UKVI Action Plan: 2025 Sponsor Guide

Section A: What is a UKVI Sponsor Action Plan?

As a Home Office approved employer with a sponsor licence, your organisation will be placed on the national register of sponsors, and you’ll be given a licence rating. You’ll automatically get an A-rated licence if your application is approved. An A-rated licence will allow you to start assigning Certificates of Sponsorship (CoS) to prospective migrant workers to come to work for you in the UK.

An A-rated licence essentially means that you’ve been able to demonstrate to the Home Office that you have the necessary HR systems in place to monitor sponsored employees, together with trustworthy people capable of carrying out your sponsorship duties. However, where the Home Office has reason to believe that you’re failing to meet your responsibilities as a sponsor, typically following a compliance visit, this could potentially result in your licence being downgraded from an “A” rating to a “B” rating, and a sponsor action plan being put in place.

Action plans are outlined in the “Workers and Temporary Workers: Guidance for Sponsors – Part 3: Sponsor Duties and Compliance”.

While the plan is running you cannot assign any CoS to new hires or add branches or new routes, but you may assign a CoS only to someone you were already sponsoring for an in-country extension if eligible. UKVI will decide the number of CoS permitted for such extensions during the plan.

1. When UKVI issues an action plan

An action plan is usually triggered after UKVI identifies breaches that are material but fixable. The most common catalysts are gaps in Appendix D records, late or missing SMS reports for worker or organisational changes, and weaknesses in monitoring attendance or role details against sponsored SOC and salary. A plan is UKVI’s way of forcing remedial work while pausing expansion, rather than moving straight to suspension or revocation. The notice will explain the failures found and set expectations for evidence of improvement within the three month window.

2. What a plan expects in practice

Expect specific, time-bound actions tied to the issues UKVI found. These often include a full audit of sponsored files against Appendix D, a review of right to work procedures, staff training for SMS users, and documented processes for reporting and record-keeping. UKVI will look for named owners, dates, and artefacts such as training logs, corrected records, and evidence of internal checks. Plans that only restate policy without proof of implementation tend to fail, so maintain an audit trail from day one.

3. Operational impact while B-rated

The restrictions affect recruitment, budgeting, and workforce planning. You cannot assign new CoS to new hires, so pipeline offers that depend on sponsorship stall or fall away. Your Level 1 user should tell hiring managers which candidates can still proceed on an extension-only basis and which cannot. Communicate clearly with affected candidates to avoid abandoned applications and reputational damage. Finance should plan for the action plan fee and any costs of external audits or training needed to complete the plan on time.

Comparison of Licence Ratings (A vs B vs Revoked)

4. Governance that helps you pass first time

Set up a small project group led by the Authorising Officer, with your Level 1 user and HR lead. Map each UKVI requirement to a concrete task, an owner, and a completion date. Run weekly checkpoints, capture evidence as you go, and keep a single repository for documents you will present at the compliance review. If you rely on third-party HR systems, make sure they can export the records UKVI expects without delay. Where processes were unclear or undocumented, write short, practical SOPs that staff can follow.

5. Typical pitfalls to avoid

Do not assume the plan is a formality. Sponsors fail when they treat it as paperwork rather than operational change. Leaving payment beyond the 10 working day deadline risks revocation. Spreading accountability too thinly can slow progress, so keep decision-making tight. Finally, avoid over-promising in your response, since UKVI will test whether the measures are live and working, not just drafted.

Section B:  How does a UKVI Sponsor Action Plan Work?

A sponsor action plan is a plan designed to address relatively minor breaches of duty as a licensed sponsor, in circumstances where the sponsor is willing and able to correct any issues. The plan will set out the steps that need to be taken to help reinstate “A” licence rating.

If your licence rating is downgraded, and a sponsor action plan imposed, although you’ll still be able to issue CoS to workers you already employ who want to extend their permission to stay in the UK, you’ll not be able to issue new certificates until you’ve made improvements and upgraded back to an A-rating. Any overseas recruitment will therefore be put on hold.

Sponsor Action Plan Timeline

The process begins with a Home Office notification via email or letter, detailing the proposed downgrade and reasons (e.g., breaches listed in Annex C2 or C3 of the guidance, like lacking processes to manage sponsored workers).

You must pay the action plan fee of £1,579 using the SMS under the ‘Action plan payments’ function within 10 working days of being informed of the downgrade, or return the licence surrender declaration. If you fail to act within that time, UKVI will revoke your licence.

The plan itself is tailored to your organisation’s breaches, for instance, enhancing HR processes, limiting CoS assignments, or improving inter-branch communication, and lasts a fixed 3 months, the maximum time deemed necessary for rectification. You may request an early compliance review if you believe you have completed the actions before the 3 months have passed.

The downgrade means your licence becomes B-rated, restricting activities. Your CoS allocation is limited to extension-only CoS for workers you were already sponsoring, and UKVI will set the number permitted. You cannot sponsor new workers, add branches or routes, or assign new CoS beyond those extensions.

During the plan, you must implement all specified steps, cooperating with Home Office checks (digital or on-site) and providing evidence like updated records or training logs. Progress is monitored, and you can request an early compliance review if confident of completion before 3 months.

At the end of the action plan, if you’ve satisfactorily completed all the steps, you’ll be upgraded to an A-rating.

A second action plan is issued (with a fresh £1,579 fee) only if you finish the first one but new issues, not serious enough for revocation, are found. You can only be B-rated twice in any rolling 4-year period. If UKVI finds you need downgrading again after that, they must revoke the licence.

Note that provisional sponsors on the UK Expansion Worker route cannot be downgraded; UKVI may revoke the licence if they fail to meet duties.

1. Step-by-step process once downgraded

The downgrade process is structured and time-sensitive. The first point is the notification letter or email, which sets out the specific breaches. Sponsors should immediately assess the reasons cited against their own records and decide whether to contest or accept. If you accept, payment of the action plan fee is the first compliance hurdle — missing the 10-day deadline results in automatic revocation. Once paid, the 3-month timetable starts, so you must treat it as a short project with hard milestones. Every week counts when producing evidence for UKVI review.

2. What UKVI expects during the plan

UKVI will not accept generic assurances. Evidence must be tangible and auditable. This can include signed attendance sheets, screenshots of updated SMS records, documented escalation procedures, and training logs for HR staff. If breaches were related to right to work checks, UKVI will expect to see properly dated and copied documents for each sponsored worker, aligned with statutory excuse requirements. Where HR systems are used, make sure they generate exportable reports that can be submitted quickly if UKVI asks for them during a monitoring review.

3. Managing the impact of the B-rating

For employers, the B-rating halts international recruitment and puts pressure on existing workforce planning. Projects reliant on overseas talent may face disruption, so HR and recruitment teams should engage with managers to manage expectations and plan alternatives. The extension-only CoS allocation is finite and set by UKVI, so prioritisation is necessary. Be clear with sponsored workers about what can and cannot be done during the plan period, to avoid false assurances or failed visa applications that could harm both staff and the organisation’s reputation.

4. Strategic lessons for sponsors

Many sponsors underestimate the reputational and operational cost of a downgrade. While it is not a public sanction in the same way as revocation, the inability to recruit from overseas can have a severe impact. Treat the action plan as a warning that your systems did not meet the required standard. The process is as much about proving cultural and systemic compliance as it is about paperwork. If you use the 3 months effectively, you can emerge with stronger systems and lower risk of repeat breaches. Failing to do so risks the end of your ability to sponsor for at least a year if revocation follows.

Section C: UKVI Action Plan Costs and Timescales

If your licence rating is downgraded, you’ll have to pay for a sponsor action plan at a cost of £1,579 to upgrade your licence to an A-rating. You must pay this fee within 10 working days of the date of being informed by the Home Office of its decision to downgrade. If you fail to make payment in full within that period, you’ll lose your licence because of this. If you’re given another B-rating after your first sponsor action plan, you’ll have to follow a new action plan and pay the fee again.

A Home Office sponsor action plan is time-limited, where the maximum time a business can be the subject of an action plan is 3 months. You may request an early compliance check once you believe every action is complete.

As a downgraded sponsor, you’ll therefore need to respond to the recommendations contained within the plan, both quickly and effectively.

If you fail to comply with all necessary steps set out within your sponsor action plan, and your licence is revoked as a result, you cannot appeal, but you can reapply. However, you’ll have to wait at least 12 months before being able to do so, without any guarantee that your new application will be successful. This will be treated in the same way as any other application, requiring you to pay the relevant fee, submit the necessary documentation in support, and be able to satisfy the Home Office that you’re capable of carrying out your sponsorship duties.

1. Financial implications for sponsors

The £1,579 fee is a fixed, non-refundable cost imposed for each action plan. Sponsors should budget for the possibility of paying this more than once if compliance issues persist, since UKVI can issue a second plan in a rolling 4-year period. The fee is payable in addition to other sponsorship costs, such as the Immigration Skills Charge or visa application fees, meaning the financial burden of non-compliance can be significant. For smaller businesses, this outlay can be particularly difficult, especially when combined with halted overseas recruitment during the B-rating period.

2. Time pressures and operational impact

The 10 working day payment deadline is strict. Missing it results in immediate revocation, regardless of whether you intended to comply. Once the fee is paid, the 3-month action plan clock starts. The timeframe is deliberately tight, forcing sponsors to act quickly and demonstrate progress from the outset. Any delays in assigning responsibilities or gathering evidence can leave you scrambling at the end of the period, which UKVI will interpret as poor management of compliance duties.

3. Cooling-off risks after revocation

If your licence is revoked for failing to complete an action plan, you will normally face at least a 12-month cooling-off period before you can reapply. This gap creates real business risk, particularly if your operations depend on sponsored workers. You will lose the ability to sponsor new staff, and existing sponsored workers’ visas will be curtailed. Planning for contingencies is therefore crucial — whether by seeking legal support to avoid revocation, or by identifying alternative visa routes that could keep projects running if sponsorship is withdrawn.

4. Strategic considerations

Timescales and costs make action plans both disruptive and expensive. Sponsors should treat them as a wake-up call to embed permanent compliance systems, rather than just completing a checklist to restore their A-rating. The real cost is not only the £1,579 fee, but the reputational and operational damage that comes with restricted recruitment and the risk of losing sponsored talent if the plan fails. Building resilience into HR processes and monitoring systems ensures that compliance is sustainable beyond the life of the plan.

Section D:  Received a UKVI Sponsor Action Plan?

If you have been notified that your organisation’s sponsor licence has been downgraded and that you are now subject to an action plan, you will need to take action quickly. With appropriate advice and remedial steps, you can rectify the issues and reinstate your A-rating. However, failing to act or to address the issues raised could result in more damaging and serious enforcement action.

1. Your options

First, you should review the notification carefully. It details the breaches (e.g., from Annex C2 or C3) and the plan’s specifics. If contested unsuccessfully, focus on execution. The plan is fixed at 3 months and will be tailored to your issues, like improving HR processes or limiting CoS assignment, and aims to restore compliance without full revocation.

You will also need to pay the £1,579 fee, usually within 10 working days, via the SMS. Use your Level 1 user to accept and process payment. Non-payment leads to revocation, so prioritise this.

Next, implement the plan immediately. Assign a dedicated team member such as your Authorising Officer to oversee actions. For instance, if records are faulty, audit Appendix D documents and provide training to staff. Document everything as evidence. Cooperate with Home Office monitoring, which may include digital audits.

During the B-rating period, restrictions will apply. No new CoS assignments, branch additions or route expansions are permitted, but you can extend existing workers if eligible. Your CoS allocation is limited to extension-only CoS, with UKVI setting the number allowed. Monitor sponsored workers closely to avoid further breaches, like unreported absences or salary reductions.

If you complete actions early, request a compliance review via SMS for potential A-rating restoration ahead of 3 months.

At the end, a final check occurs; success upgrades the licence, but failure may trigger another plan, up to a maximum of two B-ratings in 4 years from licence grant. A third downgrade within that period will result in licence revocation.

Enforcement Outcomes for Non-Compliance

2. Further penalties for non-compliance

If you fail to comply with your sponsorship duties, instead of downgrading your licence rating and putting in place a sponsor action plan, there are various other sanctions that may be imposed by the Home Office, depending on the nature and seriousness of any breach. For example, where there’s been a significant or systematic failing, and you pose a serious threat to immigration control, or you no longer meet the eligibility or suitability requirements for holding a sponsorship licence, you’re at risk of having your licence suspended or revoked.

The Home Office will suspend your sponsorship licence where it needs to investigate the matter further before making any decision. This could then result in the revocation of your licence. In some cases, however, where a breach is especially serious and indefensible, the Home Office has the power to revoke your licence altogether without prior suspension.

You’ll be at risk of losing your licence if you’ve been found to be employing illegal workers. If you’ve failed to carry out prescribed right to work checks to establish a statutory excuse against illegal working, you’ll also be facing a possible civil penalty of up to £45,000 per illegal worker for a first breach, and up to £60,000 for repeat breaches, and potentially criminal prosecution. If you’re found guilty of employing a migrant who you knew, or had reasonable cause to believe, didn’t have permission to work in the UK, you could be given a custodial sentence of up to 5 years and be ordered to pay an unlimited fine.

Even in the context of relatively minor breaches, your licence will be revoked if you fail to comply with any Home Office sponsor action plan designed to reinstate your licence rating. If your sponsorship licence is revoked, this can have a serious impact on your business, especially if you’re heavily reliant on migrant workers. Having revoked your licence, the Home Office will also curtail the leave of any migrant workers currently employed by you, typically limiting them to no more than 60 calendar days to find a new sponsor or leave the UK.

3. Practical response strategy

Once downgraded, the best approach is to treat the action plan like an urgent compliance project. Appoint a project manager, set internal deadlines earlier than UKVI’s, and maintain an evidence log of every action taken. Communicate with your sponsored workers so they understand the limitations of your B-rating and do not make assumptions about new hires or changes. Where breaches relate to systemic issues, consider external audits to add credibility and show UKVI you are serious about sustainable compliance. Proactive steps taken during this period can influence UKVI’s assessment at the end of the plan and reduce the likelihood of further enforcement action.

Section E: How to Avoid a UKVI Sponsor Action Plan

Avoiding the imposition of a costly and time-consuming Home Office sponsor action plan, or any other possible sanctions that could be imposed, including suspension and revocation, is all about understanding and complying with your sponsorship duties at all times.

Being a UK sponsor is a significant responsibility, where the rules can be demanding and subject to constant change, often resulting in confusion or error, and exposing employers to serious compliance risks. If there is ever any uncertainty, to avoid action being taken against you, you should always seek expert advice from an immigration specialist. In this way, you can ensure that you’re not falling foul of the law.

1. Sponsorship duties

The grant of a sponsorship licence will allow you, as a Home Office approved sponsor, to recruit someone from outside the UK who doesn’t otherwise have immigration status to undertake work, or the work in question — provided they meet the requirements for a visa.

However, having been granted Home Office approval, significant trust is placed in you as a licence holder to act in accordance with the sponsorship requirements and to prevent abuse of the UK’s immigration system. As a licensed sponsor, you’re therefore agreeing to meet the various duties associated with sponsoring a migrant worker, including:

• Reporting any change in circumstances of a sponsored worker, such as regular absences or resignation, within prescribed timescales. You must also report certain changes to your business, such as a change in details, like your address or allocated roles for those responsible for managing your licence under the Sponsor Management System (SMS). The SMS is the Home Office online portal that allows UK sponsors to manage their migrant workforce, and related sponsor activities, such as issuing CoS, and reporting any relevant changes to your own or a migrants’ circumstances.
• Monitoring and recording employee attendance to ensure that all sponsored workers are complying with the conditions of their work visa. If, for example, you’re privy to information that suggests or shows that a migrant worker is breaching the conditions of their grant of leave, this must be reported to the Home Office through the SMS.
• Complying with the law, not least only assigning CoS to workers when the job is suitable for sponsorship, checking that migrant workers have the necessary skills, qualifications or professional accreditations to do their jobs, and conducting regular prescribed right to work checks on all prospective employees — as well as repeat checks for any employees with time-limited permission to work in the UK. In this way, you’ll not only help to prevent illegal working, but to avoid any civil or criminal penalty for employing illegal workers.
• Maintaining accurate and up-to-date records for all sponsored migrant workers, comprising, for example, their UK address and contact details. You must also retain copies of any online or manual right to work checks, to prove the entitlement of your migrant employees to work in the UK and undertake the work in question.
• Cooperating with the Home Office, whenever required, such as responding to any requests for further information or documentation, and providing access during any compliance visits. Naturally, the duty to co-operate includes acting honestly in any dealings with the Home Office, such as not making false or misleading statements.

2. Who is responsible for meeting these sponsorship duties?

As a licensed sponsor, you’re required to allocate certain responsibilities to key personnel within your business, some or all of whom will have access to the SMS once your sponsorship licence has been granted by the Home Office.

The authorising officer must be a senior and competent person within your business, as they will be responsible for the activities of all SMS users, and ensuring that you meet your responsibilities as a licensed sponsor. The key contact will be your main point of contact with the Home Office, whilst the Level 1 user is the person responsible for the day-to-day management of your sponsorship licence via the SMS. These roles can be filled by either the same person or different people. You can also appoint optional Level 2 users, with more restricted permissions than a Level 1 user, once your licence has been granted.

That said, as a licensed sponsor, you retain overall responsibility for ensuring compliance with the rules. As such, if either the authorising officer, or any system user, fails in their duties, you’ll still be strictly accountable to the Home Office. This means that you should always exercise caution, and carry out thorough background checks, to ensure that the individuals appointed to act as your key personnel are honest, dependable and reliable.

3. A culture of HR compliance

Action plans are most often triggered where compliance is reactive rather than embedded. Sponsors who rely on one or two individuals without proper oversight or delegation run higher risks. To avoid reaching the downgrade stage, treat compliance as a standing function of HR, not an occasional task. Build in quarterly file audits, regular SMS training refreshers, and board-level reporting to ensure senior accountability. Encouraging managers across the business to understand reporting triggers, such as changes in job role or pay, reduces the likelihood of breaches slipping through unnoticed. UKVI wants to see systems that operate consistently, not just during inspection windows.

Section F: Summary

UKVI sponsor action plans are designed to give licence holders an opportunity to put their compliance house in order, but they are not a soft option. A downgrade to a B-rating restricts overseas recruitment, forces immediate payment of the £1,579 plan fee, and imposes a tight three-month timetable to deliver evidence of improvement. For organisations dependent on migrant workers, these constraints can disrupt hiring pipelines, unsettle existing staff, and damage commercial credibility with clients and partners. Treating the plan as a simple formality is a mistake that can quickly escalate to suspension or revocation, particularly if payment is late or the Home Office decides remedial steps lack substance.

The real value of an action plan lies in what it teaches sponsors about risk. Most breaches arise not from deliberate non-compliance but from weak HR processes, poor training of SMS users, or inadequate oversight of reporting and record-keeping. Sponsors that respond effectively use the process to build lasting compliance frameworks: scheduled file audits, clear escalation routes, properly trained personnel, and board-level ownership of sponsor duties. These measures not only satisfy UKVI but also reduce the likelihood of repeat downgrades, which are capped at two within four years before automatic revocation follows.

In practice, prevention is always less costly than correction. Simple operational measures can significantly reduce risk. These include maintaining a central compliance calendar with reporting deadlines, keeping template checklists for Appendix D files, and ensuring at least two trained SMS users are active at all times to cover absences. Many sponsors also conduct mock audits using external advisers to identify weaknesses before UKVI does. Prevention costs less than rectification — both financially and reputationally — making investment in proactive compliance the most effective way to avoid action plans altogether.

Where problems do arise, prompt, organised, and well-evidenced responses give the best chance of restoring the A-rating and safeguarding long-term access to global talent.

Section G: Need Assistance?

Employers who embed compliance into everyday HR and management processes are far less likely to face downgrades and action plans. DavidsonMorris’ business immigration specialists are highly experienced in supporting sponsor licence holders facing Home Office enforcement action. We have a dedicated team of sponsor licence lawyers who work with employers to resolve compliance issues, deal with the Home Office and advise on how to prevent future compliance breaches through auditing and training. Contact us to minimise the impact and disruption to your organisation of Home Office scrutiny.

Section H: Sponsor action plan FAQs

How much is a Home Office Sponsor Action Plan? 

The Home Office will charge the sponsor £1,579 for an action plan to resolve compliance issues.

How long does it take to get a sponsor licence in the UK?

Most sponsor licence applications are dealt with in less than 8 weeks, although UKVI may want to first visit your business to ensure that you’re capable of meeting your responsibilities as a sponsor.

How much does it cost to sponsor a skilled worker?

There are various costs associated with sponsoring a skilled worker, from the fee to apply for a sponsor licence and issue Certificates of Sponsorship (CoS), to the Immigration Skills Charge when assigning an CoS.

How long does it take for a CoS to be issued?

A Certificate of Sponsorship (CoS) is an electronic record to confirm that the conditions under the relevant visa route have been met. A CoS can be issued using the online sponsorship management system, with approval taking around one working day.

What is sponsor evidence for UK visa?

Sponsor evidence for a UK visa comes in the form of a unique reference number found on a Certificate of Sponsorship issued by a Home Office approved employer, and can be used to submit a valid visa application.

Section I: Glossary

Section J: Additional Resources and Links