Earlier this year we explained some of the changes that were taking place on the sponsor management system (‘SMS’) here. Further changes are being introduced and while they are relatively minor, it is important to stay compliant and we explain more in this post.
From the 8th of October 2023, when replacing an Authorising Officer or Key Contact on the SMS or amending their details, their national insurance number must be inputted into the system. If they do not have a national insurance number, they must be prepared to explain why and provide supporting evidence. This mirrors the change made in July 2023 for Level 1 users.
If the correct information is not inputted, it could lead to the request being rejected.
All key personnel can choose to voluntarily input their national insurance numbers into the SMS even if they are not updating their details or being replaced, but this is not compulsory.
From the 8th of October 2023, sponsors are being asked to input their Companies House reference number (if they have one) into the SMS. The idea behind this is to enable the Home Office to check sponsor details when considering requests. This appears to be part of the Home Office’s overall agenda to streamline the sponsor management process and system. Level 1 users can add Companies House reference numbers by using the ‘amend your organisation’s details’ function. The Home Office has not given a deadline for when this information should be inputted, but sponsors are encouraged to do it at their earliest convenience.
These changes are relevant for businesses who hold a sponsor licence. The requirement to add Companies House reference numbers applies to all sponsors who are registered with Companies House (such as limited companies). The requirement to add national insurance numbers is relevant to all sponsors, but only compulsory for those who are replacing their key personnel, or changing current details.
Sponsor compliance is an important aspect of having a sponsor licence. The Home Office views having a licence as a privilege, not a right, and sponsors are expected to be aware of their record keeping and reporting duties and comply with them for the lifetime of their licence. While these are relatively minor housekeeping points, sponsors must update their details in line with these requests to demonstrate to the Home Office that they know what their responsibilities are, and that they are proactively taking steps to meet them.
For more details on the full range of sponsor duties and responsibilities, get in touch with our team of expert immigration lawyers.