Over the past few months, we have seen a significant rise in sponsor licenses being revoked. The message from the Home Office is clear – compliance action is under closer scrutiny than ever before. 

We recently attended a business immigration conference where representatives of the Home Office were in attendance. Figures discussed showed that around 3000 sponsor licenses were revoked in 2025, marking a stark increase compared to previous years. The number of revocations is expected to rise again due to heightened processes within the Home Office. 

Why is Home Office compliance action increasing? 

The Home Office has dramatically improved the way it shares and analyses data with HMRC through bulk data sharing. This includes real-time PAYE information, which allows the Home Office to quickly identify discrepancies and there is a particular focus on where the salary paid does not match the salary stated on a Certificate of Sponsorship (CoS). 

We have also seen HMRC use this enhanced data sharing to learn whether those whose right to work limits them to working 20-hours per week are working more. Our previous blog post covers advising sponsors on the Home Office’s position on sleep-in shifts counting towards the 20-hour limit. 

Home Office representatives have indicated that data sharing is set to expand even further this year. This means it's important for sponsors to ensure they have effective processes in place.

Officials have made it clear that where salary discrepancies are identified – for example, where pay falls below the required threshold – the Home Office is increasingly moving straight to revocation, without suspending the licence first. Though sponsors will be given at least one opportunity to comment before the licence is revoked. Sponsors must respond appropriately within the timeline set by the Home Office. 

What should sponsors do now? 

Here are some practical steps every sponsor should take – ideally sooner rather than later: 

1. Review internal procedures – ensure you have robust systems in place to identify, record, and report changes in pay, location, job role and absences as soon as possible and at least within ten working days
2. Audit sponsored workers’ files – check that all sponsored workers are being paid in line with the correct salary thresholds, have up-to-date HR files, and check whether any changes need to be reported. Unreported changes, such as time spent on maternity leave, resulting in a reduced salary, can cause salary data to appear non-compliant when compared with HMRC records and it flags reporting breaches
3. Review recruitment policies – confirm that the recruitment and onboarding of sponsored workers strictly comply with the Immigration Rules
4. Provide refresher training – offer refresher training to HR teams, key personnel, and line managers so they understand their reporting and record-keeping obligations 

How we are supporting clients 

We have been assisting organisations, in particular in the care sector, to respond to increased Home Office activity, including: 

• Helping a care organisation whose licence was suspended by making representations to the Home Office, which resulted in their licence being reinstated.
• Making representations in relation to how HMRC interpret national minimum wage legislation and in relation to reporting duties.
• Compliance action is also increasing in relation to right to work and illegal working and we have made representations in the last few months, which have resulted in civil penalties being overturned or reduced.
• Assisting clients with making sponsor licence applications and advising them on how to structure their licences to fit their organisational needs and to mitigate risks of compliance issues.
• Delivering training on right-to-work checks and sponsor compliance duties.

For advice on right to work, civil penalties or sponsorship, please get in touch with Hazel Findlay. To find out more about our expertise in this area and learn more about how we can help you, visit our website.