Sponsor Licence Revoked? Next Steps for Sponsors

Section A: Has Your Sponsor Licence Been Revoked?

If you’ve received formal notification from the Home Office that your company’s sponsorship licence is at risk of revocation, your next steps will be crucial in determining the resulting impact on your business.

A revoked sponsor licence means your organisation has lost its permission to lawfully employ sponsored workers across all sponsorship visa categories. It is a highly damaging, punitive measure, impacting an organisation’s operations and resulting in curtailed visas for its sponsored employees, who must then find employment with another sponsor or leave the country.

Following revocation, you cannot apply for a new sponsor licence until at least 12 months from the date of revocation. The minimum increases to 24 months if your licence has been revoked on more than one occasion. In specified civil penalty scenarios set out in the guidance, longer periods may apply, including up to 5 years from the date the relevant penalty is paid in full.

Licence revocations are extremely daunting for sponsors and must be handled effectively to maintain any potential for reinstating the licence and avoiding further punitive action.

Given the severe implications of a sponsor licence revocation, it will be important to take immediate legal advice on your options.

You will be required to respond to the notification within the given timeframe, taking into account the grounds for revocation, as stated by the Home Office in the notification letter.

Any decision you make in terms of next steps should be well-informed and based on a specialist assessment of all the facts and circumstances. Any response you make to the Home Office must be evidence-based and should address the allegations that have been made against the organisation.

In some circumstances, it may make better financial and commercial sense to accept the revocation and use the cooling-off period to address the issues that have resulted in the licence being revoked.

This could include developing and implementing HR processes and procedures to ensure compliant practices are in place, as well as delivering training to all relevant internal personnel. Any application for a new sponsor licence will need to evidence that the previous revocation grounds have been corrected and any new licence would be compliant and managed as required by the rules.

Our sponsor licence and compliance specialists are highly experienced with a strong track record in helping organisations deal with a revoked sponsor licence. To discuss your options and next steps, contact us.

Section B: What Does a Sponsor Licence Revocation Mean?

Having a sponsor licence revoked is one of the most severe enforcement actions that the UK Home Office can take against a business that employs migrant workers. It means that the Home Office has identified serious breaches in the company’s compliance with the sponsorship rules and obligations.

Read more about Sponsorship Licences here >>

1. Why Sponsor Licences are Revoked

As a sponsor licence holder, you are required by law to meet a number of duties in relation to the management of your sponsor licence.

The Home Office takes a vigilant approach to immigration enforcement and has powers to revoke a sponsor licence where the organisation has failed to comply with its immigration compliance duties or to engage actively with the Home Office.

Revocations can be used by the Home Office in many different circumstances and usually result from the failure of the sponsor to address issues raised following a sponsor licence suspension or where employers have acted fraudulently and provided false information in their licence application, CoS allocation or on the sponsorship management system.

Poor record keeping is a common breach, particularly if personnel records relating to sponsored workers are not kept up to date.

Failure to notify the Home Office of changes in circumstances, relating both to migrant employees and the organisation, can also trigger punitive action, as can inconsistencies in information relating to the sponsored roles, such as salary and job duties, which should be consistent with the details given on the CoS.

Revocations can also result when an employer has failed to follow the stipulated action plan following a licence downgrade to a B rating.

2. Difference Between Sponsor Licence Suspension and Revocation

It is important to differentiate between a suspension and a revocation.

Suspension is a temporary measure taken when the Home Office identifies potential non-compliance or risks that need further investigation. During suspension you cannot assign any Certificates of Sponsorship (CoS), your entry is removed from the public register of sponsors, and existing sponsored workers with current permission are not affected unless or until revocation follows. A suspension allows time for the company to address the issues, demonstrate compliance, and potentially restore its full sponsorship status.

Revocation is a more serious and final decision following evidence that the business has failed to meet the required standards after an investigation or has committed significant breaches. Revocation removes your licence in all routes. You cannot sponsor any workers and UKVI will normally cancel the permission of any workers you are sponsoring. Your organisation’s details are also removed from the public register. Unlike suspension, revocation is not reversible, and the company must reapply for a new licence if eligible, often after a cooling-off period.

3. Impact of Sponsor Licence Revocation on the Employer

When a sponsor licence is revoked, it means that the Home Office has permanently removed the business’s ability to sponsor migrant workers. Unlike a suspension, where a business still holds the licence pending an investigation, a revocation is final and cannot be reversed through negotiation. The company is immediately stripped of its sponsorship rights, and its details are removed from the public Register of Licensed Sponsors.

The company loses its capacity to employ sponsored workers, which can disrupt projects, affect productivity, and lead to potential financial losses. Clients and partners may also lose confidence in the business’s reliability and compliance standards, damaging its reputation.

4. Impact of a Revoked Sponsor Licence on Employees

Sponsor licence revocation can also have immediate and serious consequences for the organisation’s sponsored workers and those it is in the process of recruiting.

Migrant workers sponsored by the company face immediate uncertainty. UKVI will normally shorten their permission so they have up to 60 days’ permission remaining, or the time left on their current leave if shorter.

A revoked sponsor licence will also impact recruits who have been offered a sponsored role but have not yet started with the company or are still outside the UK.

If a sponsored recruit has been issued a visa but has not yet travelled to the UK, the Home Office will usually cancel their visa once the sponsor licence is revoked, meaning they will not be able to enter the UK to begin employment with the company.

Any unused Certificates of Sponsorship are cancelled and pending applications may be refused. Where a visa has already been issued but the worker has not yet travelled, UKVI may cancel that visa.

5. Can You Appeal a Revoked Sponsor Licence?

There is no right of appeal against revocation. The decision can be challenged only by Judicial Review. If UKVI concludes the revocation was made in error, it can reinstate the licence.

Our sponsor licence specialists have particular expertise in advising on the merits of seeking a reversal or applying for a Judicial Review, guiding sponsors through the process.

Where these options are not available or appropriate, the organisation would be subject to a cooling-off period before it can apply for a new licence.

Section C: Why Are Sponsor Licences Revoked?

The Home Office has strict regulations and standards that businesses must adhere to in order to sponsor migrant workers. Failing to meet these expectations can lead to enforcement action, with licence revocation reserved for the most serious breaches.

1. Circumstances when revocation may follow

UKVI may conduct compliance visits at any stage. Findings that point to serious non-compliance can result in immediate revocation where UKVI considers there is a significant risk to immigration control. Less severe findings may lead to suspension with an opportunity to make representations, but revocation can still follow if the issues are not resolved.

Suspension indicates UKVI has identified concerns that require investigation or remedial action. If the sponsor fails to respond within the timeframe, cannot evidence remediation, or further non-compliance is found, revocation is a likely outcome. Existing sponsored workers may continue during suspension, but the position changes if the licence is revoked.

Where UKVI issues an action plan to remedy specific weaknesses, failure to complete the required steps or meet the deadlines can lead to revocation.

In cases involving deliberate abuse, deception, illegal working or other serious breaches, UKVI may revoke without first suspending the licence.

After any cooling-off period, UKVI may inspect before deciding a new licence application. If previous issues persist or systems remain inadequate, the new application can be refused and the business remains unable to sponsor workers.

Inspectors review documents, interview HR staff and managers, and assess the systems in place for monitoring sponsored employees. Findings can include gaps in right to work checks, incomplete Appendix D records, or undocumented changes to roles, salaries or work locations. Severe breaches can lead to immediate revocation.

2. Grounds for sponsor licence revocation

Common grounds for revocation include:

a. Non-compliance with UKVI regulations

Non-compliance spans a wide range of duties, from maintaining effective HR systems to responding to information requests. Failure to meet the standards during an inspection or to respond adequately to UKVI can justify revocation. Sponsors should maintain procedures that demonstrate compliance at all times.

b. Failure to maintain accurate records and reporting duties

Sponsors must keep complete, up-to-date records for sponsored workers, including contact details, contracts, absences and right to work evidence, and must keep the Sponsorship Management System current. Significant changes to a worker’s job role, salary or work location must be reported within the published deadlines, usually within 10 working days for worker changes. Persistent or serious record-keeping failures are a frequent basis for revocation.

c. Issues related to right to work

All employers must carry out compliant right to work checks on all workers. Employing someone who is not permitted to do the job offered, whether knowingly or through oversight, is a major breach and can lead to revocation. This includes reliance on expired permission, incorrect documents or non-compliant online checks.

d. Breaching sponsorship duties

Sponsored workers must be employed in accordance with the terms on their CoS. Breaches include placing a worker in a role that does not match the SOC code description, failing to monitor attendance, or not reporting prolonged unpaid leave. UKVI treats role drift, unmanaged hybrid working that changes work location, and unreported job changes as indicators of non-compliance.

e. Poor engagement with the Home Office

Ignoring UKVI correspondence, missing deadlines for representations, or refusing reasonable access to premises or records are serious issues. Sponsors should keep contact details current and respond promptly and substantively to all requests.

f. Misuse or abuse of Certificates of Sponsorship

Assigning CoS without genuine vacancies, assigning to roles that do not meet skill or salary thresholds, or creating roles to facilitate migration rather than meet a genuine hiring need are grounds for revocation.

g. Salary and role non-compliance

Pay falling below the stated rate on the CoS or below the threshold for the route, unapproved reductions in hours, or failure to apply the correct going rate for the SOC code can justify revocation.

h. False statements, deception or withholding information
Providing false information in a licence application, during an inspection or on the SMS, or withholding material facts, can lead to immediate revocation.

i. Failure to notify organisational changes
Changes such as mergers, acquisitions, changes of ownership, insolvency events, new trading names or changes to key personnel must be reported within the required timescales. Failure to do so can result in revocation, especially where new controlling parties are unsuitable.

j. Illegal working and civil penalties
Receipt of civil penalties for employing illegal workers can trigger revocation, particularly where multiple penalties or repeat non-compliance are involved.

k. Fitness and suitability concerns
Sponsors and key personnel must be honest, dependable and reliable. Relevant criminal convictions, previous revocations, association with non-compliant sponsors or behaviour not conducive to the public good can lead to revocation.

l. Ceasing to trade or inadequate systems
Where a sponsor ceases trading, lacks appropriate premises, or cannot demonstrate effective HR systems to discharge sponsor duties, UKVI may revoke the licence.

A previous suspension is often a precursor to revocation. Suspension signals serious concerns and gives an opportunity to put matters right within a set timeframe. Failure to meet the action plan or to evidence sustained improvement can move the sponsor from suspension to revocation.

Section D: Actions to Take if Your Sponsor Licence is Revoked

A revoked sponsor licence is a significant and stressful event. The immediate aftermath requires quick, strategic action to mitigate damage, protect business interests, and support affected employees.

Step 1: Assess the Home Office’s Grounds for Revocation

The first step after receiving notification of sponsor licence revocation is to carefully review the communication from the Home Office. The notice will outline the specific reasons behind the revocation and the evidence they have based their decision on.

It is essential to understand these reasons fully as they will guide your next steps and inform you of any possible challenge.

Businesses should pay close attention to whether the breaches involve record-keeping failures, compliance issues, or more severe breaches such as employing ineligible workers. Understanding the nature and scope of these violations helps you determine the most effective response.

Step 2: Take Advice and Review Your Options

Once you have assessed the Home Office’s decision, seeking professional legal advice is highly recommended, given the implications of losing the licence.

Our sponsor licence and compliance specialists can advise on the options open to you in light of the severity of the alleged breaches, the number of sponsored employees that will be affected – as this may be relied on as mitigation to challenge the revocation – and your conduct and that of the Home Office during any investigations.

Your options could include challenging the Home Office’s conduct during the process, seeking a reversal of the decision or reapplying for a new sponsor licence:

a. Home Office Conduct & Procedural Breaches

When the Home Office decides to revoke a sponsor licence, it must follow specific procedural rules to ensure the decision is fair, transparent, and legally sound. These rules include giving the sponsor clear reasons for revocation, detailing the compliance breaches found, and providing evidence that supports its decision. Any deviation from these procedural requirements could provide grounds to challenge the revocation.

We will review the process followed by the Home Office to determine whether the correct procedure was followed and whether the decision was made in accordance with the relevant rules. Issues could include lack of evidence, failure to give adequate notice or general procedural errors.

If it can be shown that the Home Office did not adhere to procedural requirements, there may be grounds to challenge the decision. There is no right of appeal or Administrative Review of a revocation. The only route to challenge the decision is Judicial Review, which must be brought promptly and within the applicable time limits. A judicial review is particularly helpful if there are strong grounds to argue that the revocation was unfairly handled. Our advisers are highly experienced in pursuing procedural challenges in relation to sponsor licence revocations.

b. Reversal

Our experts will assess your case by considering a range of factors which could help to justify a reversal of the Home Office’s decision. For example, from the details given by the Home Office, are they justified in taking the most severe of enforcement measures against your business? If your sponsor licence is revoked, what will be the full impact on your business and the wider economic implications on job security for other non-sponsored workers? Are there any factual errors which can be challenged and corrected through evidence? Where non-compliance is not disputed, how will you rectify the issues?

We support employers in building a strong and compelling response to the Home Office by interviewing members of staff, preparing statements, collating documents, and obtaining documents from other government agencies, such as HMRC, to be able to respond to the allegations that have been made.

c. Applying for a new licence

If the best course of action is to apply for a new licence, the employer should use the cooling-off period to rectify compliance issues and bring the organisation up to the required standards. Training for staff and robust record-keeping will also be essential to include within the new application.

Step 3: Communicate with Affected Employees

Revocation of a sponsor licence directly impacts sponsored employees, as their visas may be curtailed, typically giving them a limited timeframe (e.g., 60 days) to find a new sponsor or leave the UK.

Inform affected employees as soon as possible after the revocation, explaining the situation clearly and being empathetic to their situation, as this will inevitably be devastating news to them.

Outline what has happened and reassure them that the business is taking immediate steps to address the issue.

Offer support such as legal assistance or referral services to help employees understand their options for securing alternative employment or visa arrangements, and share updates as the situation develops.

Section E: Applying for a New Sponsor Licence

Applying for a new sponsor licence is not a simple process; it requires a detailed understanding of the issues that led to the revocation, a robust action plan to address those shortcomings and full compliance with Home Office regulations. This means taking strategic and comprehensive steps to recover their sponsorship privileges.

1. Timeline and Process for Reapplying for a Sponsor Licence

Reapplying for a sponsor licence after revocation typically involves a mandatory cooling-off period. In most cases, this will be a period of 12 months, although the exact duration can vary based on the severity of the non-compliance issues that led to the revocation.

During this time, businesses must focus on addressing any compliance gaps and preparing a thorough reapplication.

Steps for the reapplication process include:

Step 1: Assessing Previous Failures: Review the reasons for the initial revocation and ensure all identified issues have been rectified. Typically, this involves an audit exercise to address all areas of non-compliance.

Step 2: Preparation Period: Use the cooling-off period to implement improvements in compliance practices and documentation.

Step 3: Submitting the Application: Complete and submit a new application for the sponsor licence via the UK Home Office portal. Ensure all required fees are paid.

Step 4: Awaiting Decision: The processing time for a new application can range from a few weeks to several months, depending on the volume of applications and complexity of the case.

2. Compliance Measures

Compliance measures should be strengthened to include:

a. Regular Audits

Establish periodic reviews of HR processes and compliance practices. For reapplication, an audit report demonstrates to the Home Office that the business has taken compliance seriously and has established robust systems to prevent future breaches. It provides a concrete record of measures such as improved HR practices, regular internal checks, and updated staff training—all actions that show lessons have been learned and weaknesses addressed.

b. Training for Relevant Personnel

Ensure staff responsible for sponsorship are fully trained and understand the Home Office regulations. This may mean including personnel outside of the HR department, such as those involved in recruiting and managing sponsored workers.

Training should cover the full scope of the requirements, including the specific duties and responsibilities that come with holding a sponsor licence.

Ongoing refresher courses should also be provided to ensure all relevant personnel stay updated on regulatory changes.

c. Robust Reporting Systems

Implement digital tools or systems to maintain accurate and up-to-date records of sponsored employees.

These systems should be designed to track and record key information such as right to work documentation, visa expiry dates, job roles, salaries, work locations and any changes in employment conditions. These systems reduce the risk of human error and facilitate faster, more accurate responses during audits or in response to Home Office enquiries.

3. Tips to Improve the Chances of Approval

To improve the likelihood of approval, businesses must demonstrate that significant improvements have been made since the revocation. Key strategies include:

a. Enhanced Record-Keeping Practices

Develop and maintain comprehensive employee records that comply with Home Office standards. This includes proof of right-to-work checks and updates on employment changes.

b. Compliance Training and Protocols

Establish mandatory training for HR and management staff involved in sponsorship duties. Document this training to show a proactive approach to understanding and adhering to compliance obligations.

c. Detailed Action Plans

Submit an action plan with the application that outlines the steps taken to address the issues that led to the previous revocation.

Section F: How to Maintain Compliance and Avoid Future Revocations

Once a sponsor licence has been secured, maintaining compliance is critical to avoiding future revocations and ensuring the continuity of employing skilled migrant workers. The UK Home Office holds sponsors to high standards, and any breach of these can lead to severe consequences, including licence suspension or revocation.

HR practices form the backbone of compliance for sponsor licence holders. Maintaining thorough, organised, and accessible records ensures that a company can respond effectively to Home Office audits, which may be unannounced. Key strategies include:

1. Comprehensive Employee Record-Keeping

Keep accurate and up-to-date records for all sponsored employees, including right-to-work documents, contact details, job roles, salaries, and any changes in their employment status. This information should be securely stored but easily retrievable during an audit.

2. Automated Tracking Systems

Invest in HR software that can automate the tracking of key dates such as visa expirations and required reporting timelines. Automation minimises the risk of human error and ensures that the business stays on top of important deadlines.

3. Regular Compliance Audits

A compliance audit is an in-depth review of a business’s processes and practices to ensure adherence to UK Home Office requirements for sponsor licence holders.

The audit should assess key areas such as the SMS, employee records, right to work documentation and reporting procedures, highlighting any gaps or deficiencies in the organisation’s compliance efforts.

For businesses facing licence revocation, a compliance audit is especially valuable as it identifies specific areas of non-compliance and provides a clear framework for corrective action.

Read more about our compliance audits here >>

4. Regular Training for HR Staff on Compliance Requirements

Training is essential to ensure that all relevant staff understand their roles and responsibilities in maintaining compliance. Without proper training, HR and management teams may unintentionally overlook key obligations.

Develop a structured training plan for all HR staff and managers involved in the sponsorship process. This should include initial training when they take on the role and regular updates as regulations change.

Take part in webinars and seminars conducted by immigration experts to stay informed about changes in sponsorship laws and compliance expectations. Our programme of free webinar training is here.

Create detailed guides and resources that outline the procedures and policies related to sponsorship. Make these resources easily accessible to staff and ensure they are updated regularly.

5. Ongoing Review of Sponsorship Obligations

Compliance is not a one-time task; it requires consistent effort and a proactive approach. Regularly reviewing sponsorship obligations helps businesses stay aligned with Home Office standards and ensures that any adjustments needed are promptly made.

Conduct thorough quarterly reviews of all sponsorship-related activities, ensuring that any updates in Home Office regulations are integrated into company practices.

Appoint a compliance officer or a dedicated team responsible for monitoring and managing the company’s adherence to sponsorship duties. This team should act as a liaison with the Home Office and be accountable for all compliance-related documentation.

Regularly check the attendance and performance of sponsored employees to ensure they are fulfilling the terms of their visas. Report any significant changes, such as job role changes, salary adjustments, or unauthorised absences, to the Home Office within the stipulated timeframe.

Section G: Summary

When a sponsor licence is revoked by the UK Home Office, it has significant and immediate implications for employers and their sponsored workers.

A revocation indicates severe non-compliance with sponsorship duties, such as failing to maintain accurate records, not adhering to right to work checks, or employing non-eligible workers. This action results in the permanent removal of the employer’s ability to sponsor migrant workers and leads to the company’s name being removed from the list of licensed sponsors.

The most direct impact is on business operations; employers lose the capacity to recruit or retain skilled international employees, potentially leading to gaps in their workforce. Current sponsored employees may have their visas curtailed, usually within a 60-day period, causing uncertainty and possible job loss for those individuals. This can disrupt projects, damage productivity, and affect team morale.

Licence revocation is also damaging to the employer’s reputation, impacting relationships with clients, partners and employees. In practical terms, revocation can also invite further Home Office scrutiny in the future, making it more challenging to reapply for a new licence after the cooling-off period.

Employers must address these consequences swiftly by assessing compliance failures, supporting affected employees, and seeking legal advice. Implementing corrective measures and reinforcing internal policies is essential to rebuilding trust and ensuring compliance in preparation for potential future reapplication.

Section H: Need Assistance?

DavidsonMorris’ team of specialist UK immigration lawyers bring substantial experience in advising companies facing a sponsor licence revocation.

We can help by:

a. Assisting with understanding the grounds for revocation

b. Advice on collating the supporting evidence

c. Advice on building a response that factors in wider business and economic implications of a revoked sponsor licence

d. Advice on remedial steps to address areas of non-compliance

e. Support in engaging with UKVI

f. Advice and support in relation to Home Office site visits including follow-up guidance

g. Advice on the merits of challenging the decision under Judicial Review

Speak to our sponsor licence specialists for advice on your specific circumstances and the options available to you to deal with a revoked sponsor licence.

Section I: FAQs

What is the difference between a sponsor licence suspension and revocation?
A suspension is a temporary measure imposed when the Home Office identifies potential non-compliance that requires further investigation. During a suspension, a business cannot sponsor new employees but may continue employing current sponsored workers. A revocation, however, is permanent and results in the complete loss of the sponsor licence, halting all sponsorship capabilities.

What happens if my sponsor licence is revoked?
Pending sponsored visa applications will usually be refused, and your existing sponsored workers’ leave will be curtailed. You will lose permission to recruit and employ workers from all visa categories under the licence and the organisation will be removed from the register of sponsors.

Can a business continue to operate after its sponsor licence is revoked?
The business can continue operating, but it cannot employ or sponsor migrant workers. This situation can lead to operational disruptions, particularly if a significant part of the workforce consists of sponsored employees who may need to leave the UK after their visas are curtailed.

Can you appeal a licence revocation?
There is no right of appeal against a decision to revoke a sponsor licence. In limited circumstances, there may be grounds for Judicial Review of the revocation decision.

Can I apply for a new sponsor licence after a revocation?
Following a sponsor licence revocation, the organisation will be prohibited from applying for a new licence for a specified cooling-off period. In most cases, this would be 12 months, but can extend to five years if the breach is sufficiently serious.

How long is the cooling-off period before reapplying for a sponsor licence?
The cooling-off period is typically 12 months, though this can vary depending on the specific reasons for the revocation. This period should be used to address any compliance failures and prepare for a reapplication.

Section J: Glossary

Section K: Additional Resources and Links