Sponsor Duties in a New Enforcement Period: Easy methods to Keep Compliant

By Georgina Griggs –
Immigration Barrister

09 Jan 2026

UK companies have lengthy understood that holding a sponsor licence is a privilege, not a proper, however within the present local weather of elevated compliance audits and revocations, correct administration of a sponsor’s duties is extra essential than ever. 

The Dwelling Workplace has confirmed a dramatic escalation in enforcement. Between July 2024 and June 2025, 1,948 sponsor licences have been revoked, greater than double the earlier 12 months’s whole of 937. This large enhance is echoed by the Authorities’s rhetoric on ‘cracking down’ on non-compliant sponsors. 

Subsequently, it’s obvious that the Dwelling Workplace is actively on the lookout for non-compliance, and the tolerance for error seems to be shrinking. In view of this, sponsors needs to be conducting thorough evaluations of their practices to make sure compliance with their duties. 

Sponsor duties are the duties that sponsors should adjust to so as to maintain a sponsor licence. The duties usually are not non-obligatory – they’re circumstances of holding a licence. Broadly, they fall into 4 areas:

1. Document-keeping – retaining prescribed paperwork for the corporate and every sponsored employee (for instance, proper to work proof, contracts, contact particulars, and proof of expertise/{qualifications} the place related).
2. Monitoring and reporting – monitoring attendance, adjustments in function/pay/location, and reporting particular occasions throughout the stipulated strict timeframes via the Sponsor Administration System (SMS).
3. Real emptiness and compliant employment – guaranteeing the job is actual, on the said ability degree, throughout the appropriate SOC code, and paid as required.
4. Cooperation with UKVI – together with responding to queries, permitting inspections, and being candid if points come up.

The duties apply from the second a sponsor’s licence utility is granted, and proceed till the licence is surrendered or revoked. The responsibility to adjust to the above is steady – even when the Dwelling Workplace assesses a sponsor’s capacity to conform throughout its utility for a licence, doesn’t imply that it’ll proceed to be thought of compliant. Sponsors have an obligation to make sure continued compliance and failure to take action might end result within the suspension or revocation of the licence. 

Current press bulletins on immigration present that the Authorities is critical about decreasing web migration to the UK and a part of its plan is to revoke sponsor licences from non-compliant sponsors. The rise in revocations isn’t, subsequently, a fluke, however fully purposeful. 

The Dwelling Workplace is conducting extra audits throughout the board, however notably inside ‘in danger’ sectors, corresponding to care, building, hospitality, and different high-volume sponsoring sectors. The Dwelling Workplace, in conducting these audits, is data-sharing with HMRC and Firms Home to establish inconsistencies (notably with pay) so as to decide which sponsors to focus on for audit.

Audits can happen on an introduced or unannounced foundation, although usually we’re seeing most sponsors being audited remotely. On account of this, sponsors ought to all the time be ready for a Dwelling Workplace audit. 

A suspension usually happens the place the Dwelling Workplace suspects breaches and freezes the sponsor’s capacity to assign new CoS whereas it investigates. Sponsors are faraway from the public register throughout suspension, however sponsored staff can proceed working till the licence is both reinstated or revoked. 

Revocation ends sponsorship instantly. Which means any staff sponsored below this licence now not have permission to work. Staff’ permission will then be cancelled to run out in 60 days, by which time they are going to both must make a brand new utility to stay within the UK, or depart. 

The employer might face a cooling-off interval earlier than reapplying, and another licences that the Key Personnel are concerned with could also be affected. 

Past immigration impression, revocations for sponsor licences may create reputational hurt, operational disruption and lack of Key Personnel, contractual danger the place challenge supply relies on sponsored workers, and doubtlessly civil penalties if unlawful working is discovered.

Current caselaw (notably Prestwick Care Ltd & Ors, R (On the Software Of) v Secretary of State for the Dwelling Division [2025] EWCA Civ 184 and Supporting Care Ltd, R (On the Software Of) v Secretary of State for the Dwelling Division [2024] EWHC 68 (Admin)) has proven that the courts are taking the view that there isn’t a obligation for the Dwelling Workplace to train discretion in instances involving critical and necessary breaches. Which means difficult these selections by means of  judicial overview is an uphill route except clear public-law errors could be proven.

Whereas each case activates its info, some frequent failures of compliance duties have arisen in revocation instances, together with:

• Failure to take care of Appendix D paperwork (lacking right-to-work proof, outdated contact particulars, incomplete information);
• Late or absent SMS reporting (e.g., unreported unpaid depart, function adjustments, decreased wage, or worksite strikes);
• Position genuineness issues (staff doing totally different duties than the CoS states; incorrect SOC classification);
• Pay and dealing circumstances points (together with underpayment in comparison with the CoS or immigration wage thresholds); and
• Inadequate Key Personnel oversight (Stage 1 customers with out correct coaching; delegated compliance with no senior accountability).

Usually, these usually are not deliberate failures however are a results of a busy enterprise placing their compliance duties on the again burner. A failure to prioritise sponsor responsibility compliance can, nevertheless, have catastrophic impacts for companies. 

It’s crucial that each one sponsors take the chance to overview their practices and system to make sure that they’re compliant with sponsor duties and stay ‘audit prepared’ always. We suggest working routine inside audits to make sure that any gaps/errors are caught early.  Coaching for Key Personnel and managers can also be important for guaranteeing that workers are conscious of what their sponsor duties truly are, and learn how to comply. 

We’ve additionally seen elevated data sharing between governmental departments, together with Firms Home and HMRC. Which means the Dwelling Workplace is being made conscious of any discrepancies in pay between salaries truly paid and what was said on the CoS earlier than the sponsor has even been requested to offer documentation. Subsequently, monitoring wage charges, hours, and CoS knowledge is crucial as discrepancies in pay can lead to an immigration audit and investigation by the Dwelling Workplace. 

With revocations at report highs, sponsors ought to assume UKVI scrutiny is anticipated at any level, notably within the aforementioned ‘high-risk’ sectors. Sponsors ought to take steps to make sure compliance now. 

For professional recommendation and help in relation to sponsor licence compliance, contact our immigration barristers in London on 0203 617 9173 or by way of the enquiry kind beneath.

9. Continuously Requested Questions