We recently highlighted the sharp increase in UKVI sponsor licence revocations across the adult social care sector. A detailed article by Sabina Kauser, Corporate Immigration Partner at Ward Hadaway, provides important insight into what is driving this wave of enforcement and what providers should do in response.

You can read Sabina’s full article here:
https://www.linkedin.com/pulse/home-office-crackdown-care-sponsor-licences-what-driving-kauser-axlie/

Below is a summary of the key points.

Revocations at Record Levels

Official Home Office figures show that between July 2024 and June 2025, 1,948 sponsor licences were revoked — more than double the 937 revoked in the previous year and significantly higher than previous years.

Adult social care is among the most affected sectors.

This represents the strictest sponsorship compliance environment the sector has faced to date.

What Has Changed?

1. Intelligence-Led Monitoring

The Home Office is no longer relying primarily on physical compliance visits. Instead, it is using:

HMRC/PAYE payroll data
Sponsor Management System (SMS) activity
Cross-government data-matching tools

This allows UKVI to identify discrepancies remotely — significantly increasing detection of non-compliance.

2. Reduced Tolerance for “Technical” Breaches

Issues that may previously have resulted in warnings — such as late SMS reporting, incomplete HR files, inconsistent right-to-work checks or weak absence monitoring — are now leading directly to suspension or revocation.

3. Mandatory Revocation Confirmed by Court of Appeal

A 2025 Court of Appeal ruling confirmed that where mandatory grounds for revocation are met, the Home Office is not required to consider the impact on the business, staff or service users before revoking a licence.

Sponsorship is legally defined as a privilege, not a right.

4. Wider Enforcement Context

Civil penalties for illegal working increased sharply in February 2024 (up to £45,000 for a first breach and £60,000 for repeat breaches), and enforcement capacity has expanded significantly.

Why Adult Social Care Is Under Scrutiny

The Home Office has identified systemic risks within parts of the care sector, including:

Underpayment of sponsored workers
Roles not matching the Certificate of Sponsorship
Arrangements resembling labour supply to third parties
Vulnerability of workers tied to visa sponsorship

Combined with the sector’s reliance on migrant labour, this has made care a focal point for enforcement.

Common Grounds for Suspension or Revocation

Salaries falling below required thresholds once hours or deductions are considered
“Genuine vacancy” concerns where the job does not match the CoS
Incomplete or inconsistent right-to-work checks
Failure to report role, salary, or location changes
Poor attendance and absence monitoring
Prohibited recoupment of recruitment or sponsorship fees (from 31 December 2024 onward)

Consequences of Revocation

If a licence is revoked:

All Certificates of Sponsorship are cancelled immediately
Sponsored workers’ visas are typically curtailed to 60 days
The provider cannot sponsor new workers
Significant staffing, regulatory and reputational risks arise

The operational impact can be severe and immediate.

Practical Steps for Care Providers Now

Given the current enforcement climate, providers should act proactively:

1. Strengthen Governance and Audit

Appoint a senior compliance lead.
Conduct regular internal audits aligned with UKVI guidance.
Reconcile payroll data against Certificate of Sponsorship details to ensure salary compliance.

2. Standardise Right-to-Work and Onboarding

Use prescribed online or manual right-to-work checks.
Track visa expiry dates.
Ensure contracts and job descriptions align precisely with CoS details.

3. Improve Reporting Discipline

Update the Sponsor Management System promptly for any change in Role, Duties, Salary, Work Pattern and Location
Retain documentary evidence for all reportable updates.

4. Review Supply-Chain and Fee Practices

Prohibit worker-paid recruitment fees.
Do not recoup licence or CoS costs for any CoS issued on or after 31 December 2024.
Avoid any arrangement that could resemble third-party labour supply.

SESCA continues to monitor enforcement trends closely and remains in dialogue with relevant stakeholders. Providers are strongly encouraged to undertake immediate internal compliance checks to mitigate risk.