Appendix D: Record keeping for student sponsors

In October 2020, the Tier 4 (General) and Tier 4 (Child) immigration routes were replaced by the new Student and Child Student routes. In line with the UK’s new points-based immigration system, these study routes apply equally to both EEA and non-EEA students coming to the UK to study. In order to obtain a visa under the student routes, applicants must prove that they have been offered a place on a course by a licenced student sponsor.

Like any organisation sponsoring migrants to work within their business, educational institutions approved by the Home Office to sponsor students from overseas are expected to comply with certain requirements to effectively monitor the immigration status of your migrant students. These requirements are known as sponsor duties. Keeping accurate records on your sponsored students is a key part of your sponsor duties, and failure to comply with the rules could result in your licence being downgraded, suspended or revoked.

Following the launch of the new student routes, the Home Office published a series of updated immigration guidance documents to help education providers understand their legal obligations when sponsoring students under the points-based immigration system. Alongside the updated guidance, the Home Office also revised Appendix D, the document which outlines record keeping requirements, and lists the type of evidence that sponsors must retain.

Over the past four weeks, Smith Stone Walters have published a series of articles focused on key sections of the Appendix D document, to help sponsors gain a better understanding of their record keeping responsibilities.

In this final installment of the series, we take a look at the types of documents student sponsors will need to keep for each international student being sponsored on a course of study within their institution.

What documents should student sponsors keep?

According to Appendix D, student sponsors should keep the following records for each migrant they are sponsoring under the Student route or Child Student route:

  • A copy of the student’s current passport, including all pages showing personal identity details and biometric details, stamps or immigration status document showing their period of permission to stay in the UK.
  • A record of the student’s date of entry to the UK. In most cases, you can check this by looking for an entry stamp from an immigration officer. If the student does not have an entry stamp in their passport, you must ask to see other evidence of the date the student entered the UK, such as travel tickets or a boarding pass.
  • A copy of the student’s Biometric Residence Permit (BRP) or an electronic copy of the status if the student has a digital status.
  • A manual or electronic record of the student’s absence and attendance.
  • A history of the student’s contact details including UK residential address and telephone number. Contact details must be kept up to date, with any changes recorded.
  • Where the student’s course of study requires them to hold an Academic Technology Approval Scheme (ATAS) clearance certificate, you must keep a copy of the certificate or the electronic approval notice from the Foreign and Commonwealth Office.
  • If you are a Higher Education Provider (HEP) endorsing a migrant under the Tier 1 Start-up route, you must keep evidence of the selection process that resulted in that endorsement.
  • For migrants in the Child Student category who will be cared for by a private foster carer in the UK, you must provide details of the foster carer’s name and address to the local authority of the area in which the child will be living. Sponsors must keep a record of the notification to the local authority.
  • Copies of any evidence relating to the process of making an offer to the migrant. This could include copies of references or examination certificates.

Further details can be found in Appendix D of the guidance for sponsors here.

Support with maintaining sponsor compliance

If you have any questions about which documents you should be retaining, or if you require support on any other area of sponsor compliance, Smith Stone Walters can help.

Our team of immigration experts can offer up-to-date advice and practical support to ensure your organisation is fulfilling its legal obligations and is prepared for any Home Office compliance visit.

To speak to a member of the team, please contact us today.

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