Sponsor Change of Circumstances Form UK – Complete Guide 2025

Managing a sponsor licence in the UK comes with strict legal duties. One of the most important is reporting any changes about your business or your sponsored workers to the Home Office. While most updates are made through the Sponsorship Management System (SMS), in certain cases you may need to complete the Sponsor Change of Circumstances Form instead.

If you miss a deadline or use the wrong method, you could face penalties ranging from a licence downgrade to full revocation. In this guide, we explain when the form is required, what changes you must report, how to use the form, and what happens if you fail to comply.

What is the Sponsor Change of Circumstances Form?

The Sponsor Change of Circumstances Form is a document provided by the Home Office that lets UK sponsor licence holders report certain changes when they don’t have SMS access. It is not a replacement for the SMS. Instead, it covers only a handful of situations where online access isn’t available.

You would normally use the form if:

• You need to add a new Level 1 User but have none currently in place.
• You are replacing your Authorising Officer and they are also the sole Level 1 User.
• You want to surrender your sponsor licence.
• You wish to request licence dormancy.

For all other changes, sponsors must continue to use the SMS. Using the form incorrectly could mean missing your reporting deadline, putting your licence at risk.

When Must Sponsors Report Changes to the Home Office?

UK sponsor licence holders have a legal duty to keep their licence information up to date. This duty applies both to changes affecting the business and to changes affecting sponsored workers.

Reporting Deadlines

• Organisational changes: within 20 working days.
• Sponsored worker changes: within 10 working days.

Failing to meet these deadlines is treated as a compliance breach. Even minor oversights can lead to an investigation by UKVI.

Organisational Changes You Must Report

Employers must notify the Home Office of organisational changes such as:

• Change of company name, registered address, or branch details.
• Change of Authorising Officer (AO), Key Contact (KC), or Level 1 User.
• Structural changes including mergers, takeovers, or insolvency.
• Addition of new sites or linked entities.
• Loss of a required registration or accreditation.
• Change in size or charitable status affecting licence fees.
• If the business stops trading.
• Relevant criminal convictions of directors, key personnel, or owners.

Example: If your company moves its head office and you forget to update the SMS within 20 working days, the Home Office could downgrade your licence.

Sponsored Worker Changes You Must Report

Employers must also update UKVI about changes relating to sponsored workers. These include:

• A worker not starting their role within 28 days of the agreed start date.
• A worker being absent without permission for more than 10 working days.
• Salary or working hours being reduced.
• Significant changes in job role or duties.
• Change in work location or moving to remote work.
• A worker leaving employment earlier than expected.

How to Use the Sponsor Change of Circumstances Form

When SMS access is unavailable, the Sponsor Change of Circumstances Form must be completed and emailed to sponsors@homeoffice.gov.uk.

Key points to note:

• Only specific changes can be submitted this way.
• Processing can take up to 18 weeks.
• Sponsors must provide supporting documents where required.

If you are near the deadline and do not have SMS access, using the form is the only option to stay compliant.

Priority Service for Faster Processing

The Home Office offers a Priority Change of Circumstances Service for certain requests.

• Cost: £200 per request.
• Processing time: usually 5 working days.
• Eligible requests: adding or changing a Level 1 User, changing AO or Key Contact, updating organisation address.
• Ineligible requests: defined CoS requests, some Temporary Worker routes (such as Seasonal Worker).

Slots are limited to 100 per day, and demand is high. If your request is not accepted, you may need to try again the following day.

Penalties for Failing to Report Sponsor Licence Changes

The Home Office takes sponsor compliance extremely seriously. If you fail to report changes on time or at all, the penalties can be severe.

Common Challenges Sponsors Face

Many employers struggle with reporting duties, not because they want to avoid compliance, but because:

• HR teams are not always told about changes in time.
• The SMS is difficult to use and not user-friendly.
• Staff are unsure which changes must be reported.
• Day-to-day operations take priority over immigration compliance.

Unfortunately, the Home Office will not accept these as excuses. Having clear systems, training, and legal guidance in place is the safest way to protect your licence.

How Deluxe Law Chambers Can Help

At Deluxe Law Chambers, we support UK employers with every aspect of sponsor licence management. Whether you need advice on using the Sponsor Change of Circumstances Form, reporting deadlines, or handling a compliance investigation, our solicitors provide clear and practical guidance.

We can help you:

• Understand which changes must be reported and when.
• Use the correct reporting method (SMS or form).
• Prepare supporting documents for UKVI.
• Challenge unfair decisions if your licence is downgraded or suspended.
• Put systems in place to reduce compliance risks.

Call us today on 0161 464 4140 or book an appointment online to get professional advice tailored to your business.

FAQs on Sponsor Change of Circumstances Form

What is the Sponsor Change of Circumstances Form used for? 

It is used in limited situations where you don’t have SMS access, such as adding a Level 1 User, replacing an AO who is also the only Level 1 User, surrendering a licence, or requesting dormancy.

When must sponsors report changes? 

Most organisational changes must be reported within 20 working days, and most worker-related changes within 10 working days.

How long does processing take? 

Standard processing can take up to 18 weeks. The priority service (if eligible) aims to complete requests within 5 working days.

Is there a fee? 

Standard service is free. The priority service costs £200 per request.

What happens if I fail to report changes? 

You risk licence downgrade, suspension, or revocation, which could impact your ability to employ overseas workers.

Can multiple changes be reported at once? 

Yes, but each change must be clearly listed and supported with documents.

Do mergers or acquisitions require a new licence? 

In some cases, yes. Major structural changes often require a fresh sponsor licence.

Managing a sponsor licence is not just about hiring overseas workers. It is about ongoing compliance and taking responsibility for every change in your business and workforce.

The Sponsor Change of Circumstances Form is only required in limited situations, but understanding when and how to use it is essential. Missing deadlines or reporting incorrectly could put your entire licence at risk.For immediate advice and support with your sponsor licence duties, call Deluxe Law Chambers on 0161 464 4140 or book an appointment here.