Sponsor licence duties for care providers: reporting, records and the 2025 visa changes

Sponsored workers have kept many care homes and home care services staffed through years of vacancies. Keeping the sponsor licence that makes it possible depends on the unglamorous part: reporting changes on time and keeping the right records for every worker. A missed report can lead to a downgrade, and a revoked licence affects every sponsored worker you employ.

This guide summarises the Home Office sponsor guidance as it stands in October 2026. The guidance changes often, so check the current version on GOV.UK before acting.

What changed for care in 2025

From 22 July 2025, care worker (occupation code 6135) and senior care worker (6136) roles closed to new recruitment from overseas. Applicants in those roles must already be in the UK and be applying for permission to stay. Under the Sponsor a Skilled Worker guidance, a worker can be sponsored in these roles if either:

• they have worked legally for you in the role for at least three months (this route is open to applications made no later than 22 July 2028); or
• they were last granted Skilled Worker permission in these occupation codes and have held continuous permission since.

Other points for care sponsors:

• Registration. In England, to sponsor in these roles you must be carrying out a regulated activity and hold active CQC registration. In Wales, Scotland and Northern Ireland the guidance says you must be registered with the regulator for that part of the UK: Care Inspectorate Wales, the Care Inspectorate or RQIA. The licence can be revoked if registration lapses.
• Salary. Care workers and senior care workers on the Health and Care visa must be paid at least £25,000 a year and at least £12.82 for each hour worked (guidance version 04/26).
• The care worker recruitment requirement has been removed. Considering displaced workers through a regional care partnership is now optional.
• Other roles. The closure covers occupation codes 6135 and 6136 only. Roles such as registered nurses follow the normal Skilled Worker rules.

The same duties in every UK nation

Sponsorship is run by the Home Office, so the reporting duties, record keeping, salary rules and right to work checks in this guide are the same whether your home is in England, Wales, Scotland or Northern Ireland. What differs is the care side around them: the regulator you must be registered with, the workforce register your sponsored care workers must join (Social Care Wales, the SSSC or NISCC; there's no register for care workers in England) and the criminal record check (DBS in England and Wales, PVG in Scotland, AccessNI in Northern Ireland). Nurses need NMC registration everywhere.

Reporting duties: the 10 working day rule

Part 3 of the sponsor guidance (version 08/26) says changes about a sponsored worker must be reported through the sponsor management system (SMS) within 10 working days of the event. The main ones:

Reports go through the "Report migrant activity" function in the SMS.

Why the rota matters

Two of these are rota problems in disguise. Unauthorised absence is counted in working days, so you need to know which days someone was rota'd and didn't turn up. Hours and pay can quietly drop below the certificate if a sponsored care worker is given fewer shifts in a quiet month. Watch both week by week, not at the end of the quarter.

Record keeping (Appendix D)

Appendix D (version 10/26) lists the documents you must keep for each sponsored worker, for the whole period you sponsor them. You can destroy them one year after the date sponsorship ended (or sooner if a compliance officer has approved it). They include, among others:

• evidence of the right to work check;
• recruitment records showing how you filled the role (adverts, applicants, selection notes);
• evidence of salary, such as payslips and the contract or written statement of particulars;
• evidence of skill level, such as the job description, qualifications and any professional registration (for example a nurse's NMC registration);
• National Insurance number, a history of contact details, a DBS check where required, and a record of absences.

You must be able to produce them on request, and Part 3 says compliance visits can be announced or unannounced.

Right to work: for everyone, not just sponsored staff

You must check that every job applicant is allowed to work for you in the UK before they start, using the Home Office online service with the applicant's share code where they have one. If permission is time-limited, check again before it expires.

The civil penalty is up to £60,000 per illegal worker. The code of practice in force from 1 October 2026 sets a starting point of £45,000 per worker for a first breach and £60,000 for a repeat breach within three years, and also brings in some arrangements that aren't direct employment.

Right to work is an immigration law duty. CQC's Schedule 3 pre-employment checks (identity, enhanced DBS, conduct in previous care work, employment history and so on) are separate and also apply in England; Wales, Scotland and Northern Ireland have their own equivalents under their care regulations.

What happens if you get it wrong

The Home Office can:

• reduce your allocation of certificates of sponsorship;
• downgrade your licence to a B-rating, with an action plan of up to three months during which you can't assign new certificates;
• suspend the licence while it investigates;
• revoke the licence. There is no appeal, and you usually have to wait at least 12 months to reapply.

A monthly sponsor compliance check

• Every sponsored worker's visa expiry date known, with renewal plans started early.
• Right to work follow-up checks booked before time-limited permission expires.
• Rota hours and pay for each sponsored worker at or above their certificate of sponsorship.
• Any absence of more than a few days without permission tracked in working days.
• Any change in job, hours, pay or location reported within 10 working days.
• Leavers reported within 10 working days.
• Appendix D documents in each worker's file.
• The people named on your sponsor licence and SMS users still correct.

How ShiftComplete helps

ShiftComplete for care doesn't report to the Home Office for you, but it keeps the dates and the rota in one place:

• The staff compliance file holds right to work (document type, check date, expiry) and visa and sponsorship dates for each worker, visible only to managers with permission, with expiry warnings.
• The rota warns you if you put someone on whose right to work or visa has lapsed.
• Every published rota is kept, giving you a dated record of who was rota'd on which days, which is what you need to count absences in working days.
• Everything is named, timestamped and kept, so you can show a compliance officer what happened and when.

It costs £2.49 per active staff member per month with no minimum or contract, and the first 60 days are free with no card needed. See it for residential care on our care homes page, or for nursing homes, where sponsored nurses are common, on our nursing homes page. For staffing nursing shifts, read our nursing home rota guide.