"We've Moved!" - Change of address reporting duties for sponsor licence holders

Our colleagues across the firm regularly support clients with the arrangements for changing address. This could be related to two independent schools merging; a national charity acquiring a smaller organisation; or a social enterprise having the opportunity to move to larger premises. Finalising new leases, planning law requirements, insurance paperwork and updates to the Charity Commission and/or Companies House are often at the forefront of everyone's mind.

In any of these scenarios, if the organisations involved hold a Sponsor Licence, then UKVI reporting duties are also triggered. The Home Office's guidance confirms that sponsors must report any changes to the organisation's circumstances, including a change of address. 

For straightforward scenarios where a single organisation has moved from one location to another, reports are completed through the Sponsorship Management System (SMS). The notification must be made by a Level 1 user, as they are the only Key Personnel with the appropriate type of access to the SMS.

The sponsor has 10 working days from the change becoming effective to make a compliant update. For example, if a charity begins operating from a new address on 1 September, the notification must be submitted within 10 working days of that change taking effect. The relevant reports would therefore need to be made by 10 September. Once the updates are made online, a sponsor has a further 10 working days to provide any supporting evidence to the Home Office by email, including the completed Submission Sheet. The supporting evidence will depend on whether the sponsor is also an educational establishment and whether the new address can be verified against Companies House.

A common compliance issue is the assumption that updating the organisation’s address alone is sufficient. However, additional notifications may be required in relation to any individuals on the licence (Key Personnel and sponsored workers alike) whom this change impacts. These reports must be made individually on the SMS, for example to confirm that the work address recorded for the Authorising Officer has also changed to the new location. For organisations with more than one location and hybrid working, which reports are necessary must be assessed on a case-by-case basis. 

Our immigration team regularly assists with notifications relating to address changes, as well as assessing whether the circumstances for the change trigger more complicated reporting duties. Should your organisation require support in this regard, please do get in touch as we would be delighted to provide tailored support.