in the UK, you’ll need to hold a sponsor licence.  

This is authorisation by the Home Office to employ migrant workers. Employers don’t require a sponsor licence to employ certain categories of person, such as Irish citizens, those with settled or pre-settled status under the EU Settlement Scheme or those with indefinite leave to enter – or remain in – the UK.  

What are the specific obligations?

Let’s take a closer look at the specific obligations of those employers who are licence holders. 

It’s estimated that, as of October 2025, there are approximately 122,596 sponsor licence holders in the UK and this number is on the rise. Unsurprisingly, with the increase in licence holders, we’re seeing a surge in enforcement activity by the Home Office to ensure that those employers are complying with the Immigration Rules.  

Should a sponsor licence holder be found to have flouted the rules, there are very serious consequences, not only for their sponsor licence but also their pocket. At present, an initial breach of the rules will result in a fine of £45,000 per illegal worker, increasing to £60,000 after that. As such, it’s important that sponsor licence holders are aware of their duties. 

As you may know, a sponsor licence allows the holder to tap into a wider recruitment pool by enabling them to employ skilled individuals from across the globe. The Home Office sees this position as a privilege and one that requires a high level of responsibility. Accordingly, they expect holders to play their part in preventing illegal working in the UK. 

To this end, licence holders have two vital duties: recording and reporting. These two duties are expected to be exercised along with the wider obligations of complying with UK law and the Immigration Rules, as well as acting in good faith and co-operating with the Home Office.  

The Recording Duty 

All holders must have robust HR systems in place to be a licence holder and this is to ensure that they’re able to record and maintain accurate records of those migrant workers in their employ. This includes keeping accurate records of the worker’s home address, contact details, salary and role. 

The Reporting Duty 

This places an obligation on holders to tell the Home Office of any changes to the worker’s or holder’s circumstances within a set time-frame. This is done through the Sponsor Management System to which each licence holder has access. Should the worker’s hours, pay or role change, the holder is required to notify the Home Office within 10 working days. Equally, should the worker be dismissed, quit or go AWOL, the holder must also report this to the Home Office within the same timescale. This is important as, if an individual is found to be in breach of their visa conditions, their visa may be cut short. In this way, the licence holder plays a vital part in the policing of sponsored employees and ensuring compliance within the wider UK Immigration sphere. 

In addition to the financial penalties applicable where a holder fails to comply with their duties (which are set out in detail in the Government’s Worker and Temporary Workers Guidance for Sponsors document), there are potentially very serious repercussions for the holder’s licence as well. 

If a holder is deemed to have committed a serious breach, the Home Office may decide to suspend or even revoke the licence. 

In the case of suspension, the holder will be unable to issue certificates of sponsorship to workers whilst the Home Office investigate an alleged breach of their duties. The holder will need to respond to the allegations put forward by the Home Office and only if that response is accepted will the suspension be lifted. 

Revocation, as you can imagine, is saved for the most serious breaches. In this case, the holder loses the right to sponsor workers. The effect of this is far-reaching as it could lead to the Home Office cancelling or shortening the visas of the sponsored workers employed by the holder. The Home Office can also ban the holder from applying for another licence for 12-24 months or even longer. 

As such, it’s vital that licence holders comply with their obligations to avoid falling foul of UK law and the Immigration Rules