When must we report a sponsored worker's delayed start date?

After permission is granted, a sponsored worker should normally start within 28 days of the latest date specified in Sponsor Guidance Part 2. If they do not, report the new start date and reason, or stop sponsoring them, by the end of 10 working days after that period. Earlier changes use different rules.

First establish which stage applies

The reporting action depends on whether the worker has applied for permission, whether a decision has been made and whether permission has been granted.

Sponsor Guidance Part 2, paragraph S3.13 says a changed start or end date before application or decision should be reported by adding a sponsor note to the CoS because it may affect the permission period.

Paragraph S3.14 says a worker can start once they have permission even if this is earlier than the CoS start date. A brought-forward start after permission is granted does not need to be reported.

Calculate the 28-day period correctly

Part 2, paragraph S3.15 says the worker should normally start no later than 28 days after the latest applicable date in its list. The list includes the CoS start date, taking account of changes reported before decision, and the valid-from date on the worker's immigration permission. It also includes specified alternative dates for particular circumstances.

Do not automatically count 28 days from the CoS date. Record every potentially applicable date and identify which is latest under S3.15.

Act when the worker has not started

Paragraph S3.16 says that if the worker has not started by the end of the period, the sponsor must either tell the Home Office the new start date and reason, if sponsorship will continue, or stop sponsoring the worker.

Paragraph S3.17 requires the report by the end of 10 working days after the 28-day period, using the Report migrant activity function in the Sponsor Management System.

Keep evidence of the reason

Paragraph S3.18 says UKVI may cancel the worker's permission if it does not consider the reason valid. Paragraph S3.19 gives examples of reasons that may be acceptable, but the decision remains fact-specific.

Keep evidence such as travel disruption, notice-period correspondence or another contemporaneous record. Do not create a generic reason after the deadline has passed.

Maintain a start-date register

Record the CoS start date, permission valid-from date, decision notification date where relevant, planned arrival, actual start, latest S3.15 date, end of the 28-day period, reporting deadline, reason, action and SMS confirmation.

Set reminders before the worker reaches the end of the period. A reminder should prompt a factual review, not an automatic report with an unverified reason.

Check the wider file

Sponsor Guidance Part 3, paragraph C1.15 lists failure to start within 28 days as a reportable worker circumstance and directs sponsors to Part 2, section S3. Appendix D, section 1 covers relevant right-to-work and entry evidence.

After the worker starts, check that the contract, payroll, attendance and work-location records use the actual date. Keep the original planned date and the reporting evidence so the sequence remains clear.

This article provides general information, not legal advice.

Related questions

Is every delayed start immediately reportable?

No. The action depends on the stage and the S3.15 calculation. After permission is granted, the worker should normally start within the defined 28-day period.

Which date starts the 28-day period?

Use the latest applicable date listed in Part 2, paragraph S3.15. Do not assume it is always the date written on the CoS.

When is the delayed-start report due?

Paragraph S3.17 requires the report by the end of 10 working days after the S3.15 28-day period ends.

Can we keep sponsoring the worker after a delayed start?

You may report the new start date and reason, but paragraph S3.18 says UKVI may cancel permission if it does not consider the reason valid. Keep evidence and carry out the required right-to-work check.

Do we report a start date brought forward after permission is granted?

Part 2, paragraph S3.14 says you do not need to report that brought-forward start, provided the worker has permission to undertake the sponsored role.