Sponsor licences and compliance

If your licence is revoked, every sponsored worker you employ loses their permission. That is a business continuity problem that happens to be administered by the Home Office.

What revocation actually costs

It is worth being specific, because sponsor compliance is usually treated as an HR administrative task and it is not.

Every sponsored employee’s permission is curtailed. Not at renewal — at once. If a meaningful part of your workforce is sponsored, you lose them within a short period and cannot replace them through the same route.
You cannot reapply immediately. A cooling-off period applies, during which you cannot sponsor anyone.
It is public. The register of licensed sponsors is published, and so is the fact that you are no longer on it.
It affects more than immigration. Client contracts with continuity obligations, investor due diligence, and any transaction where the workforce is part of what is being bought.

Most licences are not revoked out of bad faith. They are revoked because nobody owned the compliance duties and an audit found gaps.

The duties, plainly

Record keeping. Right to work checks, contact details, contracts, absence records, recruitment records where required — kept in the specified form and produced on request.
Reporting. Changes must be reported through the Sponsorship Management System within defined periods: a worker not starting, employment ending, unauthorised absence, a change of role, salary or workplace, and changes to the business itself.
Monitoring. Knowing where your sponsored workers are, what they are doing, and that it matches the Certificate of Sponsorship.
Genuineness. The role must be genuine, at the required skill level, and paid at the required rate.

The change that has made compliance harder

From 8 April 2026, the required salary must be met in each pay period rather than averaged across the year.

This is a significant practical shift. An employer paying an annualised salary against genuinely variable hours, or running a short unpaid period, can now be in breach in a single month even where the annual figure is correct. Limited averaging remains available for genuinely variable-hours contracts, but only where it is properly documented.

Combined with the RQF 6 skill threshold since 22 July 2025 — which narrowed the eligible occupations considerably — a licence that was compliant two years ago may not be now.

If you have not reviewed your sponsorship arrangements since mid-2025, they are probably out of date.

The audit you should run before the Home Office does

Compliance visits can be unannounced. A review conducted while there is time to fix things is a different exercise from one conducted afterwards.

What it covers: whether your sponsored roles still meet RQF 6 and the correct SOC codes; whether every worker’s salary meets the threshold and the going rate in each pay period; whether reporting has been done within the time limits; whether the right to work checks were carried out correctly and would establish a statutory excuse; whether records are in the specified form; and whether the people named on the licence are still in post and still doing the job.

That last one accounts for more problems than any other. Key personnel leave, nobody updates the licence, and reporting stops.

If you have been suspended or revoked

Act immediately. There are short windows to respond, and what you say in that response matters a great deal.

Do not respond without advice. A response that concedes more than it needs to, or that fails to address the specific allegations, is difficult to recover from. There is no appeal against revocation in the ordinary sense — the route is judicial review, on short deadlines and a demanding standard.

What we do

Licence applications, including for businesses that have been refused before. Compliance audits. Preparing for and attending compliance visits. Responding to suspension and revocation. Training key personnel. And advising on what a licence means before you apply — it is a set of ongoing duties, not a permission.

Ongoing compliance work sits naturally within our business counsel arrangement.

What it costs

Licence applications are a fixed fee, quoted before we begin. Compliance audits are a fixed fee based on the number of sponsored workers. Suspension and revocation work is hourly at £400 plus VAT, because the scope depends entirely on what is alleged.

Questions

Questions people ask us

How long does a licence application take?

Home Office processing times vary and priority services are sometimes available. The longer part is usually preparation — having the systems, records and named personnel in place before applying, rather than promising to put them in place afterwards.

What triggers a compliance visit?

They can be unannounced and are not always triggered by anything. A first licence, a sudden increase in Certificates of Sponsorship, an allegation, or a pattern in reporting can all prompt one.

A sponsored worker resigned. What do I report?

The end of employment, through the Sponsorship Management System, within the specified period. Late reporting is one of the most common findings against sponsors and one of the easiest to avoid.

Our salaries are annualised across variable hours. Is that a problem?

Potentially, since 8 April 2026. The required salary must be met in each pay period, with limited averaging available only for genuinely variable-hours contracts that are properly documented. Worth checking now rather than at an audit.

Our licence has been suspended. Can we appeal?

Not by way of appeal. You respond within the window given, and if the outcome is revocation the route is judicial review — short deadlines, demanding standard. The response to the suspension is therefore the most important document in the process.

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