Further changes to SMS updating requirements for employers
17 October 2023
The Home Office has announced two important changes that impact employers who hold a licence to sponsor overseas workers. Authorising Officers and Key Contacts on sponsor licences will be asked to provide their national insurance number. Sponsors registered with Companies House will be asked to provide their Companies House reference number.
Sponsors should make staff with responsibility for administering their sponsor licence aware of these changes so that the relevant information can be updated via the Sponsor Management System (SMS).
Requirement for Authorising Officer and Key Contact to provide their national insurance number
The Home Office has recently placed a notification on the SMS confirming that:
- From 8 October 2023, when an Authorising Officer or Key Contact is replaced on the sponsor licence, their National Insurance Number (NINO) must be provided.
- From the same date, if the Authorising Officer or Key Contact’s details are amended in the SMS, their NINO must be provided if it has not been provided already.
- An Authorising Officer or Key Contact who does not have a NINO, may be asked to provide evidence that they have applied for one (or asked to provide reasons why they do not have one and to provide evidence if an exemption is claimed).
A similar process was introduced in June 2023 for Level 1 users, see our earlier article for information.
Existing Level 1 Users, Authorising Officers and Key Contacts may choose to proactively update the SMS with details regarding their NINO. However, they are not required to provide NINO-related information unless another update is required.
NINO updates will be made in the SMS immediately and automatically unless there are other changes to details that are not eligible for automatic update.
A failure to provide NINO details when replacing or amending details of Level 1 Users, Authorising Officers and Key Contacts may impact the outcome of the request.
Request for sponsors to provide their Companies House reference number
The other recent Home Office notification confirms that:
- From 8 October 2023, sponsors registered with Companies House should add their Companies House reference number via the SMS at their earliest convenience.
This is a new development introduced by the Home Office.
Sponsors have an interest in proactively updating the SMS with their Companies House reference number, as it should allow the Home Office to efficiently check and process sponsor requests.
The Home Office has long promised an improved sponsorship system and within the notification itself, they suggest that adding the Companies House reference number will ‘aid the migration of sponsors to the transformed sponsorship system’.
Sponsors can follow the steps in SMS guide 2: manage your sponsorship licence and use the process to ‘amend your organisation’s details’.
Companies House reference number updates will be made in the SMS immediately and automatically.
If you have questions about these developments, please get in touch with a member of our Immigration Team.
Changes to SMS updating requirements for employers29 June 2023
The Home Office has confirmed that Key Personnel on sponsor licences will be asked to provide their national insurance number, and also that (contrary to sponsor guidance that was updated in March 2023) sponsors are not required to report hybrid working arrangements for their sponsored workers.