Sponsor Licence Revocation UK Guide

A sponsor licence is the Home Office approval that enables UK employers to lawfully sponsor overseas workers. When a licence is revoked, the permission to sponsor is removed across all routes and the organisation is taken off the public register. There is no statutory right of appeal or Administrative Review; the public-law route of challenge is Judicial Review, which is time-sensitive, complex and uncertain. UKVI will normally curtail sponsored workers’ permission, typically allowing 60 days or until the end of their current leave if sooner, to find a new sponsor or depart. Reapplication is barred during a cooling-off period: at least 12 months for a first revocation, 24 months where there has been more than one revocation, and longer in specified civil-penalty or conviction scenarios.

This article explains what revocation means in practice, how it differs from suspension, the common grounds for revocation, immediate actions to mitigate risk, and how to plan a compliant reapplication after the cooling-off period. It also sets out governance measures to prevent repeat breaches, aligned with current sponsor guidance.

• Revocation removes your ability to sponsor workers in all routes and your entry from the public register.
• No right of appeal or Administrative Review; the only route of challenge is Judicial Review.
• UKVI will normally curtail sponsored workers’ permission (typically 60 days or to leave expiry if sooner).
• Cooling-off before reapplying: at least 12 months; 24 months for repeat revocations; longer in certain penalty/conviction cases.
• Unused Certificates of Sponsorship become invalid; pending applications are usually refused; granted visas for recruits who have not yet travelled may be cancelled.
• Early remediation, evidence preservation, and stakeholder communications are critical to risk control and future reapplication strength.

Section A: Has Your Sponsor Licence Been Revoked?

If you have received a Home Office notice indicating your sponsor licence will be or has been revoked, your organisation has lost permission to lawfully sponsor workers across all sponsored routes. From that point, you must stop assigning Certificates of Sponsorship. Your details will be removed from the public register, unused CoS will become invalid, and pending applications based on those CoS are likely to be refused. Where entry clearance has already been granted but the worker has not yet travelled, UKVI may cancel the visa. For sponsored workers already employed, UKVI will normally curtail permission, typically allowing 60 days or until their current leave expires if sooner, to switch to a new sponsor or leave the UK.

Your immediate priorities are to confirm the nature of the notice (final revocation decision versus suspension with intent language), identify the precise grounds cited, and map the operational impact across roles, locations, and contracts. Restrict Sponsorship Management System access to named Level 1 users, preserve evidence (including Appendix D records), and export audit logs. Generate an up-to-date list of sponsored workers and current CoS to coordinate compliant communications and contingency planning with managers and affected workers.

Where revocation is final, you cannot apply for a new licence until the cooling-off period has passed. The default minimum is 12 months from the date of revocation. If the organisation has had more than one revocation (or relevant Key Personnel have been associated with more than one revoked licence), the minimum cooling-off increases to 24 months. In specified civil-penalty scenarios and certain criminal-conviction cases, the bar to reapply can be longer (including up to five years, with time typically running from full payment of the relevant penalty). Any application submitted during a live cooling-off period will ordinarily be refused unless UKVI reinstates the licence on the basis that revocation was made in error.

Given the absence of a statutory appeal, options are narrowly framed. Judicial Review is the court-based remedy in public law and is highly technical and time-sensitive. Parallel to any legal assessment, you should consider whether using the cooling-off window for remediation, training, and systems uplift presents a better commercial and risk-managed route to a strong reapplication.

Section Summary

A revocation removes sponsorship across all routes, triggers invalidation of unused CoS, and will normally lead to curtailment of workers’ permission. There is no appeal or Administrative Review; JR is the only challenge mechanism. A cooling-off period applies before reapplication (12 months minimum; 24 months for repeat revocations; longer in specified scenarios). Immediate steps include evidence preservation, controlled SMS access, impact mapping, compliant communications to affected workers, and a decision on legal challenge versus remediation and future reapplication strategy.

Section B: What Does a Sponsor Licence Revocation Mean?

Having a sponsor licence revoked is one of the most severe enforcement actions UKVI can take against an employer. It signifies that the Home Office has determined serious or repeated breaches of sponsorship duties that are considered incompatible with the continued holding of a licence. Unlike a suspension, revocation permanently removes the organisation’s authority to sponsor across all routes and deletes its entry from the public register of sponsors. It also signals to UKVI that the organisation presents an elevated compliance risk in any future application.

Revocation affects more than the ability to recruit overseas. It disrupts operational planning, contracts, and workforce continuity, with immediate implications for both the business and its sponsored workers. Reputational harm is also likely, as clients, suppliers, and staff become aware of the enforcement action.

1. Why Sponsor Licences Are Revoked

UKVI expects sponsors to meet strict compliance duties. Revocation can follow where UKVI finds breaches during an inspection, intelligence-led enforcement, or a compliance visit, particularly where issues are severe or repeated. Examples include:

– Failure to respond adequately to a suspension action plan.
– Employing individuals who are not entitled to do the job offered.
– Poor record-keeping of Appendix D documentation.
– Failure to notify UKVI of organisational or worker changes within prescribed timescales.
– Assigning Certificates of Sponsorship for non-genuine roles or in breach of salary/skill thresholds.
– Providing false or misleading information on applications, SMS entries, or during inspections.

Where breaches are considered deliberate, deceptive, or a significant risk to immigration control, UKVI may revoke without first suspending the licence.

2. Difference Between Suspension and Revocation

It is important to distinguish between the two enforcement measures:

– **Suspension** is temporary. During this period, the organisation cannot assign CoS, its entry is removed from the public register, but existing sponsored workers’ permission is not normally affected unless revocation follows. The suspension gives the organisation an opportunity to make representations and address concerns.
– **Revocation** is permanent. The licence is removed across all routes, no further CoS can be issued, unused CoS become invalid, pending visa applications are refused, and current sponsored workers’ permission is normally curtailed. The company must wait until the cooling-off period expires before reapplying.

3. Impact on Employers

Employers lose the legal ability to sponsor new or existing migrant workers immediately. Operational disruption is often significant, as sponsored workers leave and recruitment plans collapse. Reputational damage can affect tendering, contract performance, and investor or client confidence. Internally, board-level engagement is usually required to manage the consequences and contingency planning.

4. Impact on Sponsored Workers

For employees already in the UK, UKVI will normally curtail leave to 60 days (or until visa expiry if sooner). During this period, they must find a new sponsoring employer or depart the UK. For those offered roles but not yet employed:

– Any unused CoS are invalidated.
– Pending visa applications will usually be refused.
– If a visa has been granted but the worker has not yet travelled, UKVI normally cancels it.

This leaves affected individuals in uncertainty and can disrupt international relocation plans.

5. Appeal Rights and Legal Challenge

There is no statutory right of appeal or Administrative Review against a revocation decision. The only route of legal challenge is Judicial Review, which tests the lawfulness of UKVI’s decision-making. JR is highly technical, subject to strict deadlines, and offers no guarantee of reinstatement. UKVI may reinstate only if it accepts that the revocation was made in error.

Section Summary

Revocation is a final sanction that permanently removes an employer’s ability to sponsor, with immediate operational and workforce impact. Suspension is temporary and offers an opportunity to remedy issues, but revocation follows if breaches are serious or unresolved. Employers cannot appeal and must either pursue Judicial Review on narrow public-law grounds or accept the cooling-off period before reapplying. The consequences for both business continuity and sponsored workers are severe, making proactive compliance governance critical.

Section C: Why Are Sponsor Licences Revoked?

The Home Office reserves licence revocation for the most serious compliance breaches or where there is a significant risk to immigration control. UKVI operates an escalating enforcement ladder: warning or reporting points, licence downgrades with action plans, suspension, and finally revocation. Where breaches are severe, deliberate, or repeated, UKVI may bypass earlier stages and proceed directly to revocation.

Revocation can follow compliance visits, desk-based audits, or intelligence-led enforcement. Sponsors are expected to demonstrate full compliance with all duties at all times, and failure to do so can result in immediate and permanent loss of licence.

1. Circumstances Leading to Revocation

UKVI undertakes different types of checks:

– **Pre-licence audit**: to assess readiness and systems before issuing a licence.
– **Routine compliance visit**: unannounced inspection to ensure ongoing compliance.
– **Intelligence-led enforcement**: targeted checks where allegations or risks arise.
– **Re-application inspection**: to confirm that previous breaches have been rectified before granting a new licence.

Findings of significant non-compliance during any of these can lead to revocation.

2. Common Grounds for Revocation

Frequent reasons why licences are revoked include:

– **Non-compliance with sponsor duties**: failures in record-keeping, reporting, or systems to monitor sponsored workers.
– **Failure to maintain accurate records**: gaps in Appendix D records such as contact details, contracts, or right to work evidence.
– **Right to work breaches**: employing someone without lawful permission or relying on expired or invalid evidence.
– **Breaching sponsorship terms**: such as role drift, unreported changes to salary or job description, or failing to monitor absences.
– **Ignoring UKVI correspondence**: missed deadlines for responses or obstructing access during visits.
– **Misuse of Certificates of Sponsorship**: assigning for non-genuine vacancies or roles below the skill or salary threshold.
– **Salary and role non-compliance**: paying below the rate stated on the CoS or below the route threshold.
– **False statements or deception**: providing misleading information in applications, inspections, or SMS updates.
– **Failure to notify organisational changes**: including mergers, acquisitions, insolvency, or changes in Key Personnel.
– **Illegal working and civil penalties**: receiving civil penalties for employing illegal workers, especially multiple or repeat breaches.
– **Fitness and suitability concerns**: unspent criminal convictions, previous revocations, or association with non-compliant entities.
– **Ceasing to trade or inadequate systems**: lack of premises, staff, or HR systems to discharge sponsorship duties.

Where an organisation has previously been suspended and fails to rectify issues or comply with an action plan, UKVI will almost always escalate to revocation.

3. Patterns of Non-Compliance

While revocation may sometimes follow isolated serious misconduct, it more often arises from repeated or systemic failings in HR governance. These can include inadequate training for HR staff, poor use of the Sponsorship Management System, or neglecting to keep up with policy changes. Sponsors should assume UKVI may visit without notice and expect them to evidence compliance immediately.

Section Summary

Revocation is usually the outcome of serious or persistent failures in sponsor duties, ranging from poor record-keeping and unreported changes to deliberate deception or employment of ineligible workers. UKVI can revoke immediately in the most serious cases, and sponsors who fail to address concerns raised at suspension stage should expect escalation. Understanding the common grounds for revocation helps employers strengthen governance and reduce enforcement risk.

Section D: Actions to Take if Your Sponsor Licence is Revoked

A sponsor licence revocation is an urgent compliance crisis that requires immediate, structured action. The consequences extend across operations, workforce stability, and regulatory standing. Employers must respond quickly to minimise disruption, support affected employees, and prepare the organisation for either challenge or reapplication.

1. Assess the Home Office’s Grounds for Revocation

The Home Office notification letter sets out the reasons for revocation and supporting evidence. Review this carefully and catalogue the breaches cited, such as record-keeping failures, non-compliance with reporting deadlines, or right to work issues. Understanding the scope and seriousness of these allegations is essential for deciding on next steps.

2. Take Legal Advice and Review Options

Given the absence of appeal rights, professional advice is critical. Options typically include:

– **Procedural challenge**: If the Home Office has not followed correct procedure (e.g. inadequate notice, lack of supporting evidence, or errors in the decision-making process), Judicial Review may be an avenue to challenge lawfulness.
– **Reversal**: In rare circumstances, UKVI may reinstate a licence if revocation is shown to be made in error.
– **Preparation for reapplication**: If revocation is final, use the cooling-off period to remedy weaknesses, improve governance, and build a strong case for a future licence application.

Judicial Review must be lodged promptly, with strict time limits. It is costly, technical, and uncertain, but remains the only public-law remedy.

3. Workforce Contingency and Employee Communication

Revocation directly impacts sponsored workers, whose visas will normally be curtailed to 60 days (or to leave expiry if sooner). Employers should:

– Notify affected staff immediately and transparently.
– Provide information about their options, including switching to a new sponsor.
– Offer reasonable support, such as referrals to immigration advisers or assistance with finding new employment.

Early and empathetic communication reduces distress and helps maintain goodwill with employees during a highly disruptive period.

4. Internal Evidence and Record Preservation

Export audit logs from the Sponsorship Management System, preserve Appendix D records, and retain correspondence with UKVI. These may be needed for legal challenge, future reapplication, or to demonstrate remediation. Restrict SMS access to authorised Level 1 users to prevent accidental or non-compliant actions after revocation.

5. Strategic Remediation During Cooling-Off

Where reapplication is the chosen path, use the cooling-off period productively. Steps include:

– Conducting a comprehensive HR audit to identify and address compliance gaps.
– Redesigning recruitment and onboarding processes to ensure sponsor duties are embedded.
– Training HR staff, recruiting managers, and Key Personnel on sponsorship rules.
– Introducing digital tracking tools to monitor visa expiry, role changes, and reporting deadlines.

Evidence of these improvements will be vital when applying for a new licence.

Section Summary

In the event of revocation, employers should promptly assess the grounds, seek legal advice, and decide whether to pursue Judicial Review or prepare for reapplication. Immediate action is also required to manage workforce impact, including transparent communication with sponsored staff and evidence preservation. Remediation during the cooling-off period is essential to restore compliance credibility and strengthen any future licence application.

Section E: Applying for a New Sponsor Licence

Reapplying for a sponsor licence after revocation is a demanding process. UKVI regards previously revoked organisations as high-risk, meaning scrutiny will be closer and evidential standards higher. Businesses must demonstrate that all previous failings have been rectified and that robust systems are now in place to ensure future compliance. Attempting to apply during a cooling-off period will normally result in automatic refusal unless the revocation is reinstated by UKVI on the basis of error.

1. Timeline and Cooling-Off Periods

The standard cooling-off period following revocation is **at least 12 months**. Where an organisation has had its licence revoked more than once, or where relevant Key Personnel have been linked to multiple revoked licences, the minimum is **24 months**. In certain civil penalty or conviction scenarios, the cooling-off period can be up to **five years**, typically running from the date the penalty is paid in full.

Employers should use this time to implement systemic change and ensure that all compliance obligations can be met consistently in future.

2. Preparing for Reapplication

Preparation should be strategic and comprehensive:

– **Assessing previous failures**: Conduct an audit to identify every compliance gap that led to revocation.
– **Remediation**: Rectify deficiencies by updating policies, redesigning recruitment and onboarding, and tightening oversight.
– **Training**: Ensure HR staff and managers receive full training on sponsorship duties and ongoing refresher courses.
– **Record-keeping systems**: Put in place digital or manual systems to track right to work checks, contract details, salaries, work locations, visa expiry, and absence monitoring.
– **Evidence collation**: Retain documentation of all remedial steps to demonstrate to UKVI that weaknesses have been addressed.

An inspection is likely before a new licence is granted, so the business must be “audit ready” at all times.

3. Demonstrating Compliance to UKVI

UKVI will test whether the business can be trusted again with a licence. Strengthening compliance measures is critical:

– **Independent audits**: Commissioning an external review of HR and compliance systems provides objective evidence of improvement.
– **Governance protocols**: Create a compliance manual for HR and managers, detailing duties and escalation routes.
– **Internal accountability**: Assign a compliance officer or designate responsibility within HR for monitoring sponsorship obligations.
– **Staff training records**: Keep signed attendance sheets or certificates to prove that all relevant staff have undergone compliance training.

Clear documentation and proactive measures will help rebuild trust with UKVI and support approval of a new licence application.

4. Tips for Improving Chances of Success

To maximise prospects:

– Submit a detailed action plan showing how each area of weakness has been addressed.
– Provide evidence of remedial training and new systems, not just policy documents.
– Demonstrate transparent and proactive engagement with compliance — for example, voluntary internal audits and documented governance improvements.
– Ensure Key Personnel meet the “honest, dependable and reliable” requirement and have no history of association with revoked licences.

Section Summary

Reapplying for a sponsor licence is not automatic after revocation. Employers face heightened scrutiny and must wait out a cooling-off period of at least 12 months, 24 months for repeat revocations, or longer for serious breaches. Success depends on a demonstrable programme of remediation, including audits, training, governance protocols, and robust HR systems. Evidence-led preparation is key to persuading UKVI that the organisation is suitable to hold a licence again.

Section F: How to Maintain Compliance and Avoid Future Revocations

Once a sponsor licence has been obtained or reissued, maintaining compliance is a continuous obligation. UKVI expects sponsors to demonstrate ongoing adherence to sponsorship duties, supported by strong HR systems, training, and governance. Even minor breaches can attract enforcement action, and repeat failures can escalate to suspension or revocation. Proactive compliance management is therefore essential to safeguard business operations and workforce continuity.

1. Comprehensive Record-Keeping

Employers must maintain full, accurate, and accessible records for all sponsored workers. This includes:

– Proof of right to work checks.
– Contracts of employment and job descriptions.
– Current contact details.
– Salary and working hours.
– Records of absences and performance monitoring.

Appendix D specifies exactly what must be kept and for how long. Records should be retrievable immediately during a UKVI visit.

2. Automated Tracking and Reporting Systems

Investing in HR software or digital tools can significantly reduce compliance risk. Systems should be capable of:

– Tracking visa expiry dates.
– Monitoring salary thresholds and role consistency.
– Triggering alerts for reporting deadlines.
– Generating compliance reports for internal audits.

Automation supports accuracy, minimises human error, and ensures timely reporting to UKVI.

3. Regular Compliance Audits

Internal or external audits should be scheduled to review HR systems and compliance practices. Key focus areas include:

– Sponsorship Management System records.
– Appendix D document storage.
– Right to work check procedures.
– Reporting of changes in migrant or organisational circumstances.

Audits should be held at least annually, with findings documented and actioned. Independent audits are highly persuasive to UKVI in demonstrating commitment to compliance.

4. Ongoing Training for HR and Management Staff

Training must extend beyond HR to include recruiting managers and any staff who influence sponsored workers’ roles or pay. Training programmes should cover:

– Sponsor duties and UKVI expectations.
– How to conduct and record right to work checks.
– Reporting timelines for role, salary, or location changes.
– Responding to UKVI correspondence and visits.

Refresher training should be conducted quarterly or bi-annually, with attendance recorded as evidence.

5. Embedding Compliance into HR Governance

Compliance must become a routine element of HR operations. Measures include:

– Appointing a compliance officer or designating Key Personnel with accountability.
– Incorporating compliance checks into recruitment and onboarding workflows.
– Documenting compliance policies in an internal handbook, accessible to all relevant staff.
– Holding quarterly review meetings to update policies in line with rule changes.

Embedding duties into everyday processes reduces reliance on reactive measures and ensures continuous readiness for UKVI inspections.

Section Summary

Avoiding revocation requires more than responding to UKVI action; it demands a culture of ongoing compliance. Employers should maintain complete records, implement automated systems, conduct regular audits, and train staff at all levels. By embedding sponsor duties into HR governance, organisations can demonstrate reliability to UKVI, minimise enforcement risk, and protect their ability to employ overseas talent long-term.

Section G: Summary

Revocation of a sponsor licence is the most severe enforcement measure available to the Home Office. It permanently removes an employer’s ability to sponsor overseas workers across all routes, leads to removal from the public register, and usually results in sponsored employees’ permission being curtailed to 60 days or until visa expiry if sooner. Unused Certificates of Sponsorship are invalidated, pending visa applications are refused, and entry clearance already granted but not used for travel is typically cancelled.

The impact on the business is immediate and wide-ranging: operational disruption, reputational damage, workforce instability, and the loss of access to international recruitment. Employers cannot appeal a revocation or seek Administrative Review; the only legal challenge is Judicial Review, which is technical, costly, and time-limited. Otherwise, the organisation must observe the cooling-off period — at least 12 months, 24 months for repeat revocations, and up to 5 years in specified penalty or conviction cases — before reapplying.

Future success depends on robust remediation, documented evidence of compliance improvements, and transparent HR governance. Proactive compliance — through strong systems, regular audits, comprehensive training, and embedding sponsor duties into daily HR practice — is the only effective safeguard against enforcement.

Section H: Need Assistance?

Facing a sponsor licence revocation places your organisation in one of the most challenging compliance situations under UK immigration law. The stakes are high: loss of sponsorship rights, workforce disruption, reputational damage, and barriers to future international recruitment. Taking the right steps immediately can make a critical difference in managing the risks.

Specialist legal and compliance support can help you to:

– Understand the specific grounds for revocation and assess the Home Office’s evidence.
– Collate and preserve relevant records to protect your legal and compliance position.
– Develop a strategy for responding, whether through Judicial Review or preparation for reapplication.
– Design and implement remedial systems to address compliance failings.
– Support communication with affected sponsored workers and guide workforce contingency planning.
– Prepare for potential Home Office audits during any future application.

Employers confronted with revocation should seek tailored advice to determine the most effective course of action in their circumstances, ensuring that both immediate and long-term business risks are managed.

Section I: FAQs

What is the difference between a sponsor licence suspension and revocation?

A suspension is a temporary measure imposed when UKVI identifies potential non-compliance. During suspension, no new Certificates of Sponsorship can be assigned and the sponsor is removed from the public register, but existing workers’ permission is not normally affected unless revocation follows. Revocation is permanent and results in complete loss of the licence, invalidation of CoS, refusal of pending applications, and curtailment of existing workers’ permission.

What happens if my sponsor licence is revoked?

The organisation loses all rights to sponsor workers under any route. Sponsored workers’ permission will normally be curtailed to 60 days (or to leave expiry if sooner). Pending visa applications are refused, unused CoS become invalid, and entry clearance granted but unused is usually cancelled.

Can a business continue to operate after its licence is revoked?

Yes, but without the ability to employ or sponsor migrant workers. If a significant proportion of the workforce is sponsored, operational disruption is likely, affecting service delivery, contracts, and workforce planning.

Is there a right of appeal against revocation?

No. There is no statutory appeal or Administrative Review. The only challenge route is Judicial Review, which examines whether UKVI acted lawfully in making the decision.

When can we reapply for a sponsor licence after revocation?

A cooling-off period applies. This is normally at least 12 months, but rises to 24 months where the organisation (or associated Key Personnel) has been involved in more than one revocation. In some civil penalty and conviction cases, the period can extend up to 5 years.

What should we do during the cooling-off period?

Use the time to remediate compliance systems, train HR and management staff, commission independent audits, and prepare evidence to show that failings have been addressed. UKVI will apply closer scrutiny to any future application.

Section J: Glossary

Section K: Additional Resources and Links