What is a sponsor licence?
A sponsor licence is a permission granted by the Home Office that allows an organisation to employ overseas workers on the Skilled Worker route. It is always tied to a specific legal entity, one Companies House registration number. A sponsor licence cannot be transferred between organisations.
Licence structure and branches
A single sponsor licence can cover multiple sites or branches of the same legal entity. Where a business operates from several locations, these can be added as branches under the same licence. Workers at any branch are sponsored under the single licence held by the legal entity.
What happens when ownership changes?
When a business is acquired, merged, or undergoes a significant change in ownership or control structure, the existing sponsor licence does not automatically transfer to the new entity. The correct approach depends on the circumstances:
If the existing legal entity remains unchanged (e.g. shares are sold but the company remains the same), the licence continues and the change must be reported to the Home Office within 20 working days
If a new legal entity becomes the employer (e.g. a new holding company or a restructured group), a new sponsor licence application must be submitted for that entity before it can sponsor workers
Selling a business that holds a sponsor licence
A sponsor licence is tied to the legal entity that holds it. When the business is sold to a different legal entity, three steps run in parallel.
First, the change of ownership must be reported on the Sponsor Management System within 20 working days of the sale completing. This is a hard deadline.
Second, the new owner must apply for their own sponsor licence. The existing licence cannot transfer to the new owner because it is tied to the previous licence holder.
Third, sponsored workers currently employed by the business must be transferred onto the new owner's sponsor licence once that licence is approved. Until the transfer is in place, the workers' sponsorship situation needs careful handling and Borderless should be involved before completion.
A change in ownership is treated as triggering a new licence requirement only where there is a change in persons with significant control. This means a change in any shareholder considered a majority owner, or in cases where ownership is split, a change in either of the controlling shareholders. Internal director changes that do not change significant control do not require a new licence application but do still need to be reported on the SMS.
TUPE transfers, and when a new CoS is not needed
Where workers transfer to a new employer under TUPE (Transfer of Undertakings, Protection of Employment), the new employer must hold its own sponsor licence in the relevant route in order to continue sponsoring those workers. The licence itself does not transfer.
A new Certificate of Sponsorship (CoS) is not always needed. Sponsor guidance Part 3, paragraph C4.10, sets a narrower position than assigning a new CoS as a matter of course. Workers who change employer under TUPE or similar protection do not need to make a new application for permission, and the new sponsor does not have to assign a new CoS, provided both of the following apply:
The new sponsor holds a valid sponsor licence in the relevant route and has confirmed through its SMS account that it accepts responsibility for the worker.
The worker's duties remain unchanged.
From the date of the transfer the new sponsor takes full responsibility for the worker and must meet all the associated sponsor duties.
If the new employer does not already hold the right licence, it must apply within 20 working days of the move taking place. If it does not, the transferred workers' permission is cancelled. Where duties do change on transfer, or the conditions above are not met, a new CoS and a new application will be needed, so raise it with Borderless before the transfer completes.
Unallocated CoS do not transfer to a new licence
Certificate of Sponsorship allocations are tied to the specific licence they were granted under. If a licence is replaced or stops being used, any unallocated CoS on the old licence do not transfer to the new one. To obtain CoS on a new licence you must submit a fresh CoS allocation request against that licence.
Unused licences: there is no dormant status
A sponsor licence has no dormant setting. The requirement to renew every four years was removed on 6 April 2024, so a licence you stop using stays live indefinitely until you surrender it or the Home Office revokes it, and every sponsor duty continues while it is live.
Version 08/26 of the guidance states that the register of licensed sponsors is intended for organisations actively using their licence, and invites sponsors who are not sponsoring anyone to surrender. Before you do, weigh the cost: once the Home Office accepts a surrender you cannot re-apply for 12 months, or 24 months if your licence has been revoked on more than one occasion. If you expect to sponsor again inside a year, keeping the licence and meeting your duties is usually the better option. Speak to Borderless before surrendering.
Reporting ownership changes on the SMS
Changes in ownership or control must be reported via the SMS using the "Request any other change to your licence details" option. A detailed explanation of the change should be provided in the free text field. The Home Office will review and update the licence record accordingly.
Sponsor licence fees from 8 April 2026
Worker sponsor licence (small sponsor): £611 (up from £574)
Worker sponsor licence (large sponsor): £1,682 (up from £1,579)
Worker and Temporary Worker sponsor licence (large sponsor): £1,682 (up from £1,579)
CoS assignment: £525 per Skilled Worker CoS, unchanged
What happens when the Key Contact or Authorising Officer goes on leave?
The Key Contact and Authorising Officer roles carry specific compliance responsibilities. If the person holding these roles is going to be absent for an extended period, such as maternity or paternity leave, it is important to ensure another suitably senior person can cover these responsibilities. Whether a formal change needs to be reported to the Home Office depends on whether the role is being transferred permanently or temporarily. If the absence is temporary and another individual can act in this capacity without a formal change of appointment, no SMS update may be required. However, if the absence is extended, it is advisable to review the role assignments on the SMS to ensure licence management responsibilities remain covered. Borderless can advise on the appropriate approach for your circumstances.
Government guidance: https://www.gov.uk/government/publications/visa-regulations-revised-table/home-office-immigration-and-nationality-fees-8-april-2026
Government guidance: https://www.gov.uk/uk-visa-sponsorship-employers/change-sponsor-details
Government guidance: Sponsor guidance Part 3: sponsor duties and compliance