Approval is only the beginning. Sponsors must carry out proper right to work checks, keep the records required by the sponsor guidance, monitor sponsored workers, report certain worker-related changes within ten working days and report significant business changes within twenty working days. The Home Office can inspect the sponsor at any stage and can compare Sponsor Management System activity against payroll, contracts, attendance records and other evidence.
This is why a sponsor licence should be treated as a live risk and governance issue inside the business. If ownership changes, branches move, jobs change, salaries change or key personnel leave, the licence position may also need attention.
Important 2026 sponsor compliance updates (reviewed 10 October 2026): The Home Office is rolling out mandatory multi-factor authentication (MFA) for Sponsorship Management System (SMS) users on a phased basis from 3 September 2026, with all sponsors expected to have it enabled by November 2026. New Level 2 Users cannot be appointed from 9 September 2026; existing Level 2 Users must be upgraded to Level 1 where eligible or deactivated by 8 March 2027. Sponsors must keep SMS user details active and up to date. From 1 October 2026, the Right to Work Scheme also covers certain additional working arrangements, including some worker contracts, individual sub-contractors and online matching services. Check the current sponsor guidance and the final Right to Work employer guide for the requirements that apply to your arrangement.