Sponsor Licence Compliance, Suspension and Revocation

Your duties as a sponsor

Holding a sponsor licence is a privilege that comes with duties set out in the Home Office's Workers and Temporary Workers sponsor guidance. The Home Office checks compliance through unannounced visits, digital audits and data matching with HMRC. The main duties are:

• Record keeping: right-to-work checks, contact details, contracts, salary evidence and absence records for every sponsored worker (Appendix D).
• Reporting: telling the Home Office within 10 working days when a worker does not start, is absent without permission for 10 consecutive working days, stops working for you, changes role or salary, or when your business changes ownership, address or key personnel.
• Genuine vacancy and skill level: only sponsoring workers in roles that exist and meet the rules, at the salary on the CoS.
• Cooperation: allowing visits and providing information on request.
• Not passing on costs: never recovering the licence fee, CoS fee or Immigration Skills Charge from workers.

Suspension: what happens and how to respond

If a compliance visit or a data check raises concerns, the Home Office may suspend your licence and write setting out the alleged breaches. While suspended you cannot assign new Certificates of Sponsorship, but existing workers can continue to work. You have 20 working days to make written representations with evidence. The Home Office then decides whether to reinstate the licence (with or without an action plan and downgrade to a B-rating), or revoke it.

This is where the outcome is decided. A well-organised response that addresses each allegation with documents, explains any errors honestly, and shows what has been fixed can and does result in reinstatement. Vague assurances do not. We have restored licences for care providers, hospitality groups and professional firms by rebuilding the evidence file and demonstrating that the compliance systems now work.

Revocation and what you can do about it

Revocation ends your ability to sponsor. Your sponsored workers receive letters curtailing their permission to 60 days to find a new sponsor or leave, and you will usually face a 12-month cooling-off period before you can apply again. There is no right of appeal. The only legal challenge is judicial review in the Administrative Court, which must be brought promptly and in any event within 3 months of the decision.

Judicial review tests whether the Home Office acted lawfully and rationally, not whether it was right on the merits, so the strength of the original representations matters enormously. Where the decision is unlawful (for example because the Home Office did not consider your evidence or applied the wrong guidance) we send a pre-action letter immediately, which in some cases leads to the decision being withdrawn without proceedings.

In parallel we advise on protecting your workers, including new sponsorship by a group company where possible, and on the fastest lawful route back to sponsoring.

Compliance audits and mock visits

The best time to instruct us is before a letter arrives. Our audit reviews your Sponsorship Management System, HR files, right-to-work checks, salary payments and reporting history against the current guidance, then delivers a written report and an action plan. We can attend a real Home Office visit with you and prepare your key personnel for the interview questions officers actually ask.

1. Document request

   We ask for your SMS access, HR files for a sample of sponsored workers and your policies.

2. Gap analysis

   We test each sponsor duty and identify breaches, missing reports and weak evidence.

3. Fix and train

   Templates, checklists and a short training session for HR and key personnel.

4. Ongoing support

   Optional retainer for reporting queries, CoS assignments and annual re-audits.

Sponsor licence revoked with immediate effect: what happened next

Watch

Sponsor licence revoked with immediate effect: what happened next

A care provider lost its licence. How we responded and what every sponsor should learn from it.

More on this topic:

• Expired BRP? Read this before you act

All videos and guides

Frequently asked questions