Sponsor Licence Ratings: At a Glance
A sponsor licence rating affects how an employer can use its licence to recruit and manage sponsored workers. For most licensed sponsors, the two principal ratings are A-rating and B-rating.
An A-rating is the standard rating for sponsors operating their licence in line with Home Office requirements. A B-rating is generally imposed where UK Visas and Immigration (UKVI) identifies compliance failings that it considers capable of being corrected through a formal action plan.
A B-rated sponsor remains licensed, but its ability to use the licence is restricted. In particular, the organisation will generally be unable to sponsor new workers while B-rated and will need to address the compliance deficiencies identified by UKVI within the fixed action-plan period.
A B-rating is different from suspension or revocation. UKVI does not have to downgrade a sponsor before taking more serious enforcement action where the relevant grounds are met.
Sponsor ratings can also change over time. An A-rated sponsor can be downgraded following compliance concerns, while a B-rated sponsor can return to an A-rating if it successfully completes the Home Office action plan and demonstrates that the required improvements have been made.
For employers, maintaining an A-rating depends on ongoing sponsor compliance. Growth, changes in personnel, new work locations, acquisitions, restructures and changes to HR systems can all affect whether the systems supporting the licence remain effective.
Section A: What is a Sponsor Licence Rating?
A sponsor licence rating is the status assigned by UKVI to an organisation holding a Worker or Temporary Worker sponsor licence.
The rating reflects the organisation’s current standing within the sponsorship system and affects how it can use the licence, including whether it can sponsor new workers in the normal way.
Most sponsors will encounter two principal ratings:
- A-rating – the standard sponsor licence rating.
- B-rating – a downgraded rating requiring remedial action through a Home Office action plan.
There is also a Provisional rating in certain circumstances under the UK Expansion Worker route. This is a route-specific status and should not be confused with a B-rating imposed because of sponsor compliance concerns.
An organisation will normally receive an A-rating when its sponsor licence application is approved. Retaining that rating depends on the organisation continuing to meet its sponsor duties and the wider requirements of the sponsorship regime.
UKVI can review a sponsor’s compliance throughout the life of the licence. This may follow a compliance visit, information received by the Home Office, activity on the Sponsor Management System (SMS), changes reported by the sponsor or other compliance activity.
Where UKVI identifies failings, the outcome will depend on their nature and seriousness. A B-rating and action plan may be used where the Home Office considers the issues capable of remediation. More serious or systemic failures can result in suspension or revocation instead.
For employers, the rating has practical consequences beyond the organisation’s formal status with UKVI. A downgrade can affect recruitment pipelines, existing sponsored workers, workforce planning and the organisation’s ability to use sponsorship as part of its wider operating model.
1. A-Rating vs B-Rating Compared
| Issue | A-Rated Sponsor | B-Rated Sponsor |
|---|---|---|
| Standard sponsor rating | Yes | No |
| Sponsor new workers | Yes, subject to the relevant sponsorship requirements | Generally no |
| Continue sponsoring existing workers | Yes | Generally yes while the licence remains in force and the worker continues to hold valid immigration permission |
| Assign a CoS to certain existing sponsored workers | Yes, subject to the relevant route requirements | May be permitted in specified circumstances, including certain in-country extension applications for workers already sponsored by the organisation |
| Home Office action plan | No | Yes |
| Action plan fee | Not applicable | £1,579 under the current Home Office fee schedule |
| Action plan period | Not applicable | Fixed period of three months |
| Ability to add new sponsor routes or branches during action plan | Subject to normal sponsorship rules | No |
| Compliance remediation required as a condition of rating | No | Yes |
| Risk of further Home Office enforcement | Normal ongoing compliance exposure | Materially increased if action-plan requirements are not met |
| Rating shown on sponsor register | A | B |
For an employer that depends on international recruitment, the difference between an A-rating and a B-rating can be commercially significant. A downgrade can restrict recruitment activity at the same time as the organisation is required to run a time-limited compliance remediation programme.
The employer should therefore assess both sides of the impact immediately: what UKVI requires to restore the licence to A-rated status, and what the restrictions mean for current recruitment, sponsored workers and planned workforce activity.
2. Can a Sponsor Have Different Ratings for Different Routes?
Where an organisation is licensed under more than one route within the same licence type, the sponsor rating will generally apply across those routes rather than being assigned separately to each route.
For example, an organisation licensed under both the Skilled Worker route and the Senior or Specialist Worker route would not ordinarily hold an A-rating for one Worker route and a B-rating for the other. If the Worker sponsor licence is downgraded, the B-rating generally applies across the relevant Worker routes covered by that licence.
Different ratings can arise in exceptional circumstances where an organisation holds more than one type of sponsor licence, for example separate Worker, Temporary Worker or Student sponsor permissions.
For employers operating across several sponsorship routes, the wider impact of a downgrade therefore needs to be considered carefully. A compliance issue identified in one part of the organisation can affect sponsorship activity beyond the individual worker, team or route that first brought the problem to UKVI’s attention.
That can be particularly significant for larger sponsors where different business units rely on different sponsored routes but operate under the same licence type. A downgrade affecting the licence can therefore have consequences across a broader recruitment and workforce programme than the original compliance issue might suggest.
Section B: What is an A-Rated Sponsor Licence?
An A-rated sponsor licence is the standard rating for an organisation authorised by the Home Office to sponsor workers.
When UKVI approves a sponsor licence application, the organisation will ordinarily be granted an A-rating, provided the relevant requirements are satisfied.
An A-rating allows the organisation to use its sponsor licence in the normal way, subject to the rules applying to the particular immigration routes covered by its licence.
This can include assigning Certificates of Sponsorship (CoS) to eligible workers, applying for or managing CoS allocations and carrying out permitted sponsor-management activities through the Sponsor Management System.
Holding an A-rating does not, however, remove the employer’s ongoing compliance obligations.
The sponsor must continue to comply with its duties relating to matters such as:
- record keeping;
- reporting changes to UKVI;
- monitoring sponsored workers;
- maintaining appropriate HR systems;
- complying with immigration law and wider UK law;
- ensuring sponsored roles satisfy the requirements of the relevant immigration route;
- managing its sponsor licence and SMS appropriately; and
- notifying UKVI of relevant organisational changes.
An A-rating should therefore be viewed as the sponsor’s current operating status, rather than as a permanent approval of its compliance arrangements.
UKVI can reassess the organisation during the life of the licence. If subsequent compliance activity identifies failings, the sponsor’s rating can change.
1. Does an A-Rating Mean the Sponsor is Fully Compliant?
Not necessarily.
An A-rating means the organisation currently holds the standard sponsor rating and can generally use its licence without the restrictions associated with a B-rating.
It should not be treated as a Home Office guarantee that every aspect of the organisation’s immigration compliance is correct.
At the point of grant, UKVI is effectively accepting that the organisation has systems capable of meeting its sponsor duties and is suitable to participate in the sponsorship system. That does not mean those systems will remain effective indefinitely or that future compliance failures cannot arise.
Compliance weaknesses can develop after a licence has been granted. For example, an organisation may grow rapidly, change its HR structure, acquire another business, open new locations or lose experienced members of its sponsor-management team.
Processes that were adequate when the sponsor licence was originally granted may therefore become ineffective over time.
This is one reason why sponsors should monitor their compliance arrangements throughout the life of the licence rather than waiting for Home Office scrutiny before identifying weaknesses.
2. Can an A-Rated Sponsor Become B-Rated?
Yes.
UKVI can downgrade an A-rated sponsor where it identifies relatively minor compliance breaches that it considers capable of being addressed through remedial action.
A downgrade can have immediate operational consequences because the sponsor will generally lose the ability to sponsor new workers while it remains B-rated.
The sponsor will also normally be required to follow a formal Home Office action plan designed to address the identified deficiencies.
However, downgrading is not the only enforcement option available to UKVI. Where the concerns are sufficiently serious, the Home Office can take stronger action, including suspension or revocation of the sponsor licence.
This distinction is important because UKVI does not have to downgrade an organisation to a B-rating before taking more serious enforcement action.
Section C: What is a B-Rated Sponsor Licence?
A B-rated sponsor licence is a downgraded, transitional sponsor licence status imposed by UKVI where it identifies relatively minor breaches of the sponsorship requirements that it considers capable of being corrected through a formal action plan.
A B-rating does not mean that the sponsor licence has been cancelled. The organisation remains a licensed sponsor, but restrictions are placed on how it can use its licence while the B-rating remains in force.
The purpose of the B-rating is remedial. UKVI identifies areas in which the sponsor is failing to meet the required standards and sets out the improvements that must be made for the organisation to return to an A-rating.
This places the sponsor in a materially different position from an A-rated organisation. The employer will generally be unable to sponsor new workers while B-rated and will have to implement the measures specified by UKVI within the fixed three-month action-plan period.
The organisation will also face serious consequences if it fails to make the required improvements. Where the sponsor does not meet the requirements of the action plan within the specified period, its sponsor licence can be revoked in accordance with the Home Office sponsor guidance.
A B-rating should therefore be treated as a formal compliance intervention rather than simply a change in administrative status.
1. Why Does UKVI Give Sponsors a B-Rating?
UKVI can downgrade a sponsor where compliance concerns are identified but are considered capable of remediation.
In general, the Home Office uses downgrading and an action plan for relatively minor breaches that it considers can be corrected within the action-plan process.
The circumstances will depend on the individual sponsor and the findings made by UKVI. Issues can relate to weaknesses in areas such as:
- sponsor record keeping;
- reporting changes within the required timescales;
- monitoring sponsored workers;
- maintaining accurate contact information;
- absence monitoring;
- SMS administration;
- management of sponsor key personnel;
- responding to Home Office requests for information;
- maintaining appropriate HR systems and processes; or
- complying with other sponsor duties.
The fact that UKVI identifies a compliance breach does not automatically mean that a B-rating will be imposed.
The Home Office has a range of compliance and enforcement options. The appropriate response will depend on the nature and seriousness of the breach and the relevant provisions of the sponsor guidance.
Where the failings are sufficiently serious, UKVI may suspend or revoke the licence rather than allowing the organisation to address the issues through a B-rating and action plan.
2. Is a B-Rating the Same as Sponsor Licence Suspension?
No. A B-rating and sponsor licence suspension are different forms of Home Office action.
A B-rating allows the organisation to retain its sponsor licence subject to restrictions and requires it to complete an action plan to regain its A-rating.
A suspension places the sponsor licence into a formal enforcement process while UKVI investigates or considers concerns about the organisation’s compliance.
The practical consequences and procedures are different.
An employer should therefore not assume that every compliance problem will first result in a B-rating. Depending on the circumstances, UKVI can move directly to suspension where the relevant grounds are met.
Equally, the fact that an organisation currently holds an A-rating does not prevent UKVI from suspending the licence if sufficiently serious compliance concerns subsequently arise.
3. Is a B-Rating the Same as Sponsor Licence Revocation?
No.
Revocation is substantially more serious because the sponsor licence is withdrawn. A B-rated organisation, by contrast, continues to hold a sponsor licence while it attempts to correct the compliance failings identified by UKVI.
However, a B-rating can ultimately lead to revocation if the sponsor does not comply with the action plan or otherwise fails to satisfy the requirements for retaining its licence.
For example, where a sponsor fails to make the improvements required under its action plan within the specified period, the Home Office guidance provides for revocation of the licence.
For this reason, employers should not treat a downgrade simply as an administrative change to their sponsor status.
It is a formal warning that UKVI has identified compliance deficiencies, has imposed restrictions on the organisation’s sponsorship activities and expects the deficiencies to be remedied within a fixed period.
Section D: What is the Difference Between an A-Rated and B-Rated Sponsor Licence?
The central difference between an A-rated and B-rated sponsor is the organisation’s ability to use its sponsor licence normally.
An A-rated sponsor can generally sponsor eligible new workers and operate its licence in accordance with the normal sponsorship rules.
A B-rated sponsor remains licensed but is subject to additional restrictions while it completes a Home Office action plan.
For employers, one of the most important consequences is international recruitment. A B-rated sponsor will generally be prevented from assigning Certificates of Sponsorship to new workers until its A-rating has been restored.
This can have significant operational consequences where recruitment plans depend on sponsored workers. It can affect candidates who are already progressing through recruitment, planned overseas recruitment campaigns and projects that depend on the employer being able to sponsor additional workers.
The distinction between A-rating and B-rating is therefore not merely a measure of compliance status. It can directly affect the organisation’s ability to recruit and deploy sponsored workers.
1. A-Rating vs B-Rating: Key Differences
| Sponsor Licence Issue | A-Rating | B-Rating |
|---|---|---|
| Sponsor licence remains valid | Yes | Yes, subject to compliance with the action plan and other licence requirements |
| Sponsor new workers | Generally yes | Generally no |
| Employ existing sponsored workers | Yes | Generally yes while the licence remains valid and the workers continue to hold valid immigration permission |
| Assign CoS to existing sponsored workers | Yes, subject to normal route requirements | May be possible in specified circumstances for certain workers already sponsored by the organisation |
| Formal Home Office action plan required | No | Yes |
| Action plan fee payable | No | Yes |
| Action plan period | Not applicable | Fixed period of three months |
| Remedial compliance programme | Not required by virtue of the rating | Required |
| Add a new route or branch during the action-plan period | Subject to the normal sponsorship requirements | No |
| Restrictions on sponsor activity | Normal sponsorship rules apply | Additional restrictions apply |
| Risk if action-plan requirements are not met | Not applicable | Licence revocation |
The precise effect of a B-rating should always be considered against the sponsor’s circumstances, the immigration route involved and the current Home Office sponsor guidance.
In particular, employers should distinguish between sponsoring a new worker and taking necessary sponsorship action in relation to a worker whom the organisation already sponsors.
Those situations are not treated in the same way.
Section E: What Happens When a Sponsor Licence is Downgraded to a B-Rating?
When UKVI downgrades a sponsor from an A-rating to a B-rating, the organisation enters a period of formal remediation.
The sponsor will be required to follow an action plan setting out the steps it must take to address the compliance failings identified by the Home Office.
During this period, restrictions apply to the use of the sponsor licence.
The immediate priorities for the employer will typically be to understand:
- why UKVI has downgraded the licence;
- which sponsor duties or systems have been identified as deficient;
- what the action plan requires;
- what restrictions now apply to sponsorship activity;
- which existing or planned sponsored workers may be affected;
- whether any existing sponsored workers will require further sponsorship action during the action-plan period;
- what evidence will be required to demonstrate improvement; and
- what must be completed before UKVI reassesses the organisation.
The B-rating therefore has both a compliance consequence and an operational consequence.
The compliance issue is the requirement to correct the identified deficiencies.
The operational issue is that restrictions on sponsorship can interfere with recruitment and workforce planning until the A-rating is restored.
1. Can a B-Rated Sponsor Sponsor New Workers?
Generally, no.
While an organisation is B-rated, it will generally be prevented from assigning Certificates of Sponsorship to new workers.
This is one of the most commercially significant consequences of a downgrade.
An organisation may have candidates already identified, recruitment campaigns underway or business projects dependent on overseas recruitment. A B-rating can prevent those recruitment plans from proceeding through sponsorship until the relevant restrictions are lifted.
UKVI monitors the use of Certificates of Sponsorship while a sponsor is B-rated. If a CoS assigned during the B-rating period is used to sponsor a new worker contrary to the applicable restrictions, this can result in revocation of the sponsor licence.
Employers facing a downgrade should therefore assess the effect on their recruitment pipeline immediately rather than treating the matter solely as an HR compliance exercise.
2. Can a B-Rated Sponsor Continue Employing Existing Sponsored Workers?
Generally, yes, provided the sponsor licence remains in force and the workers continue to have valid immigration permission and satisfy the relevant requirements.
A B-rating does not itself automatically terminate the immigration permission of workers already sponsored by the organisation.
However, employers need to distinguish between simply continuing to employ an existing sponsored worker and needing to take further sponsorship action for that worker.
For example, an existing worker may need a new Certificate of Sponsorship in connection with an application to extend their permission to stay in the UK.
Specific provisions apply to the use and allocation of Certificates of Sponsorship while an action plan is in force.
The employer should therefore review its sponsored workforce as soon as the licence is downgraded, identifying workers whose immigration permission is due to expire or whose circumstances may require sponsorship action during the B-rating period.
3. Can a B-Rated Sponsor Assign a CoS to an Existing Sponsored Worker?
In specified circumstances, a B-rated sponsor may be able to assign a Certificate of Sponsorship to a worker it already sponsors.
The exception is narrower than a general right to continue issuing Certificates of Sponsorship to existing employees.
Under the applicable sponsorship provisions, this can include certain circumstances where the worker is applying from within the UK for permission to stay on the same immigration route as their previous grant, the B-rated organisation assigned the Certificate of Sponsorship that led to that previous grant and the organisation is continuing to sponsor the worker.
This is different from assigning a CoS to recruit a new sponsored worker.
The availability of the exception also depends on the particular immigration route. Employers should therefore check the requirements applying to the worker before assigning a CoS.
In particular, sponsors under the Scale-up Worker and Seasonal Worker routes must hold an A-rating to assign a Certificate of Sponsorship, so the general existing-worker exception should not be assumed to apply to those routes.
The Home Office can also control the sponsor’s CoS allocation during the action-plan period.
This distinction can be particularly important where an existing sponsored worker’s immigration permission is approaching expiry during the B-rating period.
The employer should identify affected workers and relevant immigration deadlines as soon as the downgrade occurs rather than waiting until the worker’s existing permission is close to expiry.
4. Can a B-Rated Sponsor Add a New Route or Branch?
No. During the action-plan period, a B-rated sponsor cannot add a new route or branch to its sponsor licence.
This can have wider consequences for organisations that were planning to expand their use of the sponsorship system at the time the downgrade occurred.
For example, an employer intending to add another sponsored work route or extend its sponsorship arrangements to another part of its organisational structure may have to postpone those plans until the compliance issues have been addressed and the A-rating restored.
The restriction reinforces the purpose of the B-rating regime: the sponsor is expected to concentrate on correcting its existing compliance deficiencies before expanding its sponsorship activities.
5. Does a B-Rating Affect Sponsor Key Personnel and SMS Arrangements?
It can.
A B-rating can affect certain sponsor-management privileges that may previously have applied to the organisation.
In particular, where the sponsor previously benefited from arrangements allowing specified changes to key personnel or SMS users to take effect automatically, those privileges can be removed while the organisation is B-rated.
This can affect changes involving the Authorising Officer, Key Contact and Level 1 Users.
Employers should therefore review their sponsor-management arrangements following a downgrade and should not assume that changes to key personnel will be dealt with in the same way as they were while the organisation held an A-rating.
This is particularly important where a downgrade coincides with the departure or replacement of an individual responsible for operating the sponsor licence.
Section F: Sponsor Licence Action Plans
Where UKVI downgrades a sponsor licence from an A-rating to a B-rating, the sponsor will normally be required to follow a sponsor licence action plan.
The action plan sets out the improvements the Home Office requires the organisation to make before its A-rating can be restored.
This is not simply advisory guidance. The sponsor must address the requirements within the action-plan period and be able to demonstrate that the identified compliance weaknesses have been corrected.
The specific requirements will depend on the deficiencies identified by UKVI. An action plan could require improvements to areas such as:
- record-keeping systems;
- monitoring of sponsored workers;
- reporting procedures;
- absence management;
- SMS administration;
- management of sponsor key personnel;
- internal compliance controls;
- staff training;
- processes for identifying reportable changes; and
- the allocation of responsibility for sponsor compliance.
Employers should avoid approaching the action plan as a checklist exercise. Where UKVI has identified a systemic weakness, correcting individual records without addressing the underlying process may not demonstrate that the organisation is capable of complying consistently in future.
The employer should instead consider why the failure occurred, whether the same weakness affects other workers or areas of the organisation and what controls are needed to prevent recurrence.
1. How Much Does a Sponsor Licence Action Plan Cost?
The current Home Office fee for a sponsor licence action plan is £1,579.
This fee is payable by the sponsor following the decision to downgrade the licence.
The fee is separate from the cost to the organisation of carrying out the remediation itself. Depending on the nature of the compliance issues, the employer may also need to dedicate management time and resources to reviewing records, correcting systems, training staff, conducting internal audits and preparing evidence of compliance.
Employers should check the current Home Office fee schedule when dealing with a downgrade, as immigration and sponsorship fees are subject to change.
2. How Long Does a Sponsor Have to Pay for the Action Plan?
Where UKVI notifies an organisation that it has been downgraded to a B-rating and requires an action plan, the sponsor will normally have 10 working days from the date of the notification to pay the action-plan fee.
This is a critical deadline.
If the sponsor ignores the notification or fails to pay the required fee within the permitted period, UKVI can revoke the sponsor licence in accordance with the applicable sponsor guidance. Limited provision may apply where the failure resulted from circumstances genuinely beyond the sponsor’s control, but employers should not rely on this as an alternative to meeting the deadline.
Where an organisation has no sponsored workers and does not wish to proceed with the action plan, it may instead need to consider whether surrendering the sponsor licence is appropriate and follow the prescribed Home Office process.
The notification from UKVI should therefore be reviewed immediately on receipt. Responsibility for responding should be clearly allocated and relevant deadlines recorded rather than relying on the correspondence simply being forwarded internally.
3. How Long Does a Sponsor Licence Action Plan Last?
A sponsor licence action plan is set for a fixed period of three months.
The purpose of this period is to give the organisation an opportunity to make the improvements specified by UKVI and demonstrate that it can meet the required sponsorship standards.
Three months can be a relatively short remediation period where the identified weaknesses affect multiple parts of the organisation.
For example, correcting a systemic compliance problem may require the employer to:
- audit sponsored worker files;
- reconcile HR data against SMS records;
- identify unreported or incorrectly reported changes;
- review the circumstances of affected sponsored workers;
- revise internal procedures;
- retrain relevant personnel;
- clarify responsibility between HR, recruitment, payroll and management teams;
- introduce new reporting and escalation controls;
- test whether revised processes operate effectively; and
- assemble evidence showing that the action-plan requirements have been satisfied.
The remediation programme should therefore begin as soon as the B-rating is imposed.
Waiting until the end of the three-month period before testing whether the new systems work can leave insufficient time to identify and correct further weaknesses.
Section G: How Do You Regain an A-Rated Sponsor Licence?
A B-rated sponsor can return to an A-rating by successfully completing the Home Office action plan and demonstrating that the required improvements have been made.
The precise steps will depend on the deficiencies identified by UKVI, but the process will ordinarily involve the sponsor addressing each requirement in the action plan and ensuring that the improvements operate effectively in practice.
The objective should not simply be to produce documentation showing that a new procedure exists.
UKVI will need to be satisfied that the organisation meets the required sponsorship standards.
A structured remediation process will typically involve:
- Analysing the Home Office findings and action plan to establish exactly what UKVI considers deficient.
- Identifying the underlying cause of each compliance failure rather than dealing only with the individual example identified by UKVI.
- Allocating responsibility for each remedial action to an appropriate person within the organisation.
- Correcting affected records and outstanding reporting issues where appropriate and permitted.
- Revising policies, systems and procedures to address the identified weaknesses.
- Training relevant personnel so that the revised processes are understood and applied consistently.
- Testing the revised controls to establish whether they work in practice.
- Assembling evidence showing that the action-plan requirements have been met.
- Reviewing the wider sponsor licence for related compliance weaknesses that may not have been expressly identified in the action plan.
- Preparing for further Home Office compliance activity and ensuring relevant personnel can explain how the organisation’s sponsorship systems operate.
The organisation should also consider whether the weaknesses identified by UKVI indicate wider problems that are not expressly listed in the action plan.
For example, if UKVI identifies failures to report changes affecting several sponsored workers, the immediate issue may be the missing reports. The underlying problem, however, could be that line managers do not notify the sponsor-management team when workers change roles, work locations or employment circumstances.
Correcting the historic records without correcting that information flow could leave the same compliance risk in place.
1. Will UKVI Carry Out Another Compliance Check?
UKVI can undertake further compliance activity to determine whether the sponsor has made the improvements required by the action plan.
The sponsor should therefore work on the basis that its revised processes, records and personnel may need to withstand further Home Office scrutiny.
This can involve examining whether the organisation has implemented the required measures and whether its systems demonstrate effective compliance in practice.
UKVI may also carry out additional compliance activity where information suggests that there are sponsorship failures outside the matters already addressed by the action plan.
The employer should therefore retain appropriate evidence of the remediation undertaken.
Depending on the issues involved, this could include:
- revised policies and procedures;
- training records;
- internal audit results;
- corrected personnel files;
- SMS and reporting records;
- internal responsibility matrices;
- records of compliance checks;
- evidence of management oversight; and
- evidence that new controls are operating in practice.
This is another reason why the remediation exercise should extend beyond correcting the specific examples originally identified by UKVI.
2. Can a Sponsor Ask UKVI to Check Compliance Before the Three Months End?
A sponsor may be able to request that UKVI conducts its assessment before the end of the fixed three-month action-plan period.
An employer should only consider doing this where it is confident that all of the required improvements have been completed and can be evidenced.
Requesting an earlier assessment before the organisation is genuinely ready can expose unresolved deficiencies.
Importantly, where a sponsor requests an early compliance check, UKVI can take the appropriate action following that assessment even though the original three-month action-plan period has not yet expired.
An early assessment should therefore not be regarded simply as a mechanism for testing whether the organisation is ready.
For many sponsors, the more important objective is not restoring the A-rating at the earliest possible moment, but ensuring that the remediation is sufficiently robust to withstand the Home Office’s reassessment.
3. When is the A-Rating Restored?
Where UKVI is satisfied that the sponsor has successfully met the requirements of the action plan and there are no further compliance concerns preventing restoration, the organisation can be upgraded from a B-rating to an A-rating.
Once the A-rating has been restored, the restrictions associated specifically with the B-rating cease to apply and the organisation can resume normal sponsorship activity, subject to the general requirements of the sponsor regime and any route-specific requirements.
Restoration of the A-rating should not, however, mark the end of the compliance exercise.
The organisation should retain the systems introduced during remediation and continue monitoring their effectiveness. A sponsor that returns to an A-rating but subsequently falls back into non-compliance can face further Home Office action.
This is particularly important because the Home Office limits the number of times a sponsor can use the B-rating and action-plan process within the relevant rolling period.
Section H: What Happens if a Sponsor Fails the Action Plan?
Failure to meet the requirements of a sponsor licence action plan can result in the organisation losing its sponsor licence.
The purpose of the B-rating period is to give the sponsor a defined opportunity to correct the compliance deficiencies identified by UKVI. The organisation is expected to make the improvements specified in the action plan within the fixed three-month period.
If the sponsor does not meet the requirements of its action plan within the specified period, its sponsor licence will be revoked in accordance with the Home Office sponsor guidance.
This makes the action-plan process materially different from an informal compliance recommendation. Once the organisation has entered the B-rating process, successful remediation is necessary to protect the licence.
The consequences of failure can extend beyond the sponsor’s ability to recruit new workers. Revocation can also affect workers already sponsored by the organisation and can create significant workforce, operational and reputational issues for the employer.
A sponsor subject to an action plan should therefore treat the remediation programme as a business-critical compliance exercise.
1. What if UKVI Finds New Compliance Problems?
The Home Office assessment is not necessarily limited to checking whether individual items listed in the action plan have been completed.
UKVI can undertake additional compliance activity where it has information or evidence suggesting that the organisation may be failing to comply with sponsorship requirements outside the matters already addressed by the action plan.
If further compliance problems are identified, these can affect the outcome of the action-plan process and the sponsor’s wider licence position.
Depending on the circumstances, the sponsor’s compliance history and the nature of the additional failures, the Home Office may take further action under the sponsorship regime.
This is why a sponsor should consider conducting a broader review of its sponsorship arrangements rather than restricting its work to the individual examples of non-compliance originally identified by UKVI.
If one reporting failure has been discovered, for example, the organisation should determine whether the same weakness has affected other sponsored workers. If one personnel file is incomplete, it should consider whether the problem reflects a wider record-keeping issue.
Likewise, if UKVI identifies a failure involving one work location or business unit, the sponsor should consider whether the same processes are being used elsewhere in the organisation.
The objective is to identify and correct the systemic cause of non-compliance, rather than merely repairing the particular records examined by UKVI.
Section I: How Many Times Can a Sponsor Licence Be B-Rated?
The Home Office places strict limits on repeated periods of B-rating and action-plan remediation.
Under the current sponsor guidance, a sponsor can generally only be B-rated and subject to an action plan twice during any rolling four-year period in which it holds a sponsor licence.
This prevents repeated use of the B-rating process as an indefinite alternative to maintaining the required sponsorship standards.
Where a sponsor has already been B-rated twice during the relevant rolling four-year period and subsequently commits further breaches that would otherwise justify another downgrade, UKVI will revoke the sponsor licence rather than impose a third B-rating and action plan.
For employers that have previously been B-rated, compliance history is therefore particularly important.
A return to an A-rating should not be viewed as wiping the slate clean. The organisation should retain records of the previous compliance issues, understand why they occurred and maintain controls designed to prevent recurrence.
1. Does a Previous B-Rating Matter After the A-Rating is Restored?
Yes.
Restoration to an A-rating means the sponsor has successfully returned to the standard sponsor rating, but previous action-plan history can remain relevant under the Home Office rules governing repeated downgrades.
The rolling four-year restriction means that an organisation’s previous periods of B-rating can affect the enforcement consequences of later compliance failures.
There is also a practical compliance reason to retain this institutional knowledge.
Where a sponsor has previously been downgraded because of weaknesses in reporting, record keeping, worker monitoring, SMS administration or another area of sponsorship compliance, those issues should form part of the organisation’s ongoing internal audit programme.
This can be particularly important where the personnel responsible for the original remediation subsequently leave the organisation.
Without effective handover and documented procedures, compliance improvements introduced in response to a previous downgrade can gradually disappear.
The organisation should therefore retain an appropriate record of:
- the circumstances that led to the previous downgrade;
- the deficiencies identified by UKVI;
- the measures implemented under the action plan;
- the evidence used to demonstrate remediation;
- any changes subsequently made to the compliance framework; and
- the controls required to prevent the same failures recurring.
This history can also be useful when carrying out future sponsor compliance audits or preparing for Home Office compliance activity.
Section J: Does UKVI Have to Downgrade a Sponsor Before Suspending or Revoking its Licence?
No.
There is no general requirement for UKVI to give an employer a B-rating and action plan before taking more serious enforcement action.
The appropriate Home Office response depends on the nature and seriousness of the compliance issue and the applicable provisions of the sponsor guidance.
This means employers should not regard the B-rating system as a guaranteed warning stage before suspension or revocation.
Where UKVI identifies relatively minor deficiencies that it considers capable of remediation through an action plan, downgrading may be appropriate.
Where the circumstances justify stronger action, the Home Office can instead exercise its powers to suspend or revoke the sponsor licence without first allowing the organisation to progress through the B-rating process.
The distinction can broadly be understood as follows:
| Home Office Status | General Position | Practical Effect |
|---|---|---|
| A-rating | Standard sponsor status | Sponsor can generally operate the licence normally, subject to ongoing sponsor duties and route requirements |
| B-rating | Relatively minor compliance deficiencies considered capable of remediation | Licence remains in force but sponsorship activity is restricted and an action plan is required |
| Suspension | Formal Home Office enforcement action while compliance concerns are considered | The sponsor’s ability to use the licence is significantly affected while UKVI determines what further action should be taken |
| Revocation | Sponsor licence withdrawn | The organisation ceases to be a licensed sponsor under the affected licence |
The consequences of each status are different, and employers receiving correspondence from UKVI should establish precisely what action the Home Office is proposing or has taken.
In particular, an employer should not assume that an opportunity to complete an action plan will be available simply because the organisation currently holds an A-rating or because it has not previously been subject to compliance action.
Section K: Provisional Sponsor Licence Ratings
Although A and B are the principal sponsor licence ratings, there is an important exception under the UK Expansion Worker route.
In certain circumstances, an organisation licensed to sponsor UK Expansion Workers can initially hold a Provisional rating.
This reflects the particular structure of the UK Expansion Worker route, which is designed for overseas businesses establishing a presence in the UK.
A Provisional rating is not the same as a B-rating.
It should not be interpreted as indicating that the organisation has been downgraded because of compliance failures. It is a route-specific sponsor status applying in defined circumstances.
A Provisional rating can arise where the organisation’s Authorising Officer is an employee of the overseas business who will be assigned a Certificate of Sponsorship to come to the UK under the UK Expansion Worker route and will initially act as the Level 1 User.
Once the relevant requirements are met, including the necessary steps following the individual’s entry to the UK and the updating of the sponsor’s arrangements, the organisation can be upgraded to an A-rating.
1. Can a Provisional Rating be Downgraded to a B-Rating?
No.
A Provisional rating cannot be downgraded to a B-rating in the same way as an A-rated sponsor licence.
If an organisation holding a Provisional rating fails to meet its sponsor duties or the conditions applying to its licence, it should not assume that it will be given the opportunity to remedy those failures through the B-rating and action-plan process.
Under the Home Office sponsor guidance, a Provisional-rated licence will normally be subject to revocation where the sponsor fails to meet the applicable duties or conditions.
This makes it particularly important for UK Expansion Worker sponsors operating with a Provisional rating to understand the restrictions applying to that status and the steps required to obtain an A-rating.
For most employers using mainstream sponsored work routes, particularly the Skilled Worker route, the principal ratings distinction will nevertheless remain between A-rated and B-rated sponsor status.
Section L: How to Protect an A-Rated Sponsor Licence
The most effective way to protect an A-rating is to treat sponsor compliance as an ongoing operational responsibility rather than an immigration task that arises only when a worker needs a visa.
Sponsor duties continue throughout the life of the licence.
This means employers need systems capable of identifying relevant events, determining whether action is required and ensuring that the correct action is taken within the applicable timeframe.
For organisations sponsoring significant numbers of workers, this usually requires coordination between HR, recruitment, payroll, line management and the individuals responsible for operating the Sponsor Management System.
The compliance framework should also be capable of adapting as the organisation changes. Systems that worked when a sponsor licence was first granted may become inadequate as the sponsored workforce grows, new locations are opened or responsibility is distributed across different teams.
1. Maintain Clear Responsibility for Sponsor Compliance
Responsibility for the sponsor licence should be clearly allocated.
The organisation should know who is responsible for:
- overseeing the sponsor licence;
- operating the SMS;
- identifying reportable events;
- maintaining sponsored worker records;
- monitoring immigration permission;
- monitoring attendance and absences where relevant;
- reviewing changes to sponsored roles;
- escalating potential compliance problems;
- reviewing organisational changes for sponsorship implications; and
- maintaining communication between HR, management and sponsor key personnel.
A common compliance risk arises where everyone assumes somebody else is responsible.
The Authorising Officer has an important role within the sponsor-management structure, but effective compliance should not depend entirely on one individual remembering every requirement.
Processes should continue to function during holidays, sickness, staff turnover and organisational change.
There should also be appropriate escalation arrangements where the person responsible for day-to-day sponsorship activity identifies an issue that requires senior management involvement.
2. Keep Sponsor Records Up to Date
Sponsors must maintain the records required under the sponsorship regime.
Record keeping should form part of normal HR administration rather than being undertaken retrospectively when UKVI requests documents or announces a compliance visit.
Employers should have a reliable system for identifying:
- which documents must be retained;
- where those documents are stored;
- who is responsible for maintaining them;
- how long the relevant records must be retained;
- whether required documents are available for each sponsored worker; and
- whether the information held remains accurate.
Periodic file audits can help identify gaps before they become Home Office compliance issues.
Employers with decentralised HR functions or multiple work locations should also consider whether records are maintained consistently across the organisation rather than assuming that each business unit is following the same process.
3. Build Sponsor Reporting Duties into HR Processes
Many sponsor compliance failures arise because an event occurs within the business but the information does not reach the person responsible for determining whether it needs to be reported to UKVI.
A sponsored worker might, for example, change their work location, duties or other employment circumstances without the sponsor-management team being notified promptly.
Likewise, changes affecting the organisation itself can create reporting obligations.
Employers should therefore build sponsor reporting considerations into ordinary HR and corporate processes.
Relevant changes should trigger a compliance review rather than relying on an individual to recognise an immigration issue by chance.
This can involve incorporating sponsorship checks into processes dealing with:
- promotions and changes of role;
- salary changes;
- changes to working patterns;
- changes of work location;
- long-term absence;
- termination of employment;
- corporate restructuring;
- mergers and acquisitions;
- changes in ownership or control; and
- opening, closing or relocating business premises.
The objective is to create a reliable information flow between the part of the organisation where the change occurs and the people responsible for sponsorship compliance.
4. Control Access to the Sponsor Management System
SMS access should be properly governed.
The organisation should know:
- who currently has access;
- what level of access each user has;
- whether those individuals still require access;
- whether the details recorded for key personnel remain accurate;
- who is responsible for completing particular SMS functions;
- who reviews significant SMS activity; and
- what happens when an SMS user leaves the organisation or changes role.
Access should not simply accumulate as personnel change.
Sponsors should periodically review their SMS users and key personnel arrangements to ensure they remain appropriate.
Where responsibility changes, the employer should also ensure that knowledge of outstanding sponsorship matters is transferred rather than relying solely on access to the SMS itself.
5. Monitor Sponsored Workers Effectively
Sponsors need systems that allow them to monitor the workers they sponsor and identify circumstances requiring action.
The appropriate controls will depend on the organisation and its workforce, but the system should allow relevant information to move from operational teams to those responsible for sponsor compliance.
This becomes increasingly important where sponsored workers are spread across different sites, departments or business units.
A central HR team cannot report an event it does not know has happened.
Line managers and other relevant personnel should therefore understand which changes or concerns need to be escalated, even where they are not themselves responsible for determining the immigration consequences.
6. Carry Out Periodic Sponsor Licence Audits
Internal compliance audits can help identify weaknesses before UKVI does.
An effective audit should look beyond whether individual personnel files contain the expected documents.
It should test whether the organisation’s overall sponsor-management system works in practice.
This can include reviewing:
- sponsored worker records;
- SMS information;
- right to work documentation;
- reporting history;
- recruitment records;
- sponsored roles;
- salary and working arrangements;
- absence-monitoring processes;
- key personnel arrangements;
- corporate information;
- CoS assignment processes;
- internal escalation procedures; and
- the organisation’s response to previous compliance issues.
The audit should also test whether relevant personnel understand what they are expected to do.
A written policy has limited value if the employees responsible for implementing it do not know that it exists or do not understand when it applies.
For larger or rapidly changing organisations, periodic auditing can also provide evidence that senior management is actively overseeing the sponsor licence rather than relying solely on reactive compliance when an issue arises.
Section M: Sponsor Licence Rating Risk Indicators
An A-rating should be treated as an operating condition, not an award.
One of the more significant risks for established sponsors is that their organisation changes while their sponsorship arrangements remain static.
A compliance system that worked when an employer sponsored five workers from one location may not remain adequate when the organisation sponsors 100 workers across multiple sites.
The same issue can arise following acquisitions, restructures, rapid recruitment, changes in senior management, the introduction of new HR systems or the departure of experienced sponsor key personnel.
The fact that the organisation continues to hold an A-rating does not establish that these changes have been successfully incorporated into its sponsor compliance framework.
Employers should therefore consider whether any of the following indicators suggest that their sponsor compliance arrangements need review.
1. Governance Risk
Governance risk arises where there is no clear ownership of sponsor compliance.
HR may assume responsibility sits with the Authorising Officer, while the Authorising Officer assumes the HR team is handling day-to-day compliance.
Individual SMS users may understand how to perform administrative functions without anyone taking responsibility for the overall integrity of the licence.
In larger organisations, responsibility can become even more fragmented. Recruitment may handle Certificates of Sponsorship, HR may maintain personnel records, payroll may hold salary information and line managers may be responsible for monitoring day-to-day changes affecting sponsored workers.
Each team may perform its own function without anyone having visibility across the entire sponsorship process.
The risk is therefore not necessarily that nobody is doing anything. It is that nobody has effective oversight of how all the different elements of sponsor compliance fit together.
Employers should be able to identify who has overall responsibility for the licence, who performs individual compliance functions and how potentially significant issues are escalated.
2. Systems Risk
Systems risk arises where the organisation’s HR and management systems do not reliably identify events that could trigger sponsor action.
Information may exist somewhere within the business but fail to reach the sponsor-management function.
This can occur where payroll, recruitment, HR, operational management and immigration compliance operate through separate systems or teams.
For example, payroll may know that a worker’s salary has changed, a line manager may know that their duties have changed and facilities may know that they have moved to another work location. Unless those changes reach the appropriate sponsor-management personnel, their immigration significance may never be considered.
As the organisation becomes larger or more complex, reliance on informal communication becomes increasingly vulnerable.
Sponsors should therefore consider whether their systems actively identify potentially reportable events or merely depend on individual employees remembering to notify the immigration or HR team.
3. Knowledge Risk
Knowledge risk arises where the individuals involved in sponsorship do not have sufficient understanding of the current sponsor requirements or of their own responsibilities within the compliance process.
This can affect Level 1 Users, HR personnel, recruiters, payroll staff and operational managers.
Not every manager needs detailed knowledge of the Home Office sponsor guidance. They do, however, need enough understanding to recognise events that should be escalated to the appropriate person.
A line manager does not necessarily need to determine whether a particular change must be reported through the SMS. The organisation does need a process that ensures the manager recognises that the change should be referred to the person who can make that determination.
Training should therefore reflect the individual’s role in the compliance process rather than being confined to employees with direct SMS access.
Knowledge should also be maintained as Home Office requirements change. Processes based on outdated sponsorship rules can create compliance failures even where staff believe they are following established internal procedures.
4. Change Risk
Change risk arises where significant business or workforce changes take place without immigration compliance being considered.
Examples can include:
- mergers and acquisitions;
- TUPE transfers;
- changes in ownership or control;
- corporate restructures;
- opening or closing locations;
- changes to sponsored workers’ roles;
- changes to working arrangements;
- rapid expansion;
- changes to HR or payroll systems;
- reorganisation of business functions;
- changes in responsibility for sponsored workers; and
- departure or replacement of sponsor key personnel.
Corporate activity that appears unrelated to immigration can have consequences for the sponsor licence.
The compliance risk increases where immigration is considered only after a transaction, restructure or workforce change has already taken place.
Building immigration compliance into change-management procedures can help ensure potential sponsorship consequences are identified before reporting deadlines are missed, incorrect action is taken or the organisation’s sponsor licence position is affected.
Section N: Sponsor Licence Ratings: Employer Checklist
Employers seeking to maintain their A-rating should periodically test whether the systems supporting their sponsor licence continue to operate effectively.
As a minimum, the organisation should be able to answer the following questions confidently:
- Do we know who has overall responsibility for our sponsor licence?
- Are our Authorising Officer, Key Contact and SMS users still appropriate?
- Is the information recorded on our sponsor licence accurate and up to date?
- Can we identify all workers currently sponsored by the organisation?
- Do we know when each sponsored worker’s immigration permission expires?
- Are required sponsor records complete and readily accessible?
- Are reportable worker changes identified promptly?
- Are reportable organisational changes escalated appropriately?
- Do HR, recruitment, payroll and line managers understand when immigration compliance needs to be considered?
- Are sponsored worker roles consistent with the basis on which the workers are sponsored?
- Are salary and working arrangements consistent with the applicable sponsorship requirements?
- Do we periodically reconcile HR information against the SMS?
- Are CoS assignments subject to appropriate checks and authorisation?
- Do we know who has access to the SMS and whether that access remains appropriate?
- Do we have arrangements for maintaining compliance during holidays, sickness and staff turnover?
- Are corporate changes reviewed for potential sponsor licence implications?
- Have we tested our processes through an internal sponsor compliance audit?
- Have weaknesses identified during previous audits or Home Office activity been fully remediated?
- Can relevant personnel explain how our sponsor compliance processes operate?
- Would we be able to demonstrate effective compliance if UKVI carried out a compliance visit?
If the answer to any of these questions is unclear, the organisation may have a compliance vulnerability even though it currently holds an A-rating.
The objective should be to identify that vulnerability while the organisation remains A-rated, rather than after UKVI has identified the problem and imposed a B-rating or taken more serious enforcement action.
For employers with a significant sponsored workforce, the checklist should form part of a wider programme of periodic sponsor licence auditing rather than being treated as a one-off exercise.
Section O: Frequently Asked Questions About Sponsor Licence Ratings
1. Can a B-Rated Sponsor Still Employ Skilled Workers?
Generally, yes.
A B-rating does not automatically prevent an organisation from continuing to employ Skilled Workers it already sponsors.
Existing sponsored workers can generally continue working for the organisation while the sponsor licence remains valid and they continue to hold the required immigration permission.
The more significant restriction concerns new sponsorship. A B-rated sponsor will generally be unable to assign a Certificate of Sponsorship to a new worker until its A-rating has been restored.
Employers should nevertheless review their existing sponsored workforce as soon as a downgrade occurs, particularly where workers have upcoming visa expiry dates or may require further sponsorship action during the fixed three-month action-plan period.
2. Can a Worker Apply for a Visa Using a B-Rated Sponsor?
The answer depends on whether the individual is a new worker or someone the organisation already sponsors, as well as the immigration route involved.
A B-rated sponsor will generally not be permitted to assign a Certificate of Sponsorship to a new worker.
Different provisions can apply where an existing sponsored worker needs a new CoS to make an application for permission to stay in the UK.
In specified circumstances, this can include a worker applying from within the UK for permission to stay on the same immigration route as their previous grant, where the B-rated organisation assigned the CoS that led to that previous grant and continues to sponsor the worker.
This exception should not be interpreted as a general right for B-rated sponsors to issue Certificates of Sponsorship to existing employees. The relevant route requirements and the worker’s individual circumstances have to be considered.
In particular, sponsors under the Scale-up Worker and Seasonal Worker routes must hold an A-rating to assign a Certificate of Sponsorship.
3. Does a B-Rating Automatically Mean the Sponsor Licence Will Be Revoked?
No.
The purpose of the B-rating and action-plan process is to give the sponsor an opportunity to address compliance deficiencies that UKVI considers capable of remediation.
If the organisation completes the required improvements and satisfies UKVI that the relevant standards have been met, its A-rating can be restored.
However, once an action plan has been imposed, the sponsor has to comply with its requirements within the specified period. Failure to meet the action-plan requirements can result in revocation in accordance with the Home Office sponsor guidance.
The B-rating should therefore be viewed as an opportunity to remediate identified compliance problems, but also as a formal Home Office intervention with potentially serious consequences if the required improvements are not made.
4. Can the Public See if a Sponsor is B-Rated?
Yes.
The Home Office publishes the Register of Licensed Sponsors, which identifies organisations licensed to sponsor workers and includes information about their sponsor rating.
A B-rating can therefore have implications beyond the internal relationship between the employer and UKVI.
Workers, prospective recruits, professional advisers and other parties can consult the published register.
This is another reason why organisations should respond promptly to a downgrade and work towards restoring their A-rating.
5. Can a B-Rated Sponsor Become A-Rated Again?
Yes.
Returning the organisation to an A-rating is the objective of the action-plan process.
The sponsor will need to implement the improvements required by UKVI and demonstrate that the identified compliance deficiencies have been addressed.
If UKVI is satisfied that the action-plan requirements have been met and there are no other compliance issues preventing restoration, the organisation can return to an A-rating.
Once the A-rating is restored, the restrictions associated specifically with the B-rating cease to apply, although the organisation remains subject to its continuing sponsor duties.
6. How Long is a Sponsor Licence B-Rated?
A Home Office sponsor action plan is set for a fixed period of three months.
The sponsor should use this period to implement the required improvements and prepare for UKVI to assess whether the action plan has been successfully completed.
Employers should not assume that three months provides substantial time to address the issues. Where deficiencies are systemic or affect large numbers of sponsored workers, remediation can involve significant work.
The organisation should therefore begin reviewing the Home Office findings and implementing the required improvements as soon as the downgrade occurs.
7. How Much Does it Cost to Restore an A-Rating?
The current Home Office action-plan fee is £1,579.
This is the government fee associated with the action plan. It does not include the employer’s own costs of investigating and correcting the compliance issues, implementing new systems, training personnel, conducting audits or obtaining professional advice where required.
Home Office fees can change, so sponsors should check the current fee schedule when dealing with a downgrade.
8. How Long Does a Sponsor Have to Pay the Action-Plan Fee?
A sponsor will normally have 10 working days from the date of UKVI’s notification to pay the required action-plan fee.
The deadline should be treated as critical.
Failure to pay within the permitted period can lead to revocation of the sponsor licence under the applicable Home Office guidance, subject to limited provision for circumstances genuinely outside the sponsor’s control.
Employers should therefore ensure that Home Office correspondence concerning the sponsor licence is identified, escalated and acted upon immediately.
9. Can a B-Rated Sponsor Add Another Sponsorship Route?
No. A B-rated sponsor cannot add a new route to its licence during the action-plan period.
The sponsor is expected to address the compliance deficiencies affecting its existing licence before expanding its sponsorship activities.
The restriction can be commercially significant where the organisation was planning to begin sponsoring workers under another route.
10. Can a B-Rated Sponsor Add a New Branch?
No. A B-rated sponsor cannot add a new branch to its sponsor licence during the action-plan period.
Organisations planning expansion, restructuring or changes to their corporate arrangements should therefore consider how a downgrade affects those plans as well as the immediate restrictions on recruiting new sponsored workers.
11. How Many Times Can a Sponsor be B-Rated?
Under the current Home Office sponsor guidance, an organisation can generally be B-rated and subject to an action plan a maximum of twice during any rolling four-year period in which it holds a sponsor licence.
If the sponsor has already been B-rated twice during the relevant period and subsequently commits further breaches that would otherwise justify another downgrade, UKVI will revoke the licence rather than impose a third B-rating and action plan.
A previous B-rating therefore remains relevant even after the organisation has successfully returned to an A-rating.
12. Does UKVI Have to Give a Sponsor a B-Rating Before Revoking the Licence?
No.
A B-rating is not a mandatory preliminary stage before suspension or revocation.
UKVI generally uses the B-rating and action-plan process for relatively minor breaches that it considers capable of remediation.
Depending on the nature and seriousness of the compliance issue, UKVI can take more serious enforcement action where the relevant grounds are met without first downgrading the sponsor to a B-rating.
Employers should therefore not assume that they will always receive an opportunity to correct compliance failures through an action plan before their licence is put at greater risk.
Section P: How DavidsonMorris Can Help
Sponsor licence ratings have direct implications for an employer’s ability to recruit and retain sponsored workers.
Where an organisation has been downgraded to a B-rating, the priority is to understand why UKVI has taken action, what restrictions now apply and what must be done within the fixed three-month action-plan period to restore the A-rating.
DavidsonMorris advises employers on all aspects of sponsor licence management, compliance and Home Office enforcement.
We can support organisations that have received a B-rating by reviewing the Home Office decision and action plan, identifying the underlying compliance failures and developing a structured remediation programme.
This can include:
- reviewing the reasons for the sponsor licence downgrade;
- advising on the implications of the B-rating for current and planned sponsorship activity;
- reviewing the Home Office action plan and required improvements;
- conducting a wider sponsor licence compliance audit;
- reviewing sponsored worker files and record-keeping systems;
- checking SMS records and reporting history;
- identifying outstanding or potentially incorrect sponsor reporting;
- reviewing Certificate of Sponsorship processes;
- reviewing key personnel and SMS user arrangements;
- assessing HR systems for monitoring sponsored workers;
- reviewing internal reporting and escalation processes;
- helping implement revised sponsor compliance procedures;
- supporting training for relevant personnel;
- preparing the organisation for further Home Office compliance activity; and
- helping the employer demonstrate that the required improvements have been implemented.
Where an organisation remains A-rated, we can also help employers identify compliance weaknesses before they result in a downgrade or more serious Home Office action.
This can be particularly important for organisations that have experienced rapid growth, changes in key personnel, restructuring, acquisitions, expansion to new locations or significant increases in the number of sponsored workers.
Proactive sponsor licence auditing can help establish whether the organisation’s current systems remain appropriate for the size and complexity of its sponsored workforce.
If your organisation has been downgraded to a B-rating, has received Home Office correspondence concerning its sponsor rating or wants to assess the resilience of its current A-rated licence, seek advice on the steps required to protect your sponsorship position.
Section Q: Sponsor Licence Ratings: Key Takeaways for Employers
Sponsor licence ratings are an important part of the Home Office sponsorship compliance regime.
For most licensed employers, the central distinction is between an A-rated sponsor licence and a B-rated sponsor licence.
An A-rating is the standard rating and generally allows the organisation to use its sponsor licence normally, including assigning Certificates of Sponsorship where the relevant sponsorship requirements are met.
A B-rating is a downgraded status generally used where UKVI identifies relatively minor compliance breaches that it considers capable of being resolved through a Home Office action plan.
A B-rating does not mean that the sponsor licence has been suspended or revoked. The licence remains in force, but the organisation’s sponsorship activities are restricted while it completes the required remediation.
In particular, employers should remember that:
- an A-rating is the standard sponsor licence rating but does not remove the employer’s continuing sponsor duties;
- a B-rating generally prevents the organisation from sponsoring new workers;
- existing sponsored workers can generally continue working while the licence remains valid and they continue to hold valid immigration permission;
- limited provision exists for certain existing sponsored workers requiring further permission to stay, subject to the applicable conditions and immigration route;
- Scale-up Worker and Seasonal Worker sponsors must hold an A-rating to assign a Certificate of Sponsorship;
- a B-rated sponsor cannot add a new sponsorship route or branch during the action-plan period;
- a downgrade can affect key personnel and SMS arrangements;
- the current Home Office action-plan fee is £1,579;
- the sponsor will normally have 10 working days to pay the action-plan fee following notification;
- the action plan runs for a fixed three-month period;
- UKVI can undertake further compliance activity to assess whether the required improvements have been made;
- failure to meet the action-plan requirements can result in revocation of the sponsor licence;
- a sponsor can generally only be B-rated and subject to an action plan twice within the relevant rolling four-year period;
- UKVI does not have to downgrade a sponsor before taking more serious enforcement action where the applicable grounds for that action are met; and
- a Provisional rating under the UK Expansion Worker route is different from a B-rating and cannot be downgraded to a B-rating.
For employers, the wider lesson is that sponsor licence compliance should be treated as a continuing business process.
An organisation can remain A-rated for years while its workforce, management structure and HR systems change substantially. Unless its sponsor compliance framework evolves at the same time, weaknesses can develop without being immediately apparent.
The strongest approach is therefore to identify and correct those weaknesses while the organisation remains A-rated rather than waiting for a Home Office compliance intervention.
An A-rating should be treated as an operating condition, not an award. Maintaining it requires ongoing governance, accurate records, effective reporting systems and active oversight of the organisation’s sponsor duties.
Section R: Sponsor Licence Ratings Glossary
| Term | Meaning |
|---|---|
| A-Rating | The standard sponsor licence rating. An A-rated sponsor can generally use its licence normally, including assigning Certificates of Sponsorship where the relevant sponsorship and immigration requirements are met.
An A-rating does not mean the organisation is exempt from compliance action or that UKVI has certified that every aspect of its sponsorship arrangements is compliant. The sponsor remains subject to its continuing sponsor duties. |
| B-Rating | A downgraded sponsor licence rating generally used where UKVI identifies relatively minor breaches that it considers capable of being resolved through an action plan.
The sponsor licence remains in force, but the organisation’s sponsorship activities are restricted while it completes the required remediation. |
| Sponsor Licence Action Plan | A Home Office action plan setting out improvements a B-rated sponsor is required to make to address identified sponsorship compliance deficiencies.
The action plan runs for a fixed period of three months. The current Home Office action-plan fee is £1,579. |
| Certificate of Sponsorship (CoS) | An electronic sponsorship record assigned by a licensed sponsor to an eligible worker for use in connection with an application under a sponsored work route.
A B-rating restricts the circumstances in which an employer can assign a CoS. In particular, a B-rated sponsor generally cannot assign a CoS to sponsor a new worker. |
| Sponsor Management System (SMS) | The Home Office online system used by licensed sponsors to manage their sponsor licence and carry out sponsorship functions, including assigning Certificates of Sponsorship and reporting relevant changes. |
| Authorising Officer | The senior person within the organisation with overall responsibility for the sponsor licence and the activities of the organisation’s SMS users.
The Authorising Officer forms part of the sponsor’s key personnel structure. |
| Key Contact | The person who acts as a main point of contact between the sponsoring organisation and UKVI in relation to the sponsor licence. |
| Level 1 User | An individual authorised to carry out day-to-day sponsor management functions through the Sponsor Management System.
Level 1 Users can perform significant functions affecting the sponsor licence, making appropriate selection, access control and oversight important elements of sponsor compliance. |
| Sponsor Duties | The continuing obligations imposed on licensed sponsors under the Home Office sponsorship regime.
These include requirements relating to record keeping, reporting, worker monitoring, compliance with immigration requirements and wider obligations associated with the sponsor licence. |
| Compliance Check | Home Office activity used to assess whether a sponsor is meeting its sponsorship obligations.
A compliance check can involve examination of the organisation’s records, systems, sponsored workers, personnel and processes. UKVI can conduct compliance activity at different stages of the sponsor licence lifecycle, including in connection with a B-rating and action plan. |
| Sponsor Licence Downgrade | A change in the sponsor’s rating from A to B following Home Office compliance action.
A downgrade allows the licence to remain in force but places the sponsor under restrictions and requires the organisation to complete an action plan. |
| Sponsor Licence Suspension | A form of Home Office enforcement action under which the sponsor licence is suspended while UKVI considers compliance concerns and determines what further action should be taken.
Suspension is different from a B-rating and should not be treated as another name for sponsor licence downgrading. |
| Sponsor Licence Revocation | The withdrawal of a sponsor licence by the Home Office.
Revocation is materially different from a B-rating because the organisation ceases to hold the affected sponsor licence. It can also have serious consequences for workers sponsored under that licence. |
| Provisional Rating | A route-specific sponsor rating that can apply in certain circumstances under the UK Expansion Worker route.
A Provisional rating is not a B-rating and does not indicate that an A-rated licence has been downgraded because of compliance failures. A Provisional rating cannot be downgraded to a B-rating. |
Section S: Useful Links
| Resource | URL |
|---|---|
| Home Office: Workers and Temporary Workers – Sponsor Duties and Compliance | https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance |
| Home Office: Register of Licensed Sponsors – Workers | https://www.gov.uk/government/publications/register-of-licensed-sponsors-workers |
| GOV.UK: UK Visa Sponsorship for Employers | https://www.gov.uk/uk-visa-sponsorship-employers |
| GOV.UK: Sponsorship Management System | https://www.gov.uk/uk-visa-sponsorship-employers/sponsorship-management-system |
| Home Office: Immigration and Nationality Fees | https://www.gov.uk/government/publications/visa-regulations-revised-table |
