Skip to content
Working with care providers across England

Services · Workforce

How exposed is your sponsor licence?

Eight questions on the duties that actually get licences revoked. Not the ones in the guidance you were sent when you applied — the ones the Home Office is currently acting on.

Current at September 2026. England.

4,403Skilled Worker licences revoked in the year to June 2026 — the highest in any 12 months since 2020
872Care sector licences revoked since 2022 — the largest single sector, ahead of hospitality, retail and construction
3.4%Of displaced sponsored care workers who found new sponsored employment
Why a licence is now an asset you cannot replace. Overseas recruitment of new care workers closed on 22 July 2025. What remains is in-country only: switching a worker who has already worked for you in these roles for at least three months, or taking on someone who already holds Skilled Worker permission in them — and the first of those routes closes for good on 22 July 2028. There is no reapplying your way back in. Lose the licence and, on the published data, your sponsored staff are very unlikely to be rematched anywhere.

The eight

01

Is every sponsored worker actually doing the job on their Certificate of Sponsorship?

The single most dangerous question on this page. A worker doing a role that does not match the occupation code or job description on the CoS is a mandatory ground for revocation — not discretionary, not a warning first.

Yes — and I could evidence it from rotas and job descriptions todayDefensible
Broadly, but people cover other duties when we are shortExposed
We have sponsored staff working across more than one service or roleAct now
The configuration to check firstIf you hold both a CQC registration and an Ofsted registration, a sponsored care worker must actually be working in the care role at the CQC-regulated service. Drifting them into the children's service, even helpfully, even occasionally, is the mismatch. Compliance officers interview sponsored workers precisely to test what the job really is.
02

Does everyone clear the hourly floor, in every pay period?

Two thresholds apply, and both must be met — the annual figure and the hourly one. The hourly rate bites independently: a worker on the annual minimum who is rostered above full-time hours falls below the hourly floor even though the salary looks right.

RouteAnnualHourly
Health and Care Worker visa£25,000£12.82
Standard Skilled Worker£33,400£17.13
We check the hourly rate against actual hours worked, every pay runDefensible
We check the annual salary and assume the hourly followsExposed
Hours vary a lot and we have never tested itAct now
New from April 2026For certificates assigned on or after 8 April 2026, the going rate must be paid for every hour worked in each pay period — not averaged across the year. And the Home Office makes regular checks with HMRC to confirm sponsors are paying in line with the rules, so this is verified against real payroll data rather than against what you declared.
03

Can you produce the evidence that you told your sponsored workers their UK employment rights?

A duty introduced on 6 March 2026, and the one most providers do not yet know about. Sponsors must have HR systems or processes demonstrating they provide this information — minimum wage, working time, pension auto-enrolment, statutory leave and pay, health and safety, trade union membership, equality duties, grievance procedures — and must keep records of having done so.

Yes — documented, for every sponsored workerDefensible
We do it for new starters onlyExposed
We have not heard of thisAct now
Why it is urgentIt applies to your existing sponsored workforce, not only to new hires. Any currently sponsored worker with no documented evidence is a live breach today, not a risk for the future — and it is a fast, cheap thing to put right before anyone asks.
04

Do you know which reports are ten working days and which are twenty?

The rule is simple once you see it: changes about a worker are ten working days; changes about your organisation are twenty. Most late reports come from getting that backwards.

10 working days — worker20 working days — organisation
Does not start within 28 days · absent without permission more than 10 consecutive working days · unpaid or reduced-pay absence over 4 weeks in a year · salary reduced · change of job within the same code · change of normal work location · leaves or you stop sponsoring themChange of key personnel — authorising officer, key contact, level 1 or 2 users · organisation name, address or contact details · structure, branches, linked entities · changes to registration or accreditation status · insolvency · mergers and takeovers · convictions
Yes, and someone owns SMS reporting as a named responsibilityDefensible
We report things, but not to a schedule and not always on timeExposed
Reporting happens when someone remembersAct now
Two details worth knowingThe absence clock runs from the tenth day — you report within ten working days after the tenth consecutive day of unauthorised absence. And a permanent change of work location must be reported, while hybrid working need not be. A change to a different occupation code is not a report at all; it needs a new certificate and usually a new application.
05

Do your CQC record and your Sponsor Management System record tell the same story?

Active CQC registration, and actually carrying on at least one regulated activity, is a condition of sponsoring care workers in England. If you do not meet it, the worker's application is refused outright.

Locations, activities and job roles match across both, and we check when either changesDefensible
We have added or closed a location recently and have not updated SMSExposed — 20-day clock
We do not know what SMS currently saysAct now
How the exposure actually arisesThree separate duties converge here: a change to your registration status is a reportable change within twenty working days; a worker in a role that does not match the CoS is a mandatory revocation ground; and operating without a legally required registration is a revocation ground in itself. Your registered activities, trading presence, contact details, contracts and staffing should all tell one consistent story — a compliance officer's job is to find the place where they do not.
06

Could you hand over a complete file for any sponsored worker, this afternoon?

Not the file you would assemble if given a week. The one that exists now.

Right to work evidence, and a repeat-check schedule where permission is time-limitedRequired
Payslips and bank transfer records showing the individual worker being paidRequired
Signed contract with hours, pay and job details; job description matching the CoSRequired
Recruitment evidence, qualifications, references, DBS, National Insurance numberRequired
Current UK address, email and phone — kept up to dateRequired
Absence records, and the three months' employment history for in-country switchesRequired
The retention rule people get wrongDocuments are kept until the earlier of one year after your sponsorship of that worker ended, or the date a compliance officer has examined and approved them. Not one year flat, and not indefinitely.
07

Are you recovering any sponsorship cost from workers — in any form?

Sponsors must not pass sponsorship fees or associated administrative costs to the sponsored worker where that is prohibited. In this sector it usually appears as a repayment or clawback clause rather than as a direct charge, which is why providers do not recognise it as the same thing.

No clawback, no repayment clause, no deduction of any sponsorship costDefensible
We have a training or recruitment repayment clause and have never had it reviewedGet it read
We recover the certificate or immigration skills charge from the workerAct now
08

If a compliance officer arrived at a service user's home tomorrow, would that be a problem?

Visits can be announced or unannounced, and can also be conducted remotely by video. Officers may verify what you said in your application, photograph the location, speak to any sponsored worker, inspect records and systems, and run checks on workers who are not sponsored at all.

We have thought about it, and third parties at work locations know visits can happenDefensible
We have never considered how this works when the workplace is someone's homeAct now
Specific to domiciliary care and supported livingSponsors must allow full access to premises or sites under their control, and must ensure third parties at workers' locations are aware that visits may occur. Where the work location is a service user's own home or a third party's site, that obligation needs thinking about in advance — not improvised on the doorstep.

What happens if it goes wrong

The position
Right of appealThere is none. The remedy is an error correction request, then judicial review — a challenge to legality, not to the merits, and rarely successful
SuspensionNo certificates can be assigned, and you are removed from the public register of sponsors — visible to commissioners, lenders and insurers while enquiries run
Cooling-off12 months before reapplying. 24 months if revoked more than once, or if you surrendered the licence to avoid revocation — surrendering does not avoid the wait
Your workersPermission is normally curtailed to 60 days from the decision, or to the visa expiry if sooner. "Normally" — a shorter period or none at all is possible where deception is involved
Illegal working penalties£45,000 per worker for a first breach, £60,000 for a repeat
A change that lands on 1 October 2026, and it is aimed squarely at how this sector staffs itself. Illegal working civil penalties and criminal sanctions extend beyond employees to people working under a contract to perform work personally, individual sub-contractors, individuals listed on online matching or platform services, and arrangements carrying substitution rights. Domiciliary care sub-contracting and platform-sourced carers are directly captured. If you use either, the right-to-work position on those arrangements needs looking at before October, not after.
If you are an Ofsted-registered children's provider without a CQC registration. The registration requirement for sponsoring care workers is drawn by reference to CQC registration and regulated activities under the health and social care regulations. Children's social care settings are regulated by Ofsted and do not carry on those activities — so on the face of the rules an Ofsted-only provider cannot satisfy the requirement for these occupation codes. That reading is consistent with attempts in Parliament to have the position reversed, though there has been no ministerial statement resolving it. If your workforce plan assumes otherwise, get it checked before you assign anything.

What the Home Office says it is acting on

Its own stated reasons for revoking care sector licences are underpayment of workers, facilitating circumvention of the immigration rules, and failure to provide the promised work. Practitioners add discrepancies between the roles on certificates and the duties actually performed, and the absence of a genuine vacancy. Note what is not on that list: nothing about the quality of care. This is an employment-records and payroll exercise, and it is won or lost in the file.

England, September 2026. Duties, deadlines and penalty amounts taken from the Home Office sponsor guidance and the Immigration Rules current at the time of writing, and revocation volumes from published data and freedom of information responses. Two points of care: the care sector share of revocations is drawn from a broader "human health and social work activities" category, so it is indicative rather than exact; and several claims circulating in the trade press about payroll data feeds, income averaging and what counts as working time could not be verified in the published guidance and are deliberately not repeated here. This is a risk-flagging tool, not immigration advice — sponsor compliance is a regulated legal activity and a licence at risk needs a qualified immigration adviser, quickly.

A revoked licence takes the workforce with it.

Thirty minutes, no charge. Tell us which duties you are not certain about and we will tell you what a compliance visit would find.

Call us

020 3856 8549

Someone answers, including out of hours.

Text or WhatsApp

07426 919823

If it is easier to write it down than say it out loud, send a message.

Email us

No documents needed first. If you already have an action or a suspension, say so.

The question, before it becomes a problem.

The Care Business
Consultants

Care · Compliance · Development ·
Specialist accommodation

MCB-HUB Ltd T/A The Care Business Consultants

England and Wales · Company No. 13962703

Registered office: Generator Building, Counterslip, Bristol BS1 6BX

VAT registration: GB 479 0951 48

ICO registration: ZB312478

Professional indemnity insured

Talk to us

+44 20 3856 8549Landline

07426 919823Text or WhatsApp

[email protected]

Coverage England. London and Greater London in person, and providers throughout the rest of the country.
© 2026 MCB-HUB Ltd, trading as The Care Business Consultants.