The rule and its limits
Under Part 3 C1, worker changes normally have a 10-working-day reporting limit unless another provision applies. The trigger and required action depend on the event.
- Capture the date the event happened and the date it reached HR separately.
- Identify the exact C1 or route-specific provision before calculating a due date.
- Assess whether a new immigration application is needed as well as an SMS report.
Make the evidence follow the report
Recommended practice: keep a change record linking the original CoS, approved contract variation, payroll effective date and SMS receipt.
- Record who approved the decision and the source paragraph used.
- Track submission status separately from internal approval.
- Escalate a late report promptly; record the actual facts and remedial action rather than backdating.
Suggested reporting queue design
Give each event a unique reference and preserve its original description. Add the affected worker reference, factual event date, date received, applicable source paragraph, decision owner and proposed action. Keep an unresolved event visible while a reviewer obtains missing facts. A label such as ‘promotion’ may conceal changes to duties, hours, pay or location that need separate consideration.
Use distinct queue stages for fact gathering, review, approval, submission and reconciliation. The final stage should compare the submitted narrative with the approved record and retain confirmation of what was actually sent.
- Link related changes without losing their different effective dates.
- Record why a decision is pending and who can resolve it.
- Check a sample of closed cases against the original manager notification.
Suggested quality checks before submission
Ask a second reviewer to verify the identifiers, chronology and factual wording. A report should be understandable without relying on an informal conversation. Where payroll dates and contract dates differ, explain the discrepancy in the internal file before deciding what belongs in the submission.
Useful evidence includes the manager's dated notification, the approved variation, the reporting decision and the submission record. A task marked complete with no receipt is an evidence gap. A draft saved in a shared folder does not establish that the authorised user submitted it.
Fictional practice scenario
A fictional employer agrees a revised role on Monday, changes payroll later that month and tells the sponsor team at the next routine meeting. The practice exercise records all three dates and asks which actual event and provision govern the decision.
The team avoids choosing the latest administrative date merely because it is convenient. It escalates the chronology for review and changes the manager notification process so future proposals reach the sponsor team earlier.
Primary sources & review
- Workers and Temporary Workers: Part 3 — sponsor duties and compliancePublisher update: 2 September 2026 · Checked 4 November 2026
- Workers and Temporary Workers: Part 2 — sponsor a workerPublisher update: 8 October 2026 · Checked 4 November 2026
Sources checked on 4 November 2026. Open the current official text before making a report or decision. Working suggestions on this page are internal control recommendations unless expressly identified as an official requirement.