Hiring EU Citizens For A UK Business: Does Your Business Need A Sponsor Licence?

A UK business does not need a sponsor licence simply because a candidate is an EU, EEA or Swiss citizen.

The deciding question is whether that person already has permission to work in the UK.

An EU citizen with valid settled or pre-settled status, Irish citizenship or another visa permitting the proposed work can normally be employed without sponsorship. An EU citizen moving to the UK for work without independent work permission will usually need to be sponsored under a route such as Skilled Worker.

Key points

• EU nationality alone no longer gives an automatic right to work in the UK.

• Settled and pre-settled status normally permit work without sponsorship.

• Irish citizens do not require UK immigration permission to work.

• Other visa holders may have independent work permission.

• New Skilled Worker roles are usually required to be higher-skilled.

• The usual Skilled Worker salary threshold is £41,700 or the going rate.

• Employers must complete a valid right-to-work check before employment begins.

• Current sponsorship costs are substantially higher than pre-2025 figures.

Do UK businesses need a sponsor licence to hire EU citizens?

Not always.

Following the end of EU free movement, most EU, EEA and Swiss citizens are subject to the UK immigration system in the same way as other non-British and non-Irish nationals.

However, nationality does not determine whether sponsorship is required. Immigration status does.

A UK employer will not normally need to sponsor an EU candidate who has:

• settled status under the EU Settlement Scheme;

• pre-settled status under the EU Settlement Scheme;

• Irish citizenship;

• indefinite leave to remain;

• a valid visa granting suitable work permission;

• a pending in-time application that preserves an existing right to work.

If the candidate has no independent permission to undertake the role in the UK, the employer will usually need an appropriate sponsor licence and must sponsor them under an eligible immigration route.

Official guidance confirms that most EU, EEA and Swiss citizens now prove their right to work using the Home Office online service, while Irish citizens can continue to use an Irish passport or passport card. See the Home Office guidance on employing EU citizens.

EU citizen hiring decision table

The employer must assess the actual work proposed. Permission that allows one type of activity does not necessarily permit every role or working arrangement.

Which EU citizens do not need sponsorship?

EU Settlement Scheme status

EU, EEA and Swiss citizens with valid settled or pre-settled status normally have the right to work in the UK without employer sponsorship.

The employer should use the Home Office online service to confirm:

• the person’s identity;

• whether they have the right to work;

• whether the proposed work is permitted; and

• whether a follow-up check is required.

Settled status provides a continuous right to work. Pre-settled status is time-limited immigration permission, although Home Office extensions and conversion arrangements may affect the date displayed in an inpidual case.

Employers should rely on the result of the official right-to-work check rather than trying to determine the employee’s future eligibility for settled status themselves.

Irish citizens

Irish citizens are protected by the Common Travel Area arrangements and do not normally require immigration permission to live or work in the UK.

They can prove their right to work using:

• a current or expired Irish passport; or

• a current or expired Irish passport card.

Irish citizens are not required to obtain EU Settlement Scheme status to work in the UK.

Holders of other UK visas

An EU citizen may already hold another visa that permits the proposed employment.

Examples include:

• Graduate;

• High Potential Inpidual;

• Global Talent;

• Youth Mobility Scheme;

• dependant partner;

• UK Ancestry; or

• family-route permission.

These routes have different conditions and expiry dates. The employer should check the actual Home Office record rather than assuming that every non-sponsored visa gives unrestricted work permission.

Which EU citizens normally need sponsorship?

An EU, EEA or Swiss citizen will normally require sponsorship where they:

• plan to move to the UK for employment;

• are not Irish;

• do not have settled or pre-settled status;

• do not hold another visa permitting the role; and

• cannot qualify under an unsponsored immigration route.

The most common employer-sponsored route is the Skilled Worker visa.

Example: recruiting a software engineer from Germany

Apex Digital Solutions wants to recruit Lukas, a German software engineer currently living in Berlin, for a permanent position in London.

Lukas is not Irish, does not have status under the EU Settlement Scheme and does not hold another UK visa.

Before Lukas can begin working in the UK, Apex will normally need to:

1. Confirm the visa category they wish to sponsor Lukas in (in this case it would be Skilled Worker);

2. hold a valid Skilled Worker sponsor licence;

3. identify the correct occupation code;

4. confirm that the position is eligible;

5. check that the salary meets the applicable requirements;

6. obtain and assign a Defined Certificate of Sponsorship;

7. pay the Certificate of Sponsorship fee;

8. pay the Immigration Skills Charge, unless an exemption applies; and

9. wait for Lukas to obtain the required immigration permission.

A job offer by itself does not give Lukas permission to begin work.

What are the Skilled Worker requirements in 2026?

RQF Level 3 and B1 requirements are no longer applicable for most new applicants.

The main requirements currently include:

These are general rules. Exceptions and alternative salary calculations can apply to:

• new entrants;

• relevant PhD holders;

• certain healthcare and education occupations;

• roles on the Immigration Salary List;

• medium-skilled roles on the Temporary Shortage List;

• applicants with transitional protection; and

• workers whose first Skilled Worker sponsorship pre-dates a relevant rule change.

The current standard salary requirement is generally £41,700 or the occupation going rate, whichever is higher. See the current Skilled Worker salary guidance.

Is RQF Level 3 still enough for a Skilled Worker visa?

Not generally.

From 22 July 2025, the normal skill threshold for new Skilled Worker applications increased to RQF Level 6.

Roles classed as “higher skilled” that are under Table 1 of Appendix Skilled Occupations can qualify, subject to the other requirements.

A role classed as “medium skilled” may qualify only where, for example:

• it appears on the Immigration Salary List;

• it appears on the Temporary Shortage List;

• a specific route provision applies; or

• the applicant benefits from transitional arrangements.

Employers should therefore not use the old “A-level or above” test when assessing a new hire. They should find the correct occupation code and check its current classification in the Home Office eligible occupations table.

Job titles are not decisive. The occupation code must reflect the worker’s actual duties.

What salary must an EU Skilled Worker receive?

Most new Skilled Worker applicants must be paid at least the higher of:

• the applicable general salary threshold; and

• the relevant occupation going rate.

The usual general threshold is currently £41,700 per year, but the precise calculation can change according to the applicable salary option.

Lower thresholds may apply in defined circumstances, including some:

• new entrants;

• relevant PhD holders;

• Immigration Salary List roles;

• healthcare or education roles using national pay scales; and

• applicants protected by transitional provisions.

A lower threshold should never be assumed merely because:

• the candidate is an EU citizen;

• the employer is a small business;

• the role is difficult to fill;

• the candidate accepts the salary; or

• the role previously qualified under older rules.

The employer must also assess whether particular allowances can be included and whether working hours alter the going-rate calculation.

What English level does an EU applicant need?

For most new Skilled Worker applicants, the requirement is now B2 on the Common European Framework of Reference for Languages.

The applicant must normally demonstrate reading, writing, speaking and listening ability through an accepted method, unless an exemption or transitional provision applies.

Evidence may include:

• nationality from a majority English-speaking country;

• an eligible UK qualification;

• an overseas degree taught in English and confirmed through the required process;

• an approved Secure English Language Test; or

• previous successful satisfaction of the requirement under an applicable route.

EU nationality does not create an automatic exemption.

The Home Office publishes the current route-specific levels in its English-language requirements guidance.

What is a genuine vacancy?

The position must represent genuine employment that exists within the sponsoring organisation.

The Home Office may question a role where:

• it appears to have been created primarily to secure immigration permission;

• the duties do not match the occupation code;

• the salary is inconsistent with the position;

• the business cannot explain why the role is required;

• the worker will actually undertake a different job;

• the proposed working arrangement is implausible; or

• the role involves providing personnel to fill an ongoing routine position for another organisation.

A genuine vacancy requirement does not mean the business must prove that no British worker was available. The former resident labour market test has been abolished.

The sponsor should nevertheless retain credible evidence of:

• the recruitment process;

• the job description;

• the reporting line;

• the business need;

• the candidate’s suitability;

• the work location; and

• how the role fits within the organisation.

How much does it cost to sponsor an EU citizen in 2026?

The employer’s principal sponsorship costs are:

The Certificate of Sponsorship and Immigration Skills Charge normally apply per sponsored worker, subject to route-specific exemptions.

Current ISC rates are confirmed in the Home Office employer guidance, while sponsorship and application fees appear in the Home Office fees table effective from 8 April 2026.

Example: sponsoring for three years

If a small sponsor assigns a three-year Skilled Worker CoS and no ISC exemption applies, its principal employer-side worker costs would normally include:

• £525 Certificate of Sponsorship fee; and

• £1,440 Immigration Skills Charge.

That produces £1,965 in worker-specific employer costs, excluding the original sponsor-licence application, legal advice and any optional immigration costs the employer chooses to cover.

For a medium or large sponsor, the equivalent CoS and ISC total would normally be £4,485.

Who must pay the sponsorship fees?

The sponsor is responsible for paying the sponsor-licence fee, Skilled Worker CoS fee and Immigration Skills Charge.

Home Office guidance restricts sponsors from recouping certain sponsorship costs from sponsored workers. Attempting to recover prohibited fees can place the sponsor licence at risk.

The worker will normally be responsible for their visa application fee and Immigration Health Surcharge unless:

• an exemption applies; or

• the employer voluntarily pays these costs.

Any repayment agreement should be reviewed carefully for immigration and employment-law compliance.

Does a sponsor licence still last four years?

Sponsor licences no longer generally expire after four years.

The Home Office abolished routine sponsor-licence renewals from 6 April 2024. Existing expiry dates were removed or extended, and newly granted licences do not normally require four-year renewal applications.

However, a licence can still be:

• suspended;

• downgraded;

• revoked;

• surrendered; or

• made dormant in relevant circumstances.

Sponsors must continue to meet their compliance duties even though routine licence renewal has ended.

How long does a sponsor licence application take?

Most sponsor-licence applications are decided in less than eight weeks, although the Home Office may conduct a compliance visit or request further information.

An eligible applicant may be able to pay £750 for pre-licence priority consideration. The service aims for the application to be considered within 10 working days.

Priority service:

• is subject to availability;

• does not guarantee a place;

• does not guarantee approval;

• does not prevent additional enquiries; and

• may not produce a final decision within 10 working days where the case requires further checks.

A business should therefore avoid promising a candidate a start date until the licence, CoS and worker’s visa are in place. See the official sponsor-licence application guidance.

Defined and Undefined Certificates of Sponsorship

The distinction is based primarily on the visa application being made—not merely the worker’s physical location.

Defined CoS

A Defined CoS is normally required where the prospective Skilled Worker will apply for entry clearance from outside the UK.

The sponsor must request it through the Sponsorship Management System and assign it after allocation.

Undefined CoS

An Undefined CoS is normally used for Skilled Worker applications made from inside the UK, including eligible extensions and changes of employment.

The worker must still be permitted to make the relevant application from inside the UK. A person cannot use an Undefined CoS to bypass the switching restrictions.

Can an EU visitor switch to Skilled Worker in the UK?

No. A person in the UK with Visitor permission cannot normally switch to the Skilled Worker route from inside the country.

The employer may still be able to sponsor them, but the person must ordinarily:

1. leave the UK;

2. receive a Defined CoS;

3. apply for Skilled Worker entry clearance from abroad; and

4. wait until permission is granted before starting the sponsored employment.

Employers should not allow a visitor to begin productive work while waiting for the visa.

How should employers check an EU citizen’s right to work?

The employer must use a check permitted by Home Office guidance.

For most EU, EEA and Swiss citizens with digital immigration status, the process is:

1. Ask the candidate to generate a right-to-work share code.

2. Obtain the candidate’s date of birth.

3. Enter the details in the Home Office employer service.

4. check that the photograph matches the candidate;

5. confirm that the person may undertake the proposed employment;

6. identify whether the permission is time-limited;

7. retain a clear copy of the online profile page; and

8. record the date on which the check was completed.

The employer must conduct the check before employment begins to establish a statutory excuse against a civil penalty.

Important exception for Irish citizens

An Irish citizen may normally prove their right to work using an Irish passport or passport card. The employer should not require an Irish citizen to produce EUSS status or a share code where an eligible document check is available.

Can an EU passport prove a right to work?

An EU, EEA or Swiss passport or national identity card alone is generally no longer acceptable evidence of a right to work.

The principal nationality-based exception is an Irish passport or Irish passport card.

Do not confuse proof of identity with proof of immigration permission.

What if the candidate has a pending EUSS application?

Some inpiduals with a valid pending EU Settlement Scheme application may have a temporary right to work.

The employer may need to examine the candidate’s Certificate of Application and use the Home Office online service or Employer Checking Service, depending on the document and the circumstances.

An employer should not automatically reject someone because their application is pending. Equally, it should not allow them to begin work merely because they say they have submitted an application.

The Home Office result must support the person’s right to undertake the proposed employment.

Employer scenarios

Scenario 1: French candidate with settled status

Claire’s company offers a role to Élodie, a French national who holds settled status.

Élodie provides a right-to-work share code. The online check confirms an ongoing right to work.

The company does not need a sponsor licence, a CoS or an Immigration Skills Charge payment for her employment.

Scenario 2: Spanish candidate with a Graduate visa

Mateo holds a Graduate visa valid for another 11 months.

The employer can hire him without sponsorship after completing the correct right-to-work check. However, it should record the visa expiry date and discuss future sponsorship well before the permission ends.

The Graduate visa cannot itself be extended, although Mateo may be able to switch into Skilled Worker if the role and application meet the rules.

Scenario 3: German candidate relocating to the UK

Lukas lives in Germany and has no UK immigration status.

The company wants him to work from its Manchester office. It must normally obtain the relevant sponsor licence and sponsor him before he begins work in the UK.

His German passport does not give him permission to take the job.

Scenario 4: EU employee working permanently from Europe

Sofia lives and works permanently in Portugal for a UK company and does not perform her employment duties in the UK.,

A UK sponsor licence is not normally required merely because the employer is British. However, the company must examine Portuguese employment, payroll, tax, social-security, data and permanent-establishment obligations.

If Sofia later begins working physically in the UK, the immigration analysis must be reconsidered.

Sponsor licence and EU hiring checklist

Before making an unconditional start-date commitment:

• Confirm the candidate’s nationality.

• Ask whether they already hold UK immigration permission.

• Identify the exact immigration route and expiry date.

• Complete the appropriate right-to-work check.

• Confirm that the permission covers the proposed work.

• Record whether a follow-up check is required.

• If sponsorship is needed, confirm the business holds the correct licence.

• Check that the licence is A-rated for new sponsorship.

• Identify the occupation code from the actual job duties.

• Confirm whether the role is higher-skilled or qualifies through a specific list.

• Calculate the applicable salary threshold and going rate.

• Confirm the worker meets the English-language requirement.

• Prepare evidence that the vacancy is genuine.

• Determine whether a Defined or Undefined CoS is required.

• Budget for the CoS fee and Immigration Skills Charge.

• Check whether any ISC exemption applies.

• Avoid passing prohibited sponsorship costs to the worker.

• Wait for appropriate permission before employment begins.

• Add the worker to the sponsor’s reporting and record-keeping systems.

Frequently asked questions

Do EU citizens need a visa to work in the UK after Brexit?

Usually, yes, unless they are Irish or already hold another status permitting work, such as settled status, pre-settled status or an eligible UK visa.

Do all EU employees need sponsorship?

No. Sponsorship is required only where the person does not already have permission to undertake the proposed work.

Can an employer accept an EU passport as proof of right to work?

Generally not. An EU, EEA or Swiss passport alone is normally insufficient. Irish passports and passport cards are an important exception.

Do settled-status holders need sponsorship?

No. A person with valid settled status can normally work without being sponsored.

Do pre-settled-status holders need sponsorship?

No, while their status gives them a valid right to undertake the employment. The employer should complete the online check and follow any stated follow-up requirements.

Does a Graduate visa holder need sponsorship?

Not during the valid Graduate permission. The employer may need to sponsor the person later if they wish to continue employing them after it expires.

What is the minimum Skilled Worker salary in 2026?

The usual general threshold is £41,700, but the worker must normally also meet the relevant occupation going rate. Different thresholds can apply under specific salary options.

Is an RQF Level 3 job eligible for Skilled Worker?

Not automatically. Most new applications require a higher-skilled occupation. Some medium-skilled RQF 3–5 roles remain eligible through the Immigration Salary List, Temporary Shortage List or transitional rules.

What English level is required for Skilled Worker?

Most new applicants must demonstrate English at B2 level, unless an exemption or transitional provision applies.

How much is a Skilled Worker CoS?

The current Skilled Worker Certificate of Sponsorship fee is £525.

How much is the Immigration Skills Charge?

For the first 12 months, it is currently £480 for a small or charitable sponsor and £1,320 for a medium or large sponsor. Additional six-month periods cost £240 or £660 respectively.

Does a sponsor licence need renewing every four years?

No. Routine four-year sponsor-licence renewals were abolished in April 2024.

How quickly can a company obtain a sponsor licence?

Most applications are dealt with within eight weeks. A limited £750 priority service aims for consideration within 10 working days but does not guarantee approval or availability.

Can an EU citizen visit the UK and begin working while sponsorship is arranged?

No. Visitor permission does not normally allow the person to begin UK employment or switch into Skilled Worker from inside the UK.

Can a UK company employ an EU citizen remotely from Europe?

Usually, no UK sponsor licence is required if the person remains physically outside the UK. Local employment, tax, payroll and regulatory requirements must still be assessed.

Does an employer have to advertise a role before sponsoring an EU worker?

There is no general resident labour market test. However, the employer must be able to demonstrate how the migrant worker was recruited and that the vacancy is genuine and appropriately coded.

Final thoughts

Brexit did not create a rule that every EU employee must be sponsored. It removed the assumption that EU nationality itself provides an unrestricted right to work.

For employers, the correct sequence is:

1. establish the candidate’s immigration status;

2. complete the appropriate right-to-work check;

3. determine whether sponsorship is genuinely required; and

4. if it is, test the role against the current occupation, salary and English-language rules.

This distinction matters commercially. Sponsoring unnecessarily creates cost and administration. Hiring without sponsorship where it is legally required can expose the business to civil penalties, disrupted onboarding and wider sponsor-licence action.

WBBI can assess the candidate’s existing work permission, determine whether the role qualifies for sponsorship and help the business establish a compliant hiring route.