Sponsor Licence Reportable Events: The 10 and 20 Working Day Rules Explained

Reporting is one of the four duties every sponsor takes on, alongside record keeping, monitoring and complying with the law. It is also the duty most often missed, not because sponsors ignore it, but because the trigger happens in one part of the business and the person with SMS access is in another.

All references below are to Part 3 of the Home Office sponsor guidance, version 08/26.

The two headline deadlines

• Changes about a sponsored worker: unless stated otherwise, report within 10 working days of the relevant event.
• Changes about your business: generally report no later than 20 working days after you became aware of the change.

Reports are made in the Sponsor Management System using the "Report migrant activity" function for worker events, and through your Level 1 User for business changes.

Worker events in detail

The worker does not start

If a sponsored worker does not start the role within 28 days of the expected start, report it within 10 working days.

Unauthorised absence

This is the one most often counted wrongly. The trigger is absence without your permission for more than 10 consecutive working days, and the report is due no later than 10 working days after the 10th day of absence. You must report it even if you intend to keep sponsoring the worker. The guidance also asks for the worker's last known address, phone number and personal email.

Absence without pay

Report if a sponsored worker is absent without pay, or on reduced pay, for more than 4 weeks in total in any calendar year, unless one of the exceptions set out in the guidance applies.

Pay reductions

Report if a worker's salary or pay is reduced from the level stated on their Certificate of Sponsorship (CoS). Salary increases generally do not need reporting.

Role changes

If a worker's role changes in a way that does not need a new application, report it within 10 working days of the change. A role that no longer matches the occupation code or job description on the CoS is a mandatory ground for revocation, so treat role drift seriously.

Work location

Report a move to a branch or client site that is not on the CoS, or to permanent or full-time remote working. Hybrid working and day-to-day changes of location do not need reporting.

You stop sponsoring the worker

Report when sponsorship ends for any reason: resignation, dismissal, redundancy, the contract ending early, loss of a required professional registration, refusal or cancellation of permission, or the worker settling.

Business changes in detail

Changes your Level 1 User must report include:

• Replacing or amending the Authorising Officer or Key Contact
• Adding or removing Level 1 Users (keep at least one at all times)
• Changes to your address, contact details or head office
• Changes to your organisation structure, such as branches and sites
• Changes to registrations or accreditations you need to trade
• Stopping trading, insolvency, administration, liquidation or a company voluntary arrangement
• Mergers, takeovers and changes of ownership, including TUPE transfers

Most of these carry the 20 working day deadline. Where the Home Office asks for supporting documents after you report a change, send them within 5 working days.

How to count working days

Working days exclude weekends and public holidays. Two practical rules prevent most mistakes:

1. Start the clock on the right date: the date of the event for most worker changes, the 10th day of absence for unauthorised absence, and the date you became aware for most business changes.
2. Count bank holidays out. A report due over Christmas or Easter lands later in the calendar than it looks, but only if you count correctly.

Making it routine

• Make the HR, rota and payroll teams responsible for flagging changes, and the SMS user responsible for reporting them.
• Keep a reporting log: event, date of the event, deadline, date reported, SMS reference.
• Treat late reports as late: record them honestly rather than leaving them unrecorded.

How ProRota helps

Available in ProRota today: attendance from GPS clock-in and clock-out, leave and absence records, right to work records and visa expiry monitoring. These are the data most worker events start from.

Sponsor Licence Readiness detects reportable events from that data, such as consecutive missed working days, pay or hours reductions, rostered sites that are not on the CoS, and leavers. It counts the deadline in working days with bank holidays excluded, and records the SMS reference once you have reported. ProRota never logs into the SMS itself.