Sponsor licence holders asked to update Sponsor Management System to help UKVI conduct more audits remotely
Organisations which hold a sponsor licence are being asked to add Companies House reference numbers and National Insurance Numbers of their Key Personnel to their Sponsor Management System to increase UKVI audit capability.
There are currently in excess of 77,000 organisations in the UK which hold a licence issued by UK Visas and Immigration (UKVI) to sponsor foreign national workers under the Worker or Temporary Worker immigration routes. Those organisations who have logged into their Sponsor Management System since 8 October 2023 will have been confronted by two new notification from UKVI on the "SMS message board". The messages ask sponsors to add their Companies House reference numbers to the SMS, along with the National Insurance numbers of their Authorising Officer (AO) and Key Contact (KC).
Following this notification, it is now a requirement for sponsors to include the National Insurance Numbers with any request to change a AO or KC, or with any request to update their details. If no changes are being made, sponsors are still asked to add the details in 'at your earliest convenience'. To add a National Insurance Number to the details held about an existing AO or KC, this is done through the "request changes to licence details" menu under the options for amending a current AO's or KC's details. If a AO or KC doesn't have a National Insurance Number then sponsors will be asked to provide reasons why, and may be asked to provide further evidence that those individuals have applied for one.
Sponsors can add their Companies House reference number to the Sponsor Management System via the 'amend your organisation details' screen. The provision of this reference number will help UKVI check Companies House records more effectively, and will also "aid the migration of sponsors to the transformed sponsorship system". UKVI routinely carry out checks of sponsors' Companies House records when requests are being considered. This is primarily to monitor whether any reportable events about the sponsor organisation have occurred but not yet notified to UKVI. Such reportable events would include a change in the size of a company (based on the Companies Act definition). Additionally, changes in ownership are also reportable but often overlooked in the drama of a corporate transaction, even though such a change may trigger a requirement for the organisation to apply for a new sponsor licence.
It appears that both of these changes are being implemented to allow UKVI to carry out more 'desk-based' compliance reviews of sponsors. AO and KC National Insurance Numbers will presumably help establish that those nominated to those positions satisfy the criteria to hold them; Companies House reference numbers will help ensure that UKVI are checking the details of the correct legal entity and that the details held by Companies House are consistent with those held by UKVI. We do not know at this stage whether those checks are conducted manually or are automated, but either way it is clearly important for sponsors to ensure that the details are correct and that they have complied with their various sponsorship duties in case UKVI's checks trigger a more thorough compliance review.