A costly mismatch: occupation codes, job descriptions and sponsor compliance

What has changed?

The updated Workers and Temporary Workers: guidance for sponsors, Part 3: Sponsor duties and compliance, issued on 20 May 2026, now expressly requires sponsors to match the worker’s job role to both the occupation code and the job description when assigning a CoS (section C1, paragraphs C1.43 to C1.47). 

This is an important clarification. In the past, some sponsors may have focused primarily on job title when selecting an occupation code. The updated guidance makes it clear that the key question is what actions the worker actually performs. The job description must genuinely reflect the worker’s day-to-day duties and responsibilities. Vague, generic or exaggerated job descriptions are likely to attract Home Office scrutiny and may lead to visa refusals and even compliance action. 

Sponsors should therefore assess the role as a whole, taking into account the actual duties and the sector in which they operate, and select the occupation code that most accurately reflects what the worker does or will be employed to do.

In practice, sponsors are increasingly being asked to provide information about the role and occupation code even when applying for a new CoS allocation. It is therefore vital to assess each role carefully and identify the best-matched occupation code when sponsoring a worker.

The Home Office may ask the sponsor or the worker for further information or evidence to confirm that the role meets the relevant requirements. If that information is not provided by the deadline, the Home Office may refuse a request for additional CoS allocation, refuse the worker’s application, or take compliance action against the sponsor.

Ongoing duties after a CoS is assigned

Once a CoS has been assigned, the sponsor must ensure that the worker’s role in practice continues to correspond with the information stated on the CoS for the full period of sponsorship. 

Sponsors must report certain changes that affect their sponsored workers – those include (but are not limited to) changes of the job role, job title, core duties, or promotion.  If the worker’s role changes, the sponsor must consider whether that change needs to be reported through the Sponsor Management System (SMS), and whether it affects the occupation code.

Sponsors can continue sponsoring the worker if they change to a different role within the same occupation code, providing the new role meets all the eligibility requirements and is within the same occupation code that is indicated on the worker’s current CoS.  The Sponsor Guidance Part 2 indicates that if such a change of role occurs during a period of worker’s permission and before they need to make a visa extension application, the sponsor does not need to assign a new CoS, but must inform the Home Office of the change via their SMS account within 10 working days of the change.

Changes to the job description are particularly important. If the worker’s duties change significantly, the role may fall under a different occupation code from the one stated on the CoS. In that case, the sponsor must reassess the role against the standard occupation codes to determine whether the original code still applies:

• If a different occupation code applies and the sponsor wishes to continue sponsoring the worker in the revised role, a new CoS will usually be needed and the worker will need to make a change of employment application.
• If the change does not require a new CoS or change of employment application, as explained above, the sponsor can continue to sponsor a worker but must still report the change through SMS by no later than 10 working days after the relevant change has happened. 

These obligations are not entirely new, but the revised guidance brings them together more clearly and signals a stricter compliance approach. Sponsors should not assume that occupation code selection is a one-off exercise at the start of sponsorship; it must be kept under review throughout the worker’s employment where the role evolves.

Revocation risk

Lastly, it is important to note that paragraph C1.47. of the updated guidance now gives the Home Office more scope for revocation of sponsor licence: 

“If we discover that a sponsored worker is working in a role that does not match the occupation code or job description for which the CoS was assigned, and this is not a permitted change as described above, this will be a mandatory ground for revocation of your sponsor licence.”

Sponsors should therefore approach occupation code selection carefully and keep a clear record of how the role was matched to the chosen code. If the Home Office questions that decision, the sponsor may need to show how the worker’s duties align with the relevant occupation listed in the rules and explain the basis on which the code on the CoS was selected.

How we can help

For more information about Irwin Mitchell’s immigration services or assistance with UK visa sponsorship, including guidance on matching workers’ job roles to standard occupation codes to comply with sponsorship duties, contact us or visit our website here.