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Reporting a Change of Circumstance

How to update employee or business details in Borderless to stay compliant and keep your records accurate.

Written by Tom Hext

How to Start

Go to Cases in the sidebar and select the Changes of Circumstance tab. Click Create to start a new change and select whether the change is for an employee or business.

Borderless can now also flag some employee changes for you automatically. When you mark a sponsored worker as a leaver, or change their salary or weekly hours, the platform prompts you to report the change straight away with the details pre-filled, and attaches the 10 working day reporting deadline. If you choose Report later, the change stays visible in Halo under Changes to report so nothing slips through. See What's new: Halo and tracked changes to report for details.

Business Changes

A business Change of Circumstance refers to any significant update to your organisation's details that the Home Office must be informed of via the SMS. These changes typically include:

  • Change of address (head office or any branches)

  • Change of ownership or company structure (e.g. mergers, takeovers)

  • Change in Authorising Officer, Key Contact or Level 1 user

  • Addition or removal of a branch or site

  • Closure of a business location or branch

  • Insolvency, administration or liquidation events

These changes must be reported within 20 working days of taking effect to stay compliant with sponsor duties.

Employee Changes

An Employee Change of Circumstance refers to any significant update to a sponsored worker's employment or immigration status that must be reported to the Home Office via the SMS. These typically include:

  • Termination of employment (including resignation, dismissal, redundancy)

  • Change of job title or role (within the same SOC code)

  • Change in work location (to a new site or branch)

  • Change in salary or working hours (including pay rises or pay increases affecting the annual salary)

  • Unexplained absence (10+ consecutive working days without contact)

  • Switch to part-time or different work pattern

  • Long-term absence (e.g. maternity/paternity leave, sick leave)

  • Employee no longer sponsored (e.g. switching visa routes or leaving the UK)

  • Change of immigration status (if no longer requires sponsorship)

When to report a salary increase: If a worker receives a pay rise, you must report this as a change of circumstance to ensure the Home Office records are updated. The new annual salary should exceed the current CoS salary threshold for the role. Report the change within 10 working days of the increase taking effect.

These changes should be reported within 10 working days of the change taking place. Terminations and salary or hours changes made on the platform are flagged automatically and show their deadline in Halo under Changes to report.

Correcting an Error on a CoS (for example the salary)

If the salary recorded on an assigned CoS does not match the worker's contract or the amount actually being paid, treat this as a priority. A mismatch between the CoS salary and the contract has led to workers being questioned by Immigration Enforcement at the border, so it should not be left unaddressed.

Report the correct salary to the Home Office as a Change of Circumstance, stating the correct figure and the applicable salary threshold for the role, and give the worker a copy of the notification for their records. Where the pay being received is below the CoS rate or the going rate for the role, correct the pay as well and keep evidence of the correction. As with other changes, start this from Cases, then the Changes of Circumstance tab, and our immigration team will submit it to the Home Office on your behalf.

Reduced or unpaid pay periods (and when a flagged payslip means you must report)

If a payslip is flagged because a worker was paid less than their CoS salary for a temporary reason, resolving the flag in Borderless and reporting the change to the Home Office are two separate things. Clearing a flag does not report anything.

As a general rule, you must report to the Home Office if a sponsored worker is absent without pay, or on reduced pay, for more than 4 weeks in total in any calendar year (1 January to 31 December). This can be one continuous period or several shorter ones added together.

Statutory leave is treated differently. Absences on statutory maternity, paternity, shared parental, neonatal care or parental leave are exceptions and do not usually trigger this reporting requirement, even where they run beyond 4 weeks. If you are unsure whether a specific reduced-pay period needs reporting, check the GOV.UK guidance below or ask your CSM before dismissing it.

Report a reportable change within 10 working days of it taking effect. Reduced-pay reasons that commonly need reporting include unpaid leave and agreed temporary reductions in pay or hours.

Submit and Track

Once your Change of Circumstance has been submitted, our immigration team will review the details and then submit it to the Home Office on your behalf. You can monitor its progress at any time in Cases under the Changes of Circumstance tab, and flagged and submitted employee changes also appear in Halo under Changes to report.

Video Guide Tutorial

For a walkthrough of the Changes of Circumstance process, please see the tutorial video in the Borderless platform Help section.

If Borderless Is Not Yet a Level 1 User on Your Licence

Borderless can only submit changes of circumstance once we have been added as a Level 1 user on your Sponsor Management System (SMS). Until that is in place the reporting duty stays with you, and the ten working day deadline still runs. Report the change directly on your own SMS rather than waiting for us to do it.

If you see the message "Borderless cannot report a change of circumstance until we are added as an L1 user on this sponsor licence", that is what it means. Log the change on your SMS now, and complete the Sponsor Licence integration steps on Borderless so we can take this over for future reports.

Representative Access and Level 1 Access Are Not the Same

These are two separate permissions, and having one does not give us the other.

  • Representative. Lets us correspond with the Home Office about your licence.

  • Level 1 user. Gives us SMS access to assign CoS and submit changes on your behalf.

Adding us as a representative is the step before adding us as a Level 1 user. To check where you are, log in to your SMS and open "Manage Level 1 or 2 users". If Borderless is not listed there, we are not a Level 1 user yet, even if the representative step is complete.

Once you have added us as a Level 1 user, the Home Office issues Borderless a separate SMS password before we can act. There is a short wait for that, and we request it as soon as the Level 1 user is added. You keep your own Level 1 access throughout, and a licence can have more than one Level 1 user.

Speeding Up Level 1 Access With the Priority Service

The Home Office runs a priority service for sponsor licence changes at £350 per request. Eligible requests are normally considered within five working days of payment being received. Adding a new Level 1 user is on the eligible list, alongside additional and annual CoS allocation requests, replacing or amending the authorising officer or key contact, adding a representative, and updating your premises.

If a reporting deadline or a CoS assignment is being held up by Level 1 access, speak to your Borderless contact about whether a priority request is worthwhile in your case.

Need help or an update? Open the Support tab at the bottom right of your screen to contact our team directly.

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