Immigration update: Offshore Worker Reporting Requirement on the Sponsorship Management System

The previous position

Previously, as of the 12th of April 2023, a sponsor of an offshore worker needed to notify the Home Office when:

A sponsored worker first arrives at an offshore work location without entering the UK landmass, passing through immigration control and
They depart UK waters at the end of the job.

There used to be no provision to do this via the SMS, sponsors had to email a specific Home Office email address.

The updated position

The updated guidance (Manual 9 of the Sponsor Guidance) provides that the above can now be done via the SMS alone. In the SMS drop downs, the following options have been added:

“Sponsor continuing to sponsor migrant worker” has been added for first arrivals; and
“Sponsor has stopped sponsoring migrant worker” has been added for employees leaving UK waters.

The notification must be submitted to the SMS between the day of arrival-departure or 10 working days after arrival/departure.

There is no further information that needs to be recorded as a result of this update but, as a helpful reminder, the specific information needed includes:

The sponsor licence reference number
The Certificate of Sponsorship reference number of the offshore worker
The name, date of birth, and nationality of the offshore worker
The name of the ship or vessel the offshore worker will be based and
The date the offshore worker arrived, or left, UK waters.

A link to the updated guidance with useful example screenshots can be found here.

Practical implications for sponsors

We would recommend keeping a register for each sponsored employee and all their relevant details independently of the SMS. This would be updated and kept as an internal reference by the Key Personnel for sponsorship. We would also recommend training staff in the most recent update to remain compliant with the sponsorship notification requirements.

If you fail to comply with the above notification requirements then your sponsor licence may be revoked, permission to enter the UK may be cancelled, and any future applications to enter or stay in the UK may be refused. So, it is imperative that this is complied with and there is adequate training in place to make Key Personnel aware of the requirement changes and any necessary actions they may need to take.