On 11 November 2025, the UK Home Office published updated versions of its Primary Worker and Temporary Worker sponsor guidance. The changes follow the recent Statement of Changes to the Immigration Rules and introduce several practical updates that will affect how licensed sponsors manage compliance, recruitment and internal processes.
While some of the updates clarify existing positions, others introduce increased costs and remove services that many sponsors previously relied on. For businesses employing sponsored workers, particularly those with complex group structures or high volumes of sponsorship activity, the new guidance signals a need to review systems and timelines carefully.
This article looks at the most significant changes and what they mean in practice for licensed sponsors.
Overview of the updated sponsor guidance
The Home Office has updated three sponsor guidance documents covering Primary Worker and Temporary Worker routes. These documents govern how sponsors interact with the Sponsor Management System, manage sponsored workers and comply with ongoing reporting and record keeping duties.
Although the overall sponsorship framework remains in place, the updates reflect a move towards tighter compliance expectations and greater responsibility on sponsors to manage issues without enhanced Home Office support.
Businesses shouldn’t assume that processes which worked previously will remain sufficient under the new guidance.
Closure of the premium customer service
One of the most impactful changes is the closure of the premium customer service. This service previously allowed sponsors to pay for enhanced support, including access to a dedicated account manager, faster handling of licence related requests and prioritised responses to compliance issues.
The Home Office has confirmed that the premium service is now closed and that no new applications will be accepted. For sponsors who previously relied on this service, this change is likely to result in longer response times and reduced flexibility when dealing with urgent matters.
Without a dedicated account manager, sponsors will need to be more proactive in managing their sponsor duties. Internal timelines may need to be extended to allow for slower responses, and greater care will be needed to ensure that reporting deadlines and compliance obligations are met without direct Home Office guidance.
This change also increases the importance of accurate record keeping and internal checks. Where issues arise, sponsors may no longer be able to rely on rapid intervention from the Home Office to resolve problems before they escalate.
Increased priority service fees
Alongside the removal of the premium customer service, the Home Office has increased the fees for its priority services. These services allow sponsors to fast track certain applications or licence related requests where timing is critical.
The pre licence priority service has increased from £500 to £750, while the post licence priority service has risen from £200 to £350. While priority processing remains available, the higher costs mean sponsors will need to plan more carefully when urgent recruitment or compliance changes are anticipated.
For employers with frequent sponsorship needs, this may have a noticeable impact on budgets. Priority services may still be worthwhile in time sensitive situations, but they are no longer a low cost solution for resolving delays.
Phasing out Level 2 users
The updated guidance confirms the Home Office’s intention to phase out Level 2 users over time. Historically, Level 2 users were given more limited access to the Sponsor Management System, with Level 1 users retaining overall responsibility and control.
The Home Office has indicated that the practical distinction between these roles has diminished. As a result, sponsors should prepare for a system where Level 1 users carry full responsibility for sponsorship activity.
For businesses, this means it’s important to review who currently holds Level 1 access and whether they have the capacity, training and understanding needed to manage sponsor duties properly. Sponsors should also ensure that all key personnel details are accurate and that any inactive or outdated users are removed. Leaving this too late could create operational risks once Level 2 access is formally withdrawn.
Clarification on branches and group structures
The updated guidance provides clearer direction on how the Home Office views branches of licensed sponsors, including branch offices, subsidiaries and parent or system companies.
Under the new clarification, a sponsored worker is permitted to start work at an unregistered branch before that branch has been formally added to the sponsor licence. This flexibility applies where the relationship between the main sponsor and the branch meets the definition of common ownership or control, and where the main sponsor retains full responsibility for the worker’s duties.
The sponsor must still meet strict reporting obligations. The Home Office must be notified of the change in work location within ten days, and a request to add the branch to the licence must be made within twenty days of the worker starting work at that location.
This change provides welcome flexibility for businesses with multiple sites or evolving group structures. However, it also places responsibility firmly on sponsors to track worker movements carefully and ensure that reporting deadlines are met.
TUPE transfers and the Immigration Skills Charge
The Home Office has also clarified its position on the Immigration Skills Charge where sponsored workers transfer to a new sponsor under TUPE 2006 or similar protections.
Where a worker moves to a new sponsor in these circumstances, the original sponsor won’t receive a refund of any Immigration Skills Charge already paid. This clarification is particularly relevant for businesses involved in restructuring, outsourcing, mergers or acquisitions.
Sponsors should factor this into commercial decision making and ensure that immigration costs are properly accounted for during transactions. There is also an increased compliance risk where cost recovery arrangements aren’t handled correctly, making it important to review internal policies and contractual terms.
What licensed sponsors should do next
Licensed sponsors should treat the updated guidance as a prompt to review their internal systems. Processes and timelines may need to be adjusted to reflect longer Home Office response times now that premium support has been removed.
Training HR and recruitment teams is increasingly important, particularly given the higher compliance burden and the phasing out of Level 2 users. Sponsors should also review Sponsor Management System access to ensure that Level 1 users are active, informed and capable of managing their responsibilities.
Budgeting should be updated to reflect higher priority service fees, and communication with sponsored workers may be necessary to explain how these changes could affect processing times or internal procedures.
Finally, sponsors should review policies relating to the movement of workers within group structures to ensure that reporting obligations are met and licence updates are made promptly.
Staying compliant in a changing sponsorship system
The updated sponsor guidance reflects a broader shift towards tighter control, higher costs and increased responsibility for licensed sponsors. While some changes provide greater flexibility, others remove support mechanisms that businesses may have relied on in the past.
By reviewing processes now and taking a proactive approach to compliance, sponsors can reduce risk and avoid disruption as these changes take effect.
Please note that this article is solely for informational purposes. It’s not a substitute for legal advice. We encourage readers to contact Osbourne Pinner for case specific guidance.
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