Sponsor Licence Suspended, Downgraded, or Revoked?

HR systems and record-keeping

Personnel files, contracts, job descriptions, and evidence that sponsored workers are doing the jobs described on their Certificates of Sponsorship.

Right-to-work records

Document checks, copy retention, and follow-up checks for time-limited permission holders.

Genuineness of roles

Whether the roles you're sponsoring actually exist, match the stated occupation codes, and meet the required skill and salary thresholds.

SMS compliance

Your Sponsorship Management System usage, reporting history, and whether changes have been reported within required timeframes.

No new Certificates of Sponsorship

You cannot assign any new CoS while suspended, meaning you cannot recruit or onboard new sponsored workers.

Existing workers are not immediately affected

Sponsored employees already in the UK can continue working during the suspension period.

The Home Office will decide next steps

After reviewing representations, they will either lift the suspension and restore your A-rating, downgrade you to a B-rating with an action plan, or proceed to revocation.

Updating HR and record-keeping systems to meet Home Office standards

Conducting and documenting retrospective right-to-work checks

Filing overdue reports on the Sponsorship Management System

Providing evidence that sponsored workers' roles, salaries, and working conditions match their Certificates of Sponsorship

False or misleading information

Knowingly providing false information in a licence application, or in a Certificate of Sponsorship (CoS), including about skill level, salary, or job requirements.

Loss of UK trading presence

The business is sold, becomes insolvent, goes into liquidation, is struck off the Companies House register, or otherwise stops trading in the UK.

Loss of required registration or licence

Where a business must be registered with, inspected by, or licensed by a regulatory body to trade legally (e.g. CQC, professional regulators) and stops being so registered or licensed.

Underpaying a sponsored worker

Paying a sponsored worker less than stated on their CoS, without properly notifying the Home Office or having a permitted reason for the reduction.

Illegal working / civil penalties

Failing right-to-work checks, employing illegal workers, or being issued civil penalties that remain unpaid once appeal rights are exhausted.

Non-genuine or mismatched roles

Assigning a CoS for a role that doesn't exist, is exaggerated, or doesn't match the actual job the worker performs (occupation code or job description).

Reporting duty failures

Failing to report changes such as a worker's absence, resignation, change of role, or changes to the business (ownership, structure, address) within required timeframes.

Failed action plan (B-rating)

After being downgraded to a B-rating for a minor breach, failing to meet the requirements of the resulting action plan within the specified period (usually 3 months).

Misuse of Certificates of Sponsorship

An SMS user assigning a CoS to themselves or a close relative, or assigning CoS while B-rated to workers not previously sponsored.

No right of appeal

Revocation decisions cannot be appealed, the only route is a legal challenge (e.g. judicial review) or a fresh application after the cooling-off period.

Minimum 12-month cooling-off

You cannot reapply for a licence for at least 12 months (24 months if revoked more than once) from the date of the decision letter.

All CoS become invalid

Every Certificate of Sponsorship you've assigned is automatically invalidated, pending visa applications based on them will be refused.

Sponsored workers' visas curtailed

Workers' permission is typically cut to 60 days (or less), forcing them to find a new sponsor or leave the UK.

Removal from the public register

Your organisation is removed from the Register of Licensed Sponsors, visible to clients, partners, and regulators.

Immediate loss of sponsorship rights

You cannot assign any further CoS in any route while the revocation stands.

A civil penalty notice is issued when the Home Office determines you employed someone without the right to work, or failed to conduct proper right-to-work checks.

Under the mandatory grounds for revocation, unpaid civil penalties (once appeal rights are exhausted) will result in your licence being revoked.

Even where a penalty is paid, the underlying right-to-work failures may separately trigger a compliance visit, suspension, or B-rating downgrade.

Dental practice: self-employment status mistaken for underpayment

Certain regulated professions, doctors, dentists, and similar, can lawfully engage staff on a self-employed basis under a Sponsor Licence, provided the sponsor remains the principal employer. Our client had moved his entire team onto self-employed contracts, including roles such as nurses and administrative staff that cannot lawfully sit outside employed status under sponsorship rules. Because these staff hadn't yet received P60s or filed self-assessment returns, the Home Office read this as evidence the sponsor was underpaying its workers, a mandatory ground for revocation. We successfully demonstrated that staff had in fact been paid on time and at the correct amount under their self-employed arrangements, overturning the Home Office's position. Licence reinstated in 24 days.

Pharmacy: what not to do when applying for a sponsor licence

Not every lesson comes from a courtroom win. This pharmacy client engaged legal support for a Sponsor Licence application, but progress stalled repeatedly on the employer's side, documents were delayed, and their accountant was consistently unresponsive to information requests needed to complete the application. Instructing a lawyer doesn't remove the need for a business, and its accountant, to respond quickly and fully. Delays on the client's side can undo even the strongest legal strategy, and in immigration compliance, missed deadlines have real consequences. Speed and cooperation matter as much as legal strategy.

Laboratory: reinstated despite a Companies House strike-off

This client's licence was revoked after their company was struck off the Companies House register, normally treated by the Home Office as loss of a genuine UK trading presence, a mandatory ground for revocation. However, this didn't reflect the reality of the business's continued lawful operation, and specific regulatory provisions covering this type of licensed activity meant the standard Home Office approach did not properly apply to this case. We argued the revocation was unjustified on this basis. Although reinstatement in circumstances like this runs against typical Home Office practice, we secured it, because the underlying decision was wrong. Licence reinstated.

Rapid response

Specialist immigration solicitors for employers, acting the moment a compliance issue arises, whether it's a visit notice, suspension letter, or revocation decision.

Sector expertise

Experience across healthcare, dental, pharmacy, laboratory, and other regulated sponsor sectors.

Challenging the Home Office

We know when a sponsor licence decision is wrong, and how to prove it, even in cases others walk away from.

Protecting your workforce

We work to protect both your licence and your sponsored employees' immigration status.