Immigration & Recruitment Update | September 2026
Employers that sponsor overseas workers have additional compliance responsibilities, and the UK Government has introduced several important updates to the sponsorship system in 2026.
The sponsor duties and compliance guidance was updated on 2 September 2026, while further changes to Sponsorship Management System access were introduced in September.
Important September 2026 changes
From 3 September 2026, mandatory multi-factor authentication (MFA) was introduced for Sponsorship Management System users.
From 9 September 2026, sponsors can no longer appoint new Level 2 Users. The existing Level 2 User role is scheduled to be abolished after 8 March 2027.
These changes mean that businesses holding a sponsor licence should ensure that the people responsible for sponsorship are familiar with the updated system and access requirements.
Compliance remains an ongoing responsibility
Sponsor duties extend beyond obtaining a licence.
Employers are expected to maintain appropriate records and comply with reporting and monitoring requirements. Government guidance includes requirements relating to right-to-work evidence, recruitment records, salary and skill-level evidence.
For HR and recruitment teams, this means that sponsorship should be integrated into the organisation's wider recruitment and employee-record processes.
What should employers review?
Employers may wish to check:
- who currently has access to the Sponsorship Management System;
- whether MFA has been implemented;
- whether user accounts remain active and appropriate;
- whether right-to-work and recruitment records are complete;
- whether sponsored-worker records are up to date; and
- whether internal sponsorship procedures reflect the latest Home Office guidance.
For organisations recruiting internationally, strong HR administration is an important part of maintaining immigration compliance.
Disclaimer: This article provides general information and should not be relied upon as immigration or legal advice.
