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Significant changes made in relation to sponsoring workers and company sponsor licences

The Home Office published a number of significant changes to their guidance for work sponsors on 31 December 2024 and 1 January 2025.

Summary of key changes:

  • They have added to the list of people who fall within the definition of “you and your” when referring to the sponsor.
  • Significant changes have been made to rules regarding the key personnel a sponsor must have – these will affect new company sponsor licence applications and could present
    obstacles to some prospective sponsors.
  • New restrictions have been added to the guidance regarding sponsorship in a personal capacity – these mainly relate to the sponsorship of workers in private households (such
    as nannies).

The changes in more detail

“You and your” – who is a sponsor?

The guidance for sponsors is primarily an instruction manual explaining what current or prospective sponsors need to do. It sets out what “you” need to do to become a sponsor and
what “your” compliance obligations are once you become a sponsor.

Previously, when speaking to the sponsor as “you” or “your”, this included any:

  • owner;
  • director;
  • key licence personnel (the Authorising Officer, Key Contact and Level 1 Users);
  • person involved in the organisation’s day-to-day running.

A new addition has been made to include a “person recorded on your Companies House profile listing as a Person with Significant Control”.

This change means that advisers may need to ask additional questions of prospective sponsors and advise accordingly.

Key personnel eligibility

The guidance continues to require that key personnel be based in the UK and that they be a paid staff member or an office holder. As before, the guidance also requires that at least
one of the level 1 users be an employee, director or partner.

It also continues to require that at least one of the level 1 users on the licence be a “settled worker” (meaning to have either Indefinite Leave to Remain under the immigration
rules or Settled Status under the EU Settlement Scheme).

However, in a significant change, the guidance now requires that where the company sponsor licence is applied for after 31 December 2024, the sponsor must have at least one level 1
user who is both an employee, director or partner and a settled worker.

This change only applies to company sponsor licence applications made after 31 December 2024. The guidance confirms that if a company has a licence which was valid on or before this
date, they continue to benefit from the old rules where they needed a level 1 user who was an employee, director or partner and a level 1 user who was a settled worker, but these
requirements did not need to be met by the same person. However, in the future, Home Office may align these requirements so they recommend that sponsors appoint at least one level 1
user who can meet both requirements.

Sponsorship in a personal capacity

The guidance now confirms that company sponsor licences must not be used to employ or engage a worker “in a personal capacity”.

Two examples are given of when this may apply:

  • an individual person or household wishes to employ or engage a worker, or workers, in a personal capacity and the sponsor is not otherwise conducting business or providing a
    service in the UK
  • the worker, or workers, will be employed by, or engaged for the personal benefit of, an individual who works for the sponsoring organisation, or a close relative or partner
    of that individual, and the role is unrelated to the sponsor’s wider activities

For further advice and assistance with company sponsor licenses and work visas, or any other immigration matters, please contact our immigration team by emailing Robert Sookias at RobertSookias@cartercamerons.com.

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