UNITED KINGDOM – Hybrid and Remote Reporting

May 26, 2023

While immigration rule changes issued by the Home Office are typically followed by a period of review where questions and concerns are addressed, this period has been longer than usual for the new requirement of reporting the working patterns of sponsored employees.

Initially in April, the Home Office stated that all instances of hybrid or remote working should be updated by sponsors on the Sponsor Management System. Now, the Home Office’s requirements have become more concrete.

It is the Home Office’s assumption that most/all clients will be operating under some kind of hybrid or remote working model in lieu of the Covid-19 pandemic. As such, there is no need for sponsors to report on this change to the Home Office, though sponsors should retain documents pertaining to the remote working of their sponsored workers. The Home Office is not requiring sponsors to report the working patterns of all sponsored employees retrospectively.

The only two occasions that sponsors should report the working patterns of their sponsored employees are when:

  • Any new employee is coming into the country. They will need to have their working patterns put on the CoS (so a sponsor note for example) or reporting once the employee has taken residence here in the UK;
  • A person changes from office/hybrid to fully remote working. The report should state that they have stopped working in an office/hybrid pattern and are now fully remote.

As the Discovery Team deals with all things compliance, they have recommended that while there is no need to retrospectively report on the working patterns of sponsored employees, the most prudent and gold level standard would be to make reports on any new employees who started after 3rd April 2023 (after the rules changed).

It is understandable that this presents more work for our clients to undertake, but the Discovery Team are on hand to assist with:

  • Queries, questions and tactics of best practice
  • Policy reviews (including reviews for Remote, Hybrid, Sponsored employee, HR policies)
  • Mock Audits


Newland Chase Insights

Get in touch with your team leader here: [email protected] .

This immigration update is for informational purposes only and is not a substitute for legal or scenario-specific advice. Furthermore, it is important to note that immigration announcements are subject to sudden and unexpected changes. Readers are encouraged to reach out to Newland Chase for any case- or company-specific assessments.