Revocation of Sponsor Licences

Care providers are facing challenges from the Home Office, particularly in areas such as maintaining payments in line with the Certificate of Sponsorship (“CoS”) and failure to comply with reporting duties. Even discrepancies that might appear minor, such as not reporting temporary reduced hours compared to those stated on the CoS, can trigger investigations that may result in the loss of a sponsor licence.

As enforcement measures become stricter and penalties rise, it is essential for care providers to stay informed of current trends and ensure robust internal processes to safeguard their sponsorship status.

One of the significant current trends contributing to sponsor licence revocation is the Home Office’s collaboration with HMRC to obtain real-time updates on payroll information. By cross-checking the data provided by care providers to HMRC with the details submitted for sponsored workers, the Home Office can quickly identify inconsistencies with reported salaries or working hours for care workers. If, for instance, a care worker’s actual earnings do not match what was declared on their CoS, this may be seen as a breach of sponsorship duties.

The Home Office is often carrying out these investigations behind the scenes, before even notifying the care provider that it is looking into anything. The findings can prompt a request for further information from the Home Office and may lead to the revocation of a sponsor licence.

Another critical area the Home Office is actively checking is right to work checks. The Home Office has intensified its examination of care providers’ procedures for verifying employees right to work. Its expectations are that care providers must maintain thorough and accurate records as part of their sponsor duties. Failures in carrying out correct checks or gaps in records of valid checks are treated as serious breaches especially if the care worker is found to not have the right to work.

Penalties for failing to conduct a correct right to work check can reach up to £45,000 per illegal worker for a first breach. The number of civil penalties is rising. The highest number for one quarter in 2024 was 568 penalties issued, but by Q1 in 2025 they had reached 748. It is therefore essential that sponsors refresh themselves on how to carry out a proper right to work check, and that reminders are diarised to reconfirm the right to work when a visa is due to expire. Care providers should routinely audit their right to work checks and maintain clear records to minimise risk, as the Home Office is actively seeking out discrepancies and is quick to take action where compliance fails.

Our Immigration team specialises in all aspects of UK immigration law and can help you navigate these issues. With the Home Office focusing on compliance and taking action in respect of non-compliance, it is important to ensure you are meeting your sponsorship duties. Our team can assist you further by carrying out a Mock Compliance Audit of your files and processes, providing training on compliance and sponsorship duties, right to work checks and providing general advice and support including assistance and representation on instances of licence suspensions.