Sponsor Licence Changes in 2026: Six Actions for Employers
Updated: Oct 5
Updated: 18 September 2026 (EN/CN/JP versions follow)
The Home Office has introduced several changes affecting sponsor licence holders. These cover Sponsorship Management System (SMS) security, Level 2 Users, right-to-work checks, eVisas and Skilled Worker salary compliance.
Here is a practical summary of what employers need to know and do.
Key dates
3 September 2026: Phased introduction of multi-factor authentication for SMS users
9 September 2026: No new Level 2 Users can be appointed
1 October 2026: Wider right-to-work requirements take effect
November 2026: Full implementation of SMS multi-factor authentication is expected
8 March 2027: Deadline to convert or deactivate existing Level 2 Users
1. Prepare SMS users for multi-factor authentication
Multi-factor authentication (MFA) is being introduced for all SMS users. Once activated, users must enter a one-time passcode as well as their username and password.
The code will normally be sent:
by text message to a Level 1 User’s registered mobile number; or
by email where no valid mobile number is recorded and for existing Level 2 Users.
Sponsors should check that every SMS user’s personal email address, mobile number and date of birth are correct.
Email accounts must be secure, belong to the named user and not be shared with other staff.
New sponsor licences granted on or after 9 September 2026 will have MFA enabled automatically.
2. Review Level 2 Users before March 2027
Sponsors can no longer appoint new Level 2 Users.
Existing Level 2 User accounts must be dealt with by 8 March 2027. A Level 1 User must either:
convert the person to a Level 1 User, if they meet the eligibility requirements; or
deactivate the person’s SMS account.
After the deadline, the Home Office will deactivate any remaining Level 2 User accounts.
Employers should also ensure that at least one eligible and active Level 1 User remains in place. Ideally, there should be enough Level 1 User coverage for holidays, sickness and staff departures.
3. Keep SMS accounts active
An SMS account may be treated as inactive if the user has not accessed it for 12 months or more.
Where an inactive account is identified, the Home Office will normally contact the Authorising Officer and the affected Level 1 User. The user will usually have three months to log in, check their details and make any necessary updates.
If removing inactive accounts leaves the organisation without an active Level 1 User, the Home Office may suspend the sponsor licence. The organisation will then normally have 28 days to appoint an eligible Level 1 User.
Sponsors should:
review all SMS users;
remove access for anyone who has left or no longer needs it;
ensure active users log in regularly; and
review SMS users and Key Personnel every quarter.
4. Update right-to-work procedures before 1 October 2026
From 1 October 2026, the Right to Work Scheme is due to extend beyond traditional employees. It may also cover people working under:
worker contracts;
individual subcontracting arrangements;
certain employment business or platform arrangements; and
online matching services.
Whether the requirements apply will depend on how the working arrangement operates in practice, not simply how it is described in the contract.
Independent businesses and genuine business-to-business arrangements may remain outside the scheme, but each arrangement should be assessed individually.
Employers should review their arrangements with contractors, employment businesses and service providers. Contracts should clearly state who is responsible for:
carrying out right-to-work checks;
retaining evidence;
sharing relevant information; and
taking action if illegal working is identified.
Sponsor licence holders must already check and retain evidence of the immigration status of all sponsored workers, including those who are not directly employed by them.
5. Complete the correct eVisa check
Sponsored workers will now generally receive an eVisa rather than a physical visa vignette.
A visa approval email or decision letter is not evidence of a person’s right to work.
Before employment begins, employers must complete the prescribed right-to-work check. Where the worker has an eVisa, this must be an online check using the Home Office service and the worker’s share code.
Employers must retain evidence of the completed check and, where required, evidence of the worker’s date of entry to the UK.
6. Check Skilled Worker salary compliance
For workers sponsored using a Certificate of Sponsorship assigned on or after 8 April 2026, the required salary must be maintained during each relevant pay period.
The Home Office can compare PAYE information held by HMRC with the salary, working hours and occupation details recorded on the Certificate of Sponsorship.
Sponsors should ensure that:
payroll matches the salary and weekly hours stated on the CoS;
the worker receives at least the applicable going rate for the hours worked;
unpaid leave, salary reductions and irregular working patterns are recorded correctly;
reportable salary or employment changes are submitted through the SMS on time; and
payroll records, employment contracts and attendance records remain consistent.
Employer action checklist
Sponsor licence holders should now:
audit their SMS users and Key Personnel;
update SMS contact details for MFA;
review inactive and Level 2 User accounts;
update right-to-work procedures before 1 October 2026;
compare sponsored workers’ payroll records with their CoS details; and
check that reportable changes have been submitted within the applicable 10 or 20 working-day deadline.
How Beaumont Park Associates can help
Beaumont Park Associates can assist with:
SMS and Key Personnel reviews;
sponsor compliance audits;
right-to-work procedures;
Authorising Officer training; and
reporting changes to UK Visas and Immigration.
If you have questions about how these changes may affect your organisation or sponsored workers, please contact us to arrange a consultation.
Our consultation fee is £90 plus VAT for 30 minutes.
This article provides general information only and should not be treated as advice tailored to an individual organisation or worker.
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