Reporting

Sponsor licence reporting deadlines: the 10 and 20 working day rules explained

Changes affecting a sponsored worker must normally be reported through the Sponsorship Management System within 10 working days of the event, while changes to your organisation generally allow 20 working days.

Most sponsors know there is a reporting duty. Far fewer can say, without checking, which events start a clock, how many days they have, or when the count begins. That gap is where licences get downgraded — not through dishonesty, but because nobody noticed a deadline had already started running.

This guide sets out how the reporting windows work, which events fall into which window, and the events where a deadline is the wrong thing to focus on.

How many working days do you have to report a change?

Changes affecting a sponsored worker must normally be reported within 10 working days of the event. Changes to your organisation generally allow 20 working days.

That single distinction resolves most day-to-day questions. If the change is about a person you sponsor — their pay, role, location, absence or departure — assume 10 working days. If it is about the sponsor itself — its address, ownership, key personnel or structure — assume 20.

Both windows are counted in working days, and both are reported through the Sponsorship Management System (SMS).

What counts as a working day?

A working day excludes weekends and bank holidays in the relevant UK jurisdiction.

This matters more than it sounds. The same event, on the same date, can carry a different calendar deadline depending on whether the relevant jurisdiction is England and Wales, Scotland or Northern Ireland, because the bank holiday calendars differ. A change that occurs immediately before a long weekend gives you more calendar time than the raw "10 days" suggests — and a team that counts calendar days instead will either panic early or, worse, assume it has longer than it does.

If you want the exact date for a specific event, our reporting deadline calculator applies the working-day count and jurisdiction for you.

Which worker changes are reportable within 10 working days?

The reportable worker events fall into a short, knowable list. These are the ones that come up most:

| Worker event | Normal window | |---|---| | Worker stopped working or sponsorship ended | 10 working days | | Salary reduction | 10 working days | | Job title, role or duties changed | 10 working days | | Work location changed | 10 working days | | Working arrangements changed (hours or pattern) | 10 working days | | Unauthorised absence | 10 working days, once the threshold is met | | Unpaid or reduced-pay absence | 10 working days, once the threshold is met | | Worker did not start as expected | 10 working days, after the permitted start-delay period |

Note the difference in the final three rows. Most events run from the date the thing happened. Absence and non-start events run from the point a threshold is crossed, which is a different calculation entirely.

Which organisation changes are reportable within 20 working days?

Organisation changes are the ones sponsors forget, because they are handled by people who do not think of themselves as part of the compliance function — finance moves the registered office, HR appoints a new Authorising Officer, and nobody tells the Level 1 User.

| Organisation event | Normal window | |---|---| | Registered address changed | 20 working days | | New branch or location | 20 working days | | Key personnel changed | 20 working days | | Nature of business changed | 20 working days | | Organisation stopped trading | 20 working days | | Other organisation change | 20 working days |

A key personnel change is the single most commonly missed item on this list. If your Authorising Officer leaves the business and the licence still names them, the Home Office is holding a record that no longer describes your organisation.

When does the reporting clock actually start?

There are three different triggers, and confusing them is the most common source of missed deadlines.

1. From the date of the event. Most changes work this way. A salary reduction effective 1 June starts the clock on 1 June, regardless of when payroll noticed.
2. After a threshold is crossed. A worker who does not start as expected has a permitted start-delay period of 28 calendar days; the 10 working days begin when that period ends, not on the original CoS start date. Unpaid or reduced-pay absence works similarly, with its own threshold.
3. Once a condition is established. Unauthorised absence becomes reportable once the absence reaches the relevant threshold and you have established it is genuinely unauthorised rather than an unexplained gap you have not yet investigated.

The practical consequence: for threshold-based events, the clock is already running before anyone in the business has decided the situation is a problem.

Which changes need more than a report?

Some events are not really deadline questions at all, and treating them as a 20-working-day SMS task is a mistake.

• Mergers, takeovers and ownership changes. These can affect whether the licence remains valid at all, and may require a fresh application or a specific notification process rather than a routine report.
• Insolvency. This may require urgent Home Office contact rather than waiting out a reporting window.
• A significant change of role. A change of job title or duties is reportable, but if the role has moved far enough it may need a change-of-employment process rather than an SMS report. Filing a report and assuming the matter is closed can leave a worker sponsored for a job they no longer do.

For all of these, the right first step is a review of the licence implications — not a countdown.

What evidence should you keep alongside the report?

Filing the report is half the duty. Being able to show what you filed, when, and on what basis is the other half.

For each reportable event, keep the records that establish the facts you reported:

• Salary changes: payroll records, the contract variation and the salary assessment you relied on.
• Role changes: the updated job description and a comparison against the Certificate of Sponsorship.
• Location changes: the new work address, contract variation and internal approval.
• Absence: attendance records, manager notifications and investigation notes.
• Key personnel: appointment records, SMS confirmation and governance approval.
• Sponsorship ending: employment-ending records, the final payslip and related correspondence.

A compliance officer asking about a change from eighteen months ago is not testing your memory. They are testing whether the evidence still exists and still supports what you told the Home Office.

What happens if you miss a reporting deadline?

A missed report is a breach of your sponsor duties, and the consequences scale with the pattern rather than the single event.

An isolated late report, self-identified and corrected, is a very different picture from a series of unreported changes discovered during a compliance visit. The latter suggests the reporting duty is not being managed at all, which is what leads to a B-rating and an action plan, suspension, or in serious cases revocation.

The distinction officers draw is between a sponsor who has a system that occasionally slips and a sponsor who has no system.

How to stop missing them

The structural problem is that reportable events do not arrive labelled as reportable events. They arrive as a payroll adjustment, a promotion, an office move or a resignation — normal business activity, handled by people who are not thinking about the sponsor licence.

Three things reliably help:

1. Put the trigger where the change happens. Reporting duties should be attached to payroll and HR processes, not to a monthly compliance review that runs after the deadline has passed.
2. Count in working days automatically. Manual counting across three bank holiday calendars is where errors concentrate.
3. Keep the evidence at the point of filing, not when someone asks for it.

Sponsoro does this continuously: it watches for the changes that start a clock, applies the working-day count for the right jurisdiction, tells your team what needs filing and keeps the audit trail behind every report. See how reporting and deadlines work, or read how Sponsoro handles every sponsor licence duty in one place.