Navigating Home Office Sponsor Compliance Visits: An Employer’s Handbook
A Home Office compliance visit can place an organisation’s recruitment plans, workforce stability and reputation under immediate pressure.
For employers holding a UK sponsor licence, obtaining the licence is only the beginning. Sponsor compliance is a continuous obligation that applies throughout the life of the licence and for as long as the organisation remains responsible for sponsored workers.
This handbook explains why compliance visits happen, what Home Office officers examine, how employers should respond to an unannounced visit and what practical steps HR teams and Authorising Officers should take to protect their sponsor licence.
Legal position reviewed: 4 August 2026.
Why does sponsor licence compliance require continuous management?
A sponsor licence is granted on the basis that the Home Office can trust an organisation to perform an important role within the UK immigration system.
That trust requires the sponsor to:
- monitor the immigration status and attendance of sponsored workers;
- maintain accurate personnel and sponsorship records;
- report specified changes through the Sponsor Management System;
- employ sponsored workers in genuine and eligible roles;
- pay workers correctly;
- comply with wider UK employment and immigration law; and
- cooperate fully with Home Office compliance activity.
These responsibilities begin when the sponsor licence is granted. Responsibility for an individual sponsored worker generally begins when the Certificate of Sponsorship is assigned. The duties continue until sponsorship ends, the licence is surrendered, made dormant or revoked.
Why is audit-readiness now more important?
Home Office enforcement activity has increased substantially.
Between July 2024 and June 2025, the Home Office revoked 1,948 sponsor licences, compared with 937 during the preceding 12 months. Adult social care, hospitality, retail and construction were identified by the government as sectors experiencing particularly high levels of abuse. The Home Office also confirmed that improved intelligence and data-sharing had reduced its reliance on traditional physical visits alone.
Compliance monitoring can now involve:
- an on-site compliance visit;
- a remote digital compliance check by video conference;
- requests for documents or further information;
- checks against applications made by sponsored workers;
- intelligence received from members of the public;
- information from regulators or local authorities; and
- regular comparisons with HMRC payroll information.
The Home Office expressly states that it makes regular checks with HMRC to confirm that sponsored workers are being paid appropriately and in accordance with the Immigration Rules and sponsor guidance.
A sponsor may therefore come under investigation without first receiving a physical visit or an obvious warning.
When do the Home Office carry out sponsor compliance visits?
Home Office compliance activity can take place before or after a sponsor licence is granted.
What is a pre-licence compliance visit?
A pre-licence assessment may take place while the Home Office is considering:
- a new sponsor licence application; or
- an application by an existing sponsor to add another immigration route to its licence.
The officer will normally consider whether:
- the organisation is genuinely operating or trading;
- its HR systems are capable of meeting the sponsor duties;
- the number of workers it intends to sponsor is proportionate to the size and nature of the organisation;
- it can genuinely offer work at the required skill and salary level; and
- there are any concerns that it may pose a threat to immigration control.
An applicant does not need to have perfect or highly sophisticated HR software. It must, however, demonstrate that workable systems are already in place or ready to operate from the date the licence is granted.
What triggers a post-licence compliance visit?
A post-licence visit may be routine, random, intelligence-led or connected to a particular concern.
Common triggers include:
- a significant increase in Certificates of Sponsorship;
- the sponsor reaching an internal Home Office trigger point for the number of workers sponsored;
- a request for an unusually large CoS allocation;
- previous compliance concerns;
- information received from a worker, former employee, competitor or member of the public;
- evidence of possible underpayment;
- discrepancies between the Sponsor Management System and HMRC records;
- unexplained changes in working locations, duties or salary;
- sponsored workers making applications containing inconsistent information;
- regulatory concerns raised by the CQC, HMRC, a local authority or another public body;
- suspected illegal working;
- repeated late or inaccurate SMS reports;
- rapid business growth without corresponding contracts, premises or payroll;
- mergers, acquisitions, TUPE transfers or changes of ownership; and
- sector-specific intelligence indicating heightened risk.
The published caseworker guidance confirms that post-licence visits can follow intelligence about an organisation or the sponsor reaching a trigger point based on the number of workers it has sponsored. Officers assess HR systems, genuine vacancies, salary and skill levels, trading presence and whether the number of CoS requested remains justified.
Why are healthcare, hospitality and retail sponsors under greater scrutiny?
Healthcare, adult social care, hospitality and retail businesses often operate through complex staffing models. Common features include shift work, variable hours, multiple sites, subcontracting, high employee turnover and decentralised management.
These features are not themselves non-compliant. They do, however, create greater scope for discrepancies between:
- the duties stated on the Certificate of Sponsorship;
- the work actually undertaken;
- contracted and actual working hours;
- the salary reported to the Home Office;
- PAYE information submitted to HMRC; and
- the location at which the worker is working.
The government has specifically identified adult social care, hospitality and retail as sectors with high levels of sponsor abuse. Reported concerns include underpayment, failure to provide the work promised and the use of sponsorship to circumvent the Immigration Rules.
What are the main compliance risks for healthcare and care providers?
Care providers should pay particular attention to:
- CQC registration and regulated activity requirements;
- whether the sponsored role is genuinely available;
- the existence of sufficient care contracts or service demand;
- the worker’s actual duties;
- travel time and unpaid working time;
- guaranteed hours compared with hours actually offered;
- salary payments during periods of low demand;
- deductions for accommodation, transport or recruitment costs;
- work carried out at client locations;
- evidence of the worker’s working pattern and location; and
- whether any change in duties, salary or location has been reported.
For jobs in England under occupation codes 6135 and 6136, the sponsor must be carrying out a regulated activity and hold active CQC registration.
Since 22 July 2025, care workers and senior care workers under those occupation codes can no longer generally be sponsored from overseas. The worker must already be in the UK and applying for permission to stay. They must also normally have worked legally for the sponsoring employer in the relevant role for at least three months or fall within the applicable continuous Skilled Worker permission provisions.
Is there still a resident labour market test?
There is no general resident labour market test for the Skilled Worker route.
Sponsors must nevertheless retain evidence showing how each sponsored worker was recruited. Where no advertisement was placed, the employer must be able to explain how the worker was identified and why they were appointed.
Recruitment records help the Home Office determine whether:
- the vacancy genuinely existed;
- the recruitment process was credible;
- the role was created mainly to facilitate an immigration application;
- the worker has the skills or experience required; and
- the duties correspond with the occupation code used.
Appendix D requires sponsors to retain evidence of recruitment activity even where no formal resident labour market test applied.
Can sponsorship and recruitment costs be passed to workers?
Sponsors must exercise extreme caution before requiring a sponsored worker to repay any immigration, recruitment or administrative cost.
The Home Office may revoke a licence where a sponsor recoups, or attempts to recoup:
- the Immigration Skills Charge;
- the Certificate of Sponsorship fee;
- the sponsor licence application fee; or
- specified associated administrative costs.
The prohibition applies according to the route and the relevant dates set out in the sponsor guidance. For Skilled Workers, the restriction on recovering the sponsor licence fee and related administrative costs applies to recovery or attempted recovery on or after 31 December 2024. Similar restrictions have subsequently been extended across other sponsored work routes.
Repayment clauses should therefore be reviewed carefully. A contractual clause does not override the sponsor guidance.
What are the main risks for hospitality and retail sponsors?
Hospitality and retail employers should be prepared to demonstrate that:
- the sponsored job is eligible under the Immigration Rules;
- the correct occupation code has been selected;
- the role is sufficiently skilled;
- the worker is performing the duties described on the CoS;
- the job has not been artificially designed around the worker;
- salary and working hours remain compliant;
- deductions do not reduce relevant pay below the applicable threshold;
- the role is not principally lower-skilled work presented under an eligible job title;
- the worker is not being supplied to a third party as routine labour; and
- the business has sufficient turnover, premises and operational need to sustain the role.
The Home Office can refuse a worker’s application and revoke the sponsor licence where it has reasonable grounds to believe that a job does not exist, is a sham or was created mainly to enable the worker to obtain immigration permission.
Can HMRC data expose salary discrepancies?
Yes.
The Home Office makes regular checks with HMRC to assess whether sponsored workers are being paid in accordance with the Immigration Rules and sponsor guidance. Payroll discrepancies can therefore be identified without a physical compliance visit.
Risk indicators include:
- payments below the salary stated on the CoS;
- irregular or missing payments;
- unexplained changes in gross pay;
- salary paid outside the normal payroll process;
- payments from a director’s personal account;
- excessive deductions;
- unpaid periods that have not been reported;
- discrepancies between payslips and bank transfers;
- fluctuating hours that affect the applicable hourly rate; and
- payments recorded collectively rather than against an identifiable worker.
Appendix D requires evidence of both the amount and frequency of salary payments. The records must allow the Home Office to identify the payment made to each individual sponsored worker. Generic accounting entries such as “staff wages” may not be sufficient.
Automated data matching does not mean that every temporary variance will lead to enforcement. It does mean that employers should be able to explain and evidence any difference promptly.
Can the Home Office visit a sponsor without notice?
Yes.
A Home Office sponsor compliance visit may be announced or completely unannounced. The current caseworker guidance states that visits should normally be unannounced where intelligence, sector risk or previous compliance concerns suggest that this would produce a more accurate assessment.
How much notice will an employer receive?
There is no published minimum notice period and no entitlement to 24 or 48 hours’ notice.
Some announced visits may be arranged with short operational notice, potentially within 24 to 48 hours. Employers should not treat that as a guaranteed preparation period.
The sponsor guidance requires employers to provide Home Office officers with access to premises and sites under their control on demand. This obligation can extend to third-party premises where sponsored workers carry out their duties.
What should HR do when compliance officers arrive?
The organisation should remain calm, professional and cooperative.
The person receiving the officers should:
- Ask to see the officers’ Home Office identification.
- Verify their identities if necessary. The published caseworker guidance confirms that it is reasonable for a sponsor to ask officers to prove their identity and provides for verification through the Home Office.
- Notify the Authorising Officer, Level 1 User, HR lead and legal representative immediately.
- Identify a suitable private room from which the visit can be managed.
- Create a written attendance note recording:
- the officers’ names;
- identification details;
- arrival time;
- purpose of the visit;
- documents requested;
- employees interviewed; and
- departure time.
- Cooperate with reasonable requests for access to relevant premises, workers, systems and records.
- Avoid guessing. Where information is not known, say that it will be checked.
- Do not alter, recreate or retrospectively complete records.
- Keep copies of all documents provided or taken.
- Ask for a copy of any interview record before the officers leave or request that it be provided afterwards.
Refusing access can be treated as non-cooperation and may result in an application being refused or a sponsor licence being revoked. Officers cannot force entry, but refusal should never be used as a method of obtaining time to prepare.
Must every document be immediately available?
Sponsors must be able to provide relevant documents when requested, but the compliance guidance recognises that not every document will always be immediately accessible.
Where a sponsor confirms that a document exists but cannot produce it during the visit, officers may allow a reasonable period for production. The caseworker guidance indicates that this will usually be up to 48 hours, depending on the circumstances. An inability to produce records at once is very different from admitting that the records do not exist.
What will Home Office officers examine during a sponsor compliance audit?
The audit is designed to test both the organisation’s formal systems and how those systems operate in practice.
A written policy will carry limited weight if staff do not follow it.
What personnel and Appendix D records will be inspected?
The Home Office is likely to examine a sample of sponsored-worker files together with the organisation’s wider right-to-work procedures.
Records may include:
- evidence of a compliant right-to-work check;
- evidence of the worker’s immigration status and permission;
- evidence of the worker’s date of entry where required;
- current residential address;
- personal telephone number and email address;
- employment contract or written statement of particulars;
- job description;
- recruitment records;
- evidence of qualifications, experience or professional registration where relevant;
- payslips;
- payroll records;
- bank evidence showing identifiable salary payments;
- records of allowances and deductions;
- attendance records;
- absence and leave records;
- records of work locations;
- evidence of any client contracts;
- evidence supporting changes to the worker’s role, salary or hours; and
- copies of relevant SMS reports.
Records can be maintained electronically or in paper form. There is no prescribed storage system, but the documents must be accessible and capable of being produced to the Home Office. Sponsor records must generally be retained throughout the sponsorship period and until the earlier of one year after sponsorship ends or the date on which a compliance officer examines and approves them. Other employment and right-to-work laws may require longer retention.
KEY AUDIT CHECKLIST
For each sponsored worker, ensure that you can immediately locate:
- a compliant right-to-work check;
- current immigration-status evidence;
- the Certificate of Sponsorship and visa decision;
- the signed employment contract;
- the current job description and occupation code;
- recruitment and selection evidence;
- evidence of required qualifications or registration;
- current address, telephone number and personal email;
- payslips and corresponding bank-payment evidence;
- a clear record of salary, hours, allowances and deductions;
- attendance, sickness, holiday and absence records;
- normal and temporary work-location records;
- copies of relevant SMS reports;
- evidence supporting any change to salary, duties or location; and
- an audit trail showing who checked the file and when.
How will the Sponsor Management System be checked?
The Home Office will compare the SMS record against the worker’s file, payroll information and actual working arrangements.
Changes affecting an individual sponsored worker must generally be reported within 10 working days. Changes affecting the sponsoring organisation must generally be reported within 20 working days, unless a different period applies.
Which worker changes normally require reporting?
Reportable events can include:
- failure to start work within the permitted period;
- more than 10 consecutive working days of unauthorised absence;
- specified periods of unpaid or reduced-pay absence;
- a reduction in salary;
- a material change in job title, role or core duties;
- a change in normal work location;
- termination of employment;
- resignation;
- dismissal;
- redundancy; and
- other route-specific changes.
A change in duties or occupation code may require more than an SMS report. In some circumstances, the worker will require a new CoS and a successful change-of-employment application before beginning the new role.
Which organisational changes require reporting?
These can include:
- a change of trading name;
- a change of registered or trading address;
- opening or closing a branch;
- changes to key personnel;
- changes to ownership;
- mergers, takeovers and demergers;
- TUPE transfers;
- insolvency events;
- changes to relevant registrations or accreditations; and
- significant changes to the nature of the business.
A sponsor licence is not transferable. Corporate restructuring should therefore be reviewed before completion rather than reported retrospectively after the immigration consequences have already arisen.
Will Home Office officers interview sponsored workers?
Yes.
Officers may speak to:
- the Authorising Officer;
- the Key Contact;
- Level 1 or Level 2 Users;
- HR and recruitment staff;
- payroll staff;
- line managers;
- sponsored workers;
- former sponsored workers; and
- other employees encountered during the visit.
The Home Office may continue an unannounced visit even where the Authorising Officer or other key personnel are absent. It may instead speak to a director, owner or other responsible person.
What questions might sponsored workers be asked?
Workers may be asked:
- how they obtained the job;
- whether they paid anyone for sponsorship;
- what duties they perform;
- where they normally work;
- who supervises them;
- what hours they work;
- how much they are paid;
- whether they receive the work and hours promised;
- whether deductions are made from their pay;
- whether they have another job;
- whether they work at client sites; and
- whether their actual duties match the sponsored role.
Any inconsistency between the worker’s account, the CoS, payroll records and the employer’s explanation may require further investigation.
Workers should not be coached to memorise answers. They should understand their genuine employment arrangements and be able to describe them accurately in their own words.
What questions might the Authorising Officer or Level 1 User be asked?
Key personnel may be tested on:
- the organisation’s sponsor-management structure;
- who has access to the SMS;
- how right-to-work checks are performed;
- how visa expiry dates are monitored;
- how attendance and absence are tracked;
- how HR learns about changes to salary, duties or work location;
- who decides whether an SMS report is required;
- how reporting deadlines are calculated;
- how sponsored roles and occupation codes are checked;
- how payroll is reconciled against CoS information;
- how branches and client sites communicate compliance information; and
- how the organisation monitors changes to Home Office guidance.
The Authorising Officer is not expected to perform every administrative task personally. They must, however, exercise genuine oversight and understand how the sponsor system operates within the organisation.
What happens after a Home Office sponsor compliance visit?
The Home Office will review the visit report together with documents, interview records, SMS information, HMRC data and any other relevant intelligence.
The sponsor should be notified of the outcome in writing.
What does a satisfactory outcome mean?
Where the Home Office is satisfied that the organisation is meeting its duties, the sponsor will normally retain its A-rating.
There is not necessarily a separate certificate confirming that the organisation has “passed” the audit. Employers should retain the outcome correspondence and continue monitoring compliance.
A satisfactory visit does not prevent a further compliance check in the future.
What is a B-rating and action plan?
Relatively minor breaches that the Home Office believes can be corrected may result in the licence being downgraded from an A-rating to a B-rating.
The sponsor must pay the action-plan fee within 10 working days. Failure to accept and pay for the plan can result in revocation.
While B-rated, the sponsor will generally be unable to sponsor new workers. It may only assign a CoS in the limited circumstances permitted for workers it was already sponsoring.
Action plans are set for a fixed period of three months. At the end of that period, the Home Office will assess whether the required improvements have been made. Failure to meet the plan can result in revocation.
What happens when a sponsor licence is suspended?
The Home Office may suspend a licence where it believes the sponsor is breaching its duties, poses a threat to immigration control or has engaged in conduct inconsistent with the public good.
During suspension:
- the organisation cannot assign any new Certificates of Sponsorship;
- its name is removed from the public register of sponsors;
- it must continue complying with all sponsor duties;
- existing sponsored workers can normally continue working while the investigation remains unresolved; and
- pending sponsored applications may be placed on hold.
The sponsor will normally have 20 working days from the date of the suspension notification to provide written representations and supporting evidence. There is no oral hearing. The response should therefore address every allegation fully and include all material evidence within the permitted period.
A suspension response should not be treated as a routine explanatory letter. It may determine whether the business retains the ability to sponsor its workforce.
What happens if the sponsor licence is revoked?
Revocation is the most serious sponsor sanction.
The consequences can include:
- immediate loss of the ability to sponsor workers;
- invalidation of unused Certificates of Sponsorship;
- refusal of applications relying on invalidated CoS;
- removal from the public register of sponsors;
- disruption to recruitment and business operations;
- reputational damage;
- reporting to other regulators or enforcement bodies;
- cancellation or shortening of sponsored workers’ immigration permission; and
- a prohibition on applying for a new licence during the cooling-off period.
Where a worker was not complicit in the breach, the Home Office will normally shorten their permission so that they have 60 calendar days remaining, unless they already have 60 days or less. A worker believed to have been knowingly involved may have their permission cancelled immediately.
There is no statutory right of appeal against sponsor licence revocation. A legal challenge may be possible through judicial review where the decision is unlawful, procedurally unfair or irrational, but strict time limits apply.
The normal minimum cooling-off period is 12 months. It may be longer in cases involving repeated revocation, civil penalties, criminal conduct or other serious circumstances.
How can employers create an audit-ready sponsor compliance culture?
Audit-readiness should not depend on one employee or begin only after a visit letter arrives.
An effective compliance framework should include the following measures.
1. Give the Authorising Officer genuine oversight
The Authorising Officer should receive regular information about:
- sponsored-worker numbers;
- CoS assignments;
- upcoming visa expiries;
- SMS reports;
- payroll variances;
- changes of role or location;
- disciplinary and absence issues; and
- planned corporate changes.
2. Centralise sponsorship records
Create one secure electronic file for each sponsored worker, using a consistent naming structure and checklist.
Documents stored across personal inboxes, payroll software, branch computers and paper files are more likely to be missed during an audit.
3. Reconcile payroll against the CoS
At least monthly, compare:
- annual salary;
- hourly rate;
- contracted hours;
- actual gross pay;
- unpaid absence;
- allowances;
- deductions; and
- the information stated on the CoS.
Any discrepancy should be investigated immediately and, where required, reported through the SMS.
4. Introduce a change-reporting workflow
Managers should not change a sponsored worker’s duties, location, working pattern or salary without first notifying HR.
Create an internal form requiring management to confirm whether a proposed change affects:
- salary;
- occupation code;
- core duties;
- hours;
- work location;
- client deployment; or
- reporting obligations.
5. Audit all right-to-work checks
Check that:
- the correct Home Office service was used;
- the check was completed before employment began;
- the photograph was verified;
- the permitted work was considered;
- the evidence is dated and retained;
- follow-up checks are diarised where required; and
- the process covers both sponsored and non-sponsored employees.
Appendix D now expressly requires sponsors to retain right-to-work evidence for workers they sponsor even where the sponsor is not the worker’s direct employer.
6. Review recruitment evidence
Each sponsored-worker file should explain:
- how the vacancy arose;
- whether it was advertised;
- where and when it was advertised;
- who applied;
- how candidates were assessed;
- why the sponsored worker was selected; and
- why the role and occupation code are appropriate.
7. Train managers and sponsored workers
Line managers should understand that seemingly ordinary decisions can have immigration consequences.
Training should cover:
- absence reporting;
- changes in duties;
- changes in location;
- salary and hours;
- secondary employment;
- remote working;
- client-site work; and
- escalation to HR.
Sponsored workers should understand their genuine job description, salary, reporting lines and obligation to keep the employer informed of changes to their contact details and immigration position.
8. Run regular mock compliance audits
A mock audit should test:
- document availability;
- accuracy of the SMS;
- payroll compliance;
- key-personnel knowledge;
- sponsored-worker interview readiness;
- recruitment records;
- corporate reporting; and
- whether practice matches written policy.
The audit should use a representative sample of files, including:
- recent recruits;
- long-serving sponsored workers;
- workers who have changed salary or location;
- workers with periods of absence;
- employees at branch or client sites; and
- workers whose sponsorship is approaching expiry.
9. Review corporate changes before implementation
Seek immigration advice before:
- selling the business;
- acquiring another company;
- transferring employees under TUPE;
- changing direct ownership;
- restructuring group companies;
- closing or opening sites;
- changing the employing entity; or
- moving sponsored workers between group companies.
Some changes can cause the existing sponsor licence to become invalid even though the trading business appears to continue.
10. Monitor changes to the sponsor guidance
Home Office guidance changes frequently. Sponsors should record:
- when the guidance was reviewed;
- who reviewed it;
- what changed; and
- what amendments were made to internal systems.
How can our we help?
Sponsor compliance problems rarely remain confined to one missing document. A payroll issue may expose an incorrect CoS. An unreported change of duties may reveal an occupation-code problem. A corporate restructure may affect the validity of the entire licence.
Our business immigration team can assist with:
- sponsor licence compliance reviews;
- independent mock Home Office audits;
- Appendix D file audits;
- right-to-work process reviews;
- payroll and salary reconciliation;
- SMS reporting audits;
- key-personnel and HR training;
- sponsored-worker interview preparation;
- occupation-code and genuine-vacancy reviews;
- compliance software and workflow implementation;
- care-sector compliance;
- preparation for announced visits;
- urgent advice during unannounced visits;
- responses to post-visit information requests;
- B-rating action plans;
- sponsor licence suspension responses;
- revocation challenges; and
- urgent judicial review advice.
Facing an active Home Office investigation?
The first hours following a visit, suspension letter or compliance request can be critical.
Do not:
- submit a rushed explanation;
- retrospectively alter records;
- make unnecessary admissions;
- contact workers with scripted answers;
- ignore payroll discrepancies; or
- allow the response deadline to expire.
Obtain specialist advice immediately so that the allegations, evidence and potential consequences can be assessed before any substantive response is provided.
Speak to a solicitor
Frequently Asked Questions
Can the Home Office conduct an unannounced sponsor compliance visit?
Yes. Compliance visits can be announced or unannounced. Home Office caseworker guidance indicates that unannounced visits are particularly likely where the visit is intelligence-led, connected to sector risk or intended to observe the organisation’s normal working practices.
How much notice does the Home Office give before a sponsor visit?
There is no guaranteed minimum notice period. Some announced visits may be arranged with short notice, but sponsors must be capable of responding to an entirely unannounced visit.
Can I ask Home Office compliance officers for identification?
Yes. It is reasonable to ask officers to provide official identification. Their identity can also be verified with the Home Office where necessary.
Can the Home Office interview sponsored workers without management present?
Yes. Officers may interview sponsored workers and other relevant employees. In some circumstances, a worker may be told that they are not obliged to speak and may stop the interview. Interview evidence may be used when considering suspension, revocation or cancellation action.
Does every sponsored job need to be advertised?
No. There is no general advertising or resident labour market test requirement for Skilled Workers. However, the sponsor must retain evidence of any recruitment undertaken or be able to explain how the worker was recruited.
What is the deadline for reporting a sponsored worker’s change of circumstances?
Most reportable worker changes must be reported within 10 working days. Most reportable organisational changes must be reported within 20 working days, unless the sponsor guidance specifies a different period.
What happens to employees while a sponsor licence is suspended?
Existing sponsored workers with valid permission can normally continue working while the licence is suspended. The sponsor cannot assign new Certificates of Sponsorship, and some pending immigration applications may be placed on hold.
How long does a sponsor licence action plan last?
A Home Office action plan following a B-rating lasts for a fixed period of three months. The sponsor must demonstrate that all required improvements have been made within that period.
Can a revoked sponsor licence be appealed?
There is no statutory right of appeal against sponsor licence revocation. Depending on the circumstances, the employer may be able to challenge the decision through judicial review.
How long is the cooling-off period after sponsor licence revocation?
The normal minimum cooling-off period is 12 months. It can be longer where the licence has previously been revoked or where the revocation involves specified civil penalties, criminal conduct or other serious circumstances.
How often should an employer conduct a mock sponsor audit?
A full mock audit should normally be conducted at least annually and more frequently for high-volume sponsors, organisations operating across multiple sites and employers in high-scrutiny sectors. Targeted checks should also take place after material changes to payroll, management, ownership, working locations or the sponsor guidance.
Legal disclaimer: This guide provides general information on sponsor licence compliance and does not constitute legal advice. Sponsor duties and Immigration Rules change regularly. Advice should be obtained on the circumstances of the individual organisation before action is taken.
