Section A: Is there a Revoked Sponsor Licence List?
The UK’s sponsor licence system is central to controlling which employers can lawfully hire overseas workers under the Worker and Temporary Worker visa routes. The Home Office maintains a single public Register of Licensed Sponsors on GOV.UK, listing organisations authorised to assign Certificates of Sponsorship. Removal from this register is the only public signal that a sponsor’s licence has been revoked or suspended.
Status | Can assign new CoS? | Current sponsored workers affected? | Possibility of reinstatement | Typical resolution timeframe |
---|---|---|---|---|
Suspension | No – CoS assignment blocked while UKVI investigates | Usually remain in role; new visa applications may be paused | Yes – can be reinstated, downgraded to B-rating with action plan, or revoked | Weeks to several months depending on the complexity of the case |
Revocation | No – all sponsorship rights end immediately | Visas curtailed; 60 days or until leave expiry (if sooner) to switch or leave the UK | No – reapplication only possible after cooling-off (usually 12+ months) and evidencing reforms | Immediate removal; reapplication preparation and cooling-off extend timeline well beyond a year |
For employers, absence from the register ends the ability to sponsor staff and can disrupt operations immediately. For visa applicants, it can invalidate job offers and lead to curtailment of existing visas. This guide explains how the register works, how revocation is reflected, the consequences of removal, and the steps sponsors and workers can take to manage the impact. It also covers prevention strategies, reapplication rules, and the heightened risks faced in sectors under close Home Office scrutiny.
In the context of the UK’s Worker and Temporary Worker sponsorship system, there is no separate public “revoked sponsor licence list” maintained for these routes. The only authoritative public record is the Register of Licensed Sponsors (Workers) on GOV.UK. This register contains the names of organisations currently authorised to sponsor overseas workers under the relevant visa categories.
When a sponsor’s licence is revoked by UK Visas and Immigration (UKVI), the organisation’s details are removed from the register. This removal is the public signal that the organisation no longer has the authority to assign Certificates of Sponsorship (CoS) under any worker route. While UKVI maintains internal records of revocations, those details — including the reasons for removal — are not published.
This system means that revocation, suspension and downgrading are reflected differently: revoked sponsors disappear from the register entirely, suspended sponsors may also be absent during the suspension period, and downgraded sponsors remain on the register with their B-rating shown. The absence of an organisation’s name can therefore indicate either revocation or suspension, so further verification with the Home Office or official guidance may be necessary in time-sensitive situations.
1. Source and authority
The live register is published and maintained solely by UKVI on the official GOV.UK platform. It is the only legally reliable source of sponsor licence status for immigration compliance purposes. Updates are made frequently — often daily — and each version carries a “last updated” date. Any absence of a sponsor from the register is definitive confirmation that they are not currently licensed, whether due to revocation, suspension or surrendering the licence.
Third-party sites, industry publications and recruitment platforms sometimes reproduce versions of the register, but these are snapshots that may be incomplete or out of date. Employers, HR teams, recruiters and applicants must check the GOV.UK register directly at the point they need the information, rather than relying on stored or printed copies.
2. Frequency of updates
The register has no fixed update cycle. Changes can be implemented by UKVI as soon as a status change is processed, meaning an organisation could be listed one day and absent the next. Because of this, due diligence checks based on the register should be carried out as close as possible to any action that depends on sponsorship status, such as assigning a CoS, submitting a visa application, or confirming an employment offer.
Outdated register copies are a common cause of compliance breaches. Employers who fail to recheck before employing or continuing to employ a sponsored worker risk being deemed to have facilitated illegal working, with penalties that can include fines of up to £45,000 per illegal worker for a first breach, and up to £60,000 per illegal worker for repeat offences and, in the most serious cases, criminal prosecution.
3. Understanding statuses on the register
A-rating: Full compliance rating allowing the sponsor to assign CoS within the terms of their licence.
B-rating: The sponsor is still licensed but must follow an action plan to correct failings. This rating is displayed on the register.
Suspension: The sponsor may be absent from the register while UKVI investigates. They cannot assign new CoS during this period, although current sponsored workers can usually continue in role pending the outcome.
Revocation: The sponsor is permanently removed from the register and loses all sponsorship rights. Any unused CoS are cancelled, and sponsored workers’ visas are curtailed.
Distinguishing between absence due to suspension or revocation is important in live recruitment scenarios, as only revocation results in the permanent end of sponsorship rights.
4. Visibility changes
Once a licence is revoked, the organisation’s name, location and any previously displayed routes disappear entirely from the live register. There is no public archive showing past entries or the date of removal. The absence itself is the only public confirmation. This lack of detail means that stakeholders cannot see the reasons for the change; they must instead infer from absence and, where appropriate, seek clarification directly from the sponsor or legal advisers.
For suspended licences, absence from the register may be temporary, with reinstatement possible if the investigation concludes favourably. However, prolonged absence increases the likelihood of revocation.
5. Who uses the register for revocation checks
Employers and HR teams: to confirm their own organisation or group companies are still licensed and to detect sudden absences that require immediate compliance action.
- Recruiters: to ensure prospective employer clients are eligible to sponsor before advancing candidates.
- Applicants: to check that a potential or current employer remains licensed before committing financially or resigning from another role.
- Advisers and compliance consultants: to verify a client’s status during audits, prepare for renewal applications, or respond to enforcement activity.
Sector regulators and industry bodies: to identify licence losses in sectors subject to close scrutiny, such as adult social care or seasonal work, and assess any impact on service provision.
Because the register is the single point of public truth, absence from it should trigger urgent review. In high-risk sectors, monitoring the register daily or weekly is a prudent measure to avoid operational and immigration compliance shocks.
DavidsonMorris Strategic Insight
Removal from the Register of Licensed Sponsors signals that an organisation is no longer permitted to sponsor visa workers. The implications are significant for the employer and their sponsored workers.
The employer will no longer be able to continue sponsoring workers, meaning loss of personnel. Visa workers will be given notice of visa curtailment, and will be given only a limited window in which to find a new sponsor and role, apply for a different visa or leave the UK.
Section B: Why Sponsor Licences Get Revoked
Revocation is the most severe enforcement action available to the Home Office under the UK’s sponsorship framework. It permanently removes a sponsor’s authority to issue Certificates of Sponsorship (CoS) and ends its ability to employ overseas workers under the sponsored routes. A revocation decision follows a formal process in which UK Visas and Immigration (UKVI) determines that the sponsor no longer meets the eligibility or suitability criteria set out in the Workers and Temporary Workers: Guidance for Sponsors.
Every revocation case is fact-specific. However, in almost all instances, it reflects either systemic compliance failings, deliberate non-compliance, or conduct that fundamentally undermines the Home Office’s trust in the sponsor. Understanding these underlying causes is critical not only to preventing licence loss but also to interpreting why an organisation appears on the revoked list and how UKVI enforces sponsorship rules in practice.
Day | UKVI actions | Sponsor actions | Worker actions |
---|---|---|---|
Day 0 – Revocation decision | Removes sponsor from the Register; issues revocation notice to sponsor; invalidates unused CoS | Cease all sponsorship activity immediately; notify sponsored workers and recruitment partners | No action until formal curtailment notice received |
Within days | Issues curtailment notices to all affected workers | Begin internal compliance review; seek legal advice on remedial steps and potential judicial review | Review curtailment letter; note deadline to switch visa or leave UK |
Within 60 calendar days (or sooner if visa expiry date is earlier) | Monitors worker compliance with curtailment deadlines | Implement corrective measures in HR and right to work systems; prepare for potential reapplication after cooling-off | Secure new sponsor and submit visa application, switch to alternative visa route, or arrange departure |
After cooling-off period | Assesses new sponsor licence application if submitted | Submit reapplication with evidence of compliance reforms | N/A |
1. Serious non-compliance
The most common trigger for revocation is a sustained or significant breach of the sponsor duties that form the cornerstone of the sponsorship regime. These duties include:
- Accurately reporting changes in a sponsored worker’s circumstances, such as job title, work location, salary, or contract terms, within the deadlines set out in the guidance (usually 10 or 20 working days).
- Maintaining up-to-date and accurate records for each sponsored worker in line with Appendix D record-keeping requirements.
- Ensuring that sponsored workers are carrying out only the duties specified in their CoS and that their role still meets the relevant visa route requirements.
A single administrative oversight will not normally result in revocation. However, repeated failures, or one-off breaches with serious immigration consequences—such as enabling a worker to remain in the UK without lawful permission—can lead directly to licence loss. Where UKVI finds evidence of a pattern of neglect, or where compliance systems are absent or ineffective, revocation is a likely outcome.
2. Immigration law breaches
Sponsors have a statutory obligation to prevent illegal working, set out in the Immigration, Asylum and Nationality Act 2006. This requires carrying out right to work checks in the prescribed manner before employment begins and retaining evidence of those checks.
Revocation can result from:
- Failing to carry out checks at all.
- Conducting checks incorrectly, such as not using the online right to work service for biometric or eVisa holders.
- Knowingly employing someone without the correct immigration status.
These breaches can lead to civil penalty fines and can be accompanied by immediate licence revocation. If the breach involves deliberate facilitation of illegal working, criminal prosecution may also follow, alongside financial sanctions and reputational damage.
3. Misuse of Certificates of Sponsorship
A CoS is not merely an administrative formality; it is a legal confirmation from the sponsor that the vacancy is genuine, meets all skill and salary thresholds, and that the named individual will work in that role. UKVI takes misuse of CoS extremely seriously, and revocation may occur without prior warning where the sponsor:
- Assigns CoS for fictitious or non-existent roles.
- Issues CoS for roles that fall below the required skill level or salary threshold.
- Assigns CoS to individuals who will not actually be working for the sponsor, including cases where the individual is subcontracted in breach of the route conditions.
Such conduct is treated as undermining the integrity of the sponsorship system. In these circumstances, UKVI will not usually offer the opportunity to remedy the breach through an action plan or suspension; immediate revocation is the norm.
4. Criminal activity or dishonesty
Where the sponsor organisation, its controlling parties, or its named key personnel have been involved in criminal conduct, particularly offences relating to immigration, fraud, money laundering, or other dishonesty, UKVI can revoke the licence as part of safeguarding the immigration system.
Dishonesty is not limited to criminal convictions. Providing false or misleading information at any stage of the sponsorship lifecycle—whether in the initial application, in responses to UKVI correspondence, during a compliance visit, or via the Sponsorship Management System—can constitute deception. If UKVI concludes that a sponsor has acted dishonestly, revocation is almost certain.
5. Failure to co-operate with Home Office checks
UKVI has statutory powers to carry out both announced and unannounced compliance visits to assess whether a sponsor is meeting its duties. During such visits, compliance officers may request access to premises, personnel, and records.
Revocation can result from:
- Refusing entry to compliance officers.
- Failing to provide requested documentation within the time limits set.
- Obstructing the inspection or providing incomplete or evasive answers to compliance questions.
The ability to demonstrate ongoing suitability as a sponsor depends on UKVI being able to verify compliance. Where a sponsor is uncooperative to the extent that UKVI cannot make this verification, the licence will typically be revoked on the basis that the organisation cannot demonstrate that it meets the suitability requirements.
DavidsonMorris Strategic Insight
The Home Office has powers to revoke sponsor licences for the most serious of compliance breaches or for repeated non-compliance.
Sponsor licence revocation will generally not come as a surprise to the employer. It is the most serious of sanctions that the Home Office can impose, and as such should only usually come after all other appropriate penalties and opportunities to rectify have been exhausted.
Compliance is a non-negotiable for sponsor licence holders. They are under ongoing compliance obligations, and the Home Office is placing increasing resources and focus on sponsor monitoring and enforcement action. Audits and inspections are more common than ever, and sponsors have to ensure they are match-fit at any time, and able to prove their HR systems, processes and documents meet the required standards.
Section C: How to Check and Interpret the List
The list of licensed sponsors is an open-access resource published on GOV.UK. While downloading the latest file is straightforward, using it effectively requires a methodical approach. Employers, recruiters, compliance professionals,and visa applicants need to be confident that they are viewing the official, most up-to-date version, interpreting the data correctly, and cross-referencing with other authoritative records. Failure to follow these steps risks acting on outdated or incomplete information, which can result in unlawful recruitment decisions, invalid visa applications, and avoidable compliance breaches.
1. Locating the latest list
The official sponsor licence list is hosted in the UKVI section of GOV.UK, typically within the Sponsorship transparency data or Workers and Temporary Workers: Guidance for Sponsors collection. There are two reliable ways to locate it:
- Navigate to the main UKVI sponsorship guidance pages on GOV.UK and follow the link to the revoked sponsor licences section.
- Use a targeted search in a search engine, for example: revoked sponsor licence list site:gov.uk.
Once on the page, always check the “last updated” date displayed at the top. This confirms when UKVI last amended the list. If you are using a downloaded spreadsheet or PDF, confirm that its publication date matches the latest update on the live webpage. The list is generally made available in a downloadable format such as CSV or ODS, enabling direct filtering and searching by name or location.
2. Cross-checking with the live register
A revoked sponsor will no longer appear on the live Register of Licensed Sponsors (Workers). However, the reverse is not always true; an organisation may simply not appear on the live register because it has never been licensed, not because it has been revoked.
To avoid assumptions:
- Search for the sponsor in the live register to confirm whether it is currently licensed.
- Search the revoked list to check whether its licence has been removed.
If the name is absent from the live register but present on the revoked list, it confirms that the organisation has lost its licence. Cross-referencing both lists is particularly important for recruiters and HR teams making real-time hiring decisions, as relying on only one list could lead to incorrect conclusions.
3. Understanding the data fields
The revoked list typically contains several key pieces of information:
- Legal name – This is the name under which the licence was registered with the Home Office. It may differ from the trading name used in marketing or recruitment.
- Town or city – The primary registered location of the sponsor at the time of revocation.
- Type of licence – For example, Skilled Worker, Temporary Worker, or a combination of categories.
- Revocation date – Where provided, this marks the date on which the licence formally ceased.
While the live register displays ratings (A-rating or B-rating), these are irrelevant after revocation. Once a licence is revoked, the sponsor no longer holds any rating, and all sponsorship rights are withdrawn. Understanding these fields is crucial to ensure you are identifying the correct legal entity, especially in sectors where franchises, group companies, or similar brand names are common.
4. Common pitfalls
Several recurring errors can undermine the accuracy of checks:
- Using outdated versions – A downloaded file may quickly become obsolete if the list is updated several times in the same month.
- Confusing trading names with legal names – If you search only by a trading name, you may miss a match that appears under the registered name.
- Ignoring spelling variations – Minor differences in punctuation, spacing, or company suffixes (Ltd, Limited, PLC) can prevent a match when searching manually.
- Relying on unofficial sources – Some immigration blogs, commercial recruitment platforms, or news sites host copies of the list that are not maintained in real time. These should never be relied upon for compliance-critical decisions.
The safest approach is to use the official Home Office page each time a check is needed and to apply multiple search terms if the organisation might operate under different names.
5. Automation options
For organisations with ongoing sponsorship or recruitment needs, checking the list manually on an ad hoc basis can be inefficient and risky. Building the check into a formal compliance workflow reduces the likelihood of oversights. Options include:
- Scheduled manual checks – Assign responsibility within HR or compliance teams to review both the live register and the revoked list at a set interval, such as weekly or bi-weekly.
- Automated monitoring tools – Third-party compliance platforms can integrate with official datasets and trigger alerts when a sponsor’s status changes.
- Applicant tracking system integration – Larger employers and recruitment agencies can embed real-time status verification into their candidate screening process, preventing offers being made to individuals who cannot be lawfully sponsored.
Automation is particularly valuable where organisations manage multiple sponsorship licences, operate across several jurisdictions, or recruit at high volume. It ensures that any change in a sponsor’s status—either loss of a licence or reinstatement—is detected quickly enough to adjust hiring and immigration processes in real time.
DavidsonMorris Strategic Insight
The Register of Licensed Sponsors only includes organisations that currently hold a sponsor licence. Any organisation that has seen their licence revoked will be removed from the list, usually with immediate effect as the List is updated frequently.
Section D: If an Organisation is not on the List of Sponsors
The implications of licence revocation can be operational, financial, and immigration-related, and they affect not only the sponsor itself but also its sponsored workers, recruitment partners, and any businesses reliant on its services. The correct response must be prompt, structured and fully compliant with Home Office rules to limit further harm and preserve any available legal or procedural options.
Stakeholder | Immediate impact | Short-term actions required | Longer-term considerations |
---|---|---|---|
Employer / Sponsor | All sponsorship rights end; unused CoS invalidated | Cease sponsorship activity; notify affected workers; seek legal advice | Prepare for reapplication after cooling-off; rebuild compliance systems |
Sponsored Worker | Visa curtailed; deadline to switch route or leave UK | Secure new sponsor or alternative visa; seek immigration advice | Consider roles with stable, long-standing licensed sponsors |
Recruitment Agency | Placement opportunities with that sponsor halted | Withdraw offers reliant on that sponsor; redirect candidates | Maintain real-time register checks to prevent future disruption |
Business Partners / Clients | Possible project delays or cancellations if sponsored staff affected | Review contractual obligations; adjust project resourcing | Assess risk of working with sponsors in high-enforcement sectors |
Sector Regulator / Industry Body | Potential service delivery impact in regulated sectors | Engage with affected organisations to assess workforce gaps | Monitor sector-wide compliance trends to inform policy and support |
1. Employers
If your organisation’s licence has been revoked, all sponsorship activity must cease immediately. This includes:
- Withdrawing any unused Certificates of Sponsorship (CoS) in the Sponsorship Management System (SMS).
- Informing all sponsored workers without delay that the licence has been revoked and explaining the potential implications for their immigration status.
- Halting any recruitment campaigns or job offers that are conditional on sponsorship.
The revocation notice from UKVI will set out the reasons for the decision and confirm whether any limited opportunity exists to respond. Although there is no statutory right of appeal against licence revocation, you may be able to seek judicial review where there are legal grounds, such as procedural unfairness or an error of law. Judicial review is a specialist remedy and must be initiated promptly, usually within three months of the decision, so early legal advice is critical.
In parallel, employers should begin addressing the compliance failings identified by UKVI. This remedial work will be essential if you intend to reapply for a licence after the cooling-off period. Key steps include:
- Conducting an independent compliance audit.
- Updating HR and record-keeping systems in line with Appendix D requirements.
- Retraining key personnel on sponsor duties and SMS usage.
- Implementing internal controls to ensure accurate and timely reporting of relevant changes to UKVI.
2. Sponsored workers
If your current sponsor is no longer on the official Register, UKVI will send you a formal curtailment notice. This normally gives you 60 calendar days, or until the expiry of your current leave (if sooner), to take one of the following actions:
- Secure a job offer from another licensed sponsor and submit a fresh visa application supported by a valid CoS.
- Switch to a different immigration route for which you meet the eligibility requirements.
- Make arrangements to leave the UK before the curtailment period ends.
Where deception or other aggravating factors are involved, UKVI may shorten the curtailment period. It is vital to act quickly—waiting until late in the period can leave too little time for a new visa application to be prepared and decided. If you overstay after the deadline, you will lose lawful immigration status and face restrictions on future UK immigration applications.
3. Recruiters and HR teams
For recruiters and in-house HR professionals, revocation requires swift action to protect compliance and candidate relationships:
- Withdraw any job offers that depend on sponsorship from a revoked licence holder.
- Inform affected candidates promptly and provide clear explanations to avoid reputational damage.
- Assist candidates, where possible, in identifying alternative employers on the live Register of Licensed Sponsors.
For ongoing recruitment campaigns, it is advisable to re-verify the sponsorship status of all potential employer clients before progressing candidates to the offer stage. This reduces the risk of further disruption and maintains confidence in recruitment processes.
4. Linked entities
If the revoked sponsor is part of a group structure, franchise network, or other linked entity arrangement, it is essential to assess whether the revocation has implications for associated companies. UKVI has the power to extend restrictions to other licences held by linked entities if:
- The same key personnel are named across multiple licences.
- There is evidence of shared operational control or ownership.
- The compliance failings are systemic across the group.
A thorough review should be carried out to determine whether other licences within the group are at risk. Where concerns exist, proactive compliance checks and remedial measures should be implemented to prevent further enforcement action.
DavidsonMorris Strategic Insight
If your organisation’s licence has been revoked, you have to halt all visa sponsorship activity. On a practical level, you should act quickly to notify affected workers. They will receive official notification from the Home Office of what the revocation means for their visa, but inform them directly to give them as much time as possible to deal with their situation and protect their status. Recruiters may also need to be informed , if they are active with recruitment, to avoid wasting time on vacancies that will no longer be available.
For group companies with linked sponsor licences should audit their permissions to clarify how the revocation impacts the organisation as a whole.
Section E: Preventing Licence Revocation
Avoiding the operational disruption, loss of recruitment capability, and reputational harm caused by sponsor licence revocation requires a proactive, embedded compliance framework. Prevention goes beyond satisfying the minimum legal obligations; it demands an organisation-wide culture of accountability, supported by systems, policies, and oversight that ensure sponsor duties are met at all times. This includes periods of rapid organisational growth, restructuring, or changes in personnel.
A prevention strategy should be integrated into the organisation’s governance model, reinforced by leadership, and subject to regular review to adapt to changes in the Immigration Rules, Home Office guidance, and sector-specific compliance risks.
1. Internal compliance culture
Effective compliance is built on a company-wide understanding that immigration responsibilities are shared, not confined to the key personnel named on the sponsor licence.
- Leadership commitment – Senior management must actively promote and resource compliance measures, ensuring immigration obligations are factored into business planning and operational decision-making.
- Organisation-wide awareness – Employees involved in recruitment, HR administration, payroll, and line management should understand the basics of sponsor duties and the consequences of breaches.
- Continuous reinforcement – Compliance messages should be delivered regularly through staff briefings, updates, and internal communications, emphasising that immigration compliance is a standing priority, not a one-off exercise.
An organisation with visible, top-level commitment to compliance is more likely to maintain high standards and avoid accidental breaches.
2. Regular internal audits
Planned, systematic audits are a key defence against revocation. These should be scheduled at regular intervals—quarterly for high-volume sponsors or at least annually for smaller licence holders—and conducted either internally or by external immigration compliance specialists. Audits should cover:
- Right to work checks – Ensuring they are carried out in the prescribed manner for all staff and that documentary evidence is retained.
- Appendix D record-keeping – Verifying that all mandatory documents for each sponsored worker are complete, current, and stored in accordance with retention requirements.
- Reporting obligations – Checking that changes in worker circumstances and corporate details have been reported through the Sponsorship Management System (SMS) within the required deadlines.
- CoS usage and allocation – Confirming that all Certificates of Sponsorship are issued only for genuine vacancies that meet the route’s salary, skill, and eligibility criteria.
Documenting audit findings and the steps taken to address any gaps creates a record of proactive compliance, which can be valuable in demonstrating good faith to the Home Office during an inspection or in the event of adverse findings.
3. Training for key personnel
Key personnel such as the Authorising Officer, Key Contact and Level 1 Users—are legally responsible for the organisation’s compliance with sponsor duties. To perform effectively, they must:
- Receive comprehensive induction training on the sponsor guidance, SMS operation, and consequences of non-compliance before assuming their role.
- Be kept up to date on changes to immigration law, sponsorship rules, and Home Office policy.
- Undergo periodic refresher training to ensure continued competence.
Training should not stop with key personnel. Managers, HR staff, and recruitment teams who interact with sponsored workers or the sponsorship process should also be trained to identify compliance risks early and escalate them appropriately. This wider knowledge base helps prevent gaps where operational decisions may unintentionally breach immigration requirements.
4. Proactive reporting
Sponsors must report specified changes to UKVI within strict timeframes—commonly 10 working days for worker-related changes and 20 working days for certain organisational changes. Reportable events include, but are not limited to:
- Changes to a sponsored worker’s job title, duties, location, salary, or contracted hours.
- Termination of a sponsored worker’s employment before the CoS end date.
- Corporate changes such as mergers, acquisitions, demergers, or changes to ownership or key personnel.
To meet these obligations consistently:
- Establish clear escalation procedures for notifying the compliance team or SMS Level 1 Users of reportable events.
- Maintain a central register of reportable changes with dates of occurrence and reporting deadlines.
- Use compliance calendars, task management systems, or automated alerts to track deadlines and prevent missed reports.
Proactive, timely reporting not only fulfils a legal requirement but also builds a compliance record that can weigh positively in UKVI’s assessment of the organisation during renewal applications or post-revocation reapplications.
DavidsonMorris Strategic Insight
For sponsors, there is no escaping that comlying with your licence obligations does take commitment and investment. The Home Office is investigating compliance more than ever. Strategically, the goal is to develop a culture of prevention, embedding immigration compliance within everyday operations. Roles and responsibilities have to be clearly assigned, training provided and systems checked and audited. The effort is worth avoiding the operational, financial and repetutational fall-out of losing your licence.
Section F: Cooling-off Periods and Reapplying
Once a sponsor licence has been revoked, the organisation cannot immediately submit a fresh application. In most revocation cases, the Home Office will impose a cooling-off period to ensure that sponsors cannot bypass enforcement action by quickly re-entering the system without addressing the issues that led to revocation. The length of this period is determined by the nature and severity of the breaches, the sponsor’s compliance history, and whether there are any links between the revoked entity and other licence holders.
The cooling-off period applies across all worker routes and is enforced even if the business changes its trading name, relocates, or restructures—UKVI will look beyond superficial changes to assess whether there is continuity of control, ownership or management.
Requirement | Why UKVI checks it | Evidence to prepare | Common mistakes to avoid |
---|---|---|---|
Addressing all breaches in revocation notice | Confirms that past compliance failures have been fully rectified | Updated HR policies, training logs, corrected records, proof of remedial action | Submitting generic policies without proof of implementation |
Robust HR and compliance systems | Ensures ongoing ability to meet sponsor duties | Process maps, system screenshots, compliance monitoring reports | Relying on manual processes without checks or escalation routes |
Trained key personnel | Verifies those managing the licence understand duties and Home Office systems | Training certificates, attendance records, updated SMS user list | Keeping previous non-compliant personnel in key roles |
Clean compliance record since revocation | Demonstrates lawful working and adherence to immigration rules | Right to work audit reports, penalty-free record, staff lists with visa statuses | Failing to carry out periodic right to work checks post-revocation |
Evidence of genuine vacancies | Proves intent to sponsor for legitimate roles meeting visa criteria | Job descriptions, recruitment adverts, market rate salary data | Submitting speculative applications without identified vacancies |
1. Standard cooling-off
In most cases, the standard cooling-off period is 12 months from the date of the revocation decision.
During this period, the organisation is prohibited from applying for a new licence under any worker category, including Skilled Worker, Senior or Specialist Worker, Minister of Religion, International Sportsperson, and all Temporary Worker routes. The restriction applies to:
- The revoked entity itself.
- Any newly incorporated entity with substantially the same ownership, key personnel, or management.
- Entities operating under a different trading name but maintaining operational continuity with the revoked sponsor.
UKVI applies this test to prevent “phoenix” sponsorship applications—where a business attempts to circumvent a ban by setting up a new entity that is, in reality, the same as the one that was penalised.
2. Extended cooling-off
Where aggravating factors are present, UKVI can extend the cooling-off period to 24 months or more. These factors may include:
- Repeated breaches – Multiple findings of non-compliance across different inspection visits or enforcement actions.
- Deliberate deception – Providing false or misleading information in an application, compliance visit, or official correspondence.
- Multiple linked revocations – The same key personnel or controlling parties being involved in more than one revoked licence, whether within a single group or across unrelated entities.
Extended cooling-off periods are intended to protect the integrity of the sponsorship system by preventing individuals or businesses with a track record of poor compliance from returning until they can demonstrate a substantial change in operations, controls, and culture.
3. Preparation for reapplication
Sponsors intending to reapply after the cooling-off period should treat the preparation stage as an opportunity to rebuild credibility and demonstrate genuine reform. UKVI will scrutinise the new application closely to ensure that:
- The breaches leading to revocation have been fully addressed.
- The organisation has the systems and culture in place to meet all sponsorship duties consistently.
- There are no residual links to individuals or practices that caused the previous failures.
Best practice for preparation includes:
- Full post-revocation review – Conduct a detailed analysis of the revocation notice and internal records to identify every compliance failing and how it has been remedied.
- Enhanced HR and compliance systems – Implement policies, controls, and monitoring mechanisms that go beyond the minimum legal requirements, supported by clear documentation.
- Comprehensive training – Ensure all relevant personnel, from key SMS users to departmental managers, have been trained on sponsor duties, Home Office reporting deadlines, and right to work requirements.
- Evidence gathering – Compile records showing the organisation’s compliance with immigration and employment law since revocation, such as completed right to work checks, audit reports, and internal compliance logs.
When assessing a reapplication, UKVI will expect tangible evidence of improvement—not just policy documents, but proof that those policies have been implemented and are operating effectively in practice. Any lingering concerns or incomplete remedial work will almost certainly result in refusal, potentially triggering a new cooling-off period.
DavidsonMorris Strategic Insight
During a cooling off period, the organisation is effectively locked out of the sponsorship system and talent market. Delays in your recruitment programme can be commercially devastating, and even after this period, prepare for the organisation to face even greater scrutiny. You will be highlighted as a high-risk employer, meaning any immigration application will be forensically examined before any positive outcome is considered.
Section G: Sector-Specific Issues
While the core sponsor licence rules apply equally across all industries, the compliance risks that can lead to revocation often vary significantly by sector. Different industries present operational realities that affect how easily breaches can occur, and the Home Office takes these into account when assessing risk, prioritising audits, and deciding enforcement action. Understanding these sector-specific challenges enables sponsors to tailor their compliance controls to address the highest areas of vulnerability.
1. Adult social care
Adult social care has become one of the largest users of the Skilled Worker visa route, particularly for care workers and senior care workers. This high usage, combined with past non-compliance trends, has placed the sector under heightened Home Office scrutiny. Common areas of concern include:
- Underpayment of salaries – Failure to meet the Skilled Worker minimum salary threshold or the rates stated on the CoS.
- Non-genuine job offers – Assigning CoS for roles that do not meet the job description or skill level required under the route.
- Exploitation risks – Allegations of excessive hours, substandard working conditions, or unlawful deductions from wages.
In some cases, UKVI has engaged with providers proactively, offering sector-specific guidance and advisory visits. However, where breaches are serious, repeated, or linked to worker exploitation, revocation remains a likely outcome.
Best practice for adult social care sponsors:
- Maintain payroll records and payslips that clearly demonstrate compliance with Skilled Worker salary thresholds.
- Keep comprehensive records of duties performed to ensure they match the CoS description.
- Implement safeguarding and whistleblowing procedures to identify and address worker welfare concerns early.
2. Hospitality and seasonal work
The hospitality industry and seasonal work schemes face compliance challenges stemming from high staff turnover, varied shift patterns, and reliance on part-time or flexible scheduling. For sponsors, these conditions increase the risk of mismatches between the CoS details and the actual terms of employment.
Common problem areas include:
- Workers carrying out duties outside the scope of their sponsored role.
- Variations in contracted hours and pay that are not reported to UKVI within the required deadlines.
- Inadequate monitoring of seasonal and temporary workers, leading to gaps in right to work documentation.
Seasonal work schemes, particularly in agriculture and horticulture, also attract attention over recruitment practices, worker accommodation standards, and prevention of illegal working.
Best practice for hospitality and seasonal work sponsors include:
- Implement scheduling systems that can generate real-time data on hours worked and pay rates.
- Regularly reconcile payroll with CoS details to ensure compliance with salary and hour thresholds.
- Audit recruitment agency arrangements to confirm compliance with sponsorship and employment law requirements.
3. Education sector
Educational institutions that sponsor workers—especially teachers in shortage subjects—face distinct compliance duties. Although many education providers are already familiar with student sponsorship, worker sponsorship rules differ and must be applied in parallel to any existing compliance processes.
Key risks include:
- Inadequate record-keeping for worker attendance and qualifications.
- Failure to notify UKVI of changes to employment terms, such as a change in job title or teaching subject.
- Employment of individuals outside the role or subject approved on the CoS, particularly in multi-subject teaching posts.
Safeguarding responsibilities also intersect with sponsorship obligations, as UKVI expects sponsors to demonstrate that they are meeting all statutory safeguarding requirements alongside immigration compliance.
Best practice for education sponsors include:
- Maintain up-to-date personnel files containing qualifications, Disclosure and Barring Service (DBS) checks, and evidence of right to work checks.
- Implement monitoring systems to track teaching duties against CoS role descriptions.
- Ensure HR and senior leadership are trained on both student and worker sponsorship requirements to avoid cross-system errors.
Section H: Summary
The revoked sponsor licence list is a key transparency measure in the UK’s immigration system. It enables employers, recruiters, and visa applicants to verify whether an organisation has lost its right to sponsor overseas workers. Revocation has immediate and far-reaching consequences, from invalidating pending Certificates of Sponsorship to curtailing existing workers’ visas and causing reputational damage that can disrupt operations.
For sponsors, avoiding revocation depends on embedding strong compliance practices across the organisation. This includes accurate record-keeping, timely reporting of changes, and ensuring that sponsored workers meet all conditions of their visas. For workers and recruiters, regular checks of both the revoked list and the live register help prevent reliance on outdated or inaccurate information.
Although a revoked licence can be reapplied for after the cooling-off period, re-entry into the sponsorship system demands evidence of lasting compliance improvements. Treating sponsorship as an ongoing legal responsibility rather than a one-off approval is the most effective way to stay off the revoked list and maintain the trust of the Home Office.
Section I: FAQs
Where is the official revoked sponsor licence list published?
The official list is published on the GOV.UK website in the UKVI sponsorship section. It is the only authoritative source and should be checked directly on the Home Office pages rather than through third-party sites.
How often is the list updated?
There is no fixed schedule, but updates can occur multiple times per month. Always check the “last updated” date on the GOV.UK page to ensure you are using the latest version.
What is the difference between a revoked licence and a suspended licence?
Revocation is permanent removal of a sponsor’s licence, ending all sponsorship rights. Suspension is temporary, usually pending an investigation, and can lead to reinstatement, downgrading, or revocation.
Can a revoked sponsor still employ current sponsored workers?
No. Revocation triggers the curtailment of existing sponsored workers’ visas. They will typically have 60 calendar days, or until their visa expires if sooner, to find a new sponsor or leave the UK.
Do pending visa applications fail if the sponsor is revoked?
Any unused Certificate of Sponsorship becomes invalid on the date of revocation, and applications relying on it will be refused.
Is there a right of appeal against revocation?
No statutory right of appeal exists. The only formal challenge route is judicial review, which is limited to questions of law or procedure, not a re-hearing of the facts.
How long before a sponsor can reapply?
The standard cooling-off period is 12 months from the date of revocation. This can extend to 24 months or longer for serious or repeated breaches, especially where the same key personnel are involved.
What should a worker do if their sponsor is revoked?
They should check their visa curtailment notice, begin searching for a new sponsoring employer immediately, consider alternative visa routes, and take legal advice if needed to protect their status.
Are some sectors treated differently?
Sectors such as adult social care are subject to higher levels of scrutiny and, in some cases, targeted support, but they are still at risk of revocation if non-compliance is serious.
Section J: Glossary
Term | Definition |
---|---|
Sponsor Licence | Authorisation granted by the Home Office allowing an organisation to sponsor overseas nationals to work in the UK under specified visa routes. |
Revocation | The permanent removal of a sponsor licence by the Home Office, ending the organisation’s ability to sponsor workers and invalidating unused Certificates of Sponsorship. |
Suspension | A temporary status during which a sponsor cannot assign new Certificates of Sponsorship while the Home Office investigates compliance concerns. |
Downgrading | Reduction of a sponsor’s rating from A to B, often accompanied by an action plan to address compliance issues. |
Certificate of Sponsorship (CoS) | An electronic document issued by a licensed sponsor to a worker, which must be used to apply for a visa under a sponsored route. |
Curtailment | The process by which the Home Office shortens an existing visa’s validity period, often triggered when a sponsor loses their licence. |
Cooling-off Period | The minimum time an organisation must wait after licence revocation before applying for a new sponsor licence, usually 12 or 24 months depending on the case. |
Key Personnel | Individuals named on a sponsor licence who are responsible for managing the licence, including the Authorising Officer, Key Contact, and Level 1 Users. |
Sponsorship Management System (SMS) | The Home Office’s online platform for managing a sponsor licence, including assigning CoS and reporting changes in worker or organisation details. |
Appendix D | Part of the sponsor guidance specifying record-keeping requirements for sponsors, including the types of documents to be retained and their retention periods. |
Section K: Additional Resources and Links
Resource | Description | Link |
---|---|---|
Revoked Sponsor Licence List – GOV.UK | Official Home Office list of organisations that have had their sponsor licences revoked. | https://www.gov.uk/government/publications/register-of-licensed-sponsors-workers/revoked-sponsor-licences |
Register of Licensed Sponsors (Workers) | Current list of all organisations licensed to sponsor overseas workers in the UK. | https://www.gov.uk/government/publications/register-of-licensed-sponsors-workers |
Workers and Temporary Workers: Guidance for Sponsors – Part 1 | Home Office guidance on applying for a sponsor licence, including suitability and eligibility requirements. | https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-1-apply-for-a-licence |
Workers and Temporary Workers: Guidance for Sponsors – Part 3 | Official guidance on sponsor duties, compliance checks, sanctions, and licence revocation. | https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-duties-and-compliance |
Employees: If Your Sponsor Loses Their Licence | Home Office guidance for sponsored workers on what to do if their sponsor’s licence is revoked. | https://www.gov.uk/employee-sponsor-licence-revoked |
Support for International Adult Social Care Workers | Home Office information for care workers affected by licence revocations in the adult social care sector. | https://www.gov.uk/government/publications/support-for-international-adult-social-care-workers |