On 11 November 2025, the UK Home Office issued updated versions of three Primary Worker and Temporary Worker sponsor guidance documents. These updates follow the release of its Statement of Changes in Immigration Rules (which you can read about in our previous article), and mark some key changes that may affect your business as a licensed sponsor.

What are the key changes?

• The premium customer service has now been closed, and any new premium service applications will not be accepted.
• There has been an increase in prices to the UK Home Office’s priority service.
• The UK Home Office has confirmed its intention to phase out Level 2 users over time, on the basis that the distinction between Level 1 and Level 2 functions has diminished in practical terms.
• There is updated clarification on ‘branches’ of sponsors, including branch offices, subsidiaries, and parent or system companies.
• The Home Office has clarified that if a worker moves sponsor under TUPE 2006 or a similar protection, the original sponsor will not receive a refund of any Immigration Skills Charge they have paid.

What do the changes mean for you?

For employers and HR teams within licensed sponsor businesses, these changes will translate into greater compliance risks, and the need for updated and more robust internal processes. In particular, licensed sponsors will need to pay attention to the following:

Closure of the premium customer service

Licensed sponsors could previously opt to pay for a premium customer service, which offered enhanced support and faster processing, in particular by providing a dedicated account manager, faster turnaround times for licence-related requests and priority handling of compliance issues.

Licensed sponsors who previously paid for the premium customer service should consider that any urgent requests will likely take longer than they did under the old scheme. Licensed sponsors will also need to update internal policies and timelines, to account for longer response times and potential delays in applications.

Additionally, without a dedicated account manager and the direct guidance and support that comes with one, all licensed sponsors will need to be extra vigilant about satisfying their duties and meeting deadlines for sponsorships going forward.

Increased priority service fees

Along with the removal of the premium customer service, the UK Home Office has introduced an increase in the fees for priority services, which allow licensed sponsors to expedite certain processes.

The pre-licence priority service has risen by 50% from £500 to £750, with the post-licence priority service rising by 75% from £200 to £350.

Going forward, licensed sponsors will need to budget for the increased fees associated with the priority services when planning urgent recruitment and compliance changes.

Clarification on ‘branches’ of licensed sponsors

The updated guidance clarifies the UK Home Office’s position on ‘branches’ of licensed sponsors.

It states that a sponsored worker can start working at an unregistered branch before the UK Home Office approves adding that branch to the licence.

This will be allowed where:

• the relationship between the main licensed sponsor and the branch meets the definition of ‘common ownership or control’ in the Global Business Mobility Guidance;
• the main licensed sponsor has, and will continue to have, full responsibility for the worker’s duties and functions;
• the main licensed sponsor has notified the UK Home Office of the change of work location for the worker within 10 days of the change; and
• the main licensed sponsor has made a request to the UK Home Office to add the relevant branch to its licence within 20 days of the date on which the worker commenced their employment with that branch.

Licensed sponsors will now have greater flexibility surrounding the movement of sponsored workers throughout organisations within their group.

What are the next steps for licensed sponsors?

Licensed sponsors should consider:

• updating internal compliance processes and timelines to reflect the updated guidance
• preparing for longer wait times, if previously they benefited from the premium customer service
• training HR and recruitment staff to increase awareness of greater compliance risks and responsibilities
• updating Sponsor Management System Access to ensure that all Level 1 users and key personnel are active and trained, in preparation for the removal of Level 2 users
• communicating the changes to sponsored workers, and explain how they may be affected
• budgeting for the increased costs associated with the priority service
• preparing for increased compliance monitoring, particularly in relation to cost recovery breaches related to TUPE 2006 transfers
• updating policies relating to the movement of sponsored workers between branches, to ensure that the UK Home Office is made aware of any movements to unlicensed branches, and applications for licences are made in a timely manner.