UK Sponsor Licence Compliance: Guide for Employers

UK immigration compliance requires licensed sponsors to adhere to strict statutory monitoring, reporting, and record-keeping duties overseen by the Home Office. Failing to maintain compliant human resources management systems or breaching sponsorship obligations can result in civil penalties of up to £60,000 per illegal worker, licence downgrading, suspension, or immediate revocation. This guide outlines sponsor duties under current UK Visas and Immigration (UKVI) guidance, details the management of Home Office audits, and explains the statutory steps required if a compliance visit or suspension notice arises.

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Key facts

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Core sponsor compliance duties and obligations

Holding a UK sponsor licence is a privilege granted by the Home Office under conditional trust. A sponsor acts as an administrative gatekeeper for UKVI. Employers must maintain adequate human resources practices to prevent abuse of the immigration system. These obligations apply across all sponsored routes, including Skilled Worker, Global Business Mobility, and Scale-up.

For broader context on structural employer duties, read our Essential UK Immigration Guidance for Employers: Compliance, Sponsorship & Right to Work Requirements.

Under Sponsor guidance Part 3: Sponsor duties and compliance, sponsor duties are divided into five core operational areas:

                      ┌─────────────────────────────────────────┐
                      │      Sponsor Compliance Framework       │
                      └────────────────────┬────────────────────┘
                                           │
         ┌──────────────────┬──────────────┴─────┬──────────────────┬──────────────────┐
         ▼                  ▼                    ▼                  ▼                  ▼
┌─────────────────┐┌─────────────────┐┌─────────────────┐┌─────────────────┐┌─────────────────┐
│ Reporting       ││ Record-Keeping  ││ Complying with  ││ Cooperating with││ Wider UK Legal  │
│ Duties          ││ (Appendix D)    ││ Immigration Law ││ the Home Office ││ Compliance      │
│ • 10-day worker ││ • Passports/E-  ││ • Genuine roles ││ • Announced /   ││ • PAYE & NMW     │
│   changes       ││   visas         ││ • Skill/Salary  ││   unannounced   ││ • Sector-specific│
│ • 20-day org    ││ • RTW checks    ││   thresholds    ││   audits        ││   regulations   │
│   changes       ││ • Payroll / NI  ││ • Ban on recoup-││ • Employee      ││   (e.g., CQC)   │
│ • SMS updates   ││ • Tracking logs ││   ing ISC       ││   interviews    ││                 │
└─────────────────┘└─────────────────┘└─────────────────┘└─────────────────┘└─────────────────┘

1. Reporting duties

Sponsors must record specific events on the Sponsorship Management System (SMS) within statutory windows:

• Worker-related events (within 10 working days):
  • Failure of a sponsored employee to report for work on their contracted start date, with the reason given (e.g., travel disruption, illness).
  • Unauthorised absences lasting more than 10 consecutive working days without employer permission.
  • Resignations, dismissals, redundancies, or early terminations of contracts.
  • Changes in role, job title, core duties, or primary work location.
  • Reductions in salary from the level stated on the Certificate of Sponsorship (CoS), which is only permissible under specific grounds outlined in the Immigration Rules (such as parental leave or statutory sick leave).
  • Significant alterations in sponsorship conditions, such as a worker moving to a different immigration route (e.g., switching to Indefinite Leave to Remain or a Spousal Visa).
• Organisational events (within 20 working days):
  • Changes in company name, trading name, registered address, or operating sites.
  • Changes in company ownership, mergers, acquisitions, sales of divisions, or insolvency proceedings.
  • Alterations to appointed Key Personnel (Authorising Officer, Key Contact, or Level 1 Users).
  • Significant changes in operating status, such as loss of regulatory registrations, mandatory trade licences, or accreditation.

2. Record-keeping duties

Sponsors must retain comprehensive records for every sponsored worker as specified in Appendix D: Keeping records for sponsorship. Employers must retain these documents throughout the period of sponsorship and for at least one year after sponsorship ends, or until a UKVI compliance officer has inspected and approved them.

3. Complying with immigration laws

Sponsors must employ only individuals who are legally entitled to work in the UK and only assign Certificates of Sponsorship to genuine roles meeting the required standard:

• Ensuring all assigned roles align with an eligible Standard Occupational Classification (SOC) code.
• Meeting or exceeding both the general salary threshold and the applicable "going rate" for the specific SOC code under Immigration Rules Appendix Skilled Worker.
• Prohibiting the clawback or unlawful deduction of the Immigration Skills Charge (ISC) from the worker's salary.
• Refraining from assigning a CoS to an individual if the role does not represent a genuine vacancy or involves third-party supply of labour where the sponsor does not retain core management oversight.

4. Cooperating with the Home Office

Sponsors must grant Home Office officials access to all operating premises, provide requested files, and facilitate interviews with personnel and sponsored workers. Failure to cooperate during a compliance inspection is an automatic ground for licence revocation.

5. Wider UK legal compliance

Sponsors must demonstrate compliance with broader employment and statutory regulations:

• Operating PAYE and deducting National Insurance contributions through formal payroll systems (sponsored workers cannot be paid cash-in-hand or classified as self-employed sole traders under Skilled Worker sponsorship).
• Complying with the National Minimum Wage Act 1998 and the Working Time Regulations 1998.
• Holding mandatory sector-specific registrations (such as Care Quality Commission registration for healthcare organisations).

Understanding the fundamental requirements helps employers avoid basic structural errors. For detailed setup procedures, review our guide to Unlock International Talent: Your Complete Guide to UK Visa Sponsorship.

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Specific compliance obligations for the UK care sector

The adult social care sector is subject to intense regulatory oversight by the Home Office. Because care providers frequently sponsor workers under SOC codes 6135 (Care workers and home carers) and 6136 (Senior care workers), compliance officers scrutinise care home operations to detect modern slavery, illegal clawback clauses, or non-genuine vacancies.

                      ┌─────────────────────────────────────────┐
                      │   Adult Social Care Regulatory Matrix   │
                      └────────────────────┬────────────────────┘
                                           │
         ┌─────────────────────────────────┴─────────────────────────────────┐
         ▼                                                                   ▼
┌─────────────────────────────────┐                         ┌─────────────────────────────────┐
│ CQC Registration Verification   │                         │ Operational & Financial Audits  │
├─────────────────────────────────┤                         ├─────────────────────────────────┤
│ • Regulated activity scope      │                         │ • Electronic shift-logging      │
│ • Match registered locations    │                         │ • Mileage & travel pay (NMW)    │
│ • Service-user ratio validation │                         │ • Prohibition of debt bondage   │
│ • Direct operational management │                         │ • Third-party deployment checks │
└─────────────────────────────────┘                         └─────────────────────────────────┘

Statutory registration and scope

Under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, English care providers sponsoring care workers must be actively registered with the Care Quality Commission (CQC) to carry out regulated activities (such as "Personal care" or "Accommodation for persons who require nursing or personal care").

• Providers cannot sponsor overseas care workers for purely non-regulated services (such as basic domestic cleaning, companionship, or unsupported cooking).
• The physical deployment of sponsored workers must align strictly with the locations registered with the CQC and listed on the sponsor’s SMS profile.
• If a care provider loses or surrenders its CQC registration, its sponsor licence will be revoked under mandatory Home Office guidance rules.

Prohibitions on third-party supply of labour

Under Sponsor guidance Part 3, a sponsor must not act as an employment agency or intermediary supplying sponsored workers to third parties on an ongoing or ad-hoc basis:

• A care provider must retain direct, full-time line management, rota allocation, performance assessment, and direct payroll responsibility for its sponsored staff.
• Deploying sponsored care workers to third-party residential facilities where day-to-day work is directed and supervised by that third party violates Home Office sponsorship rules.

Wage compliance, travel time, and clawback clauses

Care providers face specific payroll risks under National Minimum Wage (NMW) rules:

• Travel time and mileage: For domiciliary care workers travelling between clients, travel time counts as working time under the National Minimum Wage Regulations 2015. Failing to pay for travel time or improperly deducting vehicle costs can breach NMW thresholds, triggering immediate sponsor licence suspension.
• Prohibition of debt bondage and unlawful deductions: Employers cannot charge sponsored workers recruitment fees, visa administration fees, or deduct the Immigration Skills Charge from their salaries. Repayment clauses for legitimate training costs must be fair, clearly detailed in employment contracts, and reduce over time rather than imposing disproportionate financial penalties.

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Home Office compliance audits: Pre- and post-licence visits

The Home Office can conduct audits before a sponsor licence is approved (pre-licence audits) and at any time throughout its validity (post-licence audits). These visits assess whether human resources systems are operating effectively in practice.

┌────────────────────────────────────────────────────────────────────────────────────────┐
│                        Home Office Compliance Visit Lifecycle                          │
└───────────────────────────────────────────┬────────────────────────────────────────────┘
                                            │
                                            ▼
                    ┌─────────────────────────────────────────────────┐
                    │  Entry & Notification                           │
                    │  • Announced (short notice) or Unannounced      │
                    │  • Identity check of Compliance Officers        │
                    └───────────────────────┬─────────────────────────┘
                                            │
                                            ▼
                    ┌─────────────────────────────────────────────────┐
                    │  Site Inspection & Verification                 │
                    │  • Office walkthrough                           │
                    │  • Direct physical inspection of workstations   │
                    └───────────────────────┬─────────────────────────┘
                                            │
                                            ▼
                    ┌─────────────────────────────────────────────────┐
                    │  Key Personnel Examination                      │
                    │  • Interview Authorising Officer & Users        │
                    │  • SMS procedures & HR systems interrogation   │
                    └───────────────────────┬─────────────────────────┘
                                            │
                                            ▼
                    ┌─────────────────────────────────────────────────┐
                    │  Sponsored Worker Interviews                    │
                    │  • Private interviews without management        │
                    │  • Cross-examination of pay, duties, hours      │
                    └───────────────────────┬─────────────────────────┘
                                            │
                                            ▼
                    ┌─────────────────────────────────────────────────┐
                    │  Documentation Review (Appendix D)              │
                    │  • Right to Work files                          │
                    │  • Payroll, PAYE, contracts, absence logs       │
                    └───────────────────────┬─────────────────────────┘
                                            │
                                            ▼
                    ┌─────────────────────────────────────────────────┐
                    │  Post-Visit Outcome Determination               │
                    │  • Fully Compliant (Retain A-Rating)            │
                    │  • Minor Deficiencies (B-Rating & Action Plan)  │
                    │  • Severe Breaches (Suspension Notice Issued)   │
                    └─────────────────────────────────────────────────┘

Types of compliance visits

1. Announced visits: UKVI notifies the Authorising Officer via email with a brief schedule and a list of personnel, files, and facilities they intend to inspect.
2. Unannounced visits: Compliance officers arrive unannounced at the organisation's registered office or operating branches during normal business hours. Employers must not turn compliance officers away, as refusing entry will lead directly to licence revocation.

Key personnel assessments

Compliance officers will examine the personnel appointed to manage the licence:

• Authorising Officer (AO): Must be a senior, competent member of staff who oversees sponsorship operations and remains accountable for regulatory compliance.
• Key Contact: The primary contact for UKVI operational matters.
• Level 1 User: The nominated staff member who performs daily management on the SMS.

Compliance officers test whether Key Personnel understand their statutory reporting duties, know where Appendix D records are kept, and retain genuine administrative control over internal processes.

Sponsored worker interviews

Compliance officers will interview sponsored workers privately, without management present. Officers cross-reference workers' statements against details declared on their Certificate of Sponsorship:

• Does their daily routine match the nominated SOC code job description?
• Are actual working hours, shift patterns, and over-time arrangements accurate?
• Does their net pay and gross salary match the figures entered on the SMS?
• Were they forced to pay for their Certificate of Sponsorship or other prohibited employer costs?

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Preparing for an audit: Appendix D document checklist and HR systems

Sponsors must maintain organised and easily accessible files for both sponsored workers and non-sponsored staff (to demonstrate standard Right to Work compliance across the entire business).

                      ┌─────────────────────────────────────────┐
                      │    Appendix D Verification Checklist    │
                      └────────────────────┬────────────────────┘
                                           │
         ┌──────────────────┬──────────────┴─────┬──────────────────┐
         ▼                  ▼                    ▼                  ▼
┌─────────────────┐┌─────────────────┐┌─────────────────┐┌─────────────────┐
│ Right to Work   ││ Employment &    ││ Payroll & PAYE  ││ Attendance &    │
│ Documents       ││ Qualifications  ││ Proofs          ││ Contact Data    │
├─────────────────┤├─────────────────┤├─────────────────┤├─────────────────┤
│ • Online share  ││ • Signed        ││ • Itemised      ││ • Electronic    │
│   code results  ││   contract of   ││   payslips with ││   clock-in /    │
│ • Valid stamped ││   employment    ││   PAYE data     ││   rota records  │
│   passport      ││ • Full job      ││ • Matching bank ││ • Sickness logs │
│   copies        ││   description   ││   statements    ││ • Annual leave  │
│ • Expiry alerts ││ • Degrees /     ││ • Real-Time     ││   tracking      │
│   and re-checks ││   mandatory     ││   Information   ││ • UK address,   │
│                 ││   certificates  ││   (RTI) records ││   phone, email  │
└─────────────────┘└─────────────────┘└─────────────────┘└─────────────────┘

Mandatory Appendix D document checklist

To prepare for an internal audit or a Home Office inspection, verify that every sponsored worker's physical or electronic folder includes the following records:

• Proof of Right to Work:
  • Downloaded PDF verification results from the Home Office online Right to Work checking service (generated using the worker's share code and date of birth).
  • Valid passport biographical pages and entry clearance vignette stamps (where applicable).
• Employment contracts and job descriptions:
  • Fully executed, signed, and dated contracts of employment stating working hours, salary, and holiday entitlements.
  • Comprehensive job descriptions matching the approved SOC code.
• Payroll records and payment verification:
  • Detailed, itemised monthly payslips showing gross pay, net pay, PAYE income tax deductions, and National Insurance.
  • Matching corporate bank statements demonstrating direct salary transfers to the worker's personal bank account.
  • HM Revenue & Customs (HMRC) Real-Time Information (RTI) submissions linking the worker's National Insurance Number to the sponsor.
• Qualifications, professional registrations, and references:
  • Certified copies of mandatory educational certificates, degrees, or vocational diplomas.
  • Evidence of valid professional registration (e.g., General Medical Council, Nursing and Midwifery Council) where required by law.
  • Pre-employment references and background checks (such as enhanced DBS disclosures).
• Attendance and absence tracking records:
  • Clock-in logs, biometric records, timesheets, or digital shift-management records.
  • Sickness records, statutory sick pay documentation, and medical certificates.
  • Approved annual leave requests and holiday approval records.
• Worker contact details and UK address history:
  • Up-to-date residential address, personal mobile telephone number, and home email address.
  • Historic address log documenting any domestic relocations during employment.

For details on managing non-standard working arrangements, read our analysis on New Right to Work Requirements for Gig Economy Workers: What UK Employers Must Know in 2025.

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What happens when a compliance visit goes badly?

If a compliance visit reveals administrative or operational breaches, the Home Office will escalate enforcement action. Sponsors usually receive a written outcome notice within a few weeks of the inspection.

                      ┌─────────────────────────────────────────┐
                      │    Compliance Audit Outcomes Workflow   │
                      └────────────────────┬────────────────────┘
                                           │
         ┌─────────────────────────────────┼─────────────────────────────────┐
         ▼                                 ▼                                 ▼
┌─────────────────┐               ┌─────────────────┐               ┌─────────────────┐
│ Full Compliance │               │ B-Rating Issued │               │ Licence         │
│ (Retain Rating) │               │ (Action Plan)   │               │ Suspended       │
├─────────────────┤               ├─────────────────┤               ├─────────────────┤
│ • A-rating      │               │ • Minor breaches│               │ • Severe failure│
│   retained      │               │ • Cannot issue  │               │ • 20-day formal │
│ • Allocation of │               │   new CoS       │               │   response      │
│   CoS continues │               │ • £1,476 plan   │               │   deadline      │
│                 │               │ • 3-month cycle │               │ • Risk of total │
│                 │               │                 │               │   revocation    │
└─────────────────┘               └─────────────────┘               └─────────────────┘

Scenario 1: Licence downgraded to a B-rating

If UKVI identifies administrative oversights that do not present a serious risk to immigration control, it may downgrade the licence to a B-rating:

• Consequences: The sponsor cannot assign any new Certificates of Sponsorship to new hires. Existing sponsored workers can continue their employment.
• The Action Plan: The sponsor must sign up to a formal Home Office Action Plan and pay a non-negotiable fee of £1,476.
• Rectification window: The sponsor is given up to three months to correct HR record-keeping systems, clear administrative backlogs, and address reporting issues.
• Outcome: At the end of the three-month period, UKVI reinspects the business. If the sponsor meets the requirements, it is restored to an A-rating. If issues remain unresolved, the licence is revoked.

Scenario 2: Formal suspension of the sponsor licence

When compliance officers identify severe breaches (such as unapproved changes of ownership, unrecorded long-term absences, non-genuine roles, or National Minimum Wage underpayments), UKVI will suspend the licence immediately via formal written notice.

┌────────────────────────────────────────────────────────────────────────────────────────┐
│                      Suspension Response Timeline (20 Working Days)                    │
├──────────────┬───────────────────────────────┬─────────────────────────────────────────┤
│ Stage        │ Timeframe                     │ Key Action Required                     │
├──────────────┼───────────────────────────────┼─────────────────────────────────────────┤
│ Day 0        │ Receipt of Suspension Notice  │ Note receipt date and gather files      │
│ Days 1–5     │ Internal Fact-Finding         │ Audit cited breaches and cross-check    │
│ Days 6–12    │ Evidence Gathering            │ Collate payroll, Appendix D, and rotas  │
│ Days 13–18   │ Representation Drafting       │ Prepare formal legal response bundle    │
│ Day 19–20    │ Formal Submission             │ Submit full legal response to UKVI      │
└──────────────┴───────────────────────────────┴─────────────────────────────────────────┘

Steps to manage a licence suspension notice

1. Identify the response deadline: Sponsors must submit a complete, evidenced response within 20 working days from the date of the suspension letter. Extensions are rarely granted.
2. Review the allegations: The letter will list specific allegations across Annex A, Annex B, or Annex C (such as unnotified changes of work location, unpaid salary levels, or missing Appendix D records).
3. Conduct an internal review: The Authorising Officer must cross-check company records against every allegation to establish whether the issue represents a factual error by UKVI, an administrative delay, or an internal operational failure.
4. Prepare documentary evidence: Collect concrete supporting documents for every point raised—including signed employment contracts, timestamped electronic rotas, and bank-stamped payment confirmations.
5. Draft a structured legal response:
   • Address each allegation systematically.
   • Provide document-backed rebuttals where UKVI has made a factual error.
   • Acknowledge genuine administrative oversights openly, present immediate corrective actions already taken, and provide updated Standard Operating Procedures (SOPs) to prove the error cannot recur.

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Licence suspension and revocation: Impact on business and sponsored workers

A sponsor licence suspension places the entire business under severe commercial and operational constraints. Understanding the legal status of your workforce during this period is essential.

                      ┌─────────────────────────────────────────┐
                      │    Impact of Suspension vs Revocation   │
                      └────────────────────┬────────────────────┘
                                           │
         ┌─────────────────────────────────┴─────────────────────────────────┐
         ▼                                                                   ▼
┌───────────────────────────────────┐       ┌─────────────────────────────────────────────────┐
│ During Active Suspension          │       │ Following Final Revocation                      │
├───────────────────────────────────┤       ├─────────────────────────────────────────────────┤
│ • Existing staff continue working │       │ • Visas curtailed to 60 days                    │
│ • No new CoS can be assigned      │       │ • Workers must secure new sponsor or depart     │
│ • No visa extensions allowed      │       │ • Mandatory 12-month cooling-off period applies │
│ • Licence removed from public SMS │       │ • High commercial disruption & client loss      │
└───────────────────────────────────┘       └─────────────────────────────────────────────────┘

What happens to workers while a licence is suspended?

• Existing employees: Workers already holding valid leave linked to the sponsor can continue working under their existing terms. Their right to work remains valid while the licence is suspended.
• Extensions and new hires: The sponsor cannot assign new Certificates of Sponsorship. Workers whose visas expire during the suspension cannot extend their leave with the employer, meaning they must either find a new sponsor, switch to another visa route, or leave the UK before their visa expires.
• SMS access: Level 1 Users are restricted to read-only access on the Sponsorship Management System and cannot modify worker records or request additional CoS allocations.

To help sponsored staff navigate broader immigration options during operational disruptions, share our guide on Navigating UK Visa Sponsorship: Your Guide to Immigration Success.

What happens if the sponsor licence is revoked?

If UKVI rejects the employer's response, it will issue a formal revocation notice. This decision has serious consequences for both the business and its staff:

1. Curtailment of workers' leave: UKVI will cancel (curtail) the visas of all sponsored employees under Immigration Rules Part 9: Grounds for Refusal. Workers are issued a curtailment letter shortening their permission to stay to 60 calendar days (or the time remaining on their visa, whichever is shorter). During these 60 days, workers must secure sponsorship with an alternative employer, switch to another visa route, or depart the UK.
2. Immediate cessation of sponsorship rights: The employer's name is removed from the public Register of Licensed Sponsors.
3. Mandatory 12-month cooling-off period: The organisation is barred from reapplying for a sponsor licence for at least 12 months from the date of revocation. If the revocation involved serious breaches (such as substantial civil penalties or criminal conduct), the cooling-off period can be extended indefinitely.
4. Legal remedies: There is no statutory right of administrative appeal against a sponsor licence revocation. The only legal remedy is to challenge the decision via Judicial Review in the High Court:
   • Pre-Action Protocol (PAP): The employer must first send a formal Pre-Action Protocol letter to the Home Office, identifying legal errors, factual mistakes, or procedural unfairness in the decision.
   • Judicial Review application: If the Home Office does not overturn the revocation through the PAP process, the employer can apply for permission for Judicial Review within three months of the revocation decision.

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Costs, penalties, and enforcement timelines

The financial and operational costs of immigration non-compliance are substantial. The Home Office enforces civil penalties for illegal employment alongside its sponsor licence controls.

                      ┌─────────────────────────────────────────┐
                      │    Financial Exposure & Cost Matrix     │
                      └────────────────────┬────────────────────┘
                                           │
         ┌──────────────────┬──────────────┴─────┬──────────────────┐
         ▼                  ▼                    ▼                  ▼
┌─────────────────┐┌─────────────────┐┌─────────────────┐┌─────────────────┐
│ Illegal Working ││ B-Rating Action ││ CoS Assignment  ││ Judicial Review │
│ Civil Penalty   ││ Plan Fee        ││ Fees (Loss)     ││ Legal Costs     │
├─────────────────┤├─────────────────┤├─────────────────┤├─────────────────┤
│ • First: up to  ││ • Fixed fee of  ││ • CoS issue fee ││ • Court fees,   │
│   £45,000 / hire││   £1,476 per    ││   forfeited     ││   PAP drafting, │
│ • Repeat: up to ││   plan          ││ • Immigration   ││   and High      │
│   £60,000 / hire││ • Non-refundable││   Skills Charge ││   Court legal   │
│                 ││                 ││   clawback risk ││   representation│
└─────────────────┘└─────────────────┘└─────────────────┘└─────────────────┘

Statutory fines under the Illegal Working regime

Under the Code of practice on civil penalties for unauthorised working (issued under section 19 of the Immigration, Asylum and Nationality Act 2006), civil penalties apply as follows:

• First-time breaches: Up to £45,000 per illegal worker.
• Repeat breaches within 3 years: Up to £60,000 per illegal worker.
• Statutory Excuse defence: An employer avoids civil penalties only if it carried out a valid, documented manual or digital Right to Work check before the employee began work.

Administrative fees and financial liabilities

• Action Plan Fee: £1,476 payable within 10 working days of receiving a B-rating notice.
• Immigration Skills Charge losses: If a licence is revoked, any Immigration Skills Charges paid for workers' future years of employment are forfeited.
• Business disruption costs: A business that loses its licence may face operational downtime, breached commercial contracts, and High Court litigation costs.

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Frequently asked questions

Can care homes still sponsor overseas workers?

Yes, care homes can sponsor overseas care workers, but adult social care providers in England must hold active CQC registration for regulated activities under the Health and Social Care Act 2008. Providers must employ workers directly, pay travel time under National Minimum Wage rules, and ensure roles represent genuine vacancies.

What should we do if an unannounced Home Office compliance audit occurs?

Ask the compliance officers for their identification, alert the Authorising Officer and Level 1 Users immediately, provide a clean and quiet room for the inspection, and cooperate fully. Hand over requested Appendix D records promptly and do not attempt to coach or influence sponsored employees during their interviews.

What happens to our employees if our sponsor licence is suspended?

Sponsored employees can continue working normally for your business under their existing visas while the licence is suspended. However, you cannot assign new Certificates of Sponsorship, sponsor new hires, or extend existing staff visas until the suspension is resolved.

How long do we have to respond to a Home Office suspension letter?

You have 20 working days from the date of the formal suspension letter to submit a written response and supporting evidence. This deadline is strictly enforced by UKVI, making rapid evidence gathering essential.

What is the difference between a B-rating downgrade and a licence suspension?

A B-rating downgrade is issued for minor administrative errors, giving the employer three months and a £1,476 Action Plan to correct its HR systems while retaining active sponsorship. A suspension occurs after serious breaches, placing the licence at immediate risk of complete revocation.

What documents must we retain under Appendix D rules?

Under Appendix D, you must keep Right to Work verification forms, passport copies, signed contracts of employment, job descriptions, detailed payslips, corporate bank statements proving direct payment, HMRC RTI payroll records, and attendance logs. These files must be kept throughout employment and for at least one year after sponsorship ends.

Can an employer recover the Immigration Skills Charge from an employee?

No, sponsors cannot recoup, deduct, or pass on any part of the Immigration Skills Charge or CoS assignment fees to a sponsored worker. Doing so breaches mandatory sponsorship guidance and leads directly to licence suspension or revocation.

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Sources

• GOV.UK: Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance
• GOV.UK: Appendix D: keeping records for sponsorship
• GOV.UK: Right to work checks: employer guidance
• GOV.UK: Penalties for employing illegal workers
• GOV.UK: Immigration Rules Appendix Skilled Worker
• GOV.UK: Immigration Rules Part 9: Grounds for Refusal
• GOV.UK: UK visa sponsorship for employers: Apply for your licence

Written and reviewed by Wesbridge Associates – IAA regulated (Level 1, F202537300). Last reviewed 19 October 2026. Editorial policy

Frequently asked questions

Common questions on this topic, answered by our advisers.

Can care homes still sponsor overseas workers?

What should we do if an unannounced Home Office compliance audit occurs?

What happens to our employees if our sponsor licence is suspended?

How long do we have to respond to a Home Office suspension letter?

What is the difference between a B-rating downgrade and a licence suspension?

What documents must we retain under Appendix D rules?

Can an employer recover the Immigration Skills Charge from an employee?