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The UK Home Office has released important updates to the Student and Child Student sponsor guidance, with particular focus on guardianship arrangements, sponsorship duties, and compliance thresholds. These changes are now in effect and require immediate action from all independent school sponsors.

Guardianship and care arrangements

Nominated guardians

When a guardianship organisation is arranging a nominated guardian (e.g., a homestay provider), and details of the individual guardian are not yet available, the sponsor must instead obtain:

  • Name and contact details of a member of staff at the guardianship organisation
  • Name and address of the guardianship organisation
  • Date the organisation was established
  • Confirmation that all guardians used have a current enhanced DBS check (England and Wales), PVGS (Scotland), or DBS (Northern Ireland)

Background checks

UKVI caseworkers must confirm that the intended carer or nominated contact:

  • Is a British citizen or settled in the UK
  • Provides appropriate immigration status evidence as part of the visa application

New: Letter of Undertaking requirements

For Child Students not in full-time boarding, a Letter of Undertaking is now mandatory from the carer or guardian. For clarity, this is required for “Child Students, who will be living in the UK with a guardian outside of term time/during the holidays". The letter must include:

  • Full contact and address details of the carer
  • Where the child will reside
  • Confirmation the accommodation is private and non-commercial
  • Relationship with the child’s parents or legal guardians
  • Agreement to care for the child
  • Criminal record declaration (no adult in the household has relevant convictions)
  • Confirmation of financial capacity to support the child (if applicable)
  • Signature and date

Expanded definition of ‘Nominated Guardian’

The term now includes:

  • Any individual appointed for fewer than 28 days a year
  • Any person acting in an emergency contact role

These individuals must:

  • Be a British citizen or settled in the UK
  • Undergo enhanced safeguarding scrutiny

Permitted living arrangements (Updated categories)

When assigning a CAS for a Child Student, the sponsor must confirm one of the following approved living arrangements:

1. Full boarding at an independent residential school, and during school breaks in the UK, living with a British citizen or settled person who is a:

  • Nominated guardian (under 28 days)
  • Private foster carer
  • Close relative

While UKVI does not require a guardian for a full-time boarder who will not stay in the UK during school holidays. National Minimum Guardian Standards (NMGS) do require that all international students in the UK, regardless of their boarding status, have a UK-based guardian appointed.

This requirement sits alongside UKVI immigration rules and is typically enforced by schools (especially those affiliated with the Boarding Schools' Association or using AEGIS-accredited guardianship services) to ensure:

  • 24/7 emergency contact and support
  • Local representation if a child is suspended, hospitalised or during holidays
  • Safeguarding continuity for all international students

2. Weekly boarding, and at weekends/outside term time, living with a:

  • Private foster carer
  • Close relative

3. Flexi-boarding, with supplementary care from a:

  • Private foster carer
  • Close relative

4. Living with a private foster carer or close relative who is a British citizen or settled.

5. Living with a parent or legal guardian who holds a Parent of a Child Student visa.

6. If aged 16 or 17, the student may live independently.

Sponsorship duties and record-keeping

  • Appendix D now applies primarily to Skilled Worker routes and not child student and student routes.
  • For Student and Child Student routes, sponsors must retain records under Sponsorship Duties.

Required documents include:

  • Guardian/carer consent from parents
  • Signed undertakings or contracts
  • Identity checks or AEGIS accreditation (if applicable)
  • Policies outlining guardian criteria
  • Notifications to local authorities (for private foster care)

Updated sponsor compliance metrics (BCA)

The Basic Compliance Assessment (BCA) thresholds could change in the future:

  • Refusal rate: Reduced to 5% (from 10%)

    • (Applies if you issue over 50 CAS annually, or at UKVI discretion)

  • Course completion rate: Increased to 90% (from 85%)
  • Enrolment rate: Increased to 95% (from 90%)

Additional notes

  • Agent details can be added in the CAS – not mandatory (yet)
  • Agent Quality Framework (AQF) pledge encouraged by September – not mandatory until then, but best practice

What you should do now

  • Review your guardianship policies and record-keeping
  • Update internal checklists to capture new Letter of Undertaking requirements
  • Verify all living arrangements conform to the updated categories
  • Check your current BCA metrics and plan for the new thresholds
  • Ensure your compliance staff understand these changes

Our team of experts is available to provide guidance and support to help your institution navigate these changes effectively. Please feel free to email us at se@sableinternational.com or call us on +44 20 7759 5316 if you have any questions.