The 10-Day Reporting Rule Explained: What UK Sponsors Must Report and When
Late or missing reports through the Sponsorship Management System are one of the most common reasons the Home Office takes action against sponsor licence holders. The requirement itself is straightforward: when certain events happen involving your sponsored workers, you must report them to UKVI within 10 working days. But in practice, these deadlines are missed constantly — often because the event was never flagged internally, not because anyone chose to ignore it.
This guide covers every reportable event, how to submit reports correctly, the mistakes that catch most employers out, and what happens when deadlines are missed.
What Is the 10-Day Reporting Rule?
As a sponsor licence holder, you have a legal duty to report specific changes in your sponsored workers’ circumstances to UK Visas and Immigration (UKVI). Most of these must be reported within 10 working days of the event occurring.
These reporting duties are set out in Part 3 of the Home Office’s sponsor guidance (Workers and Temporary Workers: guidance for sponsors — sponsor duties and compliance). They apply to every organisation that holds a sponsor licence, regardless of size or sector.
There are actually three reporting timeframes to be aware of:
- 10 working days — for changes relating to your sponsored workers (this is what most people mean by “the 10-day rule")
- 20 working days — for changes to your organisation itself (address, ownership, key personnel)
- As soon as reasonably practicable — for suspected immigration breaches or criminal activity
This article focuses on the 10-working-day worker reporting duties, which are the most frequently triggered and the most commonly missed.
Exactly What Must Be Reported Within 10 Working Days
1. Worker Does Not Start the Job
If a sponsored worker does not start their role within 28 days of either the start date on their Certificate of Sponsorship or the date their visa was granted (whichever is later), you must report it. The 10-day window begins after that 28th day passes.
This catches situations where a visa is granted but the worker never arrives, changes their mind, or is delayed beyond the permitted window.
2. Unauthorised Absence of More Than 10 Consecutive Working Days
If a sponsored worker is absent from work without permission for more than 10 consecutive working days, you must report it. The 10-day reporting window starts from the day after that 10th day of unauthorised absence.
Note the word “unauthorised.” This means absence where the worker has not obtained permission from you to be away. It does not include approved annual leave or pre-agreed absence.
3. Unpaid Leave or Reduced Pay Exceeding 4 Weeks
If a sponsored worker is absent from work without pay, or on reduced pay, for more than 4 weeks in total in any calendar year, you must report it.
There are exceptions — statutory maternity leave, statutory paternity leave, statutory adoption leave, shared parental leave, and statutory sick pay do not count towards the 4-week total. But any other unpaid leave does, even if you authorised it.
This is one of the most overlooked reporting triggers. A worker who takes two separate periods of unpaid leave totalling more than 4 weeks in the same calendar year has triggered a reportable event — even though neither absence on its own was long enough to flag.
4. Salary Drops Below the Level Declared on the CoS
If the sponsored worker’s salary falls below the amount stated on their Certificate of Sponsorship, you must report it. This includes pay cuts, reductions in contracted hours, changes to bonus structures that lower total compensation, and any other change that brings actual pay below the declared level.
Given that the Home Office now cross-references PAYE Real Time Information data from HMRC against CoS declarations, salary discrepancies are increasingly being detected automatically — often before the employer reports them.
5. Significant Change to Job Role or Duties
If the sponsored worker’s role, job title, or core duties change significantly, you must report it. This includes changes to the Standard Occupational Classification (SOC) code, promotions that move the worker into a different occupation category, or any shift in duties that means the role no longer matches what was described on the CoS.
A role that was genuinely a software developer at the time of sponsorship but has since evolved into a project management position is a reportable change — even if the worker’s title hasn’t changed.
6. Change of Work Location
If the sponsored worker’s normal work location changes, you must report it. This includes moves to a different office, branch, site, or client premises.
Critically, this also applies to permanent shifts to home or remote working. If a sponsored worker was sponsored to work from your London office and has since moved to working from home as their normal arrangement, that is a change of work location and must be reported.
7. Sponsorship Ends for Any Reason
If you stop sponsoring the worker — for any reason — you must report it within 10 working days. This covers resignation, dismissal, redundancy, end of a fixed-term contract, mutual termination, TUPE transfer, or any other circumstance where the employment relationship ends earlier than the end date on the CoS.
The 10-day clock starts from the worker’s last day of employment.
How to Submit Reports
All reports are made through the Sponsorship Management System (SMS), the Home Office’s online portal at points.homeoffice.gov.uk. Specifically, you use the "Report migrant activity" function within SMS.
Only authorised users can submit reports:
- Level 1 Users have full access to all SMS functions, including reporting
- Level 2 Users can only report activity on Certificates of Sponsorship they personally created and assigned
Your Authorising Officer and Key Contact are ultimately responsible for ensuring reports are submitted on time, even if the actual data entry is done by someone else.
Tips for Using SMS Reporting
- Keep your SMS login credentials accessible to more than one person. If your sole Level 1 User is on holiday when a reportable event occurs, the deadline does not pause.
- Record the date of every report you submit. If the Home Office later questions your compliance, you need to demonstrate that reports were filed within the required window.
- If SMS is genuinely unavailable due to a system outage, document your attempts and submit the report as soon as the system is restored. Technical issues are not a blanket excuse, but they are a factor the Home Office will consider.
The Deadlines Most Employers Miss
The 10-day rule is clear in theory. In practice, these are the scenarios that catch most organisations out:
Unpaid Leave That Accumulates
A sponsored worker takes one week of unpaid leave in March, another in June, and two weeks in September. No single period seems reportable. But the total has now exceeded 4 weeks in the calendar year, and the reporting obligation was triggered in September — often without anyone noticing.
Most HR systems do not flag cumulative unpaid leave against the 4-week annual threshold. This means the duty falls to whoever is manually tracking it, and in many organisations, nobody is.
Home Working Treated as Informal
Many employers moved sponsored workers to remote working during or after the pandemic and never formally reported the change of work location. The Home Office guidance is clear: if the worker’s normal place of work has changed — including to their home — it must be reported.
Delayed Termination Reporting
The worker’s last day was the 15th. Payroll processes the departure at month-end. HR updates the system the following week. The SMS report is finally submitted three weeks later. The 10-day window has closed.
This is the most common reporting failure because it depends on information flowing between line managers, HR, and whoever has SMS access — and that chain often has delays built into it.
Salary Changes That Slip Through
An annual pay review adjusts a sponsored worker’s salary. The new rate is still above the minimum threshold, so nobody flags it as a reporting issue. But if the new rate is lower than what was declared on the CoS, it is a reportable change — regardless of whether it still meets the minimum.
With HMRC payroll data now being cross-referenced against CoS declarations, the Home Office may detect the discrepancy before you report it. Being the second to notice is not a good position.
The No-Show Nobody Reports
A sponsored worker’s visa is granted, but they never arrive. The employer assumes the worker will eventually turn up, or that it’s the worker’s problem. After 28 days, the no-show becomes reportable — and many employers simply don’t have a process to track whether a sponsored hire has actually started.
What Happens If You Miss the Deadline?
Failure to report within 10 working days is treated as a breach of your sponsor duties. The Home Office has a range of enforcement actions available:
Licence downgrade — Your A-rating is downgraded to a B-rating. You’ll be given an action plan to complete, and during this period your ability to assign new Certificates of Sponsorship may be restricted. The action plan enforcement period has recently been extended from 3 months to up to 12 months.
Reduction in CoS allocation — The Home Office can reduce your Certificate of Sponsorship allocation to zero, preventing you from sponsoring any new workers until your compliance improves.
Licence suspension — Your licence is temporarily suspended while the Home Office investigates. You cannot assign new CoS during this period.
Licence revocation — The most severe outcome. Your licence is cancelled, and every worker sponsored under it will have their visa curtailed — typically to 60 days. They must find a new sponsor, switch to a different visa route, or leave the UK. You face a 12-month cooling-off period before you can reapply.
Civil penalties — If the missed report is connected to illegal working (for example, a worker whose visa expired and you failed to report it), you face a civil penalty of up to £45,000 per worker for a first breach and up to £60,000 per worker for a repeat breach. There is no cap on the total.
A single missed report will not always result in the worst outcome. But the Home Office looks at patterns. Multiple late reports, or a failure to report across several events, demonstrates systemic non-compliance — and that significantly increases the likelihood of suspension or revocation.
Don’t Forget: 20-Working-Day Organisational Reports
While this article focuses on the 10-day worker reporting duties, there is a separate set of changes to your organisation that must be reported within 20 working days:
- Changes to your organisation’s name, address, or contact details
- Changes to key personnel — Authorising Officer, Key Contact, or Level 1 Users
- Mergers, acquisitions, or takeovers
- New branches or sites
- Ceasing operations or entering insolvency
- Substantial changes to the nature of your business
- Criminal convictions involving key personnel
These are reported through the same SMS portal. The most commonly missed is the departure of an Authorising Officer or Key Contact — particularly when they leave the company and nobody realises the SMS record needs updating.
Building a Process That Actually Works
The 10-day rule is not difficult to comply with. The difficulty is having a system that ensures reportable events are captured and acted on before the deadline passes. Here is what that looks like in practice:
Define who is responsible. Reporting through SMS should be assigned to a named individual (and a backup) with Level 1 access. This person does not need to be the one who detects the event — but they must be the one who submits the report.
Create internal triggers. Every process that could generate a reportable event needs a step that routes to the SMS reporter. When HR processes a termination, the workflow should include a step for SMS reporting. When payroll processes a salary change for a sponsored worker, it should trigger a check against the CoS amount.
Track unpaid leave separately. Standard HR systems track leave balances, but they rarely track cumulative unpaid leave against the 4-week annual threshold for sponsored workers. Build this check into your quarterly review, or use a system that does it automatically.
Set reminders before deadlines expire. If a reportable event occurs on Day 1, the deadline is Day 10. Build in a reminder at Day 5 — leaving buffer for delays without cutting it to the wire.
Log everything. Keep a record of every report submitted: the date of the event, the date the report was filed, and the SMS confirmation reference. If the Home Office ever questions your reporting history, this log is your evidence.
How SponsorPro Helps
SponsorPro is built to track exactly these deadlines. When a reportable event is recorded in the system — a termination, a salary change, an absence threshold being crossed — it automatically calculates the 10-working-day deadline and sends reminders before it expires. Your compliance dashboard shows any approaching or overdue reporting obligations in real time, so nothing falls through the gaps.
- Automated 10-day deadline tracking for every reportable event
- Absence monitoring that flags when cumulative unpaid leave crosses the 4-week threshold
- Salary change alerts that compare current pay against the amount declared on the CoS
- SMS reporting log to maintain a complete audit trail of every report filed
- Real-time compliance scoring across all five Home Office inspection areas
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