• Insights

Tech Employer Considerations: Sponsored Workers in a Hybrid or Remote Workplace

May 3, 2023

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Photo of Laxmi Limbani

Laxmi Limbani

Director

Sheffield, United Kingdom

Email

[email protected]

T:+44 (0) 114 289 2132

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Laxmi Limbani

Laxmi Limbani

Director

Sheffield, United Kingdom

Email

[email protected]

T:+44 (0) 114 289 2132

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Laxmi Limbani

Laxmi Limbani

Director

Sheffield, United Kingdom

Email

[email protected]

T:+44 (0) 114 289 2132

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Laxmi Limbani, Halil Kaya

The world of work is evolving rapidly in ways unpredictable prior to COVID-19. As technology employers adapt to new methods of working, different work patterns are being seen across the sector. Employers cannot overlook the influence COVID-19 has had on their workforces, including attitudes towards working remotely and, often, across multiple sites.

This creates several compliance challenges, including ensuring that Right to Work (RTW) checks are carried out satisfactorily to earn a statutory defence. This will be considered in more detail in the second part of this blog series, coming soon. Further to the recent updates to the Home Office’s Sponsor Guidance, there have been changes related to employee reporting requirements, specifically when employees have hybrid working patterns. 

What are the reporting changes relating to hybrid working patterns?

  • The guidance states that sponsors are required to notify when “a sponsored worker’s normal work location (as recorded on their Certificate of Sponsorship, or CoS) changes;” which includes a situation where the sponsored worker “has moved, or will be moving, to a hybrid working pattern.”
  • A “hybrid working pattern” is defined as a situation where “the worker will work remotely on a regular and planned basis from their home or another address, such as a work hub space, that is not a client site or an address listed on your licence, in addition to regularly attending one or more of your offices or branches, or a client site.”
  • The guidance adds that “sponsors do not need to report day-to-day changes in work location (for example, if a worker occasionally works at a different branch or site, or from home). Sponsors need only tell the Home Office about changes to their regular working patterns.” 

What does this mean?

On careful reading of the guidance, what is strictly required is a reporting of the fact that the normal work location/regular working patterns of a worker has changed, including to remote or hybrid working. The details of the changed location/working arrangement are not necessarily required.

How do I comply?

As of 31 March 2023, there are two options that sponsors can follow to comply with this updated guidance.

Option 1: Report the hybrid working pattern without specifying remote work addresses

  • Where a new CoS is being issued, in addition to the main office location from which the worker will be working, include a sponsor note to confirm that the sponsored worker will be working under a hybrid working pattern. You should identify the number of days they will work from the office per week and the number of days remotely, or provide a brief explanation as to the arrangement if it is not on a weekly basis. 
  • Where a CoS is to be updated by way of SMS update, the update should state that the sponsored worker will be working under a hybrid working pattern and identify the number of days they will work from the office per week and the number of days remotely, or provide a brief explanation as to the arrangement if it is not on a weekly basis.  

This option meets the requirements of the guidance and has the advantage of imposing less burdens on a sponsor.

Option 2: Report the hybrid working pattern and specify remote work addresses:

  • Where a new CoS is being issued, as an additional work address (for example, the individual’s home) from the outset of CoS issuance (where issued on or after 31 March 2023).
  • Where a CoS is to be updated by way of SMS update, in the same way that ordinary change of work locations are filed. This will have an ongoing reporting requirement in case of home moves or working at alternative office hubs.

This option may be favoured for the sake of full transparency, but of course imposes added administrative burdens each time the remote addresses change.

Additional Considerations

Irrespective of which of the above options is preferred, there are additional considerations that may apply in relation to hybrid working, for example:

  • Office hub – assuming membership to an office hub is personal, you must know the potential locations from which the sponsored worker will work.
  • Attendance – how will you manage your compliance duties to know that your sponsored worker is present for work?
  • Communications with sponsored worker – how will you manage record-keeping responsibilities and ensure that your sponsored worker is updating you of changes in real time? For example, will you track this via an application or an internal HR system?

You should be ready to explain your processes and procedures to the UKVI on any future audit.

Need to know more?

Please look out for part two of this blog series coming soon, which will focus on Right to Work checks. For more information on sponsored workers in hybrid or remote work settings, please contact Senior Manager Laxmi Limbani at [email protected] and Trainee Solicitor Halil Kaya at [email protected]. 

This blog was published on 3 May 2023, and due to the circumstances, there are frequent changes. To keep up to date with all the latest updates on global immigration, please subscribe to our alerts and follow us on LinkedIn, Twitter, Facebook and Instagram. 

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Photo of Laxmi Limbani

Laxmi Limbani

Director

Sheffield, United Kingdom

Email

[email protected]

T:+44 (0) 114 289 2132

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Laxmi Limbani

Laxmi Limbani

Director

Sheffield, United Kingdom

Email

[email protected]

T:+44 (0) 114 289 2132

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Laxmi Limbani

Laxmi Limbani

Director

Sheffield, United Kingdom

Email

[email protected]

T:+44 (0) 114 289 2132

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Fragomen news

Comment on DHS proposal to impose up to $100,000 in Optional Practical Training FeesLearn more

Media mentions

Human Resources Director: Fixed-Term Contract Limits Squeeze Visa Sponsorship, Research Warns

Co-authors Partner Charles Johanes, Senior Counsel Anna Boucher and Allens Partner Tarsha Gavin explore the intersection of Australia’s migration and employment laws and the implications for employers sponsoring temporary visa holders.

Learn more

Blog post

Trusted Digital Identity Is Critical Infrastructure for Global Mobility

In the first blog in a new series, Managing Director, Digital Identity Amit Sharma explores why trusted digital identity is becoming increasingly important to global mobility, how reusable digital credentials could work and why interoperability across systems and jurisdictions will be critical.

Learn more

Blog post

UK Global Talent Visa vs Innovator Founder Visa: A Guide for Tech Professionals, Researchers and Founders

Senior Associate Amelia Haynes compares the UK’s Global Talent and Innovator Founder visa routes, examining who each route may suit, the evidence required, professional flexibility and potential pathways to settlement.

Learn more

Blog post

Polish Citizenship by Descent: Finding Family Records and Navigating Polish Archives

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain how applicants pursuing Polish citizenship by descent can locate family records, navigate archives and obtain documentary evidence that can be used in citizenship proceedings.

Learn more
Generic Insights

Fragomen news

2026年10月 米国移民法ダイジェストLearn more

Awards

Fragomen Recognized in 2027 Best Law Firms® Rankings in the United States

Fragomen has been recognized in the 2027 edition of Best Law Firms®, earning a National Tier 1 ranking in Immigration Law and 16 regional rankings across the United States.

Learn more

Media mentions

Global Underwater Hub: The Specialist Skills Needed to Deliver Future Offshore Projects

Director Kelly Hardman explores how early UK immigration planning and investment in domestic skills can help offshore businesses access the specialist expertise needed to deliver future projects.

Learn more

Media mentions

SHRM: Why ‘Hush Trips’ Can Pose Big Risks for Employers and Workers

Senior Counsel Jo Antoons explains the immigration, social security, insurance, employment law and tax risks that undisclosed international remote work can create for employers.

Learn more

Media mentions

Times of India: Immigration After the Midterms: A New Congress, but Who Holds the Power?

Senior Counsel Mitch Wexler discusses the potential impact of the US midterm elections on immigration policy and the areas where bipartisan support could shape future developments.

Learn more

Blog post

UK Earned Settlement: When Immigration Status Becomes an Incentive for Growth and Compliance

In a new blog, UK Government Affairs Strategy Director Shuyeb Muquit examines what the framework could mean for employers, including potential impacts on sponsorship costs, retention planning, employee communications and support for internationally mobile workers and their families.

Learn more

Blog post

What the 2026 Midterm Election Results Mean for U.S. Business Immigration and Employers

In a new blog, Partner K. Edward Raleigh examines what the election results could mean for employers and where businesses should focus now, from immigration compliance and workforce planning to state response procedures and preparation for increased scrutiny.

Learn more

Fragomen news

Comment on DHS proposal to impose up to $100,000 in Optional Practical Training FeesLearn more

Media mentions

Human Resources Director: Fixed-Term Contract Limits Squeeze Visa Sponsorship, Research Warns

Co-authors Partner Charles Johanes, Senior Counsel Anna Boucher and Allens Partner Tarsha Gavin explore the intersection of Australia’s migration and employment laws and the implications for employers sponsoring temporary visa holders.

Learn more

Blog post

Trusted Digital Identity Is Critical Infrastructure for Global Mobility

In the first blog in a new series, Managing Director, Digital Identity Amit Sharma explores why trusted digital identity is becoming increasingly important to global mobility, how reusable digital credentials could work and why interoperability across systems and jurisdictions will be critical.

Learn more

Blog post

UK Global Talent Visa vs Innovator Founder Visa: A Guide for Tech Professionals, Researchers and Founders

Senior Associate Amelia Haynes compares the UK’s Global Talent and Innovator Founder visa routes, examining who each route may suit, the evidence required, professional flexibility and potential pathways to settlement.

Learn more

Blog post

Polish Citizenship by Descent: Finding Family Records and Navigating Polish Archives

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain how applicants pursuing Polish citizenship by descent can locate family records, navigate archives and obtain documentary evidence that can be used in citizenship proceedings.

Learn more
Generic Insights

Fragomen news

2026年10月 米国移民法ダイジェストLearn more

Awards

Fragomen Recognized in 2027 Best Law Firms® Rankings in the United States

Fragomen has been recognized in the 2027 edition of Best Law Firms®, earning a National Tier 1 ranking in Immigration Law and 16 regional rankings across the United States.

Learn more

Media mentions

Global Underwater Hub: The Specialist Skills Needed to Deliver Future Offshore Projects

Director Kelly Hardman explores how early UK immigration planning and investment in domestic skills can help offshore businesses access the specialist expertise needed to deliver future projects.

Learn more

Media mentions

SHRM: Why ‘Hush Trips’ Can Pose Big Risks for Employers and Workers

Senior Counsel Jo Antoons explains the immigration, social security, insurance, employment law and tax risks that undisclosed international remote work can create for employers.

Learn more

Media mentions

Times of India: Immigration After the Midterms: A New Congress, but Who Holds the Power?

Senior Counsel Mitch Wexler discusses the potential impact of the US midterm elections on immigration policy and the areas where bipartisan support could shape future developments.

Learn more

Blog post

UK Earned Settlement: When Immigration Status Becomes an Incentive for Growth and Compliance

In a new blog, UK Government Affairs Strategy Director Shuyeb Muquit examines what the framework could mean for employers, including potential impacts on sponsorship costs, retention planning, employee communications and support for internationally mobile workers and their families.

Learn more

Blog post

What the 2026 Midterm Election Results Mean for U.S. Business Immigration and Employers

In a new blog, Partner K. Edward Raleigh examines what the election results could mean for employers and where businesses should focus now, from immigration compliance and workforce planning to state response procedures and preparation for increased scrutiny.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
November 9, 2026 | United StatesUnited States: DOL Final Rule on Prevailing Wages Now Under OMB Review
November 9, 2026 | United StatesComment on DHS proposal to impose up to $100,000 in Optional Practical Training Fees
November 9, 2026 | FranceFrance: Wide-ranging Immigration Reforms, Adoption of Certain Revised EU Blue Card and Single Permit Directive Rules
November 9, 2026 | AustraliaHuman Resources Director: Fixed-Term Contract Limits Squeeze Visa Sponsorship, Research Warns
November 9, 2026 | OmanOman: New Residence Permit and Workforce Rules for Investors and Property Owners in Special Economic Zones and Free Zones
November 9, 2026 | United StatesUnited States: DOL Final Rule on Prevailing Wages Now Under OMB Review
November 9, 2026 | United StatesComment on DHS proposal to impose up to $100,000 in Optional Practical Training Fees
November 9, 2026 | FranceFrance: Wide-ranging Immigration Reforms, Adoption of Certain Revised EU Blue Card and Single Permit Directive Rules
November 9, 2026 | AustraliaHuman Resources Director: Fixed-Term Contract Limits Squeeze Visa Sponsorship, Research Warns
November 9, 2026 | OmanOman: New Residence Permit and Workforce Rules for Investors and Property Owners in Special Economic Zones and Free Zones
November 9, 2026 | United StatesUnited States: DOL Final Rule on Prevailing Wages Now Under OMB Review
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.