UK Employers: Sponsor Licence Renewals to Begin

by Morgan Lewis

[authors: Tracy Evlogidis, Nicholas J. Hobson and Gemma Goodhead]

Companies have 120 days from the time of a notification to renew their sponsor licence.

With the four-year anniversary of the launch of Tier 2 of the UK's Points-Based System approaching, employers that sponsor non-EU workers under Tier 2 may start to receive email notifications from the UK Border Agency (the UKBA) that they can soon apply to renew their Tier 2 sponsor licence. Notifications are issued by email 120 days before expiration. A large amount of current Tier 2 sponsor licences will expire the day before the four-year anniversary, on 27 November 2012.

Sponsor Licence Renewal

In order to apply to renew a Tier 2 licence, the sponsor must first ensure that they maintained HR records and implemented processes in accordance with the sponsorship duties. They must also ensure the information contained on the sponsor licence via the sponsorship management system (the SMS) (see below) is up to date, including details of the Authorising Officer and Level 1 User. The Level 1 User must then submit an online application and pay an application fee. The Authorising Officer is required to sign a declaration that the sponsor has and will continue to satisfy the sponsorship duties. The application must be submitted prior to the expiry of the current Tier 2 licence. Once the sponsorship licence renewal application has been submitted, the sponsor may then receive a compliance visit from an Immigration Officer or a request for further documentation and information.

Sponsorship Management System

As of 30 July, sponsors are now able to use the SMS to submit their sponsor licence renewal applications and to track the progress of the application as well as the progress and results of requests to amend sponsor licence details, including the appointment of a Key Contact and an Authorising Officer, the appointment of an additional Level 1 User (where there is one or more existing Level 1 Users), and the change of a sponsor's name and/or address. In these cases, sponsors will no longer be notified by email or letter when requests to change sponsor details have been granted; rather, the status of these requests will be posted on the SMS.

If the request is rejected, the UKBA will continue to provide reasons for the refusal or rejection by email to the sponsor's Authorising Officer (emails will be sent from a "no-reply" email address).

Further, sponsors will continue to receive email notification of the approval of certain requests from the UKBA where any of the following occur:

  • Sponsors request a new Level 1 User where the only other existing Level 1 User has been de-activated or has left the company.
  • Sponsors request a change to their organisation details as a result of a merger or takeover.
  • Sponsors request any other change to their sponsor details, such as the addition of a branch or appointment of a representative to act on their behalf.
  • The change was submitted using a Change of Circumstances paper form.


Employers should ensure that change notifications are submitted within the prescribed time limits (which vary depending on the type of notification being submitted) and should track the processing of the notification via the SMS. If a notification is rejected, and an email confirming the reason for the rejection is received, employers should ensure that the notification is resubmitted immediately (and the reason for the rejection is correctly addressed). Failure to notify the UKBA of changes to the sponsor licence within the prescribed time limits is a breach of the sponsorship duties and the terms of the sponsorship licence. Breaches of the sponsorship duties can cause the licence to be withdrawn or suspended by the UKBA.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morgan Lewis | Attorney Advertising

Written by:

Morgan Lewis

Morgan Lewis on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.


JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at:

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.