Two Home Office documents decide whether you get a sponsor licence and whether you keep it, and neither one is written for you. The points-based system sponsor licensing caseworker guidance tells UKVI (UK Visas and Immigration) staff how to decide an application. The compliance casework guidance tells the Sponsor Compliance Team what to do once you hold a licence: maintain your A rating, downgrade you to a B, suspend the licence, or revoke it. The second document is the one to read, because it is the one that decides whether you stay a sponsor. Borderless Immigration has read it in full, and what follows is what it instructs a caseworker to do.
It carries more weight than it did two years ago. In the first half of 2026 the Home Office revoked 2,346 Skilled Worker sponsor licences and suspended a further 2,632, and the Work Rights Centre's analysis of the same Home Office release puts Skilled Worker revocations in the year to June 2026 at 4,403, the highest twelve-month figure since sponsorship replaced free movement in December 2020.
The two documents, and which one you are in
The applications guidance runs to 97 pages and was last updated on 22 November 2024. It governs the decision made before you hold anything, and once the licence is granted you leave its territory for good.
The compliance casework guidance is version 1.0, published for Home Office staff on 20 January 2025 and on GOV.UK two days later. Several sections are withheld as "Official – sensitive", including how cases are allocated and most of what happens on the internal case-management system. What is published is the part that lands on your desk: the decisions available, the thresholds for each, and the deadlines attached.
Cases reach the Sponsor Compliance Team from pre-licence visits, post-licence visits, checks with other government departments, and digital compliance checks. That third route is worth sitting with, because a referral can open a case without any immigration official having visited you at all.
The decision ladder, and who signs it
Compliance decisions come in two stages, and knowing which stage you are in tells you what is still available to you.
First stage decisions are made on a referral or a visit report, before you have said anything: maintain A rating, intention to re-rate to B rating, suspension, or immediate revocation. You then have a window to make representations. Second stage decisions are made after those representations have been considered: re-rate to B, continuation of suspension, reinstatement to A rating, reinstatement to B rating, or revocation.
The thresholds are written down, in the guidance's own words. An A rating is maintained where minor issues were identified and had already been addressed before compliance action began. An intention to re-rate to B goes out where there is "scope to rectify minor, one-off shortcomings or omissions in systems or retained documents". A licence is suspended where findings show duties breached "more seriously or repeatedly", or a threat to immigration control, or behaviour not conducive to the public good. Suspension takes effect immediately, and it applies across every route you are licensed in rather than only the one where the problem was found.
The signing chain runs three deep. Caseworkers, meaning Administration Officers and Executive Officers inside the Sponsor Compliance Team, identify the case, consider it, and draft the letter; a Higher Executive Officer checks the draft; a Senior Executive Officer authorises it. Nothing reaches you without that final sign-off, and high profile cases are owned by the SEO outright.
One feature of that chain is worth knowing. A caseworker is allowed to reach a decision that conflicts with the visit's own overall compliance rating. To keep you A-rated when the visit report says otherwise, they complete an Alternative Decision Form naming the relevant areas of compliance and giving their reason, and a Higher Executive Officer authorises it. A poor rating on the day is not the decision.
The clocks start on the date of the letter
Every deadline in this process runs from a date printed on a document, not from the day you read it.
| What happens | The deadline |
|---|---|
| Representations on an intention to re-rate to B, or on a suspension | 20 working days from the date on the letter |
| Accepting an action plan and agreeing to pay the fee, via the SMS | 10 working days |
| The action plan period itself, followed by a further compliance check | 3 months |
| Cooling-off period after revocation, before you can apply again | 12 months from the date on the revocation letter |
An extension on the 20 working days is available only where the caseworker is satisfied there are exceptional circumstances. Asking for a copy of the visit report does not restart it: caseworkers aim to send requested documents within one to two working days, and the clock keeps running while they do. The action plan fee is £1,579, and if it is not paid within 10 working days of the date you were told about the downgrade you lose the licence.
What each rung costs you operationally varies more than the labels suggest. A B-rating stops you issuing a Certificate of Sponsorship to a new worker, although you can still issue one to a worker you already employ who is extending their permission. During an action plan you also cannot add branches or new routes to the licence, and UKVI decides how many CoS allocations you get to cover extension periods. Two B-ratings inside the licence's validity period, or two action plans, and the guidance sends the caseworker to revocation. There is no right of appeal against a revocation, so you wait the 12 months and start a new application.
Set the 20 working days against what it is asking of you. Four weeks, from a standing start, to assemble a records-based case covering every sponsored worker you employ, while the licence is suspended and your hiring has stopped. That is a test of what you already had rather than what you can build in a month.
The test is your process, not your paperwork
One line in Annex C2, quoted in the caseworker guidance, does more work than anything else in the document. The Home Office will normally revoke a licence where "we are not satisfied the sponsor is using a process or procedure necessary to fully comply with their sponsor duties, based on the information provided to us".
Read that twice. It does not say your records were wrong. It says the Home Office was not satisfied that you are using a process, judged on what you handed over. The caseworker is assessing a system, and the only evidence they have of your system is the evidence you produce.
Several other triggers in the same annexes read like paperwork problems and are really system problems:
- Having no SMS users in place at all, which normally leads to revocation.
- An SMS user assigning a CoS to themselves, a close relative, or a partner where no exception applies, which will lead to revocation.
- A Level 1 or Level 2 User disclosing their SMS password to someone else, which may lead to revocation.
- Failing to co-operate with a compliance check, or delaying compliance activity, which normally leads to revocation.
- Asking a sponsored worker to pay any part of the ISC (Immigration Skills Charge), or recouping it from them, which normally leads to revocation.
- Paying a sponsored worker in cash, which normally leads to revocation.
None of those is a policy decision anybody signed off. Each is one person's habit. At fifty sponsored workers your licence rests on what a small number of people do routinely when nobody is checking, and this guidance is written to find exactly that.
What you are entitled to ask for
After an intention to re-rate to B, a suspension, a re-rate to B, a continuation of suspension, a reinstatement to B, or a revocation, you or your representative can email the Sponsor Compliance Team and ask for the findings. With authorisation from a Higher Executive Officer, the caseworker can release the visit report, the sponsor interview record, and the migrant interview record. The migrant interview record needs a written letter of authority from the worker before it is disclosed.
Visit reports can also be wrong, and the guidance says as much. They "should be objective, factual and follow the tasking that led to the visit", and caseworkers are told to check for factual errors and for places where the Compliance Officer "recorded opinions or made assumptions which are not supported by evidence". There is a Report Rejection Form for it and a Higher Executive Officer single point of contact who confirms whether rejection is appropriate. If a report presents an assumption as a finding, pointing that out is part of the process rather than an objection to it.
One administrative detail is worth checking before you need it. The decision letter goes by email, as a PDF, to your Authorising Officer or to a representative named on the licence, with read and delivery receipts requested. If your adviser is not named on the licence, the letter still goes to your Authorising Officer unless you have provided a signed letter of authority. The clock starts whether or not the right person is watching that inbox.
What to do with this before you need it
The useful reading of this guidance is not as a map of a crisis. It is a specification for the eleven months before a compliance visit, and it should change two things.
Write the process down rather than only running it. If the governing test is whether the Home Office is satisfied you are using a process, that process has to exist somewhere other than in one person's head: who runs a right to work check and at what point, who assigns a CoS and who signs it off, and how a salary change reaches the SMS inside the reporting deadline.
Then keep the evidence in a shape you could hand over inside a fortnight. The 20 working days assumes you can produce dozens of dated worker files on demand. If that currently means a week of collating from three systems and a shared drive, you have already failed the test the annex describes. While you are at it, confirm who your Authorising Officer is and who else reads that inbox, because it is the only address the Home Office is required to write to.
Our Home Office Audit Checklist walks through the records a compliance officer asks for and the order they ask for them in, which is the quickest way to find out whether your files would survive the twenty days. If you would rather find out under supervision, a mock compliance audit does the same job with someone in the room. And if a letter has already arrived, the consequences of each rung are set out in our guide to what happens when a sponsor licence is revoked.
The guidance is public, the thresholds are written down, and the clocks are fixed. There's just too much at stake to find that out from the letter.
Sources
- Home Office, Compliance casework guidance (accessible), version 1.0, published 22 January 2025.
- Home Office, Points-based system sponsor licensing – applications: caseworker guidance, last updated 22 November 2024.
- Home Office, UK visa sponsorship for employers: your licence rating.
- Home Office, Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance, Annexes C1, C2 and C3.
- Home Office, Sponsorship transparency data, April to June 2026, sheet SC_01, for the half-year revocation and suspension figures.
- Work Rights Centre analysis of the same release, reported in Personnel Today, 27 August 2026, for the twelve-month Skilled Worker revocation figure.
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