Sponsor licence enforcement: Why employers need to be prepared

Home Office enforcement action against organisations with Skilled Worker sponsor licences can include compliance checks, licence downgrades, suspensions and revocations. It is increasing rapidly, creating additional compliance risks for employers that rely on sponsored workers.

The scale of the increase is striking. Home Office data for the 12 months to June 2026 shows that 4,840 Skilled Worker sponsor licences were suspended and 4,403 were revoked. That’s more than double the figures for the previous twelve months (2,068 suspensions and 1,828 revocations).

This makes it particularly important for sponsors to ensure that their HR practices and Sponsor Management System (SMS) records accurately reflect what is happening within their organisation.

What sponsor licence compliance issues is the Home Office looking at?

Pay is an increasingly important area. The Home Office has access to HMRC payroll data, allowing it to compare the salary actually reported through PAYE with information provided for sponsored workers, including the salary stated on their Certificate of Sponsorship. A discrepancy may therefore attract scrutiny even without a compliance visit.

Other common sponsor licence compliance failures include:

Failing to carry out prescribed right to work checks, or retain adequate evidence of those checks
Failing to report relevant changes affecting sponsored workers, such as departures and salary variations
Failing to report relevant changes to the sponsoring organisation, including mergers, takeovers and certain changes in ownership
Failing to keep key personnel details and other sponsor licence information up to date

Some breaches can have particularly serious consequences. Depending on the circumstances, the Home Office can downgrade, suspend or revoke a sponsor licence. This can have significant implications for the employer’s entire sponsored workforce, and can also make it harder for the employer to recruit internationally in future.

How can employers reduce the risk of sponsor licence enforcement action?

Prevention remains the best approach. Rather than waiting for the Home Office to raise concerns, sponsors should periodically audit their immigration records and processes. This should include reconciling payroll information against Certificates of Sponsorship and SMS records; checking right to work documentation; reviewing reporting processes for joiners, leavers and people whose employment has changed; and ensuring that records about the organisation and key personnel are up to date.

If the Home Office does take action, employers should act quickly. Any request for information, compliance visit, suspension notice or proposed sanction should be reviewed carefully, with the underlying records checked against the relevant sponsor guidance. Where discrepancies exist, employers should establish precisely what happened and assemble evidence that explains the position before responding.

Enforcement activity is at historically high levels, and the Home Office is increasingly able to identify discrepancies through information held elsewhere in government. Sponsor compliance should therefore be treated as an ongoing governance responsibility rather than a periodic administrative exercise.

If you receive an information request from the Home Office, it’s best to act quickly. Our specialist Immigration team will be happy to guide you.

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