A shareholding change in 2024, and a reporting deadline that had already passed

An architecture practice on a long-standing compliance retainer had restructured its shareholding two years earlier. Nobody had reported it. Eighteen to twenty sponsored employees were attached to a licence that now needed replacing.

At a glance

• Client: Urban design and architecture practice
• Sponsored employees: 18 to 20, all requiring transfer to a new licence
• Relationship: AY&J compliance retainer client since 2022
• Trigger: A 2024 change of shareholding requiring a new sponsor licence; the reporting deadline had passed
• Instructed: 14 July 2026

How they found us

A long-standing client, on our compliance retainer since 2022.

The challenge

• The change of shareholding had taken place in 2024 and the reporting deadline had long passed by the time the firm was instructed in July 2026.
• A new sponsor licence was required, and eighteen to twenty sponsored employees' status depended on getting it and transferring them cleanly.
• Our assessment was that while there was no guarantee of an audit, the combination of a late-reported restructuring and a new licence application increased the chance of Home Office review.
• The old licence had to be wound down without leaving anyone unsponsored in between.

What we did

• Reported the change, late, rather than leaving it unreported. A sponsor management system report notifying the restructuring, made as the first step.
• Applied for the new licence to a fixed timetable. Within twenty working days, with full legal representation, document advice, compliance systems guidance, templates, training and preparation for any pre-licence visit or interview.
• Planned the transfer before the licence arrived. Reporting to move all sponsored workers and their sponsorship certificates to the new licence once granted, then making the old licence dormant.
• Audited alongside, on the assumption of scrutiny. Full compliance audit covering worker files, payroll and salary compliance, reporting review, right to work review, gap analysis, policy review, a mock Home Office audit and interview preparation, with thirty days of post-delivery support.

Why it matters

Corporate changes that feel purely commercial, such as a share transfer, a restructure or a new holding company, are reportable events with short deadlines. The people who notice are rarely the people doing the deal. A retainer exists to catch exactly this, and here it caught it two years late, which is still early enough to fix.