A Y & J Solicitors Sponsor Licence Revocation (UK 2025 Guide)

Sponsor Licence Revocation (UK 2025 Guide)

A sponsor licence revocation is the permanent withdrawal of an employer’s sponsor licence by UK Visas and Immigration (UKVI) for serious or repeated breaches. Revocation is different from suspension. Suspension is a temporary pause. Revocation is permanent and removes you from the Register of Licensed Sponsors. You cannot sponsor workers again until you reapply after a cooling-off period that is usually 12 months and can be longer for aggravated cases.

What Is a Sponsor Licence Revocation?

Definition: The permanent withdrawal of an employer’s sponsor licence by UKVI for serious or repeated non-compliance with sponsor duties.

Revocation vs suspension:

  • Suspension is a temporary holding position while UKVI investigates.
  • Revocation is a final decision. Sponsorship rights end and CoS become invalid.

Effect on register: The business is removed from the public Register of Licensed Sponsors and cannot sponsor workers until it becomes licensed again after the cooling-off period.


Common Reasons for Sponsor Licence Revocation

Present the causes with real-world context. High-risk sectors in enforcement data include adult social care, hospitality, construction, and retail.

CategoryTypical Breach Examples
Misuse of the systemSponsoring non-genuine vacancies or helping migrants bypass rules.
Compliance failuresPoor record-keeping, missing Appendix D files, failure to report changes via the Sponsor Management System (SMS).
Illegal employmentHiring without valid right-to-work checks or allowing work after permission has expired.
Underpayment or salary breachPaying below the CoS salary or making unlawful deductions, including illegal cost recovery of employer fees.
False informationMisleading data in licence applications or responses during audits.
Criminal offencesUnspent convictions for fraud, immigration offences, or money laundering by the sponsor or key personnel.
Worker exploitationNot providing guaranteed hours or promised work conditions.
Third-party placementActing as an employment agency by supplying sponsored workers to another entity where the route forbids it.

What Happens When a Licence Is Revoked

For employers

  • All sponsorship activity ceases immediately.
  • You are removed from the Register of Licensed Sponsors.
  • Pending visa applications linked to your CoS are refused.
  • Cooling-off period of at least 12 months before reapplication.
  • Reputational and financial impact from disrupted operations and potential penalties.

For sponsored workers

  • Visas are curtailed, typically 60 days from notice.
  • They must find a new licensed sponsor, switch route, or leave the UK.
  • Any outstanding applications linked to your licence are refused.

Revocation → 60-day curtailment → Reapply after 12 months.


Home Office Process for Revocation

  1. Compliance visit or investigation identifies serious breaches.
  2. Suspension notice may be issued first with 20 working days to respond.
  3. Review and decision. If the response does not resolve the breaches, UKVI revokes.
  4. Notification. Licence removed from register. Employees receive curtailment notices.
  5. Cooling-off period applies. Typically 12 months, up to 5 years for serious violations.

Consequences and Risks for Businesses

  • Loss of sponsorship rights. No ability to hire migrant workers under sponsored routes.
  • Operational disruption. Hiring plans stall and projects risk delay.
  • Reputational damage. Appearance on revoked lists undermines confidence.
  • Financial impact. Legal costs, lost talent, and HR overhead.
  • Legal exposure. Civil penalties or criminal liability where illegal working is found.

Licence revoked? Our immigration team can assess grounds to challenge the decision and prepare a remediation and reapplication plan.


Impact on Sponsored Workers

  • Sixty-day grace period is typical, though UKVI may set a shorter remaining time if the visa expires sooner.
  • Workers can find a new sponsor, switch to an eligible route, or depart the UK.
  • Employers should communicate clearly with staff. Provide letters, references, and status guidance to avoid overstaying.

Empathy note for user trust: Revocation affects staff and families. Clear communication and rapid legal guidance protect people and reduce risk.


How to Challenge a Sponsor Licence Revocation

  • There is no formal right of appeal.
  • Judicial Review (JR) is the legal route where the decision is unlawful or procedurally improper.
    • Step 1: Pre-Action Protocol Letter (PAP) setting out the legal challenge and remedy sought.
    • Step 2: Issue JR proceedings in the High Court if unresolved.
  • If JR is unsuitable, focus on remediation and preparation for reapplication after the cooling-off period.

Reapplying After Revocation

To succeed after the cooling-off period you must show genuine remediation.

  • Rectify breaches and map each duty to a control and owner.
  • Internal audits covering HR files, payroll alignment with CoS, and SMS reporting logs.
  • Training for Authorising Officer and Key Personnel with attendance records.
  • Documented policies and evidence of improved systems and governance.
  • Legal representation to prepare a robust application dossier.

Preventing Sponsor Licence Revocation

  • Regular HR and SMS audits with board oversight.
  • Accurate records and reporting within 10 days for worker and company changes.
  • Genuine roles aligned to SOC codes and salary thresholds.
  • Right-to-work checks at onboarding and repeat checks where required.
  • Compliance retainer service for monitoring and mock audits before UKVI visits.

Timeline and Statistics

  • 2024 to 2025 trend reported at about 1,900 revocations, a record high.
  • Enforcement hotspots include adult social care, hospitality, construction, and retail.
  • Typical timeline once suspended: 20-day response window, then decision within four to six weeks in many cases, though complex matters can take longer.

FAQs

What happens if a sponsor licence is revoked?
Your licence is removed, CoS become invalid, and all sponsorship stops. Workers usually receive a 60-day curtailment.

How long is the cooling-off period after revocation?
At least 12 months. It can extend to five years for aggravated breaches.

Can I appeal a revoked sponsor licence?
There is no appeal. You can pursue Judicial Review if there are legal or procedural errors.

What is the difference between suspension and revocation?
Suspension is temporary while UKVI investigates. Revocation is permanent unless you obtain a new licence after the cooling-off period.

What happens to sponsored employees after revocation?
They keep permission for a short period, usually 60 days, to find a new sponsor, switch route, or leave the UK.

Can I reapply for a new licence after revocation?
Yes, once the cooling-off period ends and remediation is evidenced.

What documents does the Home Office review before revoking a licence?
Appendix D records, right-to-work checks, payroll against CoS, SMS reports, contracts, and governance records for key personnel.

Is there a public list of revoked sponsors?
Revoked sponsors are not listed on the register. Removal from the register signals loss of approval. UKVI correspondence confirms your status.

How does revocation affect business reputation?
It harms client confidence, delays hiring, and can impact tenders. Rapid remediation and transparent governance help restore trust.


Addressing Key Pain Points

Pain PointImpactHow This Page Helps
Permanent loss of licenceLoss of hiring capabilityClear distinction between suspension and revocation with reapplication path
Employee uncertainty and 60-day ruleRetention risk and morale dropDedicated worker impact section with next steps
No right of appealHelplessnessPractical route through Judicial Review and PAP timeline
Sector-specific scrutinyHeightened risk in care, hospitality, construction, retailSector call-outs and tailored mitigation tips
Financial riskLost contracts, legal spend, HR overheadConsequences section and value of compliance retainer
Reputational damageClient and investor concernsCommunication planning and remediation narrative
Unclear processConfusion and delayStepwise Home Office process and checklist
Fear of repeat failureAnxiety post reapplicationPreventive audits, training, and controls mapped to duties

Why instruct A Y & J Solicitors

  • Legal 500 recommended UK immigration firm with deep sponsor compliance expertise
  • 5,000 plus cases across sponsor licensing, suspensions, and revocations
  • Defence strategy within strict timelines, including PAP letters and JR assessments
  • Compliance retainers with audits, SMS training, and board-level reporting

Talk to a senior solicitor today for a rapid assessment of revocation grounds and a remediation plan that protects your people and operations.