Sponsor licence revocations in the care sector: understanding the Home Office crackdown

The care sector in the UK is increasingly coming under the microscope of one of the most stringent clampdowns on sponsorship compliance in recent years. Official Home Office statistics demonstrate the scale of recent enforcement: between July 2024 and June 2025, a total of 1,948 sponsor licences were revoked – more than double the 937 revoked the previous year, and far above the 261 and 247 revocations recorded in 2021–22 and 2022–23 respectively.

The Home Office continues to identify systemic vulnerabilities within parts of the sector, including:

• the underpayment of sponsored workers
• discrepancies between job roles assigned on Certificates of Sponsorship and the duties actually performed
• attempts to use sponsorship to circumvent immigration controls
• lack of genuine vacancy
• the heightened vulnerability of workers whose immigration status is tied to their employer.

Given the sector’s reliance on an international workforce and persistent recruitment pressures, adult social care remains an unrelenting priority area for regulatory intervention.

Reflecting this, the Home Office has moved decisively away from physical in-person audits and inspections in favour of extensive intelligence led, data‑driven enforcement with matching across HMRC/PAYE records, Sponsorship Management System activity, and other government intelligence systems increasing. This digital, desk-based approach has higher accuracy and a clearer evidence basis. An ability to leverage AI for analytics is quicker and easier to resource and has significantly enhanced the ability to identify inconsistencies and signs of non‑compliance within sponsoring organisations.

At the same time, the government has adopted a far more robust stance on compliance failures. Issues once considered more minor – such as late reporting, incomplete HR records, inconsistent Right to Work checks, or weak absence monitoring – now carry serious consequences. Sponsors increasingly face immediate suspension or even licence revocation for breaches which might previously regarded as ‘technical’. This stricter stance forms part of a broader enforcement strategy: civil penalties for illegal working now stand at £45,000 for a first breach and £60,000 for subsequent breaches, with penalty volumes reaching record highs in 2025 due to increased enforcement capacity and system automation.

The enforcement process

We are seeing a rise in incidents where the Home Office has contacted care businesses, seemingly out of the blue, to request further information. Typically, this is pay-related queries as payroll data is being shared between HMRC and the Home Office and uncovering breaches in sponsor reporting.

Request for Information

Sponsors are typically given just ten working days to reply to the Home Office request for further information when an investigation is underway. Given the large volume of data requested and the fact that data has to be shared via size limited email attachment only, this can require a lot of resource and staffing from different areas of the business. Concerns are also often raised by organisations hesitant to share large amounts of sensitive employee data without password protection or encryption. This has been raised with the Home Office as a concern from a data protection perspective but currently Home Office infrastructure doesn’t enable alternative more secure data sharing methods.

Enforcement

Where licence breaches are identified, the Home Office has two courses of action it can take.

Suspension

• Invoke a licence suspension. This will be accompanied by the sponsor being subject to an Action Plan.
• Businesses have to pay a fee to accept being subject to the action plan which is payable within 10 working days.
• Sponsors are subject to a maximum three-month action plan where significant improvement has to be made to come fully back into compliance. An action plan can either be passed and the sponsor licence is fully reinstated, or if the sponsor fails to meet the requisite standard the Home Office will move to revocation.

Revocation

• If a breach is severe enough, the Home Office may bypass suspension and move straight to revocation. We have been advised by the Home Office that this is now increasingly common.
• The Home Office is required to issue a notice of intention to revoke. This gives sponsors a 20-working day period where representations can be made to state their case and provide evidence to challenge this course of action.
• Theoretically the Home Office is required to respond to any representations received within a further 20 working days, however it is not uncommon for the Home Office to require more time and to advise that it needs additional time.
• The Home Office will then either respond to confirm its next course of action – typically this will be revocation.

Where a licence is ultimately revoked, the Home Office has confirmed that sponsored workers may continue working for 60 days from the date of their cancellation letter (or until their visa expiry date, if sooner). During this period, they must secure a new sponsor or apply for a different visa route if they wish to remain in the UK lawfully.

Once a revocation decision is issued, there is no right of appeal, and from the date of the notice the organisation immediately loses its ability to sponsor workers or issue Certificates of Sponsorship. While the business may continue trading and may still recruit individuals with an existing right to work (including UK nationals, EEA nationals, and non‑EEA nationals with lawful status), it is barred from making a fresh sponsor licence application for at least 12 months. This cooling‑off period may be extended in cases involving civil penalties or criminal convictions.

There have been a number of legal challenges to revocations of sponsor licences in the care sector with arguments being made in respect of:

• adverse impact on ability to care for patients/care-users
• impact on business ability to continue operating and subsequent adverse consequences for domestic workers
• Home Office not exercising discretion to downgrade the enforcement action taken and sanctions imposed.

A proactive and robust compliance posture

In this heightened enforcement environment, it is more important than ever for care‑sector sponsors to adopt a proactive and robust compliance posture. The surge in licence revocations, the expansion of data‑driven monitoring, and the significantly tougher consequences for even low‑level breaches all reflect the Home Office’s clear intention to drive lasting reform across the sector. Organisations reliant on sponsored workers must therefore ensure their HR systems, reporting processes, and governance frameworks are resilient, well‑documented, and consistently implemented. Consideration may also be given to the implementation of a multi-sponsor model where a group mitigates operating risks by use of multiple licences for subsidiaries.

Although losing a sponsor licence does not prevent a business from operating, the resulting workforce disruption, operational impact, and 12‑month re‑application bar can be severe. Strong compliance is no longer simply best practice – it is essential for safeguarding business continuity, protecting vulnerable workers, and securing long‑term access to the skilled labour on which the sector depends.