How to Keep Your Sponsor Licence: Duties, Home Office Audits and Revocation Risks

Getting a sponsor licence is only the start. To keep it, you must meet a long list of ongoing duties, and the Home Office can check your compliance at any time, with or without notice. If it finds problems, it can downgrade, suspend or revoke your licence. Revocation usually means your sponsored workers lose their right to work for you.

This guide is based on the Home Office sponsor guidance, Part 3: sponsor duties and compliance (version 08/26).

Your Core Sponsor Duties

1. Report Changes on Time

You must report changes through the Sponsor Management System (SMS). The main deadlines are:

• Within 10 working days, changes to a sponsored worker's circumstances, including when they are absent without permission for more than 10 consecutive working days, their salary drops below the level on their Certificate of Sponsorship (CoS), their normal work location changes, or they stop being sponsored (for example, they resign or are dismissed).
• Within 20 working days, changes to your organisation, including changes to key personnel, your address or structure, mergers and takeovers, and insolvency.

2. Keep The Right Records

You must keep specific documents for every sponsored worker, as listed in Appendix D of the sponsor guidance. These include right to work check evidence, contact details, and records of how you recruited for the role. Missing or incomplete files are among the most common problems found during audits.

3. Sponsor Only Genuine Roles That Match The CoS

Your worker's real duties must match the occupation code and job description on their CoS, and they must be paid at least the salary stated. The Home Office will revoke a licence where a sponsored worker is doing a role that does not match the occupation code or job description on their CoS. This is one of the most serious risks for employers.

4. Do Not Pass Sponsorship Costs to Workers

You must not recover sponsorship fees, such as the Immigration Skills Charge or CoS fees, or related administrative costs, from sponsored workers where the guidance prohibits it. The Home Office will normally revoke a licence if it finds you have done this.

5. Carry Out Right to Work Checks

Right to work checks apply to all staff, not only sponsored workers. The civil penalty for employing someone illegally starts at £45,000 per worker for a first breach and £60,000 for a repeat breach within three years.

Home Office Compliance Visits (Sponsor Audits)

The Home Office can visit before it grants your licence or at any point afterwards. Visits can be announced or unannounced. Compliance officers typically:

• Interview key personnel, such as the Authorising Officer and Level 1 users, about your processes
• Inspect HR files and right to work records for sponsored workers
• Interview sponsored workers about their role, hours, pay and location
• Check that the work being done matches the CoS
• Test whether you reported changes on time

Many audit problems come from staff changes, poor handovers, or HR teams who do not know the reporting rules, rather than deliberate breaches.

What Can Happen After An Audit

Downgrade to A B-rating and An Action Plan

If you are downgraded to a B-rating, you cannot assign new Certificates of Sponsorship. To return to an A-rating, you must pay for and complete a time-limited action plan, which currently costs £1,579 and runs for three months. If you do not complete it, your licence may be revoked.

Suspension

If the Home Office suspects serious breaches, it can suspend your licence while it investigates. You are removed from the public register of sponsors and cannot assign new CoS, although existing workers can usually continue working for the time being. You must still meet all your sponsor duties during the suspension. You will be given a deadline to respond, and the quality of that response can decide whether you keep your licence.

Revocation

If your licence is revoked, your sponsored workers' permission will normally be cut short, and they will need to find a new sponsor, switch to another route or leave the UK. You usually cannot apply for a new licence until 12 months after revocation, or 24 months if your licence has been revoked more than once.

Pre-audit Checklist

1. Check every sponsored worker's file against Appendix D and fill any gaps.
2. Compare each worker's real duties, hours, pay and location with their CoS.
3. Review SMS reporting over the past year and identify anything reported late or not at all.
4. Confirm your key personnel details on the SMS are correct and up to date.
5. Check that right to work checks were done correctly, and before employment started, for all staff.
6. Make sure no sponsorship costs have been recovered from workers.
7. Brief key personnel and managers on what to expect if compliance officers arrive unannounced.

If you find a problem, fix it and consider whether it needs to be reported. It is usually better to find and correct a breach yourself than to have the Home Office find it.

Do Sponsor Licences Still Need Renewing?

No. Since April 2024, sponsor licences no longer expire every four years, so there is no renewal application. That also means there is no longer a routine renewal point to review your compliance, so regular internal audits matter more than before.

Source: Workers and Temporary Workers: guidance for sponsors, Part 3 (version 08/26) and the Home Office fees table, September 2026. This article is general information, not legal advice.