Sponsor Licence compliance – How to avoid your licence being revoked

For companies looking to hire skilled workers from abroad, it is essential to have a sponsor licence.

After applying to the Home Office for a sponsor licence, it is understandable to think the hard work is over once granted but this is not the case. The licence is issued with a string of duties and obligations, and a failure by the company to adhere can lead to revocation.

The revocation of a sponsor licence is a very serious punishment and can stifle a business dependant on a migrant workforce. This blog will look at a few of the key areas of sponsor licence compliance to understand, equally important to those considering applying for a licence and those holding one.

Why revocation happens

The Home Office can propose a revocation on a sponsor licence for several reasons. The most common grounds include: 

• failing to meet sponsorship duties, such as inadequate monitoring of their workers;
• irregularities in record-keeping; and 
• failing to carry out proper right to work checks.

A company can be quite certain that, if they are failing on these duties, it will come to light during a sponsor licence compliance visit by the Home Office. It should be noted that compliance visits, where the Home Office will audit your records and processes, can be announced or unannounced. 

The most recent data provided by the Home Office indicates a 245% increase in sponsor licence suspensions, and a further 396% rise in revocations over 2024. These statistics reflect a new era in sponsor compliance, with enforcement action reaching fever pitch.

Our recommendation is to prepare for an unannounced visit, and so the best time to prepare is now.

The practical consequences

Holding a sponsor licence allows a company to hire migrant workers, and so revocation of one’s licence naturally has the opposite effect. Not only will a company be restricted from sponsoring further workers, the status of those they have already sponsored will be in question. 

Alongside high financial penalties, a company’s reputation can be damaged by the publishing of their non-compliance. 

How to challenge revocation 

After a sponsor licence compliance visit, the Home Office may choose to issue the company with a letter intending to revoke the licence and offer a deadline to submit representations challenging their intention. 

Depending on the result of these representations, challenging the revocation decision by Judicial Review may be necessary. This is both a lengthy and costly task, without a guarantee of success. 

How to prevent revocation

It is wiser to prevent than treat an issue, and so we would also recommend that a company maintains a robust sponsor licence compliance strategy to ensure they are doing everything right. It is not always possible to plug every gap, especially in a larger organisation, but in trying to do so a company can show that any issues identified by the Home Office are not systemic, but rather a one-off, and less consequential. 

Implementing sponsor licence compliance measures at the outset is crucial, and diligent record-keeping is key. This can and should involve a routine review of right to work policy, regular internal audits, and ensuring the relevant personnel are trained on the sponsorship duties to keep abreast of. 

Our experienced team of immigration lawyers are on hand to advise and help you navigate the complex UK immigration system for you. We’d be happy to have a discussion with any individuals or organisations looking for assistance. 

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