Further changes to SMS updating requirements for employers

7 November 2023 | Applicable law: England and Wales | 2 minutes

Further changes to SMS updating requirements for employers

The Home Office has announced that from 8 October 2023 there are new requirements for licenced sponsors. 

The changes relate to:

  1. the provision of National Insurance Numbers (NINOs) for certain key personnel; and
  2. request for sponsors to provide their Companies House reference numbers

Key personnel

Just by way of reminder, the roles are:

  • Authorising Officer (AO) – the individual responsible for actions of staff and representatives who use the sponsor licence
  • Key Contact (KC) – the main point of contact with UKVI
  • Level 1 users – the individuals responsible for day-to-day management of a sponsor licence using the SMS

1) Requirement for AO and KC to provide their NINO

Every sponsor must be aware of the following changes and take the relevant action:

  • From 8 October 2023, when an Authorising Officer or Key Contact is replaced on the sponsor licence, their NINO must be provided
  • From the same date, if the AO or KC's details are amended in the SMS, their NINO must be provided (if not already provided)
  • If the AO or KC does not have a NINO, the sponsor will be asked to provide reasons why, and may be asked to provide further evidence that they have applied for one. 

A similar process was introduced in June 2023 for Level 1 users. 

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.

2) Request for sponsors to provide their Companies House reference number 

From 8 October 2023, sponsors who are registered with Companies House, should add their Companies House reference number, using the ‘amending your organisation’s details’ function on the SMS, at their earliest convenience. 

The request to provide a Companies House reference number follows the enabling of requesting this information in the SMS. The Home Office have explained that provision of this number will facilitate more effective checking of Companies House records and will also ‘aid the migration of sponsors to the transformed sponsorship system’. 

Next steps

If you have any questions about these developments or need any help implementing them, please contact our UK Immigration team, or your usual Withers contact. 

This document (and any information accessed through links in this document) is provided for information purposes only and does not constitute legal advice. Professional legal advice should be obtained before taking or refraining from any action as a result of the contents of this document.


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