Sponsor Licence Revoked: What Happens to Sponsored Workers?

Sponsor Licence Revocation & Sponsored Workers: At a Glance

If an employer’s sponsor licence is revoked, the impact can extend immediately across its sponsored workforce and international recruitment pipeline. Existing sponsored workers, pending applicants, prospective recruits and workers who have been granted entry clearance but have not yet travelled can all be affected.

The consequences are not the same for every worker. Where an existing sponsored worker was not actively and knowingly involved in the circumstances leading to revocation, the Home Office will normally cancel or shorten their immigration permission so that they have up to 60 calendar days remaining. If their existing permission expires sooner, revocation does not create a fresh 60-day period.

Workers considered actively and knowingly involved in the conduct leading to revocation can face cancellation of all remaining permission. Different issues also arise for pending applications, workers outside the UK, dependants and certain sponsored adult social care workers covered by temporary Home Office arrangements.

Employers therefore need to run two workstreams in parallel: addressing the sponsor licence decision and carrying out an immediate worker-by-worker assessment of the immigration, employment and operational consequences across the sponsored workforce.

This guide explains what happens to sponsored workers after sponsor licence revocation, how the 60-day position works, what happens to Certificates of Sponsorship and pending applications, and how employers should manage affected workers and preserve available immigration options.

 

Section A: What Happens to Sponsored Workers When a Sponsor Licence Is Revoked?

 

Once a sponsor licence is revoked, the employer is no longer authorised by the Home Office to sponsor workers. Certificates of Sponsorship assigned by the organisation become invalid and the Home Office can take consequential action affecting workers whose immigration permission depends on that sponsorship.

The outcome depends on the worker’s individual circumstances. For an existing sponsored worker who was not actively and knowingly involved in the conduct leading to revocation, the Home Office will normally cancel or shorten their permission so that they have up to 60 calendar days remaining.

That period is a maximum. Cancellation cannot extend existing permission, so a worker with only 30 days remaining when the Home Office takes action would not ordinarily receive a new 60-day period.

During the time available, the worker may need to secure sponsorship from another licensed employer and make a new immigration application, apply under another immigration route where eligible or prepare to leave the UK before their permission expires.

A more serious position applies where the Home Office considers the worker to have been actively and knowingly involved in the circumstances leading to revocation. In those cases, it will normally cancel all remaining permission.

Revocation can also affect workers who have not yet started employment. An assigned CoS becomes invalid automatically. Where an overseas entry clearance application remains undecided, current Home Office sponsor guidance states that the application will automatically be refused. Where entry clearance has already been granted but the worker has not yet travelled to the UK, the guidance states that the entry clearance will be cancelled.

Applications made from within the UK require separate assessment according to the application, the worker’s existing immigration position and whether another lawful basis for remaining can be established before the Home Office reaches a decision.

Employers should therefore treat revocation as a worker-by-worker immigration exercise rather than applying one assumption or deadline across the sponsored population.

 

1. Sponsor Licence Revocation: Worker Consequences

 

Worker’s circumstances	Potential consequence
Existing sponsored worker not involved in the breach	The Home Office will normally cancel or shorten permission so that up to 60 calendar days remain.
Worker already has fewer than 60 days of permission remaining	The existing earlier expiry date will normally continue to apply. Cancellation does not create a fresh 60-day period.
Worker actively and knowingly involved in the conduct leading to revocation	The Home Office will normally cancel all remaining permission rather than allowing the usual period available to an uninvolved worker.
Worker outside the UK with a pending entry clearance application	The assigned CoS automatically becomes invalid and current sponsor guidance states that the entry clearance application will automatically be refused.
Worker has been granted entry clearance but has not travelled to the UK	Current sponsor guidance states that the entry clearance will be cancelled.
Worker has an in-country application pending	The position requires individual assessment. The worker may need to address the loss of sponsorship before the Home Office decides the application.
Worker secures sponsorship with another licensed employer	A new Certificate of Sponsorship and an appropriate immigration application may allow the worker to remain under a sponsored route.
Worker has dependant family members	The immigration position of dependant partners and children may also be affected by action against the main applicant’s permission.
Certain sponsored adult social care workers	A temporary Home Office policy may prevent cancellation where sponsor licence revocation is the sole reason for cancellation.

 

2. Employers Should Assess Each Sponsored Worker Individually

 

Employers should identify everyone whose immigration or recruitment position depends on the revoked sponsor licence and record the factors that determine the urgency of each case.

 

• the worker’s immigration route;
• the expiry date of their existing permission;
• their Certificate of Sponsorship;
• whether they are currently inside or outside the UK;
• whether an immigration application is outstanding;
• whether entry clearance has already been granted;
• whether the worker is specifically mentioned in any Home Office allegations;
• whether alternative sponsorship may be available;
• whether there are dependant family members whose permission may also be affected; and
• whether any route-specific Home Office policy or temporary concession applies.

 

For employers with a larger sponsored workforce, this should be managed as a formal workforce triage exercise with clear ownership, deadlines and escalation, rather than as an informal review of visa expiry dates.

 

3. Sponsor Licence Revocation & Visa Cancellation Are Not the Same Thing

 

Revocation of the employer’s sponsor licence and cancellation of an individual worker’s immigration permission are connected but separate Home Office actions.

Revocation removes the organisation’s authority to sponsor workers. The Home Office then considers or takes consequential action affecting individuals whose immigration permission depends on that sponsorship.

A sponsored worker does not necessarily become an overstayer at the moment the employer receives its revocation decision. Equally, the worker should not assume that their status will remain unaffected until the original expiry date shown on their visa or digital immigration status.

The employer therefore needs to establish the worker’s actual immigration position, any Home Office action taken against their permission and the deadline by which further action may be required.

Current Home Office sponsor guidance on the effect of revocation on sponsored workers is contained in Workers and Temporary Workers: guidance for sponsors, Part 3: Sponsor duties and compliance.

 

 

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Section B: Sponsor Licence Revocation: Key Consequences for Workers

 

The consequences of sponsor licence revocation can differ considerably between workers. Employers should not assume that the same immigration outcome or deadline will apply across the sponsored workforce.

The principal consequences can include the cancellation or shortening of existing immigration permission, invalidation of Certificates of Sponsorship and disruption to pending applications, recruitment and planned travel to the UK.

 

1. Existing Sponsored Workers

 

Where a worker is already in the UK with immigration permission based on sponsorship from the employer, revocation of the sponsor licence can lead to the Home Office cancelling or shortening that worker’s permission.

Where the worker was not actively and knowingly involved in the circumstances that led to the licence being revoked, the Home Office will normally cancel or shorten their permission so that they have 60 calendar days remaining.

This period can provide the worker with an opportunity to take action in response to the loss of their sponsor.

Depending on their circumstances, this could include:

 

• securing sponsorship from another licensed employer;
• making a new immigration application under an appropriate sponsored work route;
• applying under a different immigration route for which they qualify; or
• making arrangements to leave the UK before their permission expires.

 

The worker should not assume that their existing immigration permission will simply continue until its original expiry date.

 

2. Workers With Less Than 60 Days Remaining

 

The commonly referenced 60-day period is a maximum rather than a guaranteed additional period of immigration permission.

Cancellation action cannot be used to extend existing permission.

If the worker already has 60 calendar days or less remaining when cancellation action is considered, the Home Office will not normally cancel or shorten that permission.

For example, if a worker has only 25 days remaining on their existing permission when consequential action is taken following revocation, they should not expect their permission to be extended to 60 days.

This can be critical for employers managing a sponsored workforce in which different employees have different visa expiry dates.

 

3. Workers Involved in the Circumstances Leading to Revocation

 

A materially different position can apply where the Home Office considers that a sponsored worker was actively and knowingly involved in the circumstances that resulted in the sponsor losing its licence.

Current Home Office sponsor guidance gives the example of a worker who was knowingly complicit in a non-existent job arrangement.

Where the worker is considered complicit, the Home Office will normally cancel all of the worker’s remaining immigration permission rather than allowing the usual period available to an uninvolved worker to regularise their position.

Employers should therefore avoid giving all affected employees a blanket assurance that they will receive 60 days following revocation.

 

4. Certificates of Sponsorship

 

Revocation also affects Certificates of Sponsorship assigned by the organisation.

Certificates of Sponsorship assigned by a sponsor whose licence has been revoked automatically become invalid.

This is particularly important where a worker has been assigned a CoS but their immigration application has not yet been decided.

For an overseas worker who has made an entry clearance application based on that CoS, current Home Office sponsor guidance states that the application will automatically be refused.

The employer will also no longer be able to assign new Certificates of Sponsorship.

The effect on an individual worker will depend on the stage they have reached in the immigration process.

An employee already working in the UK with existing permission is in a different position from an overseas applicant whose entry clearance application is still pending.

 

5. Pending Immigration Applications

 

Pending immigration applications need to be divided between overseas entry clearance applications and applications made from within the UK.

For overseas entry clearance applications, the position is explicit. Where the application relies on a Certificate of Sponsorship assigned by a sponsor whose licence has been revoked, the CoS automatically becomes invalid and current Home Office sponsor guidance states that the entry clearance application will automatically be refused.

For in-country applications, the position requires individual assessment according to the type of application, the worker’s existing immigration status and whether another lawful basis for remaining in the UK can be established before the Home Office makes its decision. If a live application continues to rely on sponsorship from the revoked sponsor and the basis is not varied before decision, the Home Office will refuse the application.

A worker with an in-country application should not assume that the application remains unaffected simply because it was submitted before the sponsor lost its licence.

Where alternative sponsorship becomes available, urgent consideration should be given to the correct immigration procedure before the outstanding application is determined.

 

6. Workers Granted Entry Clearance But Not Yet in the UK

 

Revocation can also affect workers whose immigration application has already been approved but who have not yet travelled to the UK.

Current Home Office sponsor guidance states that where entry clearance has been granted but the sponsored worker has not yet travelled to the UK when the licence is revoked, that entry clearance will be cancelled.

Employers should therefore review not only their existing UK workforce but also sponsored recruits who are overseas and preparing to travel.

Continuing with relocation, travel or onboarding arrangements without first establishing the worker’s immigration position can create significant practical and financial difficulties.

 

7. Dependants of Sponsored Workers

 

Sponsor licence revocation can also have consequences for the dependant partners and children of sponsored workers.

Where the main sponsored worker’s immigration permission is cancelled, the Home Office must also consider whether to cancel permission granted to dependants in line with the main applicant. Where dependant permission is cancelled, the Home Office will normally align the dependant’s expiry date with the date applying to the main applicant.

The position of the whole family should therefore be considered when assessing the consequences of revocation for an individual employee.

This can be particularly important where the worker has a partner in employment in the UK, children attending school or other significant family arrangements that depend on their continuing lawful residence.

 

8. Different Workers May Need Different Solutions

 

For employers with multiple sponsored workers, revocation should therefore be treated as a workforce triage exercise rather than as a single immigration event.

The employer should establish, for each affected person:

 

1. their sponsored immigration route;
2. their current immigration permission expiry date;
3. whether they are currently inside or outside the UK;
4. whether their immigration application has already been decided;
5. whether they have an outstanding application;
6. whether a Certificate of Sponsorship has been assigned;
7. whether they have dependant family members;
8. whether any Home Office allegation concerns the worker personally;
9. whether another immigration route or alternative sponsor may be available; and
10. whether any specific Home Office policy or temporary arrangement applies to their circumstances.

 

The sooner this exercise is completed, the more time the employer and affected workers have to understand their respective positions and consider the available options.

 

 

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Section C: Does Sponsor Licence Revocation Automatically Cancel a Worker’s Visa?

 

Not necessarily. Sponsor licence revocation and cancellation of a sponsored worker’s immigration permission are closely connected, but they are legally and administratively distinct events.

Revocation is action against the sponsor. It removes the organisation’s authority to sponsor migrant workers.

Cancellation or shortening of immigration permission is action affecting the individual worker.

The loss of the sponsor licence does not mean that every sponsored worker instantaneously becomes an overstayer at the moment the licence is revoked.

Instead, the Home Office can take consequential action against the immigration permission of workers whose status depends on the revoked sponsor.

For a worker who was not actively and knowingly involved in the conduct leading to revocation, the normal approach is for the Home Office to cancel or shorten their existing permission so that they have up to 60 calendar days remaining, subject to the original expiry date of their permission.

Where the worker has fewer than 60 days remaining, their permission is not extended to provide a fresh 60-day period.

Where the worker was actively and knowingly involved in the circumstances leading to revocation, a more severe outcome can follow. Current Home Office sponsor guidance states that the Home Office will normally cancel all of the worker’s remaining permission.

There can also be circumstances where specific Home Office policy affects the usual approach. The current temporary arrangements applying to certain sponsored adult social care workers are an important example.

Employers should therefore establish the current position applying to each worker rather than relying solely on the general 60-day rule.

 

1. Revocation of Sponsorship Is Not the Same as Expiry of Immigration Permission

 

An employer should not tell workers that their immigration permission has automatically expired merely because the sponsor licence has been revoked.

Equally, workers should not be told that their immigration permission is unaffected and will simply continue until its original expiry date.

Neither statement accurately reflects the general position.

The relevant questions are:

 

1. What immigration permission does the worker currently hold?
2. When is that permission due to expire?
3. Has the Home Office taken, or indicated that it will take, cancellation action?
4. Was the worker actively and knowingly involved in the circumstances leading to revocation?
5. Is there a specific Home Office policy or temporary arrangement affecting the worker?
6. Does the worker have a pending immigration application?
7. Is the worker currently inside or outside the UK?
8. Can the worker obtain alternative sponsorship or qualify under another immigration route?

 

These questions determine the practical response and the urgency of the worker’s case.

 

2. Will the Home Office Contact Sponsored Workers?

 

The Home Office will notify sponsored workers of the revocation promptly, although it will not disclose the reasons for the sponsor’s revocation.

Employers should not assume that the absence of immediate contact means that a worker’s position is secure.

There can be a period between the sponsor being notified that its licence has been revoked and consequential action being taken in relation to individual members of the sponsored workforce.

Equally, employers should avoid attempting to predict the precise wording, effective date or outcome of an individual Home Office decision where it has not yet been issued.

The appropriate approach is to identify affected workers promptly, explain the known consequences accurately and ensure that individuals understand the importance of monitoring and responding to Home Office correspondence.

 

3. When Does Cancellation of a Worker’s Permission Take Effect?

 

Employers and workers should not automatically calculate the end of the worker’s immigration permission by counting 60 days from the date on which the sponsor receives its revocation decision.

The revocation of the sponsor licence and the consequential cancellation or shortening of an individual worker’s permission are separate actions.

Where the Home Office cancels or shortens the worker’s permission, the individual decision should identify the date on which the cancellation takes effect or the date on which the remaining permission will expire.

The worker should therefore check the Home Office notification affecting their own immigration status rather than assuming that their immigration deadline is 60 days from the date of the employer’s revocation letter.

This can become particularly important where there is a delay between the employer receiving the revocation decision and the Home Office taking consequential action in relation to individual workers.

 

4. Immigration Permission, Sponsorship & Right to Work Are Different Issues

 

Employers should also distinguish between three related but separate concepts:

 

• immigration permission – the individual’s legal permission to enter or remain in the UK;
• sponsorship – the employer’s Home Office authorisation to sponsor the worker under the relevant immigration route; and
• right to work – whether the individual is lawfully permitted to undertake the particular employment in question.

 

The fact that a worker’s digital immigration status continues to display an unexpired period of permission does not restore the employer’s sponsor licence or mean that the organisation can disregard the consequences of revocation.

Equally, the loss of the sponsor licence should not automatically be described as making every affected employee an overstayer from the moment of revocation.

The employer needs to establish the worker’s individual immigration position and the implications for their continued employment.

A right to work check should not be treated as a substitute for assessing the sponsorship and immigration consequences of revocation.

 

5. Why the Distinction Matters for Employers

 

The difference between sponsor licence revocation and individual immigration permission is not merely technical.

It affects how the employer manages:

 

• employee communications;
• immigration compliance;
• right to work issues;
• pending immigration applications;
• international recruitment;
• employees currently overseas;
• employment arrangements;
• potential moves to alternative licensed sponsors;
• workforce planning; and
• the organisation’s response to the revocation itself.

 

Employers should therefore manage the sponsor enforcement problem and the individual worker immigration problem as connected but separate workstreams.

The sponsor may need urgent advice on whether and how the revocation decision can be challenged, while individual sponsored workers may simultaneously need to consider alternative sponsorship or other immigration options.

Neither process should be allowed to obscure the other.

 

 

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Section D: Do Sponsored Workers Get 60 Days After Sponsor Licence Revocation?

 

Sponsored workers will often have up to 60 calendar days to deal with the immigration consequences of their employer losing its sponsor licence, but the frequently referenced “60-day rule” is not an automatic guarantee that every affected worker will receive a fresh 60 days in the UK.

Where the Home Office revokes an employer’s sponsor licence and the sponsored worker was not actively and knowingly involved in the circumstances leading to revocation, the normal approach is to cancel or shorten the worker’s immigration permission so that they have 60 calendar days remaining.

This can provide a limited period in which the worker can consider their options. These may include finding another licensed sponsor, making a new immigration application under an appropriate route or preparing to leave the UK.

Employers should nevertheless be careful when explaining the 60-day position to affected employees.

 

1. The 60 Days Is a Maximum, Not an Extension

 

Cancellation action cannot be used to extend a person’s existing immigration permission.

This means the worker will normally have the shorter of:

 

• 60 calendar days; or
• the time remaining until their existing immigration permission expires.

 

For example, if a Skilled Worker has 18 months remaining when their employer’s sponsor licence is revoked, the Home Office will normally cancel or shorten their permission so that they have 60 calendar days remaining, provided the worker was not actively and knowingly involved in the circumstances leading to revocation.

If another employee has only 35 days remaining on their existing permission when cancellation action is considered, the Home Office will not normally cancel or shorten that permission; the existing expiry date remains the relevant deadline.

An employer with several sponsored workers may have employees facing very different immigration deadlines following the same licence revocation.

 

2. When Does the 60-Day Period Start?

 

Employers and workers should not simply calculate 60 days from the date on which the employer receives the sponsor licence revocation decision.

The sponsor licence decision and the subsequent action affecting an individual worker’s immigration permission are separate matters.

Where the Home Office cancels or shortens the worker’s permission, the individual should check the Home Office notice affecting their immigration status to establish the date on which their permission will end.

This is particularly important where there is a delay between the sponsor being notified of revocation and the worker receiving notification about their own immigration status.

The operative deadline for the individual should therefore be established from the immigration decision affecting that individual rather than assumed from the date of the sponsor’s revocation letter.

 

3. What Can a Worker Do During the Remaining Period?

 

The period before the worker’s immigration permission expires can provide an opportunity to regularise their position, but it should not be regarded as a general grace period during which all existing employment arrangements can simply continue unchanged.

Depending on the individual’s circumstances, possible options can include:

 

1. obtaining sponsorship from another employer with a valid sponsor licence;
2. making an appropriate immigration application under the sponsored work route using new sponsorship;
3. applying under another immigration category for which the worker qualifies; or
4. leaving the UK before their immigration permission expires.

 

Where alternative sponsorship is being considered, the worker will generally need more than a job offer.

The prospective employer must be able to sponsor the worker under the relevant route, the role must meet the applicable requirements and a valid Certificate of Sponsorship will normally need to be assigned before the relevant immigration application is made.

The worker must also comply with the conditions of their existing immigration permission and the rules applying to any change of employment.

 

4. Does the 60-Day Period Mean the Worker Can Continue Working for the Revoked Sponsor?

 

No assumption should be made that shortened immigration permission gives the worker a right to continue working for the revoked sponsor throughout the remaining period.

Once the sponsor licence has been revoked, the employer is no longer authorised to sponsor migrant workers.

Current GOV.UK guidance for workers whose employer loses its sponsor licence states that the sponsored worker will have to leave their job and leave the UK unless they make a new visa application to stay.

The potential 60-day period should therefore be understood as an immigration period in which an unaffected worker may be able to address their position. It should not be presented as an automatic 60-day continuation of sponsored employment with the employer whose licence has been revoked.

This is different from sponsor licence suspension, where existing sponsored workers who already have valid immigration permission can generally continue working while the licence remains suspended.

 

5. Do Workers Have to Wait for the Home Office Before Looking for Another Sponsor?

 

No. An affected worker does not need to wait until the end of their remaining immigration permission before looking for alternative sponsorship.

Given the time required to identify another employer, complete recruitment processes, obtain a Certificate of Sponsorship and prepare an immigration application, early action can be important.

From the employer’s perspective, this means affected employees may begin exploring alternative employment very quickly after revocation.

Employers should anticipate this when considering workforce continuity, employee communications and the operational consequences of losing the sponsor licence.

 

6. Does Challenging the Revocation Stop the 60-Day Process?

 

Employers should not assume that taking steps to challenge a sponsor licence revocation automatically protects the immigration position of sponsored workers.

The employer’s challenge to the Home Office decision and the immigration position of individual employees need to be considered separately.

There is no general statutory right of appeal against sponsor licence revocation. Depending on the circumstances, an employer may instead consider whether the decision can be challenged through judicial review.

The existence of a potential challenge should not therefore be used as a reason for affected workers to ignore their own immigration position or relevant deadlines.

Starting, preparing or threatening judicial review proceedings does not by itself mean that the effects of revocation have been suspended or that individual immigration deadlines no longer apply.

Employers contemplating a challenge should consider at an early stage how the legal strategy interacts with the position of their sponsored workforce.

 

7. The 60-Day Rule Should Not Be Treated as Universal

 

There are circumstances in which the normal 60-day approach will not apply.

Most importantly, a worker who was actively and knowingly involved in the circumstances leading to revocation can face cancellation of all of their remaining immigration permission rather than the usual period available to an uninvolved worker.

There may also be specific Home Office policies affecting particular groups of workers.

Current Home Office policy concerning certain sponsored adult social care workers, for example, provides an important temporary exception to the normal cancellation approach where sponsor licence revocation is the sole reason for cancellation.

The appropriate question for employers is therefore not simply:

“Do our sponsored workers get 60 days?”

Instead, the employer should determine:

 

1. which sponsored workers are affected;
2. what immigration permission each person currently holds;
3. when that permission is due to expire;
4. whether the Home Office alleges that the worker was personally involved in the conduct leading to revocation;
5. whether the worker has received an individual cancellation decision;
6. whether a specific Home Office policy applies;
7. whether alternative sponsorship or another immigration route is available; and
8. what deadline applies to the individual worker.

 

This worker-by-worker assessment is more reliable than applying a blanket 60-day assumption across the sponsored workforce.

Official information for workers whose employer loses its sponsor licence is available in the GOV.UK guidance on what happens when a worker’s sponsor loses their licence.

 

 

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Section E: When Can a Sponsored Worker’s Permission Be Cancelled Immediately?

 

The normal position for a sponsored worker who was not actively and knowingly involved in the circumstances leading to sponsor licence revocation is that the Home Office will normally cancel or shorten their immigration permission so that they have up to 60 calendar days remaining.

However, this protection should not be assumed to apply to every sponsored worker.

Where the Home Office considers that an individual worker was actively and knowingly involved in the conduct that resulted in the sponsor licence being revoked, the worker can face a substantially more serious immigration consequence.

Current Home Office sponsor guidance states that in these circumstances the Home Office will normally cancel all of the worker’s remaining permission.

This distinction makes it essential for employers to identify whether allegations made during the sponsor compliance or revocation process concern the organisation generally or implicate particular sponsored workers personally.

 

1. What Does “Actively and Knowingly Involved” Mean?

 

The issue is not simply whether a worker happened to be employed by a sponsor that breached its sponsorship duties.

A worker should not be treated as complicit merely because their employer has lost its sponsor licence.

The relevant question is whether the worker was actively and knowingly involved in the circumstances that resulted in revocation.

Current Home Office sponsor guidance gives the example of a worker who was knowingly complicit in a non-existent job arrangement.

Depending on the circumstances of the case, concerns could potentially arise where evidence indicates that a worker knowingly participated in arrangements involving matters such as:

 

• a job that did not genuinely exist;
• sham or artificial employment arrangements;
• false information concerning the role being undertaken;
• deliberate misrepresentation of employment circumstances;
• fraudulent documentation connected with sponsorship; or
• other conduct forming part of the reasons for the sponsor licence being revoked.

 

These examples should not be treated as creating an automatic rule that any irregularity involving a worker establishes complicity. The Home Office would need to consider the individual worker’s circumstances and the evidence relevant to them.

 

2. Not Every Sponsor Compliance Breach Implicates the Worker

 

Many sponsor licence breaches arise from failures by the employer rather than misconduct by sponsored workers.

Examples can include failures relating to:

 

• record keeping;
• reporting changes through the Sponsor Management System;
• sponsor licence key personnel;
• monitoring sponsored workers;
• maintaining appropriate HR systems;
• reporting organisational changes;
• compliance with sponsor reporting deadlines; or
• other sponsor management failures.

 

The fact that an employee was sponsored by the organisation while such breaches occurred does not, without more, mean that the worker actively and knowingly participated in them.

Employers should therefore avoid treating all sponsored workers as though they have the same level of immigration risk.

The distinction between organisational non-compliance and individual complicity can determine whether a worker would normally receive a limited period to regularise their immigration position or face cancellation of all remaining permission.

 

3. Workers Specifically Mentioned in the Home Office Allegations

 

Where particular workers are named or identifiable in the Home Office allegations leading to revocation, their cases should be reviewed separately and urgently.

The employer should establish:

 

1. what allegation has been made;
2. what evidence the Home Office relies on;
3. whether the allegation concerns the employer, the worker or both;
4. whether the worker is alleged to have known about the relevant conduct;
5. whether there is evidence contradicting the allegation;
6. whether the worker has received separate Home Office correspondence;
7. what immigration permission the worker currently holds; and
8. whether any individual immigration response is required.

 

An allegation made against the sponsor should not automatically be adopted as a finding against the individual worker without considering the evidence and the worker’s own circumstances.

Equally, where the revocation decision contains clear allegations of deliberate participation by particular workers, the employer should not give those individuals the same assurances about the 60-day period that may be appropriate for uninvolved workers.

 

4. Why Complicity Can Change the Immigration Outcome

 

The distinction is significant because the usual protection for an innocent sponsored worker recognises that the employee may lose their sponsor through circumstances outside their control.

Where the worker had no involvement in the sponsor’s breaches, the normal cancellation approach can provide a limited opportunity to find another sponsor, make another immigration application or arrange to leave the UK.

Where the worker knowingly participated in the conduct that caused the sponsor to lose its licence, the Home Office does not apply the same approach.

Current sponsor guidance provides that the Home Office will normally cancel all remaining permission where it believes the worker was actively and knowingly involved in the reasons for revocation.

The difference can therefore be substantial.

An uninvolved worker with substantial permission remaining may ordinarily have that permission shortened so that 60 calendar days remain.

A worker found to have been actively and knowingly involved can instead face cancellation of all remaining permission.

 

5. Employers Should Preserve Evidence Relating to Individual Workers

 

Where revocation involves allegations about individual employees, employers should preserve relevant records and evidence.

This can include:

 

• employment contracts;
• job descriptions;
• recruitment records;
• payroll information;
• bank or salary payment records;
• timesheets and attendance records;
• work allocation records;
• emails and other workplace communications;
• performance records;
• evidence of the work actually undertaken;
• Certificate of Sponsorship information;
• SMS reporting records; and
• documents provided during any Home Office compliance investigation.

 

This evidence may be relevant both to the employer’s response to the sponsor licence revocation and to questions concerning an individual worker’s immigration position.

Employers should also avoid retrospectively altering records or creating documents intended to reconstruct a compliant position after the event. Records should be preserved in their existing form, with any subsequent explanations or evidence clearly identified as such.

 

6. Employers Should Not Promise Every Worker 60 Days

 

One of the most important practical consequences of the distinction between innocent and complicit workers is how the employer communicates with staff following revocation.

A blanket statement such as:

“Everyone has 60 days to find another sponsor.”

can be inaccurate.

The correct position depends on the individual worker.

For an employee who was not actively and knowingly involved in the circumstances leading to revocation, the Home Office will normally cancel or shorten their permission so that they have up to 60 calendar days remaining, subject to the existing expiry date of their permission.

For a worker whom the Home Office considers to have been actively and knowingly involved, all remaining permission may normally be cancelled.

Other workers may have fewer than 60 days remaining already, pending applications, dependant family members or circumstances falling within a specific Home Office policy.

The safer approach is therefore to tell employees that the immigration consequences are being assessed individually and that each sponsored worker should establish the deadline and options applying to their own immigration position.

 

7. Immediate Cancellation Should Not Be Confused With Automatic Overstaying on Revocation

 

The possibility that a complicit worker may have all remaining permission cancelled does not mean that every sponsored worker becomes an overstayer automatically when the employer’s licence is revoked.

These are different propositions.

Sponsor licence revocation removes the organisation’s authority to sponsor workers.

The Home Office then deals with the immigration consequences for affected individuals according to their circumstances and the applicable immigration rules and guidance.

Employers should therefore avoid both extremes:

 

• assuming that every sponsored worker automatically receives 60 days; or
• assuming that every sponsored worker automatically becomes an overstayer at the moment the licence is revoked.

 

The appropriate response is a worker-by-worker assessment based on the individual’s immigration status, involvement in the circumstances leading to revocation and any Home Office action taken in their case.

 

 

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Section F: Can Sponsored Workers Continue Working After the Licence Is Revoked?

 

Sponsored workers should not assume that they can continue working for an employer whose sponsor licence has been revoked simply because they still have time remaining on their immigration permission.

This is an important distinction because the period remaining on a worker’s immigration permission following revocation is not the same as a continuing entitlement to work for the revoked sponsor.

Once the sponsor licence has been revoked, the organisation is no longer authorised by the Home Office to sponsor migrant workers.

Current GOV.UK guidance for sponsored workers states that where an employer loses its sponsor licence, the worker will have to leave their job and leave the UK unless they make a new visa application to stay.

Employers should therefore not describe the commonly referenced 60-day period as a period during which sponsored employees can simply continue working as normal.

 

1. The 60-Day Period Is Not a 60-Day Right to Continue Working

 

Where an uninvolved worker has their immigration permission cancelled or shortened so that up to 60 calendar days remain, that period can provide time to address their immigration position.

It should not, however, be treated as an automatic continuation of sponsored employment with the employer whose licence has been revoked.

The worker may use the available period to consider options such as:

 

• finding another licensed sponsor;
• obtaining a new Certificate of Sponsorship;
• making an appropriate application based on new sponsorship;
• applying under another immigration route where eligible; or
• making arrangements to leave the UK.

 

The employer should therefore distinguish between the time a worker may remain lawfully in the UK and whether that worker can continue undertaking the sponsored employment following revocation.

 

2. Revocation Is Different From Sponsor Licence Suspension

 

The position following revocation should not be confused with the position while a sponsor licence is suspended.

Suspension is an interim enforcement measure. The organisation remains a licensed sponsor while the Home Office considers what further action should be taken, although its ability to undertake certain sponsorship activity is restricted.

Existing sponsored workers who already have valid immigration permission can generally continue working for the sponsor while the licence is suspended.

Revocation is different.

Once the licence has been revoked, the organisation has lost its authority to sponsor workers.

This distinction is particularly important where an employer has moved through a Home Office enforcement process involving:

 

1. a compliance investigation;
2. suspension of the sponsor licence;
3. representations by the sponsor; and
4. a subsequent decision to revoke the licence.

 

The fact that sponsored employees were able to continue working during the suspension stage should not lead the employer to assume that the same position continues after revocation.

 

3. An Unexpired eVisa Does Not Restore the Sponsor Licence

 

Employers should also be careful where a sponsored worker’s digital immigration status continues to show immigration permission extending beyond the date of revocation.

The fact that an eVisa displays an unexpired period of immigration permission does not restore the employer’s sponsor licence or remove the consequences of revocation.

There can be a distinction between:

 

• the date on which the sponsor licence is revoked;
• the worker’s existing immigration permission;
• the date on which the Home Office takes consequential cancellation action;
• the date on which that cancellation takes effect; and
• the worker’s entitlement to undertake particular employment.

 

Employers should therefore avoid relying solely on the expiry date displayed on a worker’s immigration status when determining what action should be taken following revocation.

 

4. Right to Work & Sponsorship Are Not Interchangeable

 

A further source of confusion is the relationship between sponsorship and the statutory right to work regime.

These are related but distinct compliance systems.

A right to work check concerns whether an individual has permission to undertake employment in the UK and the conditions attached to that permission.

A sponsor licence concerns whether an organisation is authorised by the Home Office to sponsor workers under the relevant immigration routes.

Employers should therefore avoid treating a right to work check as if it independently resolves all of the consequences of sponsor licence revocation.

In particular, an online status showing unexpired immigration permission should not be interpreted as restoring the employer’s authority to sponsor the individual.

Where the worker’s immigration position is unclear, the employer may need to consider the appropriate Home Office right to work process, including whether an online check or, where applicable, the Employer Checking Service is required.

The purpose of that process should remain clear: it can assist with establishing an individual’s right to work, but it does not reinstate a revoked sponsor licence.

 

5. Employers Should Avoid Two Opposite Assumptions

 

There are two potentially problematic assumptions employers can make following revocation.

The first is:

“The workers have 60 days, so they can continue working for us for another 60 days.”

This is not a safe interpretation of the 60-day provision. The remaining immigration period is not a general 60-day right to continue sponsored employment for the revoked sponsor.

The second is:

“The licence has been revoked, so every sponsored worker immediately becomes an illegal worker and an overstayer.”

This also fails to distinguish the revocation of the sponsor licence from consequential action against an individual worker’s immigration permission.

The correct approach is to identify the immigration and employment position of each worker and take appropriate action based on their circumstances.

 

6. Employment Law Issues Should Be Considered Alongside Immigration Compliance

 

The loss of a sponsor licence can create immediate employment law and workforce management issues in addition to immigration consequences.

An employer should not assume that sponsor licence revocation automatically determines how an employee’s contract should be brought to an end.

Depending on the circumstances, issues may arise concerning:

 

• contractual rights;
• notice;
• pay;
• dismissal procedures;
• fairness;
• discrimination;
• alternative employment;
• temporary arrangements;
• redeployment; and
• the employer’s ability lawfully to continue employing the individual.

 

The immigration and employment law analyses should therefore be coordinated.

Employers need to protect their immigration compliance position without assuming that the loss of sponsorship removes all employment law obligations owed to affected workers.

 

7. What Should Employers Do About Existing Sponsored Employees?

 

Following revocation, employers should undertake an urgent review of the sponsored workforce.

For each worker, the employer should:

 

1. confirm the immigration route under which they are sponsored;
2. identify the worker’s current immigration permission and expiry date;
3. establish whether the worker has received any Home Office cancellation notice;
4. review whether the worker is implicated in the reasons for revocation;
5. identify whether any specific Home Office policy applies to the worker;
6. consider the worker’s right to work and employment position;
7. identify any outstanding immigration application;
8. establish whether alternative sponsorship may be available;
9. consider the position of dependant family members; and
10. document the decisions taken in relation to the employee.

 

Where the organisation employs a significant number of sponsored workers, this process should be managed centrally to avoid different departments giving employees inconsistent information.

 

8. Communications With Sponsored Workers

 

Employee communications following sponsor licence revocation need to be accurate and carefully managed.

Employers should avoid blanket statements such as:

 

• “your visa has been cancelled immediately”;
• “you automatically have 60 days”;
• “you can continue working for us for the next 60 days”; or
• “nothing changes until your current visa expires”.

 

Any of these statements can be inaccurate depending on the worker’s circumstances.

Instead, affected employees should be informed that the sponsor licence has been revoked, that this can affect their immigration and employment position and that their individual circumstances need to be assessed.

Workers should also be encouraged to monitor Home Office communications carefully and to obtain advice on their individual immigration position where appropriate.

Official Home Office information for sponsored workers is available in the GOV.UK guidance on what happens if a worker’s employer loses its sponsor licence.

 

 

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Section G: Can a Sponsored Worker Find a New Sponsor?

 

Potentially, yes. One of the principal options for a sponsored worker affected by sponsor licence revocation is to secure sponsorship from another employer that holds a valid sponsor licence.

However, sponsorship does not automatically transfer from the revoked employer to the new organisation.

The worker will normally need a genuine qualifying role with the new employer, a new Certificate of Sponsorship and an appropriate immigration application before they can move into the new sponsored employment.

Given the potentially limited period available following revocation, workers and prospective sponsors may need to act quickly.

 

1. Sponsorship Cannot Simply Be Transferred to Another Employer

 

A Certificate of Sponsorship is assigned by a particular licensed sponsor in connection with a particular sponsored role.

It cannot simply be transferred from an employer whose sponsor licence has been revoked to another organisation.

If the worker finds another employer willing to sponsor them, the new employer will need to undertake its own sponsorship process.

This will normally involve:

 

1. confirming that the organisation holds the appropriate sponsor licence;
2. assessing whether the worker can be sponsored under the relevant immigration route;
3. confirming that the proposed role satisfies the applicable sponsorship requirements;
4. checking the relevant occupation code and skill requirements;
5. confirming that the applicable salary requirements are met;
6. assigning a new Certificate of Sponsorship; and
7. enabling the worker to make the appropriate immigration application.

 

The fact that the worker was previously sponsored does not remove the new sponsor’s obligation to establish that the new employment independently satisfies the Immigration Rules and sponsor requirements.

 

2. A New Job Offer Is Not Enough

 

A job offer from another employer does not, by itself, resolve the worker’s immigration position.

The prospective employer must be authorised to sponsor the worker and the proposed employment must qualify for sponsorship under the relevant route.

The new sponsor will normally need to assign a fresh Certificate of Sponsorship before the worker makes the relevant application.

The worker should therefore distinguish between:

 

• finding another employer;
• receiving a job offer;
• obtaining valid sponsorship from that employer;
• making the required immigration application; and
• being permitted to commence the new sponsored employment.

 

These are separate stages.

Where the worker is operating within a limited period following cancellation or shortening of their existing permission, delays at any stage can become significant.

 

3. The New Employer Must Hold the Correct Sponsor Licence

 

The prospective employer must hold a sponsor licence covering the relevant route before it can sponsor the worker.

Workers can check whether an organisation appears on the Home Office Register of licensed sponsors: workers.

However, appearing on the register does not mean that every vacancy offered by that organisation is automatically eligible for sponsorship.

The employer still needs to determine whether the particular role and worker satisfy the relevant requirements.

Where an organisation does not already hold the necessary sponsor licence, obtaining one can take time. This may make it difficult to rely on that organisation as an immediate solution where the affected worker has only a limited period remaining.

 

4. The New Role Must Qualify for Sponsorship

 

Alternative sponsorship is only viable if the proposed employment satisfies the requirements of the relevant immigration route.

For a Skilled Worker, this can require consideration of matters including:

 

• whether the job is eligible for sponsorship;
• the applicable occupation code;
• the skill level of the role;
• the salary being offered;
• the applicable going rate;
• any route-specific salary provisions or discounts;
• whether the vacancy is genuine; and
• whether the worker satisfies the relevant immigration requirements.

 

The new sponsor should carry out this assessment independently rather than relying on the fact that the worker held sponsored permission with the previous employer.

A role that qualified under the worker’s previous sponsorship does not automatically mean that a different role with another employer will also qualify.

 

5. The Worker Will Normally Need a New Certificate of Sponsorship

 

The Certificate of Sponsorship assigned by the employer whose licence has been revoked cannot simply be reused by another organisation.

The new licensed sponsor will normally need to assign its own Certificate of Sponsorship for the new role.

The Certificate of Sponsorship should accurately reflect the proposed employment, including relevant information about the role, occupation code, salary and other sponsorship details.

Where the worker is already in the UK, the new sponsor should also ensure that the appropriate type of Certificate of Sponsorship is assigned for the application being made.

The new sponsorship arrangement should be assessed on its own merits and should not be treated as an administrative transfer of the previous sponsorship.

 

6. The Worker Will Usually Need to Make a New Immigration Application

 

Obtaining a new Certificate of Sponsorship does not itself change the worker’s immigration permission.

The worker will normally need to make an appropriate application to reflect the new sponsorship.

For example, a Skilled Worker changing to a different sponsoring employer will generally need to apply to update their visa before starting the new sponsored employment.

The application should be made while the worker still has a lawful basis on which to remain and apply in the UK, where the relevant Immigration Rules permit an in-country application.

Workers should not allow their existing permission to expire merely because they are waiting for a prospective employer to complete its sponsorship process.

Official information on changing sponsored employment is available in the GOV.UK Skilled Worker guidance on updating a visa when changing job or employer.

 

7. Can the Worker Start Working for the New Sponsor While the Application Is Pending?

 

Workers should not assume that submitting an immigration application based on new sponsorship automatically allows them to start the new sponsored job immediately.

The ability to undertake employment while an application is pending depends on the worker’s existing immigration permission, the conditions attached to that permission, the nature of the application and the applicable Immigration Rules.

In a standard Skilled Worker change-of-employer situation, the worker will generally need to wait until the new application has been granted before starting the new sponsored job.

The worker and prospective employer should therefore establish the permitted start date before employment begins.

This is particularly important following sponsor licence revocation because the worker may simultaneously be dealing with:

 

• the loss of their previous sponsor;
• cancellation or shortening of existing permission;
• a new Certificate of Sponsorship;
• a new immigration application; and
• restrictions on when the new sponsored employment can commence.

 

The new sponsor should not assume that assigning a Certificate of Sponsorship is sufficient to authorise the worker to start work.

 

8. The New Sponsor Should Carry Out Its Own Compliance Assessment

 

A prospective sponsor should not treat an affected worker as a simple transfer from another employer.

The new organisation assumes its own sponsorship duties if it sponsors the worker.

Before assigning a Certificate of Sponsorship, the new employer should therefore assess matters such as:

 

• the worker’s current immigration status;
• the expiry date of their permission;
• the reason their previous sponsor lost its licence, where relevant and known;
• whether the worker was implicated in the circumstances leading to revocation;
• the eligibility of the proposed role;
• salary and occupation code requirements;
• the worker’s qualifications and experience where relevant;
• right to work requirements;
• the appropriate Certificate of Sponsorship; and
• the immigration application required before the worker starts the sponsored role.

 

This can be particularly important where the Home Office revocation decision involved concerns about the genuineness of sponsored roles or individual workers.

A new sponsor should not assume that the Home Office will disregard those circumstances simply because another organisation is willing to offer the worker employment.

 

9. Workers Should Start Looking for Alternative Sponsorship Early

 

The practical difficulty for many affected workers is time.

Finding a new sponsor can involve:

 

1. identifying suitable vacancies;
2. applying for roles;
3. completing interviews;
4. agreeing employment terms;
5. the employer completing its sponsorship assessment;
6. assignment of a new Certificate of Sponsorship;
7. preparing the immigration application;
8. submitting the application; and
9. waiting for the Home Office decision before starting the new sponsored employment where required.

 

A worker with up to 60 days remaining may therefore have considerably less practical time than the headline period initially suggests.

Where the worker already had fewer than 60 days remaining when their sponsor lost its licence, the timeframe can be shorter still.

Workers should therefore consider alternative sponsorship as early as possible rather than waiting for the end of the available period.

 

10. Alternative Immigration Routes May Also Be Available

 

Finding another sponsor is not necessarily the only way an affected worker can remain in the UK.

Depending on their personal circumstances, a worker may qualify to apply under another immigration route that does not depend on sponsorship by the revoked employer.

The available options will depend on factors such as the worker’s immigration history, family circumstances, qualifications and eligibility under the relevant Immigration Rules.

Employers should avoid advising workers that finding another sponsor is their only possible immigration solution unless the individual’s wider circumstances have been assessed.

At the same time, the employer should not assume responsibility for determining an employee’s personal immigration strategy without appropriate advice.

The immediate employer-side priority is to identify affected workers, communicate the consequences accurately and ensure that employees are given sufficient information to take action on their individual immigration position.

 

 

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Section H: What Happens to Certificates of Sponsorship After Revocation?

 

Revocation of a sponsor licence has direct consequences for Certificates of Sponsorship assigned by the organisation.

Once the sponsor licence has been revoked, the organisation can no longer sponsor workers or assign new Certificates of Sponsorship. Certificates of Sponsorship that have already been assigned by the revoked sponsor automatically become invalid.

The practical consequences depend on how far the worker has progressed through the sponsorship and immigration process.

This means employers should review not only existing sponsored employees but also their entire international recruitment pipeline as soon as the licence is revoked.

 

1. Assigned Certificates of Sponsorship Become Invalid

 

Current Home Office sponsor guidance states that Certificates of Sponsorship assigned by a sponsor whose licence has been revoked automatically become invalid.

This can affect workers at several different stages, including those who:

 

• have been assigned a CoS but have not yet made an immigration application;
• have made an overseas entry clearance application that remains undecided;
• have made an application from within the UK;
• have already been granted entry clearance but have not yet travelled to the UK; or
• are preparing to join the organisation at a future date.

 

The consequences are not identical in every scenario, which is why each worker needs to be identified and categorised separately.

 

2. What If a CoS Has Been Assigned But the Worker Has Not Yet Applied?

 

If the employer assigned a Certificate of Sponsorship before its licence was revoked but the worker has not yet used that CoS to make an immigration application, the worker cannot rely on the invalid CoS as the basis for a new sponsored application.

The employer cannot simply reissue or replace the CoS after revocation because it no longer has authority to sponsor workers.

If the individual wishes to pursue sponsored employment in the UK, they would generally need to identify another appropriately licensed sponsor willing and able to sponsor them in a qualifying role.

That new sponsor would need to undertake its own sponsorship assessment and, where the requirements are met, assign its own Certificate of Sponsorship.

 

3. What If the Worker Has Made an Overseas Entry Clearance Application?

 

The position is particularly clear where an overseas worker has already submitted an entry clearance application based on a Certificate of Sponsorship assigned by the employer whose licence has subsequently been revoked.

Current Home Office sponsor guidance states that assigned Certificates of Sponsorship automatically become invalid following revocation and that an entry clearance application based on such a CoS will automatically be refused.

This is stronger than simply saying that the application is “at risk” because of the sponsor licence revocation.

Employers should therefore identify overseas recruits with outstanding entry clearance applications immediately and ensure that they are not given inaccurate assurances that their application can continue unaffected.

Where another licensed employer is prepared to sponsor the individual, the immigration position and appropriate next steps will need to be considered separately.

 

4. What If an In-Country Application Is Pending?

 

Applications made from within the UK should not automatically be treated in exactly the same way as pending overseas entry clearance applications.

The Home Office sponsor guidance expressly addresses the automatic refusal of an entry clearance application based on a Certificate of Sponsorship that becomes invalid following revocation.

Where a worker has an application for permission to stay pending from within the UK, their position should instead be assessed according to the application they have made, their existing immigration status and whether another lawful basis for the application can be established before the Home Office makes its decision. If the live application continues to rely on sponsorship from the revoked sponsor and the basis is not varied before decision, the Home Office will refuse the application.

The worker should not assume that submitting the application before the sponsor licence was revoked protects the application from the consequences of the subsequent loss of sponsorship.

If alternative sponsorship becomes available, urgent advice may be required on the correct procedural approach to the outstanding application and any further application that may be needed.

 

5. Can a CoS Be Transferred to Another Sponsor?

 

No. A Certificate of Sponsorship cannot simply be transferred from the revoked sponsor to another employer.

The CoS was assigned by a particular sponsor in connection with a particular sponsored role.

If another organisation wants to employ and sponsor the worker, that employer must hold the appropriate sponsor licence and satisfy the relevant sponsorship requirements in its own right.

Where the requirements are met, the new sponsor would normally assign a new Certificate of Sponsorship for the new role.

The worker would then need to take the appropriate immigration steps based on that new sponsorship.

This remains the case even where the two organisations are commercially connected or form part of the same wider corporate group. Common ownership does not allow a Certificate of Sponsorship assigned by one legal entity to be administratively transferred to another sponsor.

 

6. What Happens to the Sponsor’s Remaining CoS Allocation?

 

Once the sponsor licence has been revoked, the organisation can no longer use its sponsor licence to assign Certificates of Sponsorship.

Any unused allocation should therefore not be treated as available for future sponsorship activity.

The employer should immediately stop processes that assume further workers can be sponsored under the revoked licence.

This can affect:

 

• planned overseas recruitment;
• workers awaiting CoS assignment;
• existing employees expected to move into sponsored status;
• future graduate recruitment;
• international transfers;
• new starters whose sponsorship process is incomplete; and
• business units relying on future sponsored recruitment.

 

The impact of revocation can therefore extend considerably beyond workers who already hold sponsored immigration permission.

 

7. Does Challenging Revocation Keep Existing Certificates of Sponsorship Valid?

 

Employers should not assume that challenging the sponsor licence revocation automatically preserves the validity of Certificates of Sponsorship assigned under the revoked licence.

There is no general statutory right of appeal against sponsor licence revocation. Depending on the circumstances, the sponsor may consider whether the decision can be challenged through judicial review.

However, the fact that the employer disputes the decision, is preparing a challenge or has commenced proceedings does not by itself restore the sponsor licence or make invalid Certificates of Sponsorship valid again.

The employer should therefore continue to assess the immigration position of affected workers while any challenge to the revocation is being pursued.

If the Home Office subsequently withdraws or reconsiders its decision, or a court grants relevant relief, the resulting position would need to be assessed according to the circumstances and effect of that development.

 

8. Employers Should Review the Entire Recruitment Pipeline

 

A sponsor licence revocation response should include a review of every individual whose recruitment or immigration position depends on the organisation’s sponsorship.

The employer should identify:

 

1. existing sponsored workers in the UK;
2. workers temporarily outside the UK;
3. workers with pending in-country applications;
4. overseas workers with pending entry clearance applications;
5. workers who have been granted entry clearance but have not yet travelled;
6. workers who have been assigned a CoS but have not yet applied;
7. candidates waiting for a CoS to be assigned;
8. employees expected to switch into a sponsored route;
9. international transferees whose move depends on sponsorship; and
10. future recruits whose employment plans assume that the organisation remains able to sponsor.

 

Each individual should then be categorised according to their immigration and recruitment position.

This allows the organisation to determine which cases require immediate immigration action, which recruitment processes need to be stopped and which workers may need to explore alternative sponsorship.

 

9. CoS Records Should Be Preserved

 

The employer should preserve records relating to Certificates of Sponsorship even though the licence has been revoked.

Relevant records can include:

 

• CoS reference information;
• the information recorded when each CoS was assigned;
• job descriptions;
• occupation codes;
• salary information;
• employment contracts;
• recruitment records;
• copies of immigration applications where lawfully held;
• SMS records and reports; and
• communications relating to sponsored recruitment.

 

These records may remain relevant to the reasons for revocation, any challenge to the Home Office decision, individual worker cases and the organisation’s wider compliance review.

The employer should not delete sponsorship records simply because it no longer has authority to sponsor workers.

Current Home Office guidance on the consequences of sponsor licence revocation, including the treatment of Certificates of Sponsorship, is contained in Workers and Temporary Workers: guidance for sponsors, Part 3: Sponsor duties and compliance.

 

 

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Section I: What If the Worker Has Already Applied for Their Visa?

 

Sponsor licence revocation can have serious consequences where a worker has already submitted an immigration application but the Home Office has not yet made a decision.

The precise position depends on whether the worker is applying from outside the UK for entry clearance or from within the UK for permission to stay.

This distinction is important because current Home Office sponsor guidance expressly provides for the automatic refusal of an entry clearance application based on a Certificate of Sponsorship that becomes invalid following sponsor licence revocation. An in-country application requires a more individual assessment of the worker’s immigration and procedural position.

Employers should therefore identify all outstanding immigration applications immediately after revocation rather than treating pending applicants as a single category.

 

1. Overseas Entry Clearance Application Still Pending

 

Where an overseas worker has already applied for entry clearance using a Certificate of Sponsorship assigned by the employer, and the sponsor licence is subsequently revoked before the application is decided, the consequences are significant.

Current Home Office sponsor guidance states that Certificates of Sponsorship assigned by the revoked sponsor automatically become invalid.

Where an entry clearance application relies on that Certificate of Sponsorship, the guidance states that the application will automatically be refused.

This should therefore not be described merely as creating a risk that the application might fail.

The employer should identify affected overseas applicants promptly and avoid allowing recruitment, relocation or travel arrangements to proceed on the assumption that the original sponsorship remains effective.

 

2. In-Country Application Still Pending

 

Where the worker has made an application from within the UK for permission to stay, the position requires separate assessment.

The worker should not assume that submitting the application before the sponsor licence was revoked means the application can simply proceed unaffected.

The sponsorship on which the application was based may no longer provide the basis originally relied upon, and the worker may need to consider whether another lawful immigration option is available before the Home Office determines the outstanding application. If the application continues to rely on the revoked sponsor and its basis is not varied before decision, the Home Office will refuse it.

Relevant factors can include:

 

• the immigration route under which the application was made;
• the worker’s immigration status when the application was submitted;
• whether the application was made in time;
• the Certificate of Sponsorship relied upon;
• the stage reached in the Home Office decision-making process;
• whether another licensed sponsor is available;
• whether a new Certificate of Sponsorship can be obtained;
• whether the worker qualifies under another immigration route; and
• whether the existing application can or should be varied, or whether another procedural step is required.

 

The correct procedure is fact-sensitive. Employers and workers should therefore avoid assuming that an outstanding in-country application can simply be replaced informally with details of another sponsor.

 

3. Can a Worker Change to a New Sponsor While an Application Is Pending?

 

Potentially, but obtaining a new job offer does not by itself resolve the outstanding immigration application.

If another licensed employer is prepared to sponsor the worker, the new employer will normally need to assess the role independently and assign a new Certificate of Sponsorship where the sponsorship requirements are met.

The worker will then need to establish the correct immigration procedure for relying on the new sponsorship.

Depending on the circumstances, this may involve varying an outstanding application or taking another permissible procedural step before the Home Office decides the original application. If the application remains based on sponsorship from the revoked sponsor when the Home Office decides it, refusal will follow.

The timing can be critical.

If the Home Office determines the original application before the worker has taken the appropriate steps to rely on alternative sponsorship, the worker’s options may change substantially.

Workers in this position should therefore obtain advice promptly rather than waiting for the Home Office to make a decision on an application that relied on sponsorship from an employer whose licence has been revoked.

 

4. Section 3C Leave & Pending Applications

 

Some workers who made a valid in-time application before their previous immigration permission expired may have their existing leave extended by section 3C of the Immigration Act 1971 while the application remains outstanding.

However, the existence of section 3C leave should not be confused with the continuing validity of the sponsorship relied upon in the pending application.

Section 3C can preserve a person’s existing leave, and generally the conditions attached to that leave, while a qualifying application remains undecided. It does not reinstate a revoked sponsor licence or make an invalid Certificate of Sponsorship valid again.

The worker’s position therefore needs careful assessment before any decision is made to withdraw, vary or otherwise alter an outstanding application, since procedural action can have significant consequences for section 3C leave and the individual’s continuing lawful status.

 

5. What If the Visa Has Already Been Granted?

 

If the Home Office has already granted the worker’s sponsored immigration application, the next question is whether the individual is already in the UK or remains overseas.

Where the worker is already in the UK with sponsored permission, their case generally falls to be considered as that of an existing sponsored worker affected by the loss of their sponsor.

Where the worker was not actively and knowingly involved in the circumstances leading to revocation, the Home Office will normally cancel or shorten their permission so that they have up to 60 calendar days remaining, subject to the original expiry date of that permission and any applicable exception or policy.

If the worker was actively and knowingly involved in the circumstances leading to revocation, the Home Office will normally cancel all of their remaining permission.

The position is different where entry clearance has been granted but the worker has not yet travelled to the UK.

 

6. Visa Granted But Worker Has Not Yet Travelled

 

Where entry clearance has already been granted but the sponsored worker has not travelled to the UK when the sponsor licence is revoked, current Home Office sponsor guidance states that the entry clearance will be cancelled.

The relevant sponsor guidance refers to cancellation under the suitability provisions of the Immigration Rules where the sponsor is no longer licensed.

This means the employer should not tell the worker that they can travel simply because they received their immigration approval before the sponsor licence was revoked.

The employer should also consider stopping or reviewing arrangements such as:

 

• flights;
• temporary accommodation;
• relocation services;
• shipping of personal belongings;
• planned start dates;
• induction arrangements; and
• family relocation arrangements.

 

The worker’s immigration position should be established before further travel or relocation commitments are made.

 

7. What If the Worker Has Already Travelled to the UK?

 

Where entry clearance was granted and the worker has already entered the UK before the sponsor licence is revoked, the case should not be treated in the same way as that of an individual who remains overseas and has not yet travelled.

The worker is now in the UK with immigration permission and the consequences of revocation should be assessed by reference to their existing permission, any subsequent cancellation action and their individual circumstances.

The employer should establish:

 

1. when the worker entered the UK;
2. the immigration permission they currently hold;
3. the original expiry date of that permission;
4. whether the worker has started employment;
5. whether the Home Office has issued any individual cancellation notice;
6. whether the worker is implicated in the reasons for revocation; and
7. whether alternative sponsorship or another immigration route may be available.

 

Again, the worker should not automatically be treated as an overstayer merely because the employer’s licence has been revoked, but neither should the employer assume that the original sponsored permission will continue unaffected until its original expiry date.

 

8. Employers Should Map Every Pending & Recently Decided Application

 

As part of the immediate response to sponsor licence revocation, employers should produce a complete schedule of immigration applications connected with their sponsorship.

The schedule should distinguish between:

 

1. workers assigned a CoS who have not yet applied;
2. overseas workers with entry clearance applications pending;
3. workers with in-country applications pending;
4. workers whose entry clearance has been granted but who have not travelled;
5. workers who have recently entered the UK;
6. existing sponsored employees with current immigration permission; and
7. workers pursuing alternative sponsorship or another immigration route.

 

For each individual, the employer should record the relevant immigration dates, current location, application status and any Home Office correspondence received.

This allows urgent cases to be prioritised and reduces the risk of an affected worker being overlooked because they have not yet appeared on the employer’s active sponsored workforce list.

 

9. Do Not Assume the Revocation Challenge Protects Pending Applications

 

Where the employer intends to challenge the sponsor licence revocation, pending worker applications should still be dealt with as an urgent and separate issue.

The fact that the employer disputes the Home Office decision does not by itself restore the sponsor licence, validate Certificates of Sponsorship that became invalid following revocation or suspend the immigration consequences for affected workers.

Employers should therefore avoid telling applicants that they should simply wait for the sponsor’s challenge to be resolved.

The employer’s challenge and the worker’s immigration strategy may need to proceed in parallel.

Current Home Office guidance on the effect of revocation on Certificates of Sponsorship and worker applications is contained in Workers and Temporary Workers: guidance for sponsors, Part 3: Sponsor duties and compliance.

 

 

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Section J: What Happens to Sponsored Workers Already Outside the UK?

 

Sponsor licence revocation can affect workers who are outside the UK as well as employees who are already living and working in the UK.

The consequences depend on the worker’s stage in the sponsorship and immigration process. An individual who has only been assigned a Certificate of Sponsorship is in a different position from someone with a pending entry clearance application, while a worker who already holds sponsored permission and is temporarily overseas requires a separate assessment.

Employers should therefore include overseas workers and international recruits in their immediate review following revocation.

 

1. Worker Has a CoS But Has Not Applied for Entry Clearance

 

Where the employer has assigned a Certificate of Sponsorship but the prospective worker has not yet submitted their immigration application, the CoS can no longer be relied upon following revocation.

Certificates of Sponsorship assigned by a sponsor whose licence has been revoked automatically become invalid.

The worker should therefore not proceed with an application using the invalid CoS.

The revoked sponsor cannot simply assign a replacement Certificate of Sponsorship because the organisation no longer has authority to sponsor workers.

If the individual wants to pursue sponsored work in the UK, they may need to find another employer that holds the appropriate sponsor licence, obtain a new qualifying job offer and be assigned a new Certificate of Sponsorship before making the relevant immigration application.

 

2. Worker Has an Overseas Entry Clearance Application Pending

 

Where an overseas worker has already submitted an entry clearance application using a Certificate of Sponsorship assigned by the revoked sponsor, current Home Office sponsor guidance is explicit about the consequence.

The Certificate of Sponsorship automatically becomes invalid and an entry clearance application based on that CoS will automatically be refused.

This is not simply a situation in which the application becomes more difficult or is placed at greater risk. The sponsor guidance expressly provides for refusal in this scenario.

Employers should therefore identify affected overseas applicants immediately and ensure that they understand that the original sponsorship can no longer support their application.

Where alternative sponsorship may be available, the worker will need to establish the appropriate immigration steps based on the new sponsorship rather than assuming the existing application can continue unaffected.

 

3. Entry Clearance Granted But the Worker Has Not Travelled

 

A different issue arises where the worker’s entry clearance application has already been approved but the individual has not yet travelled to the UK.

Current Home Office sponsor guidance states that where entry clearance has been granted but the worker has not travelled to the UK when the sponsor licence is revoked, the entry clearance will be cancelled.

The relevant sponsor guidance refers to cancellation under the suitability provisions of the Immigration Rules where the sponsor is no longer licensed.

The worker should therefore not assume that the grant of entry clearance before revocation guarantees that they can still travel to the UK to take up the sponsored role.

Employers should urgently identify workers in this category and review any planned:

 

• travel to the UK;
• relocation arrangements;
• accommodation;
• shipping arrangements;
• employment start dates;
• induction programmes;
• schooling arrangements for children; and
• relocation of dependant family members.

 

Further financial commitments should not be made on the assumption that the worker can still enter the UK under the original sponsorship.

 

4. Existing Sponsored Worker Temporarily Outside the UK

 

Employers should also identify existing sponsored workers who are temporarily outside the UK when the sponsor licence is revoked.

This can include employees who are overseas because of:

 

• annual leave;
• business travel;
• family commitments;
• temporary overseas assignments;
• illness or compassionate circumstances; or
• other short-term absences.

 

Their position is different from that of a new recruit who has been granted entry clearance but has never travelled to the UK.

An existing sponsored worker who is temporarily overseas may already hold immigration permission following previous lawful entry to the UK. However, sponsor licence revocation can still result in consequential action against that permission.

The worker should therefore establish their current immigration position before attempting to return to the UK rather than assuming that an unexpired eVisa or previous grant of permission guarantees readmission following revocation.

The precise position will depend on the worker’s immigration circumstances and any cancellation action taken by the Home Office.

 

5. Do Not Assume Every Worker Outside the UK Is in the Same Position

 

Employers should avoid applying the same conclusion to every sponsored worker who happens to be overseas when the licence is revoked.

There is an important distinction between:

 

1. a prospective worker who has been assigned a CoS but has not applied;
2. a worker whose entry clearance application is pending;
3. a worker whose entry clearance has been granted but who has never travelled to the UK;
4. an existing sponsored employee who has previously entered the UK and is temporarily overseas; and
5. a worker who may be affected by a specific Home Office policy or separate cancellation ground.

 

Each category can involve a different immigration consequence.

The employer should therefore establish the facts before advising the worker whether to travel, cancel travel or take further immigration action.

 

6. Workers Should Check Their Immigration Position Before Travelling

 

Where a sponsored worker is outside the UK when the employer’s licence is revoked, proposed travel should be reviewed urgently.

In particular, the worker should establish:

 

• what immigration permission they currently hold;
• whether they have previously entered the UK under that permission;
• whether the Home Office has issued a cancellation notice;
• whether their entry clearance or immigration permission remains effective;
• whether they were implicated in the reasons for sponsor licence revocation;
• whether any alternative sponsorship has been secured; and
• whether any specific Home Office policy applies to their circumstances.

 

Where the position is uncertain, the worker should obtain advice before travelling.

This is particularly important because the immigration consequences of sponsor licence revocation may develop after the employer receives its revocation decision.

 

7. Employers Should Review Overseas Recruitment Immediately

 

Revocation should trigger an immediate review of the employer’s entire overseas recruitment pipeline.

This review should identify:

 

1. candidates who have accepted job offers but have not yet been assigned a CoS;
2. workers who have been assigned a CoS but have not applied for entry clearance;
3. workers with entry clearance applications pending;
4. workers whose entry clearance has been granted but who have not travelled;
5. workers who have booked travel to the UK;
6. workers whose dependant family members are also preparing to relocate;
7. existing sponsored employees who are temporarily outside the UK; and
8. future international transfers dependent on the sponsor licence.

 

Recruitment, relocation and onboarding teams should be informed of the revocation so that they do not continue arrangements on the assumption that sponsorship remains available.

This is particularly important in larger organisations where immigration sponsorship may be managed centrally while recruitment and relocation activity takes place across several business units.

 

8. Consider the Financial & Practical Consequences

 

The impact on overseas workers can extend beyond immigration status.

Revocation may affect:

 

• flight bookings;
• temporary accommodation;
• permanent housing arrangements;
• relocation costs;
• shipping costs;
• school arrangements;
• notice given to an overseas employer;
• dependant employment arrangements;
• planned start dates; and
• business projects dependent on the worker’s arrival.

 

Employers should identify these consequences quickly and determine which commitments can be paused or cancelled while the worker’s immigration position is clarified.

Clear communication is particularly important where the worker has already incurred significant personal costs or made irreversible arrangements in preparation for relocating to the UK.

 

9. Alternative Sponsorship May Still Be Possible

 

The loss of the original sponsor does not necessarily prevent an overseas worker from pursuing employment in the UK altogether.

If another appropriately licensed employer offers the worker a qualifying role, that organisation may be able to sponsor the individual independently.

The new sponsor would need to carry out its own assessment, assign a new Certificate of Sponsorship and ensure that the worker makes the appropriate immigration application.

The previous CoS cannot simply be transferred to the new employer.

Where the original entry clearance application is still pending, the worker should obtain advice on the correct procedural steps rather than assuming that details of a new sponsor can simply be substituted into the existing application.

 

10. Overseas Workers Should Be Included in the Employer’s Revocation Response

 

Employers can make the mistake of focusing exclusively on sponsored employees physically present in the UK.

A complete revocation response should also account for workers outside the UK whose immigration, recruitment or employment arrangements depend on the sponsor licence.

The employer should maintain a central schedule recording, for each affected overseas worker:

 

• their current location;
• the relevant immigration route;
• their CoS status;
• their immigration application status;
• whether entry clearance has been granted;
• whether they have previously entered the UK;
• planned travel dates;
• planned employment start dates;
• dependant family members; and
• the action required following revocation.

 

This allows the organisation to manage the immigration, operational and employee-relations consequences of revocation in a coordinated way.

Current Home Office provisions on cancellation where a sponsor is no longer licensed are set out in the Immigration Rules: Part Suitability, alongside the relevant Home Office sponsor guidance.

 

 

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Section K: What Happens to Dependants?

 

Sponsor licence revocation can also affect the dependant partners and children of sponsored workers.

However, dependants should not automatically be treated as having lost their immigration permission at the exact moment the employer’s sponsor licence is revoked.

The starting point is the immigration position of the main sponsored worker. Where the Home Office takes cancellation action against the main applicant’s permission following sponsor licence revocation, it can also consider consequential action against dependants whose permission is linked to that person.

This makes it important for employers and affected workers to consider the immigration position of the whole family rather than focusing solely on the sponsored employee.

 

1. Do Dependants Automatically Lose Their Visas?

 

No. The revocation of the employer’s sponsor licence does not itself mean that every dependant’s immigration permission automatically disappears at the same moment.

The employer’s sponsor licence, the main sponsored worker’s immigration permission and the immigration permission held by their dependants are related but distinct matters.

Where the Home Office cancels the main worker’s permission, it must also consider whether to cancel permission granted to dependant family members in line with the main applicant.

The family should therefore not assume either that dependant permission has automatically ended or that it will necessarily remain unaffected until its original expiry date.

 

2. Can Dependant Permission Be Cancelled in Line With the Main Worker?

 

Yes. Where the main sponsored worker’s immigration permission is cancelled, the Home Office must also consider whether to cancel permission held by dependant family members who were granted permission in line with the main applicant.

Where dependant permission is cancelled, the general approach is normally to align the dependant’s remaining period of permission with that of the main applicant.

For example, where the main worker’s permission is shortened following sponsor licence revocation, the immigration position of a dependant partner or child may also need to be adjusted to reflect the changed position of the main applicant.

This does not mean that the dependant should independently be described as responsible for the sponsor’s non-compliance. It reflects the fact that their immigration permission derives from their relationship with the main applicant.

 

3. Dependants May Have Different Immigration Circumstances

 

Employers should also recognise that not every family member will necessarily be in an identical immigration position.

Relevant circumstances can include whether:

 

• the dependant is currently in the UK;
• the dependant is outside the UK;
• the dependant has an application pending;
• the dependant has been granted entry clearance but has not yet travelled;
• the dependant holds permission linked to the sponsored worker;
• the dependant has subsequently obtained immigration permission in their own right;
• the main worker is pursuing alternative sponsorship; or
• the family may qualify under another immigration route.

 

The immigration position of each family member should therefore be checked rather than assuming that every dependant will automatically have the same procedural position.

 

4. What If the Worker Finds Another Sponsor?

 

Where the main worker secures sponsorship with another licensed employer, the family’s immigration position should be considered as part of the new immigration strategy.

The worker will normally need a new Certificate of Sponsorship and an appropriate immigration application reflecting the new sponsored employment.

Depending on the circumstances and the immigration route involved, dependant family members may also need to make applications to continue their permission as dependants.

The fact that the main worker has found another sponsor should not lead the family to assume that dependant immigration permission automatically updates to reflect the new sponsorship.

The requirements and timing of any dependant applications should be checked as part of the family’s overall immigration response.

 

5. What If the Main Worker Changes Immigration Route?

 

An affected worker may decide not to remain under their existing sponsored route.

Depending on their circumstances, they may qualify to apply under another immigration category.

If the main worker changes route, the effect on dependant family members will depend on the rules of the new immigration category and the individual circumstances of the family.

Some routes allow dependant partners and children, while others have different eligibility requirements or restrictions.

Employers should therefore avoid telling affected families that dependants can automatically remain simply because the main worker has submitted another immigration application.

 

6. What If Dependants Have Applications Pending?

 

Where dependant applications are outstanding when the sponsor licence is revoked, the family should establish how the change in the main applicant’s sponsorship position affects those applications.

This can be particularly important where:

 

• the main worker has an outstanding sponsored work application;
• the dependant applications were submitted at the same time;
• the main worker’s application relied on a CoS assigned by the revoked sponsor;
• the main worker is seeking alternative sponsorship;
• the main worker intends to vary or otherwise change an outstanding application; or
• some family members are inside the UK while others remain overseas.

 

The family should not assume that an application already submitted will continue unaffected simply because the application predates the sponsor licence revocation.

 

7. What If Dependants Are Outside the UK?

 

Additional care may be required where dependant family members are outside the UK when the sponsor licence is revoked.

For example, a sponsored worker may already be living in the UK while their partner and children are overseas preparing to join them.

Alternatively, the entire family may be temporarily outside the UK when the employer loses its sponsor licence.

The family should establish the immigration position of the main worker and each dependant before making travel decisions.

Relevant issues can include whether entry clearance has already been granted, whether applications remain outstanding and whether cancellation action has been taken or is being considered.

The fact that a dependant holds an apparently unexpired grant of immigration permission should not be considered in isolation from changes to the immigration position of the main applicant.

 

8. Family Circumstances Can Increase the Urgency

 

Sponsor licence revocation can have a considerably wider impact where the sponsored worker has relocated to the UK with their family.

The consequences can potentially affect:

 

• a dependant partner’s ability to remain and work in the UK;
• children attending school;
• housing arrangements;
• family finances;
• planned travel;
• healthcare and other practical arrangements;
• future immigration applications; and
• the possibility of the family having to relocate from the UK.

 

This means a worker with dependants may need to address the consequences of sponsor licence revocation particularly quickly.

A delay that appears manageable when considering only the employee’s employment position can become considerably more serious when the immigration position of an entire family is involved.

 

9. Employers Should Record Which Sponsored Workers Have Dependants

 

As part of the employer’s workforce triage exercise, it can be useful to identify which sponsored workers are known to have dependant family members whose immigration position may be linked to the worker.

The employer should not attempt to determine the immigration status of family members without an appropriate basis or assume responsibility for their personal immigration applications.

However, identifying that dependants are involved can help the employer understand the urgency and practical consequences of the situation for the affected employee.

For each sponsored worker, the employer’s response schedule can therefore record:

 

1. whether the worker has dependant family members;
2. whether those dependants are understood to be in or outside the UK;
3. whether there are known pending dependant applications;
4. whether the worker is seeking alternative sponsorship; and
5. whether the worker has been advised to consider the immigration position of the whole family.

 

This information should be handled appropriately as personal information and only collected or used where there is a legitimate reason to do so.

 

10. Employers Should Avoid Giving Dependants Immigration Assurances

 

Employers should be particularly careful about statements made to sponsored employees concerning their family members.

Statements such as:

 

• “your family automatically has the same 60 days”;
• “your dependants are unaffected”;
• “everyone’s visa has already been cancelled”; or
• “your family can stay until the original visa expiry date”

 

may be inaccurate.

The safer approach is to explain that sponsor licence revocation can have consequences for dependant immigration permission and that the position of the main worker and each dependant should be assessed according to their individual circumstances and any Home Office action taken.

Where the main worker is pursuing alternative sponsorship or another immigration route, the immigration position of their dependants should be considered at the same time rather than as an afterthought.

Current Home Office policy on cancellation of immigration permission is set out in the Home Office guidance on cancellation and curtailment of permission.

 

 

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Section L: Special Rules for Care Workers After Sponsor Licence Revocation

 

There is currently an important exception to the usual approach to cancellation of immigration permission following sponsor licence revocation for certain sponsored workers in the adult social care sector.

Under temporary Home Office arrangements introduced in 2026, caseworkers are instructed not to cancel a qualifying care worker or senior care worker’s immigration permission solely because their employer’s sponsor licence has been revoked.

This is a significant exception to the general position described elsewhere in this guide and is particularly important for care providers whose sponsor licence has been revoked and for affected workers seeking to understand their immigration position.

The protection is, however, limited. It does not prevent cancellation where there are other grounds for taking immigration action, it does not restore the employer’s sponsor licence and it does not necessarily provide a permanent immigration solution for the affected worker.

Current position checked: October 2026. The Home Office describes this arrangement as temporary and subject to regular review. Employers and workers should therefore check the current guidance before relying on it.

 

1. Which Care Workers Are Covered?

 

The current Home Office cancellation guidance applies the temporary arrangement to individuals holding Skilled Worker or Health and Care Worker permission in specified adult social care occupations.

These include:

 

• SOC 6135 – Care workers and home carers;
• SOC 6136 – Senior care workers;
• SOC 6145 – Care workers and home carers under the previous occupational classification; and
• SOC 6146 – Senior care workers under the previous occupational classification.

 

The occupation code and immigration permission held by the individual should be checked rather than assuming that every worker employed by a care provider falls within the temporary arrangement.

A worker performing a different role within an adult social care organisation is not brought within the policy merely because their employer operates in the care sector.

 

2. What Protection Does the Temporary Policy Provide?

 

Under the current Home Office guidance, caseworkers must not cancel the worker’s permission where the sole reason for cancellation would be the revocation of their sponsor’s licence and the worker falls within the specified care worker or senior care worker categories.

This means the normal consequence of sponsor licence revocation should not, by itself, trigger cancellation of the qualifying worker’s immigration permission under this temporary arrangement.

This is materially different from the general approach applying to many other sponsored workers, where loss of the sponsor licence can result in the Home Office cancelling or shortening permission so that the worker has up to 60 calendar days remaining.

Employers should therefore avoid automatically telling qualifying care workers that their immigration permission will be shortened to 60 days simply because the sponsor licence has been revoked.

 

3. The Protection Only Applies Where Revocation Is the Sole Reason for Cancellation

 

The limitation concerning the sole reason for cancellation is critical.

The temporary arrangement does not give qualifying care workers immunity from immigration enforcement or cancellation generally.

Where there is another lawful basis on which the Home Office considers cancellation appropriate, the worker’s permission can still be considered for cancellation under the applicable Immigration Rules and guidance.

For example, the temporary policy should not be interpreted as preventing action where separate issues arise concerning:

 

• the worker’s own conduct;
• deception or false representations;
• breach of immigration conditions;
• other suitability grounds;
• the validity of the worker’s immigration status; or
• another independent basis for cancellation under the Immigration Rules.

 

The employer should therefore distinguish between a worker affected only because the organisation lost its sponsor licence and a worker who is also subject to separate individual immigration concerns.

 

4. What If the Care Worker Was Involved in the Sponsor’s Non-Compliance?

 

The temporary policy should not be treated as protecting a worker from the consequences of their own conduct where there is a separate basis for cancellation.

Elsewhere in the sponsor guidance, the Home Office distinguishes between workers who were not involved in the circumstances leading to revocation and those who were actively and knowingly involved.

Where a worker is alleged to have participated in sham employment, deception or other conduct connected with the sponsor’s non-compliance, their individual position should be assessed separately.

The existence of the care worker concession does not mean that the Home Office must disregard other cancellation grounds that apply to the individual.

Care providers should therefore avoid treating the temporary policy as a blanket protection covering every sponsored care worker irrespective of the circumstances.

 

5. Does the Temporary Policy Restore the Employer’s Sponsor Licence?

 

No. The temporary protection concerns the immigration permission of qualifying workers. It does not reverse or suspend the revocation of the employer’s sponsor licence.

The care provider remains without authority to sponsor workers unless and until the legal position concerning its sponsor licence changes.

The temporary arrangement therefore does not:

 

• restore the revoked sponsor licence;
• allow the employer to assign new Certificates of Sponsorship;
• make invalid Certificates of Sponsorship valid again;
• allow the employer to continue recruiting sponsored workers as though revocation had not occurred;
• reverse the wider consequences of sponsor licence revocation; or
• remove the need for affected workers to consider their longer-term immigration and employment position.

 

The employer’s sponsor licence position and the worker’s immigration position remain separate issues.

 

6. Does the Policy Mean Care Workers Can Ignore the Revocation?

 

No. Even where the temporary policy prevents immigration permission being cancelled solely because of sponsor licence revocation, the worker may still need to take action.

The loss of the employer’s sponsor licence can affect the worker’s employment and longer-term sponsorship arrangements even where their immigration permission is not immediately cancelled on that ground.

Qualifying workers may therefore need to consider:

 

1. their current immigration permission;
2. their employment position following revocation;
3. whether they can secure employment with another licensed sponsor;
4. whether new sponsorship and a further immigration application will be required;
5. whether government or regional support is available to help them find alternative employment;
6. the position of any dependant family members; and
7. their longer-term immigration plans.

 

The temporary protection should therefore be viewed as protection against a particular cancellation consequence rather than as a complete solution to the loss of the worker’s sponsor.

 

7. Can a Care Worker Find Another Sponsor?

 

Potentially, yes.

Affected care workers may be able to move to another appropriately licensed employer where the relevant sponsorship and immigration requirements are met.

The prospective employer would need to assess the worker and proposed role independently, hold the appropriate sponsor licence and satisfy the requirements applying to sponsorship under the relevant route.

Where new sponsorship is required, the new employer would normally need to assign its own Certificate of Sponsorship and the worker would need to take the appropriate immigration steps.

The Certificate of Sponsorship assigned by the employer whose licence has been revoked cannot simply be transferred to the new care provider.

 

8. Support for Displaced Adult Social Care Workers

 

The Government has also put arrangements in place intended to support international adult social care workers who become displaced, including workers affected by sponsor licence revocation.

Support can include regional arrangements designed to help affected workers understand their position and, where possible, connect with alternative employment opportunities in the adult social care sector.

Employers and workers should check the current Government and regional arrangements because the structure, availability and funding of support can change.

Information on current Government support for international recruitment in adult social care is available through GOV.UK adult social care international recruitment guidance.

 

9. Care Providers Should Identify Potentially Protected Workers Immediately

 

A care provider whose sponsor licence has been revoked should identify which sponsored employees may fall within the temporary Home Office arrangement.

For each potentially affected worker, the employer should establish:

 

1. the immigration route under which the worker holds permission;
2. the occupation code used for their sponsorship;
3. whether they are sponsored as a care worker or senior care worker within the specified occupational categories;
4. their existing immigration permission and expiry date;
5. whether the worker is implicated in any of the reasons for sponsor licence revocation;
6. whether there is any separate potential ground for cancellation;
7. whether the worker has received Home Office correspondence;
8. whether alternative employment or sponsorship is being explored; and
9. whether the worker has dependant family members whose immigration position also needs consideration.

 

This assessment should be undertaken separately from the employer’s challenge to or response to the sponsor licence revocation.

 

10. Do Not Apply the Standard 60-Day Message Automatically to Care Workers

 

The temporary care worker arrangement makes generic employee communications particularly risky for care providers.

A statement telling every sponsored worker:

“Your permission will now be shortened to 60 days.”

may be incorrect for workers falling within the temporary policy.

Equally, telling qualifying care workers that they are completely unaffected by the revocation would also be misleading.

The more accurate position is that current Home Office guidance provides that qualifying care workers and senior care workers should not have their permission cancelled solely because the sponsor licence has been revoked, but they may still need to address the employment and longer-term immigration consequences of losing their sponsor.

 

11. The Care Worker Policy Is Temporary

 

The Home Office expressly describes the arrangement as temporary and subject to regular review.

This means employers, workers and advisers should not assume that the policy will remain unchanged indefinitely.

The current version of the Home Office guidance should be checked whenever a case arises.

This is particularly important where:

 

• revocation occurs after the publication of this guide;
• the worker has not yet received any cancellation decision;
• the worker is considering changing employer;
• an immigration application is pending;
• the worker’s circumstances extend over several months; or
• the Home Office publishes revised cancellation guidance.

 

Current position checked: October 2026.

The temporary arrangement is set out in the Home Office Cancellation and Curtailment of Permission guidance.

 

 

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Section M: What Should Employers Do for Sponsored Workers After Revocation?

 

Sponsor licence revocation requires an immediate and coordinated response. Employers need to address the Home Office decision itself while simultaneously managing the immigration, employment and operational consequences for sponsored workers.

The response should not be limited to producing a list of employees whose visas are due to expire. Employers need to establish the position of every person whose immigration or recruitment arrangements depend on the revoked sponsor licence.

For organisations with multiple sponsored workers, the most effective approach is to create a structured workforce response plan and prioritise cases according to immigration risk and urgency.

 

1. Identify All Sponsored & Prospective Workers

 

The first step is to establish the full population affected by the revocation.

This should extend beyond employees currently working in the UK.

The employer should identify:

 

• existing sponsored workers in the UK;
• sponsored workers temporarily outside the UK;
• workers with pending in-country immigration applications;
• overseas workers with pending entry clearance applications;
• workers who have been granted entry clearance but have not yet travelled;
• workers who have been assigned a Certificate of Sponsorship but have not yet applied;
• candidates awaiting assignment of a CoS;
• existing employees expected to move into sponsored status;
• international transferees whose move depends on sponsorship; and
• future recruits whose employment plans depend on the organisation holding a sponsor licence.

 

This provides the employer with a complete picture of the workforce consequences of revocation.

 

2. Record Each Worker’s Immigration Position

 

Once the affected population has been identified, the employer should establish the immigration position of each worker.

A central schedule can record:

 

1. the worker’s name;
2. their immigration route;
3. their occupation code;
4. their Certificate of Sponsorship details;
5. the original expiry date of their immigration permission;
6. whether they are currently inside or outside the UK;
7. whether an immigration application is pending;
8. whether entry clearance has already been granted;
9. whether the worker has received individual Home Office correspondence;
10. whether the worker is implicated in the circumstances leading to revocation;
11. whether dependant family members may also be affected;
12. whether a specific Home Office policy applies; and
13. the next action and deadline for the case.

 

The schedule should be treated as a live document and updated as Home Office correspondence is received or individual workers take further immigration action.

 

3. Separate Workers Into Risk Categories

 

Not every sponsored worker faces the same consequences.

Employers should therefore categorise cases according to urgency and immigration risk.

Relevant categories can include:

 

• existing workers who were not involved in the circumstances leading to revocation;
• workers with fewer than 60 days of existing permission remaining;
• workers specifically implicated in the Home Office allegations;
• workers with pending overseas entry clearance applications;
• workers with pending in-country applications;
• workers granted entry clearance who have not yet travelled;
• existing workers temporarily outside the UK;
• workers actively seeking alternative sponsorship;
• workers with dependant family members; and
• qualifying care workers or senior care workers potentially covered by the current temporary Home Office policy.

 

This allows the organisation to prioritise cases where action may be required immediately.

 

4. Check Whether Individual Workers Are Implicated in the Revocation

 

The employer should review the revocation decision and any preceding Home Office correspondence to establish whether particular sponsored workers are identified in the allegations.

This is important because the immigration consequences can differ significantly where the Home Office believes a worker was actively and knowingly involved in the conduct leading to revocation.

Where a worker is specifically implicated, the employer should identify:

 

• the allegation concerning that individual;
• the evidence relied upon by the Home Office;
• the worker’s role in the relevant events;
• whether there is evidence contradicting the allegation;
• whether the worker has received separate Home Office correspondence; and
• whether the allegation could affect the worker’s individual immigration position.

 

Employers should preserve relevant evidence and avoid making assumptions about individual complicity solely because the worker was sponsored by the organisation.

 

5. Identify Workers Who May Need Alternative Sponsorship Urgently

 

For many affected workers, obtaining sponsorship from another licensed employer may be one possible route to remaining in the UK.

Time can be critical.

The process of moving to another sponsor may involve:

 

1. identifying suitable employment;
2. completing recruitment and interviews;
3. receiving a qualifying job offer;
4. the new employer assessing sponsorship eligibility;
5. assignment of a new Certificate of Sponsorship;
6. preparation of the worker’s immigration application;
7. submission of the application; and
8. obtaining permission to undertake the new sponsored employment.

 

Workers with shorter immigration deadlines should therefore be identified quickly.

Employers should not promise that alternative sponsorship will be available, but affected employees should be given accurate information about the consequences of revocation so they can consider their options promptly.

 

6. Review Right to Work & Employment Issues

 

The employer should assess the immigration and employment position of existing sponsored workers following revocation.

Current GOV.UK guidance states that where an employer loses its sponsor licence, a sponsored worker will have to leave their job and leave the UK unless they make a new visa application to stay.

The employer should therefore not treat the potential 60-day immigration period as an automatic entitlement for the worker to continue working for the revoked sponsor.

At the same time, the organisation should not assume that sponsor licence revocation automatically determines every employment law consequence.

Issues concerning contractual rights, notice, dismissal, pay and employment procedures may need to be considered alongside the immigration position.

Where a right to work check or verification through the Home Office is appropriate, this should be undertaken using the relevant process. A right to work check should not, however, be treated as restoring the organisation’s authority to sponsor workers.

 

7. Communicate Carefully With Sponsored Workers

 

Employee communications should be accurate, consistent and coordinated centrally where possible.

Employers should avoid blanket statements such as:

 

• “everyone has 60 days”;
• “everyone’s visa has been cancelled immediately”;
• “you can continue working for us for 60 days”;
• “nothing changes until your visa expires”; or
• “our challenge to the revocation means your visa is protected”.

 

Each of these statements can be inaccurate depending on the worker’s circumstances.

Communications should instead explain:

 

1. that the sponsor licence has been revoked;
2. that revocation can affect the worker’s immigration and employment position;
3. that the precise consequences depend on the worker’s individual circumstances;
4. that workers should monitor Home Office communications carefully;
5. that relevant immigration deadlines should not be ignored; and
6. that individual immigration advice may be required.

 

Where large numbers of workers are affected, employers should consider providing structured written communications supported by individual case reviews.

 

8. Preserve Sponsorship, Employment & Compliance Records

 

The employer should preserve relevant records following revocation.

These records may be required for:

 

• assessing the reasons for revocation;
• responding to allegations concerning individual workers;
• considering a potential legal challenge;
• managing worker immigration issues;
• employment law processes;
• future Home Office scrutiny; and
• remediation of the organisation’s sponsorship systems.

 

Relevant material can include:

 

• Certificates of Sponsorship;
• SMS records;
• employment contracts;
• job descriptions;
• recruitment records;
• salary and payroll information;
• attendance records;
• right to work records;
• Home Office correspondence;
• internal compliance records;
• emails and other communications; and
• documents relating to any compliance visit or investigation.

 

Records should be preserved in their existing form. Employers should not retrospectively amend documents in an attempt to reconstruct a compliant position after revocation.

 

9. Review Outstanding Recruitment & International Mobility

 

The impact of revocation extends beyond existing sponsored employees.

Recruitment, HR and global mobility teams should identify all planned activity that depends on the sponsor licence.

This can include:

 

• pending overseas recruitment;
• future Certificates of Sponsorship;
• international transfers;
• graduate recruitment;
• workers expected to switch into sponsored status;
• relocation arrangements;
• planned travel to the UK;
• new starter arrangements; and
• business projects dependent on sponsored personnel.

 

Processes that assume the organisation remains able to sponsor workers should be stopped or reviewed immediately.

This can prevent additional costs being incurred and avoid prospective workers making immigration or relocation decisions based on sponsorship that is no longer available.

 

10. Coordinate the Worker Strategy With the Revocation Strategy

 

The employer’s response to sponsor licence revocation and its response to the sponsored workforce should proceed in parallel.

On one workstream, the organisation may need to:

 

• analyse the reasons for revocation;
• review the Home Office evidence;
• consider whether the decision contains factual or legal errors;
• assess whether a challenge is available;
• preserve evidence; and
• address underlying compliance failures.

 

On the worker workstream, the organisation may simultaneously need to:

 

• identify affected workers;
• establish immigration deadlines;
• manage employment consequences;
• address pending immigration applications;
• review overseas recruitment;
• support accurate employee communications; and
• identify cases requiring urgent individual action.

 

Neither workstream should be postponed while waiting for the other to conclude.

In particular, employers should not assume that a potential challenge to the revocation means sponsored workers can wait before addressing their own immigration position.

 

11. Employer Response: First 10 Actions After Sponsor Licence Revocation

 

As an immediate response, employers should:

 

1. Secure the revocation decision and Home Office correspondence and establish the stated reasons for the decision.
2. Identify every sponsored and prospective worker affected by the loss of the licence.
3. Create an individual immigration schedule recording status, expiry dates, applications, CoS details and location.
4. Identify workers specifically implicated in the Home Office allegations.
5. Prioritise urgent immigration cases, including workers with short remaining permission and pending applications.
6. Review the position of overseas workers, including those preparing to travel to the UK.
7. Assess employment and right to work consequences for existing sponsored employees.
8. Issue controlled and accurate communications rather than blanket assurances about visas or the 60-day period.
9. Preserve sponsorship and employment evidence relevant to both worker cases and any challenge to revocation.
10. Run the workforce and revocation strategies in parallel so that immigration deadlines are not missed while the organisation considers its legal response.

 

The objective is to move quickly from uncertainty to a documented worker-by-worker response plan.

 

 

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Section N: Can the Employer Reverse the Effect on Sponsored Workers?

 

An employer may be able to challenge a sponsor licence revocation in appropriate circumstances, but the existence of a potential challenge does not automatically reverse or suspend the consequences for sponsored workers.

This distinction is important. The employer’s challenge concerns the lawfulness of the Home Office decision to revoke the sponsor licence. Individual workers may simultaneously be facing immigration consequences arising from the loss of their sponsor.

Employers should therefore avoid assuming that challenging the revocation allows the sponsored workforce simply to continue as though the licence remained in force.

The sponsor licence strategy and the worker immigration strategy should normally proceed in parallel.

 

1. Can an Employer Appeal Against Sponsor Licence Revocation?

 

There is no general statutory right of appeal against a Home Office decision to revoke a sponsor licence.

This means the employer cannot normally pursue a conventional immigration appeal simply because it disagrees with the revocation decision.

Depending on the circumstances, however, the organisation may have grounds to challenge the lawfulness of the decision through judicial review.

Potential issues can include whether the Home Office:

 

• made a material factual error;
• misinterpreted relevant evidence;
• failed to take relevant evidence into account;
• relied on an incorrect understanding of the sponsor’s circumstances;
• failed to follow a fair procedure;
• acted inconsistently with its published policy or guidance;
• reached a decision that was legally unreasonable; or
• otherwise acted unlawfully in reaching the revocation decision.

 

Whether any of these grounds is available will depend on the facts of the case and the reasons given by the Home Office.

 

2. Does Judicial Review Automatically Restore the Sponsor Licence?

 

No.

Preparing, threatening or commencing judicial review proceedings does not by itself restore a sponsor licence that has been revoked.

Employers should therefore not tell sponsored workers that their immigration position has been protected merely because the organisation intends to challenge the Home Office.

Unless the legal effect of the revocation changes, the organisation remains without authority to sponsor workers.

This means the employer should continue to deal with matters such as:

 

• individual worker immigration deadlines;
• cancellation or shortening of immigration permission;
• pending immigration applications;
• invalid Certificates of Sponsorship;
• workers who have not yet travelled to the UK;
• alternative sponsorship;
• right to work and employment issues; and
• dependant family members.

 

These issues should not be put on hold merely because the employer believes the revocation decision is wrong.

 

3. Does Judicial Review Automatically Stop the Home Office Taking Action Against Workers?

 

No. The commencement of judicial review proceedings does not automatically mean that consequential Home Office action affecting sponsored workers is suspended.

The employer should therefore distinguish between:

 

1. challenging the sponsor licence revocation;
2. seeking any specific interim legal protection that may be available in the circumstances; and
3. managing the individual immigration position of affected workers.

 

Employers should not assume that the first automatically produces the second or resolves the third.

Where urgent legal proceedings are contemplated, the effect of the revocation on sponsored workers should form part of the strategic assessment from the outset.

 

4. What If the Home Office Withdraws or Reconsiders the Revocation?

 

If the Home Office subsequently withdraws or reconsiders its revocation decision, the resulting position will depend on the terms and effect of that decision.

Employers should not assume that every consequence affecting sponsored workers automatically disappears without further action.

By that stage, individual workers may already have:

 

• received cancellation decisions;
• made new immigration applications;
• secured alternative sponsorship;
• left their employment;
• left the UK;
• had pending applications determined; or
• taken other steps in response to the original revocation.

 

The organisation should therefore review each affected worker again if the sponsor licence position changes.

The question is not simply whether the employer has regained sponsorship authority, but what immigration and employment position now applies to each individual.

 

5. What If a Court Quashes the Revocation Decision?

 

Where judicial review proceedings result in a court quashing a Home Office decision, the precise consequences will depend on the court’s order and the subsequent steps taken by the Home Office.

A successful judicial review should therefore not be described as automatically producing a particular immigration outcome for every affected worker.

Individual cases may require reassessment, particularly where consequential immigration decisions have already been made or workers have changed their circumstances while the challenge was ongoing.

Employers should obtain advice on both the sponsor licence consequences of the court outcome and any separate action required in relation to affected workers.

 

6. Can the Employer Simply Apply for Another Sponsor Licence?

 

An organisation should not assume that it can resolve the immediate consequences of revocation by submitting a fresh sponsor licence application.

Sponsor licence revocation normally results in a period during which the organisation is not eligible to obtain another sponsor licence.

The applicable period depends on the current sponsor guidance and the circumstances of the revocation. Employers should check the Home Office rules applying at the time rather than treating a future sponsor licence application as an immediate remedy for the affected workforce.

Even where the organisation may eventually become eligible to apply again, that does not resolve the current immigration position of workers affected by the existing revocation.

The immediate priority remains managing the consequences for the sponsored workforce while separately addressing the organisation’s longer-term sponsorship position.

 

7. A Future Sponsor Licence Does Not Automatically Repair Previous Worker Cases

 

Even if an organisation later becomes eligible for and successfully obtains another sponsor licence, employers should not assume that this retrospectively repairs the immigration consequences arising from the earlier revocation.

By that stage:

 

• workers may have moved to other sponsors;
• immigration permission may have expired or been cancelled;
• workers may have made applications under different routes;
• workers may have left the UK;
• pending applications may have been refused or otherwise determined; and
• employment relationships may have ended.

 

Any future sponsorship would need to be considered under the circumstances and immigration rules applying at that time.

A new sponsor licence should therefore not be regarded as a mechanism for retrospectively validating sponsorship that ceased when the previous licence was revoked.

 

8. The Employer Should Not Delay Worker Action While Challenging Revocation

 

One of the most significant practical risks following sponsor licence revocation is concentrating entirely on overturning the Home Office decision while failing to manage the sponsored workforce.

An employer may believe strongly that the revocation decision is unlawful and still need to deal immediately with its consequences.

While the legal team considers the challenge, the organisation should continue to:

 

1. identify all affected workers;
2. record individual immigration deadlines;
3. review Home Office correspondence received by workers;
4. identify pending immigration applications;
5. review overseas workers and planned travel;
6. consider employment and right to work issues;
7. identify workers who may require alternative sponsorship;
8. consider the position of dependants;
9. apply any relevant temporary Home Office policies; and
10. keep the workforce response under active review.

 

Waiting for the sponsor licence dispute to be resolved before taking these steps can leave workers with substantially fewer options.

 

9. Run Two Parallel Response Workstreams

 

In practice, employers should treat sponsor licence revocation as creating two parallel workstreams.

Workstream 1: Sponsor Licence Response

 

• analyse the revocation decision;
• identify the Home Office findings;
• review the evidence;
• identify factual and legal errors;
• consider whether judicial review may be appropriate;
• preserve relevant records;
• address underlying compliance failures; and
• consider the organisation’s longer-term sponsorship strategy.

 

Workstream 2: Sponsored Worker Response

 

• identify every affected worker;
• establish each worker’s immigration position;
• identify individual deadlines;
• review pending applications;
• identify workers outside the UK;
• assess cases involving alleged worker complicity;
• consider alternative sponsorship;
• address dependant immigration issues;
• apply any relevant sector-specific policy; and
• manage employment and workforce consequences.

 

The two workstreams should inform each other, but neither should depend on the other being completed first.

 

10. The Objective Is to Preserve Options

 

The immediate objective following sponsor licence revocation is not simply to determine whether the employer can overturn the decision.

It is also to preserve as many lawful options as possible for the organisation and affected workers while the position develops.

That means acting before immigration deadlines expire, before pending applications are determined where alternative action may be available and before workers make decisions based on inaccurate assumptions about the effect of revocation.

Employers should therefore approach revocation as both a legal challenge issue and an urgent workforce compliance event.

Current Home Office guidance on sponsor licence revocation and its consequences is contained in Workers and Temporary Workers: guidance for sponsors, Part 3: Sponsor duties and compliance.

 

 

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Section O: Sponsor Licence Revocation & Sponsored Workers: Employer Action Checklist

 

Where a sponsor licence is revoked, employers need to move quickly from the Home Office decision to a structured response covering every sponsored and prospective worker affected by the loss of sponsorship.

The objective is to establish who is affected, identify the immigration consequence for each individual, prioritise urgent cases and preserve the available options for both the organisation and its workers.

The following framework can be used to structure the employer response.

 

1. Sponsored Worker Revocation Consequences Matrix

 

Worker situation	Likely consequence	Employer priority
Existing sponsored worker not actively and knowingly involved in the circumstances leading to revocation	The Home Office will normally cancel or shorten permission so that the worker has up to 60 calendar days remaining, subject to the original expiry date.	Establish the individual deadline, review the employment position and ensure the worker understands the need to consider their immigration options promptly.
Existing worker with fewer than 60 days of permission remaining	Cancellation does not create a fresh 60-day period. The existing earlier expiry date will normally remain relevant.	Treat as an urgent case and establish what immigration action, if any, is available before permission expires.
Worker actively and knowingly involved in the conduct leading to revocation	The Home Office will normally cancel all remaining permission rather than provide the usual period available to an uninvolved worker.	Review the allegation and evidence concerning the individual and ensure that the worker obtains urgent advice on their immigration position.
Overseas worker with a pending entry clearance application	The assigned CoS automatically becomes invalid. Current sponsor guidance states that an entry clearance application based on that CoS will automatically be refused.	Identify the applicant immediately, stop relying on the original sponsorship and consider whether alternative sponsorship may be available.
Worker with a pending in-country application	The loss of sponsorship can affect the basis of the application. The correct position depends on the application, existing immigration status and individual circumstances.	Review urgently whether alternative sponsorship or another immigration basis is available and determine the correct procedural response before the application is decided.
Worker assigned a CoS but immigration application not yet submitted	The CoS automatically becomes invalid and cannot be relied upon for a new application.	Do not proceed using the invalid CoS. Consider whether the worker can obtain sponsorship from another licensed employer.
Entry clearance granted but worker has not travelled to the UK	Current Home Office sponsor guidance states that the entry clearance will be cancelled.	Review planned travel and relocation immediately and establish the worker’s immigration options.
Existing sponsored worker temporarily outside the UK	The worker may already hold immigration permission but can still be affected by consequential cancellation action following revocation.	Establish the worker’s immigration position before planned return travel rather than relying solely on an apparently unexpired eVisa.
Worker finds another licensed sponsor	Alternative sponsorship may allow the worker to remain under a sponsored route, subject to the relevant requirements.	Ensure the new employer undertakes its own sponsorship assessment, assigns a new CoS and that the worker makes the appropriate immigration application.
Worker has dependant family members	Dependants may also be affected if action is taken against the main applicant’s immigration permission.	Ensure the worker understands that the immigration position of their partner and children may also require assessment.
Qualifying care worker or senior care worker	Under the current temporary Home Office policy, permission should not be cancelled solely because the sponsor licence has been revoked where the worker falls within the specified categories.	Check the worker’s route, occupation code and circumstances before applying the general 60-day position. Confirm that there is no separate cancellation ground.
Worker subject to separate suitability or immigration concerns	Separate grounds for cancellation or other immigration action may apply irrespective of the general consequences of sponsor licence revocation.	Assess the individual immigration issue separately rather than assuming that the standard revocation consequences determine the outcome.

 

2. Stage One: Identify

 

The first stage is to identify every person whose immigration or recruitment position depends on the sponsor licence.

The employer should create a complete population covering:

 

• existing sponsored workers;
• workers temporarily overseas;
• workers with pending immigration applications;
• workers assigned a CoS but yet to apply;
• workers granted entry clearance but yet to travel;
• candidates awaiting sponsorship;
• employees expected to switch into sponsored status;
• international transferees; and
• future recruits dependent on sponsorship.

 

Do not restrict the exercise to workers currently appearing on payroll or physically present in the UK.

 

3. Stage Two: Categorise

 

Each affected person should then be categorised according to their immigration position and level of urgency.

For each individual, record:

 

1. their immigration route;
2. their occupation code;
3. their current immigration expiry date;
4. their Certificate of Sponsorship details;
5. whether they are inside or outside the UK;
6. whether an immigration application is outstanding;
7. whether entry clearance has already been granted;
8. whether they have received Home Office correspondence;
9. whether they are implicated in the circumstances leading to revocation;
10. whether dependant family members may be affected;
11. whether alternative sponsorship may be available; and
12. whether any special Home Office policy applies.

 

This converts a potentially large workforce problem into identifiable individual cases.

 

4. Stage Three: Protect

 

The next stage is to protect the organisation and affected workers from avoidable additional problems.

Immediate protective measures can include:

 

• preserving sponsorship and employment records;
• stopping the assignment or planned use of Certificates of Sponsorship;
• reviewing international recruitment activity;
• pausing inappropriate travel or relocation arrangements;
• identifying workers with imminent immigration deadlines;
• reviewing pending applications;
• preventing inconsistent employee communications;
• preserving evidence relevant to workers named in Home Office allegations; and
• ensuring the organisation does not continue operating on the assumption that it remains an authorised sponsor.

 

These measures should be implemented while the organisation assesses whether and how the revocation decision itself can be challenged.

 

5. Stage Four: Communicate

 

Sponsored workers will understandably want to know what the revocation means for their employment, immigration permission and families.

Communications should be factual and avoid making promises that cannot safely be applied across the workforce.

In particular, employers should avoid telling all workers that:

 

• they automatically have 60 days;
• their visa has already ended;
• they can continue working for another 60 days;
• they can remain until the original expiry date of their visa;
• a pending application will continue unaffected;
• dependants are automatically unaffected; or
• a challenge to the revocation protects their immigration status.

 

Instead, communications should explain that the sponsor licence has been revoked, that individual immigration consequences can differ and that each worker’s position is being assessed separately.

Workers should also be advised to monitor Home Office correspondence and obtain individual immigration advice where required.

 

6. Stage Five: Regularise

 

Where an affected worker wants to remain in the UK, consideration should be given to whether their immigration position can lawfully be regularised before the relevant deadline.

Depending on the worker’s circumstances, potential options can include:

 

• obtaining sponsorship from another licensed employer;
• receiving a new Certificate of Sponsorship;
• making an appropriate application based on new sponsorship;
• applying under another immigration route where eligible; or
• making arrangements to leave the UK before permission expires where no viable immigration option is available.

 

The employer should not assume that every worker can move to another sponsor or that alternative sponsorship can be completed within the available timeframe.

Equally, affected workers should not wait until the end of their remaining permission before exploring their options.

 

7. Stage Six: Challenge

 

The organisation should separately assess whether there are grounds to challenge the sponsor licence revocation.

This can require detailed review of:

 

• the revocation decision;
• the Home Office allegations;
• compliance visit records;
• previous Home Office correspondence;
• the organisation’s representations;
• the evidence relied upon by the Home Office;
• evidence that was overlooked or misunderstood;
• the relevant sponsor guidance; and
• the lawfulness and procedural fairness of the decision.

 

There is no general statutory right of appeal against sponsor licence revocation. Depending on the circumstances, judicial review may be available to challenge an unlawful decision.

Any challenge should be considered promptly, but it should not displace the parallel need to protect individual sponsored workers.

 

8. The Employer Response: Identify → Categorise → Protect → Communicate → Regularise → Challenge

 

A practical response framework can therefore be summarised as:

Identify → Categorise → Protect → Communicate → Regularise → Challenge.

Identify every worker, applicant and recruit affected by the loss of sponsorship.

Categorise each person according to immigration status, application stage, location, deadlines and individual risk.

Protect workers and the organisation by preserving evidence, stopping inappropriate sponsorship activity and prioritising urgent cases.

Communicate accurately without making blanket statements about visa cancellation, continued employment or the 60-day period.

Regularise individual immigration positions where lawful options are available.

Challenge the sponsor licence decision where there are proper grounds to do so.

This approach allows employers to manage the immediate workforce consequences without losing sight of the underlying sponsor licence dispute.

 

9. Sponsor Licence Revocation: Immediate Employer Checklist

 

Immediately following revocation, employers should check that they have:

 

• obtained and reviewed the full Home Office revocation decision;
• identified every sponsored worker and prospective sponsored recruit;
• created a central immigration status and deadline schedule;
• identified workers named or implicated in the Home Office allegations;
• identified workers with fewer than 60 days of existing permission;
• identified all pending overseas entry clearance applications;
• identified all pending in-country immigration applications;
• identified workers granted entry clearance who have not travelled;
• identified existing sponsored workers temporarily outside the UK;
• reviewed Certificates of Sponsorship and outstanding recruitment;
• identified workers who may seek alternative sponsorship;
• considered the position of dependant family members;
• identified qualifying care workers who may fall within the current temporary Home Office policy;
• reviewed right to work and employment implications;
• stopped inappropriate international recruitment and relocation activity;
• preserved sponsorship, HR and compliance records;
• prepared controlled communications for affected workers;
• identified individual cases requiring urgent immigration advice;
• reviewed whether there are grounds to challenge the revocation; and
• established parallel sponsor licence and sponsored worker response workstreams.

 

The purpose of the checklist is not merely administrative. It is to identify the cases where delay could result in a worker losing an immigration option that might otherwise have remained available.

 

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Section P: How DavidsonMorris Can Help

 

Sponsor licence revocation can create immediate legal, immigration and workforce risks for an employer. The organisation may need to respond to the Home Office decision while at the same time managing the consequences for existing sponsored workers, pending applicants, overseas recruits and dependant family members.

DavidsonMorris advises employers on sponsor licence revocation and the resulting impact on sponsored workers.

We can help organisations assess the Home Office decision, understand the consequences for their sponsored workforce and develop a coordinated response covering both the sponsor licence and individual worker issues.

 

1. Reviewing the Sponsor Licence Revocation Decision

 

We can review the Home Office revocation decision and the events leading to it to identify the legal, compliance and evidential issues involved.

This can include reviewing:

 

• the reasons given by the Home Office for revocation;
• the sponsor duties said to have been breached;
• evidence obtained during a Home Office compliance visit or investigation;
• previous Home Office correspondence;
• representations previously submitted by the organisation;
• the evidence relied upon in the revocation decision;
• potential factual inaccuracies or misunderstandings;
• the treatment of individual sponsored workers; and
• whether there may be grounds to challenge the decision.

 

The purpose is to establish both the organisation’s legal position and the immediate practical consequences of the revocation.

 

2. Assessing the Impact on Sponsored Workers

 

We can help employers identify and categorise workers affected by the loss of the sponsor licence.

This can include:

 

• existing sponsored workers in the UK;
• workers with fewer than 60 days of existing permission remaining;
• workers identified in the Home Office allegations;
• workers with pending immigration applications;
• workers who have been assigned a CoS but have not yet applied;
• workers granted entry clearance but yet to travel;
• existing sponsored workers temporarily outside the UK;
• workers seeking alternative sponsorship;
• workers with dependant family members; and
• workers potentially affected by sector-specific Home Office policies.

 

This allows the employer to move from a general concern about its sponsored workforce to a worker-by-worker response plan.

 

3. Identifying Urgent Immigration Deadlines

 

The 60-day period associated with sponsor licence revocation is frequently misunderstood.

Not every worker receives 60 days and the Home Office does not extend permission beyond its existing expiry date simply because the sponsor licence has been revoked.

We can help employers identify which workers require the most urgent attention, including individuals:

 

• whose existing permission expires in fewer than 60 days;
• who have received Home Office cancellation correspondence;
• whose immigration applications remain outstanding;
• who are preparing to travel to the UK;
• who are temporarily outside the UK;
• who may be implicated in the reasons for revocation; or
• whose family members are also affected.

 

Early identification of these cases can be critical to preserving available immigration options.

 

4. Workers Implicated in the Reasons for Revocation

 

Where the Home Office alleges that particular sponsored workers were actively and knowingly involved in the conduct leading to revocation, their immigration position can differ substantially from that of other sponsored employees.

We can review the allegations and supporting evidence concerning individual workers and advise on the potential immigration consequences.

This can be particularly important where the Home Office alleges issues such as sham employment, inaccurate sponsorship information, non-genuine vacancies or other conduct involving both the sponsor and worker.

The fact that an individual is named in a sponsor licence decision should not be treated as a substitute for analysing the specific allegation and evidence concerning that person.

 

5. Pending Immigration Applications & Certificates of Sponsorship

 

We can advise on cases where sponsor licence revocation occurs while workers are part-way through the sponsorship or immigration process.

This can include:

 

• Certificates of Sponsorship that have already been assigned;
• overseas entry clearance applications that remain pending;
• in-country applications that remain pending;
• workers who may obtain alternative sponsorship while an application is outstanding;
• entry clearance that has already been granted; and
• workers who have received entry clearance but have not yet travelled.

 

The correct response can differ significantly according to the worker’s location and the stage reached in the immigration process.

 

6. Sponsored Workers Outside the UK

 

Revocation can also create urgent issues for sponsored workers and recruits who are outside the UK.

We can advise on the position of:

 

• prospective workers assigned a CoS but yet to apply;
• workers with entry clearance applications pending;
• workers granted entry clearance but yet to travel;
• existing sponsored employees temporarily overseas; and
• dependant family members outside the UK.

 

This can help employers make informed decisions about planned travel, relocation, onboarding and international mobility arrangements.

 

7. Dependants of Sponsored Workers

 

Where sponsored workers have relocated with partners or children, the consequences of sponsor licence revocation can extend to the immigration position of the wider family.

We can help identify how action affecting the main sponsored worker may affect dependant family members and what further immigration steps may need to be considered.

This is particularly important where family members have different immigration expiry dates, outstanding applications or are currently outside the UK.

 

8. Care Workers & the Temporary Home Office Policy

 

For employers in adult social care, the current temporary Home Office arrangements for certain care workers and senior care workers require specific consideration.

We can help determine whether an affected worker falls within the relevant occupational categories and whether the temporary policy preventing cancellation solely because of sponsor licence revocation applies.

We can also advise on the limits of the policy, including circumstances where separate cancellation grounds may exist and the worker’s longer-term need to resolve their employment and sponsorship position.

As the policy is temporary and subject to review, the current Home Office position should be checked when advice is provided.

 

9. Right to Work & Employment Consequences

 

Sponsor licence revocation can create overlapping sponsorship, immigration, right to work and employment issues.

These should not be treated as interchangeable.

We can help employers establish the immigration position of affected workers and understand the implications for workforce management.

Where required, the immigration analysis can be coordinated with employment law advice concerning matters such as contractual obligations, dismissal procedures, notice and pay.

The objective is to avoid immigration assumptions driving employment decisions without proper consideration of the separate legal issues involved.

 

10. Communications With Sponsored Workers

 

Communicating with affected workers can be one of the most difficult aspects of sponsor licence revocation.

Employers need to provide meaningful information without giving inaccurate assurances about immigration status or future employment.

We can assist with the immigration content of workforce communications, helping employers avoid potentially misleading statements such as:

 

• all workers automatically have 60 days;
• all workers can continue working for 60 days;
• all visas have been cancelled immediately;
• pending applications are unaffected;
• dependants are unaffected; or
• challenging the revocation automatically protects worker immigration permission.

 

For larger sponsored populations, communications can be structured around common worker categories while preserving the need for individual assessment.

 

11. Alternative Sponsorship & Immigration Options

 

Where workers need to consider alternative sponsorship, we can advise on the immigration requirements and timing involved.

This can include assessing:

 

• whether the worker may be eligible to continue under their existing sponsored route with another employer;
• the requirement for a new Certificate of Sponsorship;
• the immigration application required to change sponsor;
• the timing of the application;
• the effect of an existing pending application;
• when the worker may be able to start employment with the new sponsor; and
• whether another immigration route may be available.

 

Where appropriate, we can also advise a prospective new sponsor on its own sponsorship obligations in relation to the proposed recruitment.

 

12. Judicial Review & Challenging Revocation

 

There is no general statutory right of appeal against sponsor licence revocation.

Where there are grounds to argue that the Home Office decision is unlawful, judicial review may be available.

We can advise on the merits and strategy of a potential challenge, including the factual and legal basis of the revocation decision and the consequences for the sponsored workforce.

Any challenge needs to be considered alongside the individual immigration position of affected workers, since preparing or commencing judicial review proceedings does not automatically restore the sponsor licence or protect worker immigration permission.

 

13. Sponsor Compliance Remediation

 

Revocation can expose weaknesses in the organisation’s sponsorship governance and compliance systems.

Alongside the immediate legal and workforce response, we can help organisations identify the underlying compliance issues and develop remedial measures.

This can include reviewing:

 

• sponsor management responsibilities;
• key personnel and governance;
• Certificate of Sponsorship processes;
• recruitment procedures;
• right to work systems;
• record keeping;
• Home Office reporting;
• monitoring of sponsored workers;
• internal escalation procedures;
• training; and
• compliance audit arrangements.

 

This work can help the organisation understand why the compliance failure occurred and strengthen its immigration governance for the future.

 

14. Coordinated Sponsor Licence & Workforce Response

 

The most effective response to sponsor licence revocation usually requires the employer to address the licence decision and the sponsored workforce at the same time.

DavidsonMorris can support employers across both workstreams:

Sponsor licence workstream:

 

• revocation decision analysis;
• evidence review;
• challenge strategy;
• judicial review considerations;
• compliance remediation; and
• future sponsorship strategy.

 

Sponsored worker workstream:

 

• worker population assessment;
• immigration deadline analysis;
• pending applications;
• overseas workers;
• alternative sponsorship;
• dependants;
• care worker cases;
• right to work issues; and
• workforce communications.

 

Running these workstreams together allows the organisation to address the Home Office decision without overlooking individual worker deadlines or immigration consequences that may require immediate action.

 

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Section Q: Conclusion

 

Sponsor licence revocation can have immediate and serious consequences for sponsored workers, but those consequences are not identical in every case.

The commonly referenced 60-day period is only part of the picture.

Where an existing sponsored worker was not actively and knowingly involved in the circumstances leading to revocation, the Home Office will normally cancel or shorten their immigration permission so that they have up to 60 calendar days remaining.

This does not mean that every worker receives a fresh 60 days. If the worker already has fewer than 60 days remaining on their immigration permission, revocation does not extend that permission.

 

1. The 60-Day Position Does Not Apply to Every Worker

 

Where the Home Office considers that a sponsored worker was actively and knowingly involved in the circumstances that resulted in the sponsor licence being revoked, the position can be substantially more serious.

In these circumstances, the Home Office will normally cancel all of the worker’s remaining immigration permission rather than applying the usual treatment available to an uninvolved worker.

Employers should therefore avoid issuing blanket communications telling their entire sponsored workforce that everyone has 60 days.

The circumstances of individual workers need to be assessed separately.

 

2. Revocation Does Not Give Workers a General Right to Continue Working for 60 Days

 

The potential 60-day period is also frequently misunderstood as a period during which the worker can simply continue working for the employer whose sponsor licence has been revoked.

That is not the correct approach.

Sponsor licence revocation means the employer has lost its authority to sponsor workers. Current GOV.UK guidance states that where an employer loses its sponsor licence, the sponsored worker will have to leave their job and leave the UK unless they make a new visa application to stay.

The worker’s immigration permission, right to work and the employer’s authority to sponsor are related issues, but they are not interchangeable.

An apparently unexpired eVisa does not restore the employer’s sponsor licence, while revocation itself should not automatically be described as making every sponsored worker an overstayer at the moment the licence is revoked.

 

3. Pending Applications & Overseas Workers Require Separate Assessment

 

The consequences can be different again where the worker has not yet started employment or is outside the UK.

Certificates of Sponsorship assigned by the revoked sponsor automatically become invalid.

Where an overseas entry clearance application is pending and relies on an invalid CoS, current Home Office sponsor guidance states that the application will automatically be refused.

Where entry clearance has already been granted but the worker has not travelled to the UK when the sponsor licence is revoked, current guidance states that the entry clearance will be cancelled.

Pending applications made from within the UK require a more individual assessment of the application, the worker’s existing immigration status and whether alternative sponsorship or another immigration basis may be available.

Existing sponsored workers who are temporarily outside the UK should also establish their immigration position before attempting to return rather than assuming that an apparently unexpired grant of permission means the revocation cannot affect their return.

 

4. Alternative Sponsorship May Be Possible

 

For some workers, obtaining sponsorship from another licensed employer may provide a route to remaining in the UK.

Sponsorship cannot simply be transferred between employers.

The new employer will generally need to hold the appropriate sponsor licence, offer a genuine role that meets the relevant immigration requirements and assign its own Certificate of Sponsorship.

The worker will then need to make the appropriate immigration application and comply with the conditions applying to their route before taking up the new sponsored employment.

Finding another job therefore does not, by itself, resolve the worker’s immigration position.

Workers who may need alternative sponsorship should start considering their options promptly rather than waiting until the end of any remaining period of permission.

 

5. Dependants Can Also Be Affected

 

The consequences of sponsor licence revocation can extend beyond the sponsored employee.

Where the worker has a dependant partner or children, their immigration position may also require consideration if action is taken against the main worker’s permission.

Dependant permission should not automatically be treated as disappearing at the moment the sponsor licence is revoked. Equally, families should not assume that dependant permission will necessarily remain unaffected until its original expiry date.

The position of the main worker and each dependant should be considered as part of the overall immigration response.

 

6. Care Workers May Be Subject to a Different Temporary Policy

 

Employers in the adult social care sector should also be aware of the current temporary Home Office arrangements applying to certain care workers and senior care workers.

Under the policy in force at the time of writing, qualifying workers should not have their immigration permission cancelled solely because their sponsor’s licence has been revoked.

The protection is limited. It does not restore the employer’s sponsor licence, does not prevent cancellation on separate grounds and does not remove the need for affected workers to consider their longer-term employment and immigration position.

As the arrangement is temporary and subject to review, the current Home Office guidance should be checked whenever a case arises.

Current position checked: October 2026.

 

7. Employers Need a Parallel Sponsor & Worker Strategy

 

For employers, sponsor licence revocation should be treated as both a sponsor compliance crisis and an individual workforce immigration issue.

The organisation may need to challenge the Home Office decision, review the evidence and address underlying compliance failures. At the same time, it needs to identify every sponsored worker, applicant and recruit affected by the loss of the licence.

These workstreams should run in parallel.

Preparing or pursuing a challenge to the revocation does not automatically restore the sponsor licence, validate Certificates of Sponsorship or protect the immigration permission of affected workers.

Employers should therefore identify immigration deadlines and worker-specific consequences immediately rather than waiting for the sponsor licence dispute to be resolved.

 

8. The Key Is Individual Assessment & Early Action

 

The two most dangerous assumptions following sponsor licence revocation are that every sponsored worker immediately becomes an overstayer or, at the opposite extreme, that every sponsored worker can simply continue working for another 60 days.

Neither provides an accurate basis for managing the workforce.

The correct response depends on factors including the worker’s existing immigration permission, its expiry date, whether the worker was involved in the reasons for revocation, whether an application is pending, whether the worker is inside or outside the UK, whether alternative sponsorship is available and whether a specific Home Office policy applies.

Employers should therefore respond to sponsor licence revocation by:

 

1. addressing the revocation decision itself;
2. identifying every affected sponsored and prospective worker;
3. establishing individual immigration positions and deadlines;
4. reviewing employment and right to work consequences;
5. communicating accurately with affected workers;
6. identifying viable alternative immigration solutions where available; and
7. taking specialist advice promptly where worker status or the sponsor licence decision is disputed.

 

Early action cannot guarantee that every affected worker will be able to remain in the UK, but it can help employers and workers understand the available options before immigration deadlines or Home Office decisions restrict them further.

 

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Section R: FAQs

 

Does Sponsor Licence Revocation Mean Sponsored Workers Immediately Become Illegal Immigrants?

No. Sponsor licence revocation does not mean that every sponsored worker automatically becomes an overstayer at the moment the employer loses its licence.

The employer’s sponsor licence and the worker’s immigration permission are separate, although closely connected. Following revocation, the Home Office may take action to cancel or shorten the worker’s permission.

Where the worker was not actively and knowingly involved in the circumstances leading to revocation, the Home Office will normally cancel or shorten permission so that the worker has up to 60 calendar days remaining, subject to the original expiry date of their permission.

Where the worker was actively and knowingly involved, the Home Office will normally cancel all remaining permission.

 

Do Sponsored Workers Automatically Get 60 Days After Sponsor Licence Revocation?

No. The 60-day period is not automatic in every case and should not be treated as a new 60-day visa.

For an existing sponsored worker who was not actively and knowingly involved in the circumstances leading to revocation, the Home Office will normally cancel or shorten permission so that the worker has up to 60 calendar days remaining.

If the worker already has 60 calendar days or less remaining when cancellation action is considered, the Home Office will not normally cancel or shorten that permission.

Workers who were actively and knowingly involved in the circumstances leading to revocation may face cancellation of all their remaining permission instead.

 

When Does the 60-Day Period Start?

The 60-day period should not simply be calculated from the date on which the employer receives its sponsor licence revocation decision.

The worker’s position depends on the Home Office action taken in relation to their individual immigration permission and the effective date specified in the relevant cancellation decision.

Affected workers should therefore monitor communications from the Home Office carefully and establish the actual expiry date applying to their permission rather than relying on an informal calculation from the sponsor’s revocation date.

 

Can a Sponsored Worker Continue Working for an Employer Whose Sponsor Licence Has Been Revoked?

Employers should not treat the potential 60-day immigration period as a general right for the worker to continue working for the revoked sponsor for another 60 days.

Current GOV.UK worker guidance states that where an employer loses its sponsor licence, a sponsored worker will have to leave their job and leave the UK unless they make a new visa application to stay.

This is different from sponsor licence suspension, where existing sponsored workers with valid permission can generally continue working while the licence remains suspended.

The worker’s immigration permission, their right to work and the employer’s authority to sponsor should therefore be assessed separately.

 

Can a Worker Find Another Sponsor After Their Employer’s Licence Is Revoked?

Potentially, yes.

A sponsored worker may be able to move to another appropriately licensed employer if they receive a qualifying job offer and meet the relevant immigration requirements.

The new employer will generally need to assign its own Certificate of Sponsorship and the worker will need to make the appropriate immigration application.

Sponsorship cannot simply be transferred from the employer whose licence was revoked.

 

Can a Worker Remain in the UK While Looking for Another Sponsor?

This depends on the immigration permission the worker holds and any cancellation action taken by the Home Office.

Where the worker was not involved in the circumstances leading to revocation, the Home Office will normally shorten or cancel permission so that up to 60 calendar days remain, subject to the worker’s existing expiry date.

The worker may use the period in which they continue to hold lawful permission to explore their options, but they should not assume that finding another employer shortly before the deadline will itself protect their status.

Obtaining a job offer, securing a new CoS and making the appropriate immigration application can take time, so alternative sponsorship should be explored as early as possible.

 

What Happens If the Worker Has Fewer Than 60 Days Left on Their Visa?

If the worker already has 60 calendar days or less remaining when cancellation action is considered, the Home Office will not normally cancel or shorten that permission. The existing expiry date therefore remains relevant.

This can make workers with fewer than 60 days remaining particularly urgent cases because they may have substantially less time to secure alternative sponsorship or pursue another immigration option.

 

What Happens If the Worker Was Involved in the Reason for Sponsor Licence Revocation?

Where the Home Office considers that the worker was actively and knowingly involved in the circumstances leading to revocation, it will normally cancel all of the worker’s remaining immigration permission.

The usual treatment of leaving up to 60 calendar days remaining does not apply in the same way.

Where an individual worker is named or implicated in the Home Office allegations, the specific allegation and evidence concerning that worker should therefore be reviewed urgently.

 

What Happens to Certificates of Sponsorship When a Sponsor Licence Is Revoked?

Certificates of Sponsorship assigned by the revoked sponsor automatically become invalid.

The employer cannot continue assigning new CoS after revocation and an existing CoS cannot simply be transferred to another employer.

If another licensed employer agrees to sponsor the worker, that employer will normally need to assign its own new Certificate of Sponsorship.

 

What Happens If the Worker Has a Visa Application Pending?

The answer depends in particular on whether the application was made from outside or inside the UK.

For an overseas entry clearance application relying on a CoS assigned by the revoked sponsor, current Home Office sponsor guidance states that the application will automatically be refused because the CoS has become invalid.

For an in-country application, the position requires individual assessment. The loss of the sponsor can undermine the sponsorship basis of the application, but the correct procedural response will depend on the application, the worker’s existing immigration position and whether alternative sponsorship or another immigration basis becomes available. If the live application continues to rely on the revoked sponsor and its basis is not varied before decision, the Home Office will refuse it.

 

What Happens If the Visa Has Been Granted But the Worker Has Not Travelled to the UK?

Current Home Office sponsor guidance states that where entry clearance has already been granted but the worker has not travelled to the UK when the sponsor licence is revoked, the entry clearance will be cancelled.

The worker should therefore not assume that they can travel to the UK simply because their immigration application was approved before the employer lost its sponsor licence.

Planned travel and relocation should be reviewed immediately.

 

What Happens to the Worker’s Dependants?

Dependants do not automatically lose their immigration permission at the precise moment the sponsor licence is revoked.

However, where the Home Office cancels or shortens the main sponsored worker’s permission, the immigration position of dependant partners and children may also be considered.

Where dependant permission is cancelled in line with the main applicant, the remaining period will normally be aligned with the main applicant’s position.

Families should therefore consider the immigration position of the main worker and each dependant together.

 

Are Care Workers Treated Differently After Sponsor Licence Revocation?

Some are, under the current temporary Home Office policy.

At the time of writing, qualifying Skilled Worker and Health and Care Worker visa holders sponsored as care workers or senior care workers under the specified occupation codes should not have their permission cancelled solely because their employer’s sponsor licence has been revoked.

The protection is limited. It does not restore the employer’s sponsor licence and does not prevent cancellation where another lawful cancellation ground applies.

The policy is temporary and subject to review, so the current Home Office guidance should always be checked.

Current position checked: October 2026.

 

Can a Sponsored Worker Transfer to Another Company in the Same Group?

Common ownership does not create an automatic right to transfer sponsorship between group companies.

If another group company is to employ and sponsor the worker, that entity would need to hold the appropriate sponsor licence and there would need to be a genuine role that satisfies the relevant immigration requirements.

The new sponsor would generally need to assign its own Certificate of Sponsorship and the worker would need to make the appropriate immigration application.

The revoked sponsor’s CoS cannot simply be moved from one group company to another.

 

Does Challenging the Sponsor Licence Revocation Protect Sponsored Workers?

Not automatically.

The fact that an employer disputes the revocation or intends to bring judicial review proceedings does not by itself restore the sponsor licence, validate Certificates of Sponsorship or suspend the immigration consequences for workers.

Employers should therefore continue dealing with individual worker deadlines and immigration issues while any challenge to the sponsor licence decision proceeds.

 

Can an Employer Appeal Against Sponsor Licence Revocation?

There is no general statutory right of appeal against sponsor licence revocation.

Where the decision may be unlawful, judicial review can potentially provide a route to challenge it.

The availability and merits of judicial review will depend on the circumstances, including the reasons given by the Home Office, the evidence, the procedure followed and whether the decision is legally flawed.

 

What Should an Employer Tell Sponsored Workers After Revocation?

Employers should communicate promptly but avoid blanket assurances or conclusions.

Workers should be informed that the sponsor licence has been revoked, that this can affect their immigration and employment position and that the consequences need to be assessed according to their individual circumstances.

Employers should avoid telling everyone that they automatically have 60 days, that they can all continue working for another 60 days or that their immigration permission has automatically ended immediately.

Workers should also be advised to monitor Home Office correspondence and take individual immigration advice where necessary.

 

What Should an Employer Do First After Its Sponsor Licence Is Revoked?

The employer should immediately review the Home Office revocation decision and identify every sponsored worker, applicant and prospective recruit affected by the loss of the licence.

It should then create a worker-by-worker schedule recording immigration status, expiry dates, Certificates of Sponsorship, pending applications, worker location, Home Office correspondence and any relevant individual risk factors.

Urgent cases should be prioritised, particularly workers with short remaining permission, workers implicated in the revocation, pending applicants, workers outside the UK and those whose dependant family members may also be affected.

At the same time, the employer should assess whether the revocation decision can be challenged and preserve the evidence required for any legal response.

The sponsor licence and sponsored worker workstreams should proceed in parallel rather than waiting for one to be resolved before addressing the other.

 

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Section S: Glossary

 

Term	Meaning
Cancellation of Permission	Home Office action that brings a person’s immigration permission to an end earlier than its original expiry date. Following sponsor licence revocation, cancellation may affect sponsored workers whose permission was based on employment with the revoked sponsor. The precise treatment depends on the worker’s circumstances, including whether they were actively and knowingly involved in the circumstances leading to revocation.
Certificate of Sponsorship (CoS)	An electronic sponsorship record assigned by a licensed sponsor to a worker for use in a sponsored immigration application. It is not a physical certificate. Certificates of Sponsorship assigned by an employer whose sponsor licence is revoked automatically become invalid and cannot simply be transferred to another sponsor.
Curtailment	An older term commonly used to describe the shortening of a person’s immigration permission. Current Home Office terminology generally refers to cancellation of permission, although the term “curtailment” continues to appear in immigration discussions and in the title or history of some Home Office guidance.
Dependant	A qualifying partner or child who holds or applies for immigration permission based on their relationship with a main visa holder. Where action is taken against the immigration permission of a sponsored worker following sponsor licence revocation, the immigration position of their dependants may also require consideration.
Entry Clearance	Immigration permission granted to an individual applying from outside the UK to enter the UK under a particular immigration route. Where entry clearance has been granted to a sponsored worker but the individual has not travelled to the UK when the sponsor licence is revoked, current Home Office sponsor guidance states that the entry clearance will be cancelled.
Health and Care Worker	A sponsored work category within the Skilled Worker route for eligible health and adult social care roles. Certain qualifying care workers and senior care workers are currently covered by a temporary Home Office policy under which permission should not be cancelled solely because their sponsor’s licence has been revoked, subject to the conditions and limitations of that policy.
Home Office	The UK government department responsible for immigration and nationality matters, including the sponsor licensing system, sponsor compliance activity and decisions concerning the immigration permission of sponsored workers.
Immigration Permission	The legal permission allowing a person to enter or stay in the UK subject to the conditions attached to their immigration route. A worker’s immigration permission is distinct from the employer’s sponsor licence, although sponsor licence revocation can lead to consequential action affecting that permission.
Judicial Review	A court procedure used to challenge the lawfulness of a decision made by a public authority. There is no general statutory right of appeal against sponsor licence revocation, but judicial review may potentially be available where there are grounds to argue that the Home Office decision was unlawful. Bringing judicial review proceedings does not automatically restore the sponsor licence or protect affected workers from immigration consequences.
Licensed Sponsor	An organisation authorised by the Home Office to sponsor eligible workers under specified immigration routes. Where a worker moves to another employer following sponsor licence revocation, the new employer will generally need to hold the appropriate sponsor licence before it can sponsor the worker.
Right to Work	The legal entitlement of an individual to undertake employment in the UK subject to any restrictions attached to their immigration status. Right to work, immigration permission and an employer’s authority to sponsor are related but separate concepts. An apparently valid right to work record does not restore a sponsor licence that has been revoked.
Sponsor	An organisation licensed by the Home Office to sponsor eligible migrant workers. Sponsors are responsible for complying with the duties and requirements of the sponsorship system.
Sponsor Licence	Home Office authorisation allowing an organisation to sponsor eligible overseas workers under specified immigration routes. Holding a sponsor licence brings ongoing compliance, reporting, record-keeping and monitoring duties.
Sponsor Licence Revocation	The withdrawal of an organisation’s sponsor licence by the Home Office. Revocation removes the organisation’s authority to sponsor workers and can result in significant consequences for existing sponsored workers, Certificates of Sponsorship, pending immigration applications and future recruitment.
Sponsor Licence Suspension	A Home Office compliance measure under which a sponsor licence is temporarily suspended while concerns are investigated or addressed. Suspension is different from revocation. During suspension, existing sponsored workers with valid immigration permission can generally continue working, although the sponsor’s ability to undertake new sponsorship activity is restricted. Revocation means the sponsor licence has been withdrawn.
Sponsor Management System (SMS)	The Home Office online system used by licensed sponsors to manage sponsorship activities. Authorised users use the SMS for functions such as assigning Certificates of Sponsorship, reporting relevant changes and maintaining aspects of the organisation’s sponsor licence.
Skilled Worker	A sponsored immigration route allowing eligible individuals to work in qualifying roles for licensed UK employers, subject to the applicable immigration requirements. A Skilled Worker affected by sponsor licence revocation may need to consider alternative sponsorship or another immigration option depending on their circumstances.
Sponsored Worker	An individual whose immigration permission to work in the UK is based on sponsorship by an organisation licensed by the Home Office. Sponsor licence revocation can affect the worker’s immigration permission, employment and ability to remain in the UK.
Sponsorship Duties	The ongoing obligations imposed on licensed sponsors by the Home Office. These include duties relating to record keeping, reporting, monitoring sponsored workers, compliance with immigration requirements and cooperation with the Home Office. Serious or systemic failures can result in compliance action, including sponsor licence suspension or revocation.
60-Day Period	The period commonly associated with the immigration consequences of sponsor licence revocation for an existing sponsored worker who was not actively and knowingly involved in the circumstances leading to revocation. The Home Office will normally cancel or shorten the worker’s permission so that they have up to 60 calendar days remaining. It is not a guaranteed new 60-day period and does not extend immigration permission that was already due to expire sooner. The 60-day period should also not be interpreted as a general entitlement to continue working for the employer whose sponsor licence has been revoked.

 

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Section T: Useful Links

 

Description	URL
GOV.UK: UK Visa Sponsorship for Employers – Your Licence Government guidance on sponsor licences, including the responsibilities of licensed sponsors and Home Office action where sponsorship requirements are not met.	https://www.gov.uk/uk-visa-sponsorship-employers/your-licence
Home Office: Workers and Temporary Workers – Sponsor Duties & Compliance Workers and Temporary Workers: guidance for sponsors, Part 3 – Sponsor duties and compliance.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
GOV.UK: What Happens If Your Sponsor Loses Their Licence? Government guidance for sponsored workers explaining the consequences where their employer loses its sponsor licence.	https://www.gov.uk/employee-lose-sponsor-licence
Home Office: Cancellation & Curtailment of Permission Home Office caseworker guidance on cancellation of immigration permission, including the approach to individuals affected by the loss of a sponsor and the current temporary arrangements applying to specified care workers and senior care workers.	https://www.gov.uk/government/publications/immigration-status-and-enforcement-action-caseworker-guidance/cancellation-and-curtailment-of-permission-accessible
Immigration Rules: Part Suitability The Immigration Rules covering suitability requirements and grounds for cancellation of immigration permission, including provisions relevant where a sponsor ceases to hold the required sponsor licence.	https://www.gov.uk/guidance/immigration-rules/immigration-rules-part-suitability
GOV.UK: Register of Licensed Sponsors The official Home Office register of organisations licensed to sponsor workers under the Worker and Temporary Worker immigration routes.	https://www.gov.uk/government/publications/register-of-licensed-sponsors-workers
GOV.UK: Skilled Worker Visa – Update Your Visa If You Change Job or Employer Government guidance on when a Skilled Worker needs to update their immigration permission after changing employer or making certain changes to their sponsored employment.	https://www.gov.uk/skilled-worker-visa/update-your-visa-if-you-change-job-or-employer
GOV.UK: Prove Your Right to Work Government service allowing individuals to obtain a share code to prove their right to work to an employer where the online service applies.	https://www.gov.uk/prove-right-to-work/get-a-share-code-online
GOV.UK: Check a Job Applicant’s Right to Work Government service for employers carrying out online right to work checks using an applicant’s share code and date of birth.	https://www.gov.uk/view-right-to-work
GOV.UK: Employer Checking Service Home Office service employers can use in specified circumstances to request verification of an individual’s right to work where the standard online or document checking process cannot establish their position.	https://www.gov.uk/employee-immigration-employment-status
GOV.UK: International Recruitment Support for Adult Social Care Government information relevant to international recruitment and support arrangements in adult social care, including measures intended to support internationally recruited care workers who become displaced.	https://www.gov.uk/government/publications/international-recruitment-fund-for-the-adult-social-care-sector

 

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