· 10 min read
Reporting changes on the Sponsor Management System: what, when and how
Reporting is the sponsor duty that runs on a clock. Most of the work isn't hard. The hard part is noticing that something reportable has happened, and getting that information to the person with SMS access in time.
This guide covers what you must report on the sponsorship management system (SMS), the deadlines, and how to report. It's written for HR teams, Level 1 Users and Authorising Officers, and for immigration solicitors and advisers who manage SMS reporting for clients. It's based on Part 3 of the Home Office sponsor guidance (version valid from 28 August 2026) and isn't legal advice. (Part 3: sponsor duties and compliance) For the full set of sponsor duties, see our sponsor licence duties checklist for 2026.
The two main deadlines
Part 3 (para C1.13) sets two default time limits:
| What changed | Default deadline | Where it's set out |
|---|---|---|
| A sponsored worker's circumstances | Within 10 working days of the event | C1.13, C1.15 |
| Your organisation | Within 20 working days of the event or of you becoming aware of it | C1.13, C2.3 |
"Unless otherwise stated" matters. Some events have their own timing, covered below.
There's also a third category with no fixed number of days. As soon as reasonably practicable, you must tell the Home Office if you know or suspect a sponsored worker has breached their conditions of stay, and give the police any information suggesting a worker may be involved in terrorism or criminal activity (C1.14).
Worker changes you must report (10 working days)
According to C1.15, you must report the following.
1. The worker doesn't start within 28 days
If a sponsored worker doesn't start the role within 28 days, you must report it. Part 2 of the guidance (section S3) covers start dates and delays.
2. Unauthorised absence of more than 10 consecutive working days
This is the one that most often catches HR teams out, because the deadline starts from a point that's easy to misread. You must report it no later than 10 working days after the 10th day of absence, even if you plan to keep sponsoring the worker (C1.19). According to C1.20, the report should include:
- the date the absence started
- the date they came back, if they have
- if they haven't, your attempts to contact them
- any salary deductions for the absence
- whether you intend to continue sponsoring them
When you report an unauthorised absence or that you've stopped sponsoring someone, you must also give their last known address, phone number and any personal email addresses (C1.17).
3. Unpaid or reduced-pay leave of more than 4 weeks
You must report a worker who is absent without pay, or on reduced pay, for more than 4 weeks in total in any calendar year. Part 2 (section S4) sets out the exceptions.
4. Pay reductions
You must report any reduction in pay from the level on the CoS. You don't need to report increases, with one exception: a pre-registration nurse or midwife who has now completed registration (C1.15).
Since 8 April 2026, Sponsor a Skilled Worker also sets out pay-period tests. These include minimum totals over rolling 3-month, 12-week or 17-week periods, and you must confirm an irregular working pattern on the CoS or in a change of circumstances notification (SK7.20 to SK7.24). The guidance says pay is checked through compliance checks, HMRC checks, or both (SK7.19). (Sponsor a Skilled Worker)
5. Significant changes to the job
You must report a change of job title, core duties or a promotion, where it stays within the same occupation code and meets the conditions in Part 2 (S9.10). Changes that need a full change of employment application go through that route instead. Part 3 makes the stakes clear: a worker found in a role that doesn't match the occupation code or job description, without a permitted change, is a mandatory ground for revocation (C1.45).
6. A change of normal work location
You must report it when a worker's normal work location changes, including (C1.21, C1.24):
- moving to a branch or client site not already on their CoS
- becoming a contractual home worker who works entirely or almost entirely from home
You don't need to report a move to hybrid working (C1.23) or day-to-day changes, such as occasionally working from another site (C1.25). You must still keep records of working patterns.
7. You stop sponsoring the worker
C1.26 gives examples, including:
- the worker resigns, is dismissed or is made redundant
- their contract ends early
- a required professional registration is withdrawn
- they get settlement or move to a route that doesn't need sponsorship
- their visa application is refused, or permission is cancelled, once any review or appeal is finally decided
- they don't take up the post, or you withdraw the offer
- unpaid leave runs past 4 weeks without an exception applying
How to report worker changes
Unless the guidance says otherwise, use the "Report migrant activity" function in the SMS (C1.16). The step-by-step instructions are in SMS Manual 9: reporting worker activity.
Organisation changes you must report (20 working days)
C2.2 to C2.5 cover changes to your organisation. A Level 1 User reports most of them in the SMS, using "request changes to licence details" or "Manage Level 1 and 2 users". They include:
- replacing or amending details of your Authorising Officer or Key Contact
- adding or removing Level 1 Users. Level 2 Users are being phased out and could only be added before 9 September 2026 (C2.4)
- changes to your organisation's name, address, branches or head office
- structural changes, such as new branches, sites or linked UK entities
- losing a registration or accreditation you need in order to trade or to hold the licence
- stopping trading, or entering an insolvency procedure
- a merger, takeover or similar change. Part 3 section C4 also gives a 20 working day limit for these.
- a relevant criminal conviction of anyone covered by the definition of "you"
- a change to your organisation's size or charitable status, which can affect fees and the Immigration Skills Charge (C2.5)
- a substantial change in the nature of your business
Supporting documents: 5 working days
If the SMS produces a submission sheet, you must send the signed declaration and any supporting documents within 5 working days. If the Home Office asks for more, the same 5 day limit applies. Missing it means the request is refused, and the licence may be revoked (C2.19).
If nobody can log in
You must have at least one Level 1 User at all times (C2.16). If your only Level 1 User has left, you can't report through the SMS and must use the sponsor change of circumstances form instead (C2.15).
Why reports slip, and how to stop it
Late reports rarely come from not knowing the rules. More often, the information just doesn't reach the right person. Three fixes help:
- Map the triggers to their owners. Line managers know about absences. Payroll knows about pay cuts and unpaid leave. Facilities know about site moves. Each one needs a simple route to whoever reports on the SMS.
- Work out the deadline the moment you learn about the event. Count working days, not calendar days. For unauthorised absence, count from the 10th day of absence, not the first.
- Keep evidence of the report. Record what you reported, when and who did it, alongside the worker's file. That supports your record-keeping duties and gives a clear trail if anyone asks later.
For immigration solicitors and advisers
If you handle SMS reporting for clients, the deadline depends on how fast the client tells you. Build the reporting triggers into your client care letter or retainer: what the client must tell you, and how quickly. A monthly check-in on absences, pay changes and site moves catches events the client didn't realise were reportable.
How SponsorGuard helps
SponsorGuard doesn't connect to the SMS and never submits reports to the Home Office. The reporting decision and the submission stay with your authorised SMS users. Based on what's live on the product today, it helps by:
- tracking reportable events against the 10 and 20 working day windows, with overdue alerts
- flagging absences at the 4-week reportable threshold, from absence data you import or send through its API
- checking recorded salaries against the SOC going rate and the general threshold
- keeping imported CoS PDFs as a permanent, searchable history and reconciling them against your workforce, so changes are easier to spot
- giving solicitor and adviser firms a multi-client view of deadlines across all their sponsor clients
It's a tracking tool. It can't guarantee you'll never miss a report, and AI-assisted outputs always need review by an authorised person.
FAQ
How long do sponsors have to report changes on the SMS?
Usually 10 working days for changes to a sponsored worker's circumstances, and 20 working days for most changes to your organisation (Part 3, C1.13 and C2.3).
When do I report a sponsored worker who stops coming to work?
If they're absent without permission for more than 10 consecutive working days, report it no later than 10 working days after the 10th day of absence, even if you plan to keep sponsoring them (C1.19).
Do I need to report a pay rise for a sponsored worker?
Generally no. Only reductions must be reported. The exception is a pre-registration nurse or midwife who has completed registration (C1.15).
Do I need to report a move to hybrid working?
No. But you must report a change to the main work location, a new client site, or a move to working entirely from home (C1.21 to C1.25).
Which SMS function do I use to report worker changes?
Use "Report migrant activity", unless the guidance says otherwise. The Home Office's SMS Manual 9 explains how (C1.16).
What if our only Level 1 User has left?
You can't use the SMS. Use the sponsor change of circumstances form, and make sure a new Level 1 User is set up, because you must have one at all times (C2.15, C2.16).
Sources
- Home Office, Workers and Temporary Workers: guidance for sponsors Part 3, sponsor duties and compliance (version valid from 28 August 2026): https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
- Home Office, Sponsor a Skilled Worker (version 04/26, valid from 8 April 2026): https://www.gov.uk/government/publications/workers-and-temporary-workers-sponsor-a-skilled-worker
- Home Office, SMS Manual 9: reporting worker activity: https://www.gov.uk/government/publications/reporting-worker-activity-sms-guide-9
- Home Office, SMS Manual 2: manage your sponsorship licence: https://www.gov.uk/government/publications/manage-your-sponsorship-licence-sms-user-manual
Want reporting deadlines tracked for every sponsored worker? SponsorGuard is running an invite-only pilot for up to 8 sponsor employers and immigration firms. It lasts 30 days, opening in October 2026. Request access at sponsorguard.com.