Sponsor Obligations: What Employers and Educators Must Do

If you employ or educate people who need permission to work or study in the UK, your sponsor licence carries ongoing duties that you must meet for as long as you hold it. The core obligations are set out in the Home Office’s Workers and Temporary Workers guidance and its appendices: you must keep records, report certain events through the sponsorship management system (SMS), and comply with the codes of practice for your sector. The same principles apply to student sponsors under the separate student sponsor guidance. In New Zealand, the parallel obligation falls on immigration advisers: any advice on immigration matters must come from a licensed immigration adviser or someone exempt from licensing, and Immigration New Zealand will refuse or decline an application if the adviser named in it is neither licensed nor exempt.

What a sponsor licence actually requires

A sponsor licence is not a one-off permission. It is a continuing permission with conditions attached, and the Home Office expects you to read all parts of the guidance to understand your duties and responsibilities as a licensed sponsor. The collection page for sponsorship guidance groups the relevant material into four main areas: policy guidance, the sponsorship management system user manuals, codes of practice, and the register of licensed sponsors.

The most important documents for understanding your obligations are the route-specific guidance and the appendices. Appendix A tells you the documents you must submit to support your sponsor licence application. Appendix B lists the immigration offences the Home Office will take into account when considering your suitability to hold a sponsor licence. Appendix D sets out your record-keeping duties as a licensed sponsor. You should read all parts of the guidance, but if you are new to sponsorship, the Home Office suggests reading the relevant route-specific guidance first.

Record-keeping duties

Appendix D of the Workers and Temporary Workers guidance is the document that tells you about your record-keeping duties as a licensed sponsor. The Home Office publishes this appendix separately, and it is updated periodically — the version currently listed was last updated on 3 August 2026. You should check that appendix directly for the full list of records you must keep, because the requirements differ by route and by whether you are sponsoring a worker or a student.

The key point is that record-keeping is not optional. It is a condition of your licence, and failure to keep the required records can put your licence at risk. The appendix also explains how long you must keep records and what happens if you cannot produce them when asked.

Reporting duties through the SMS

As a licensed sponsor, you must use the sponsorship management system to report activity relating to the people you sponsor. The user manuals cover this in detail. SMS manual 9 covers reporting worker activity, SMS manual 5 covers reporting student activity, and SMS manual 8 covers creating and assigning a certificate of sponsorship (CoS). SMS manual 4 covers creating and assigning a confirmation of acceptance for studies (CAS).

If you are a worker sponsor, you must report when a sponsored worker stops working for you, when their circumstances change, and other specified events. The exact events you must report are set out in the route-specific guidance and in SMS manual 9. If you are a student sponsor, the equivalent duties are in the student sponsor guidance and SMS manual 5. You should also be aware that multi-factor authentication is now part of the SMS — SMS manual 13, published on 1 September 2026, covers this requirement.

Compliance and priority services

The Home Office offers priority services for sponsors in certain circumstances, and these are separate from your ongoing obligations. There is a pre-licence priority service guidance document, a Worker and Temporary Worker priority service request form, and a Study post licence priority service. There is also a priority change of circumstances service for sponsors, with separate guidance for study sponsors and for workers and temporary workers.

These services are not obligations. They are optional routes to faster processing. Your obligations are the ones set out in the guidance parts 1 to 3: apply for a licence, sponsor a worker, and sponsor duties and compliance. Part 3 is the document that deals specifically with sponsor duties and compliance, and it is the one to read if you want a single overview of what you must do after you are licensed.

How the Home Office checks compliance

The Home Office can check your compliance in several ways. Appendix B lists immigration offences that will be taken into account when considering your suitability to hold a sponsor licence. Appendix C covers civil penalties and sponsorship. These appendices are part of the same collection and should be read alongside the main guidance.

The register of licensed sponsors is published separately for workers and for students, and it is updated regularly. The current versions were published on 3 September 2026. If you want to check whether an employer or education provider is licensed, this register is the place to look.

New Zealand: obligations on advisers, not sponsors

If your application involves New Zealand, the obligations sit in a different place. Immigration New Zealand requires that any immigration advice you receive must come from a licensed immigration adviser (LIA) or a person who is exempt from being licensed. Anyone can help you fill in a visa application form, but advice — information or assistance tailored to your individual needs and situation — must come from an approved source.

The Immigration Advisers Authority (IAA) is responsible for licensing immigration advisers and regulating the advice they give. Before you ask an adviser to help you, you should check the IAA register to confirm the person has a current licence and the right type of licence. Licensed immigration advisers must meet competency standards and follow a Code of Conduct set by the IAA.

The consequences of using an unlicensed adviser are severe. If an adviser named in an application does not appear on the register of immigration advisers and is not exempt, INZ will refuse to accept or will decline the application. INZ will also contact the IAA, because providing immigration advice when neither licensed nor exempt is an offence.

Who is exempt from licensing in New Zealand

Some people do not need a licence to give immigration advice because of their job or responsibility. Outside New Zealand, this includes education agents who are permitted to give immigration advice about student visas, employees of the New Zealand Government who provide immigration advice as part of their job, and foreign diplomats and consular staff. Inside New Zealand, it includes lawyers with a current certificate to practise, Members of Parliament and their staff, government employees, and volunteers at Community Law and the Citizens Advice Bureau.

If you are using a lawyer, the New Zealand Law Society website can help you find a lawyer or legal firm, or check that your existing lawyer has a current certificate to practise.

What INZ will share with your adviser or lawyer

If you have a licensed immigration adviser or a lawyer representing you, they can ask INZ for information about you and your visas. They can do this by calling the Customer Service Centre or by sending the Privacy Team a written request. Before they are given any information, they must confirm that they are representing you and that their professional details are listed on the Advisers Authority or Law Society websites.

The information INZ can share includes details of the visa you currently hold, applications you have completed, your previous visas, the processing of any current applications, medical examinations you have had, police certificates you have provided, your travel movements, verbatim copies of file notes, and contact details for INZ staff dealing with your application.

What to do next

If you are a UK sponsor or are applying for a sponsor licence, read the Workers and Temporary Workers guidance parts 1 to 3, plus Appendix D for record-keeping. If you sponsor students, read the student sponsor guidance. Check the register of licensed sponsors if you want to confirm a sponsor’s status. If you are applying for a New Zealand visa and someone is advising you, check the IAA register before you engage them, and confirm whether they are licensed or exempt.

Verify the current versions of the guidance on the official pages, because the Home Office updates these documents regularly — the collection page was last updated on 28 August 2026. The New Zealand requirements are set out on the Immigration New Zealand website, and the IAA website holds the register and the Code of Conduct.