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The Sponsor Licence - Structure, Ownership Changes and Transfers

An introduction to the Sponsor Licence structure.

Written by Tom Hext

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.

Making a dormant licence inactive

Where a business restructure means that an existing licence will no longer be used to sponsor new workers, the licence should be reported to the Home Office as dormant. A licence cannot be made dormant while there are active visa applications in progress for that licence.

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 becomes dormant or is replaced, 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.

TUPE transfers

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 order to continue sponsoring those workers. Sponsorship does not automatically transfer. The new employer must assign new CoS to the transferred workers, and the previous employer should report the end of sponsorship on their SMS.

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)

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.

The CoS fee remains unchanged at £525 per Skilled Worker CoS assigned.

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