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ExpatriatesRight to workLatest NewsGlobal mobilityImmigration

Sponsor licence revocation: what HR and mobility leaders need to know

by Rajiv Naik, Thomas Kingsmill, Ko Ito 23 Sep 2025
by Rajiv Naik, Thomas Kingsmill, Ko Ito 23 Sep 2025 Photograph: Shutterstock
Photograph: Shutterstock

Record numbers of sponsor licences are being revoked in the UK, leaving businesses with acute continuity problems where immigration compliance has failed. Rajiv Naik, Thomas Kingsmill and Ko Ito of Fragomen explore what organisations must do to avoid this scenario

Recent Home Office figures show that sponsor licence revocations have reached record levels, with 1,948 licences cancelled in the year to June 2025 – more than double the 937 revoked in the previous 12 months. For HR and global mobility professionals, this is not an abstract statistic. It is confirmation that immigration compliance has become mission-critical to business continuity.

For HR teams already under pressure to deliver workforce stability, dealing with the fallout of lost staff and public scrutiny can be crippling”

The recently published data highlights that the sectors hit hardest include adult social care, hospitality, retail and construction. These industries are not only dependent on migrant labour but are also sectors where HR teams often manage high turnover, complex rostering and acute staffing shortages. That combination of operational challenge and compliance risk makes these employers particularly vulnerable.

How and why sponsor licences get revoked

Sponsor licences are granted to organisations that can demonstrate they are legitimate, trading and have a genuine need for migrant workers, and holding a licence brings with it heavy responsibilities. Each sponsor licence requires an authorising officer – often an HR or compliance lead – who carries a legal responsibility for ensuring the licence is managed correctly.

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The most common reasons for revocation include: failing to carry out correct right-to-work checks or employing people whose visas have expired, sponsoring workers in roles that do not exist or have been exaggerated to meet immigration rules, paying staff below the minimum salary thresholds for their visa category and failing to notify authorities when a worker changes role or leaves employment.

While genuine one-off mistakes may not trigger an immediate revocation, systemic breaches or serious non-compliance will likely lead to suspension or revocation of the sponsor licence under scrutiny.

Business impact

For business leaders, the impact of a suspension or revocation is profound. Suspension immediately freezes the ability to sponsor new workers or renew existing visas. Revocation goes further – it invalidates all current sponsored visas, forcing out employees mid-contract regardless of their seniority or performance. In sectors such as care or hospitality, this can remove key staff overnight and leave workforce planning in chaos.

The reputational consequences are equally damaging. A revoked sponsor licence signals to regulators, unions, employees and the wider market that the organisation has failed to meet legal standards. For HR teams already under pressure to deliver workforce stability, dealing with the fallout of lost staff and public scrutiny can be crippling.

Can a revoked sponsor licence be retrieved?

If a sponsor licence is suspended, the Home Office may allow time for corrective action. But once a licence is revoked, there is no right of appeal. The organisation must wait at least 12 months before reapplying, and the period extends to 24 months for repeat offences. For businesses that rely heavily on international recruitment, that gap can be devastating. HR and mobility professionals should therefore treat prevention as the only realistic option, since recovery is slow, uncertain and rarely aligns with urgent workforce needs.

From raids to data-led enforcement

Many HR professionals may still picture compliance checks as unannounced site visits by inspectors. In reality, the enforcement model has shifted. Today, the Home Office relies heavily on cross-departmental data sharing and intelligence gathering. Payroll records from HM Revenue and Customs, Companies House filings and other datasets are routinely cross-referenced to identify anomalies – such as companies sponsoring employees long after ceasing to trade, or visa holders still on payroll despite expired status.

Build compliance systems on the assumption that the government already has sight of your data. Internal checks must be as rigorous as external audits”

This means that many employers may not even be aware of problems before enforcement action begins behind the scenes. For HR and mobility teams, the lesson is clear: build compliance systems on the assumption that the government already has sight of your data. Internal checks must be as rigorous as external audits.

Immigration as a mission-critical compliance function

The days when immigration compliance was viewed as a back-office administrative task are over. Today, it sits firmly alongside payroll, tax and health and safety as a board-level compliance function. For HR, personnel and mobility leaders, sponsor licence management is not about ticking boxes but about protecting business continuity, safeguarding talent pipelines and protecting the organisation’s reputation.

Practical steps include: ensuring authorising officers are trained and resourced, conducting internal audits and mock inspections, integrating immigration risks into corporate risk registers and partnering closely with legal and mobility advisers. These measures not only reduce the risk of the sponsor licence being lost but also demonstrate to the board that HR and mobility are actively managing a critical area of organisational risk.

The latest Home Office figures make clear that sponsor licence revocations are no longer rare events. They are happening in record numbers and across mainstream sectors. For HR and mobility leaders, the implications are stark: without a licence, businesses lose access to the global talent they rely on, with immediate and lasting damage.

The choice for employers is simple. Treat immigration compliance as an administrative afterthought and risk severe disruption – or embed it as a mission-critical function, managed strategically and supported at board level. Those that do the latter will not only stay compliant but will protect their workforce and secure the talent needed to compete in a challenging market.

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Rajiv Naik, Thomas Kingsmill, Ko Ito

Rajiv Naik (pictured) is a partner, Thomas Kingsmill a senior manager and Ko Ito a manager at the global immigration law firm Fragomen

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