Surge in sponsor licence enforcement: what immigration practitioners need to know

The UK’s immigration landscape is undergoing a significant shift at the moment and one way this is clearly evident is in the realm of sponsor licence enforcement.

For immigration practitioners, the latest statistics released by the Home Office for the year ending June 2025 offer both a warning and a roadmap. With sponsor licence revocations more than doubling year-on-year, understanding the enforcement landscape continues to be essential for advising clients on safeguarding their compliance.

A record year for sponsor licence revocations

According to the most recent Home Office transparency statistics, between July 2024 and June 2025 the Home Office revoked 1,948 sponsor licences — a dramatic increase from 937 in the previous year. This marks the highest number of revocations ever recorded in a single year and continues a sharp upward trend in the years following the slowdown of compliance enforcement during the pandemic.

The number of sponsor licence revocations has increased sharply over the past four years: 

According to the government, this shift has been enabled by improved data and intelligence sharing across departments, reducing reliance on physical compliance visits. However, it is telling that the government is not able to confirm how many inspections are actually taking place and thus the proportion of these that result in compliance action.

Why are licences being revoked?

According to the Home Office, sponsor licences have been revoked for a range of serious breaches of immigration and employment rules, including:

• undercutting domestic workers by paying migrant workers below the legal minimum or agreed salary thresholds (often exploiting their dependency on visa sponsorship so that they cannot complain);
• using the visa system to bring in individuals for roles that did not meet the criteria, or for jobs that did not exist;
• sponsoring migrants for roles that were never truly available, leaving them without income or legal recourse; and
• exploitation of migrant staff, including coercive practices, poor working conditions and threats of dismissal or ‘deportation’ (removal, to you and I) to suppress complaints.

The government claims that these issues were seen particularly in the adult social care, hospitality, retail and construction sectors. However, it has not published enforcement statistics broken down by sector or region. This limits the ability to compare enforcement rates in these sectors against the overall sponsor population.

Another factor affecting sponsor licence applications and revocations which has been identified by ILPA is a seemingly harsher approach to historic right-to-work checks. Although these checks are undoubtedly of great benefit to employers, they are not a strict legal requirement in the UK. This means it is not uncommon for employers not to be fully compliant with these before they begin to consider sponsorship, at which point UKVI’s higher expectations of sponsors effectively make them mandatory. 

I understand that ILPA has received reports of increased compliance activity or licence refusals based on historic right-to-work checking omissions, even where these did not result in illegal employment and processes were robustly improved in order to become a sponsor. However, I understand that the Home Office denies any new or harsher policy regarding this and claims that such factors are always considered in the round.

Enforcement tools and government messaging

The government has a number of options in its enforcement toolkit. In addition to sponsor licence enforcement such as suspending, downgrading or revoking sponsor licences and visas, government enforcement action can also lead to civil penalties and/or business closure orders for illegal employment of workers. In cases where the Home Office believes that the sponsor has deliberately provided false sponsorship information in order to secure a visa, this could be prosecuted as facilitating illegal immigration. 

In the last election, the Labour Party manifesto committed to cracking down on employers repeatedly flouting immigration rules or committing serious employment breaches. They recently increased the cooling-off period for new licence applications for sponsors/key personnel with multiple licence revocations from 12 months to two years. Future plans include extending the time that a sponsor can be downgraded and on an action plan, due to less serious compliance breaches, from three months to 12 months.

Last month, commenting on record revocation numbers, Minister for Migration and Citizenship, Mike Tapp MP, stated “we will not hesitate to ban companies from sponsoring workers from overseas where this is being done to undercut British workers and exploit vulnerable staff. These shameful practices will not be tolerated.”

Licence approval rates

Enforcement activity is of course only part of the story when it comes to the number of licensed sponsors. The other is how many organisations are applying to become sponsors and how many of these applications are being granted. 

The most recent statistics for year ending June 2025 indicate that there has been a sharp fall in the number of successful sponsor licence applications, with only about 56% of licences being granted. This year’s grants are reported to be 50% fewer than the year before. This is likely to be a result of increased scrutiny of licence applications, but the number of unsuccessful applications also includes withdrawals, which may also be due to prospective sponsors reacting to changes to the minimum salary and skill requirements (either implemented or merely trailed), which undoubtedly make the sponsorship regime less attractive. 

Expected changes from the 2025 White Paper

The May 2025 White Paper, Restoring Control Over the Immigration System, outlines further reforms to enforcement and sponsorship:

• increased compliance scrutiny for sponsors – this includes more rigorous checks on job roles, salary levels, and right-to-work documentation, as well as planned changes to thresholds in the Basic Compliance Assessment for Student sponsors;
• sector-specific audits for high-risk industries such as adult social care, hospitality, and construction;
• enhanced digital monitoring of sponsored workers’ employment status to determine whether an individual has complied with the terms of their visa; and
• reduced reliance on overseas labour, especially in low-wage sectors – we have already seen changes to the qualifying skill level for sponsored roles, with the Migration Advisory Committee currently instructed to review both the new Temporary Shortage List and sector recruitment and training strategies.

The White Paper signals a continued tightening of sponsor oversight, with a focus on reducing net migration and protecting domestic labour markets.

However, it’s worth noting that this approach contrasts sharply with the Migration Advisory Committee’s conclusions following its recent review of the use of immigration in the IT and engineering sectors. That review found that there was no over-reliance in these sectors and use of visas was proportionate. Moreover, it cautioned against a simplistic visas vs domestic skills policy approach, which could set up a clash between encouraging growth in a key sector that the UK government is currently championing and the premise behind the government’s upcoming immigration policies.

What should immigration practitioners do?

With enforcement intensifying, practitioners must take a proactive role in guiding sponsor clients to limit the risks of facing compliance action.

• Conduct regular compliance audits – review sponsor recordkeeping in accordance with Appendix D and ensure all documentation aligns with Home Office requirements. Make sure that the sponsor knows their reporting duties and has processes to ensure that Sponsorship Management System users are informed by the business of relevant changes promptly and report changes within the fixed deadlines.
• Monitor sector-specific risks – stay informed about enforcement trends in high-risk sectors. Clients in adult social care or hospitality may need additional support.
• Prepare for unannounced audits – ensure clients are audit-ready at all times. This includes maintaining up-to-date HR systems and having key personnel trained in sponsor duties.
• Respond swiftly to Home Office correspondence – if a client receives a suspension notice, act immediately. Legal representation, remedial action and prompt communication with the Home Office can make the difference between reinstatement and revocation.
• Educate clients on ethical employment – encourage sponsors to go beyond compliance and adopt fair employment practices. This not only protects migrant workers but also reduces enforcement risk.

See our post on challenging the suspension and revocation of sponsor licences here.

The sponsor licence regime is not (and has never been, despite some Home Office messaging) a straightforward or passive administrative process — it’s a dynamic and high-stakes compliance environment. For immigration practitioners, the challenge is clear: helping clients navigate this landscape with vigilance and strategic foresight.

As enforcement continues to rise, staying informed and proactive is not just good practice — it’s essential.