Guide
Our sponsor licence was revoked. What should we fix before applying again?
By Sponsor ComplIANS · 11 November 2026 · 8 min read
There is no right of appeal against a sponsor licence revocation, and a cooling-off period normally applies before you can apply again: 12 months after a first revocation, and longer in some circumstances. Waiting out that period does not, on its own, show the Home Office that anything has changed. Use the time to understand the decision, fix the cause of each finding, and keep month-by-month evidence that the new processes are being followed. Take advice early, because some options are time-limited.
What does a revocation mean for our business and our workers?
When a licence is revoked, you can no longer assign Certificates of Sponsorship, and any you have assigned but not yet used become invalid (Part 3, C10.10 to C10.12). The Home Office also looks at the people you already sponsor.
- Not involved in the breach
Permission shortened to 60 days
Workers who were not involved in the breach normally have their permission shortened to 60 calendar days, unless they already have 60 days or fewer left.
- Considered involved
Remaining permission cancelled
Workers the Home Office considers were involved normally have all their remaining permission cancelled.
- What workers are told
That it was revoked, not why
Workers are told the licence has been revoked, but not the reasons.
For a care provider, that is a staffing problem before it is anything else. Visits still need covering, and care packages, commissioner contracts and local authority relationships can all be affected while workers look for new sponsors or leave.
So the first job is a clear picture of the business over the next few months: which workers are affected and when their permission ends, which packages they cover, what the cover will cost, and what you have told workers, service users and commissioners.
The government's November 2026 response on settlement proposes giving care workers longer to find a new sponsor after a revocation, from February 2027. That is a proposal, not the current rule: the guidance today still says 60 days.
Can we challenge the revocation?
Not by appeal. The sponsor guidance says plainly that there is no right of appeal against the decision (Part 3, C10.3). It also provides for reinstatement where a licence was revoked in error (C10.16).
Outside the guidance, a revocation decision can be challenged by judicial review. That route has its own procedure and strict time limits. The Pre-Action Protocol for Judicial Review expects a letter before claim, normally with 14 days for the other side to reply, and a claim must be brought promptly and in any event within three months of the decision.
Whether a challenge is worth making depends on the decision letter, the evidence the Home Office relied on, and what you can show. Some providers have good grounds; others are better served by putting the time and cost into rebuilding. Either way, the window is short, so get advice from an appropriately qualified adviser as soon as the decision arrives.
While you take advice
- Keep every letter, email and attachment from the Home Office, with the date each one arrived.
- Do not rewrite or tidy records to make them look better. Keep originals, any corrections, and the reason for each correction.
- Write down a timeline of the compliance visit or information request, what you sent, and when.
How long before we can apply for a new licence?
It depends on your circumstances, so do not rely on a single figure. Part 1 of the sponsor guidance (L9.13 to L9.22) sets the cooling-off periods. In outline:
| Circumstance | Period | Counted from |
|---|---|---|
| First revocation | 12 months | The revocation notice |
| More than one revocation | 24 months | The latest notice |
| A refused licence application | 6 months | |
| Multiple illegal working or right to rent civil penalties | Up to 5 years | |
| Revocation only because of the inactive SMS user process | None |
Where more than one period could apply, the longest one applies, and an application made during the period is refused. Part 3 says the same thing more briefly: the period is at least 12 months and may be longer in some circumstances (C10.16).
Two further points matter for care providers. First, the people matter as well as the company: if the owners, directors or key personnel of a new application were linked to a revoked licence, that is normally a ground for refusal within the same window (Part 1, L4.26), so a new company does not get round the cooling-off period. Second, where the revocation involved dishonesty or deliberate misconduct, the guidance expects compelling evidence that things have changed (L9.22).
Check your own period, and when it started, with your adviser, and write the date down.
Why isn't waiting enough, and what should we fix?
The cooling-off period tells you the earliest date you can apply. It says nothing about whether the problems that led to revocation have gone away. A new application will be assessed on how the business works now, and the people who knew the old processes may have left. If nothing has changed, the same findings are likely to come back.
Start from the decision letter, not from a general list of good practice. Work through it in this order:
- List the findingsList every finding in the decision letter and earlier correspondence, in the Home Office's own words.
- Find the root causeKeep asking why it happened until you reach something you can change: a process, a handover, a person's role, a system.
- One action per causeChoose one corrective action per cause, with a named owner and a deadline.
- Evidence every monthCollect evidence every month that the new process is being followed, not just that it has been written down.
- Review with your adviserReview the whole plan with your adviser before you decide when to apply.
A worked example (fictional)
A fictional care provider lost its licence after findings on salary shortfalls and unreported absences. Its corrective actions looked like this:
| Finding | Root cause | Fix | Evidence kept |
|---|---|---|---|
| Workers paid below the CoS salary | Payroll paid the hours on the rota and nobody compared pay with the CoS. | A monthly pay reconciliation before payroll is approved, signed by HR. | Six months of signed sheets. |
| Absences not reported | Coordinators covered the visits but HR was never told. | A same-day absence handover and a weekly HR review of open absences. | A log kept. |
| Records hard to find | Each worker's records were split across three systems. | One file per worker and a quarterly retrieval drill. | The results recorded. |
None of those fixes is complicated. What makes them persuasive is the evidence that they have been running for months, worker by worker.
What has changed for care providers
If you plan to sponsor care workers again, check the current rules before you build a recruitment plan around a new licence. Since 22 July 2025, care workers and senior care workers cannot be recruited from overseas; new sponsorship in these roles is only possible for people already in the UK who meet the transitional conditions, which currently run until 22 July 2028 (Appendix Skilled Worker, SW 6.1B). In England, a care sponsor must also hold active CQC registration and be carrying on at least one regulated activity (Sponsor a Skilled Worker, SK4.41).
Losing our licence would have been catastrophic. Their strategic support during the revoked licence situation gave us direction and strength when we needed it most.
What records should we keep while we rebuild?
Keep two sets: the record of what happened, and the evidence of what has changed.
What happened
- Every Home Office letter, email and attachment, with the date received and any deadline it set.
- What you sent in reply, and when.
- The decision letter, and any advice you received on challenging it.
- What you told affected workers, service users and commissioners, and when.
What has changed
- The root-cause and corrective-action list, with owners and deadlines.
- Monthly evidence for each corrective action, for example signed pay reconciliations, absence handover records, a log of reporting decisions and retrieval drill results.
- Updated policies and process notes, with the date each one came into use.
- Who now holds each sponsor duty, and who covers when they are away.
Keep originals unchanged. If a record has to be corrected, keep the original, the correction, the reason and the date. The aim is a file that someone who has never met your team could follow.
This article gives general information, not legal advice. Guidance checked on 11 November 2026. Check the current guidance and your own circumstances before acting.
Free Working Pack 08: business recovery and corrective-action workbook
A four-page fillable workbook for a provider whose licence has been revoked. It does not restore a licence or set a date to apply again; it helps you fix the causes and show that the fixes are working. It covers:
- A timeline of the decision and correspondence: date, letter or event, key point, deadline and where it is filed.
- The business impact now and over the coming months: sponsored staff, care packages, commissioner contracts, revenue, costs and dependencies such as CQC, insurers and lenders.
- Root causes and corrective actions, starting from the findings in the decision letter.
- A six-month grid for the evidence that each corrective action is being followed.
- Questions to take to a qualified adviser, including time limits, your cooling-off period, your workers and what a future application would need to show.
Sponsor ComplIANS Live, 26 November 2026
Part 1 of Sponsor ComplIANS Live looks at why care providers are losing sponsor licences, what happens to a business over the following year, and what needs to change before a fresh application. Parts 2 and 3 cover who does what across HR, payroll, recruitment and coordinators, and a full demonstration of the Hub.
- When: Thursday 26 November 2026, 9am to 5pm
- Where: Leicester Marriott Hotel
- Paid by 11:59pm UK time on Thursday 19 November: £699 + VAT for the first attendee and £300 + VAT for each additional attendee booked together
- After that: £999 + VAT and £600 + VAT
Attending cannot restore a licence or guarantee a future application.
In the Sponsor ComplIANS Hub, the licence summary records your licence rating, Authorising Officer and Key Contact, and the Documents Hub keeps the organisation's records, including Home Office letters and core policies, against a checklist and shows what is still missing. The Documents Hub is part of Sponsor Compliance Core. The Hub does not restore a licence, and it cannot guarantee that a new application will succeed. See the Compliance Hub
Related reading
Related questions
Can we appeal a sponsor licence revocation?
No. Part 3 of the sponsor guidance says there is no right of appeal (C10.3). A decision can be challenged by judicial review, which has strict time limits, so take advice promptly.
How long is the cooling-off period after a revocation?
Normally 12 months from the revocation notice for a first revocation, and 24 months after more than one. Longer periods can apply, for example after multiple civil penalties, and the longest applicable period applies. Check your own position with an adviser.
Can we set up a new company and apply straight away?
The guidance looks at the people behind an application, not just the company. Key personnel linked to a revoked licence are normally a reason to refuse within the cooling-off window.
What happens to our sponsored care workers?
Workers who were not involved in the breach normally have their permission shortened to 60 days, unless they have less than that left. Workers considered to have been involved normally lose their remaining permission.
Will the Home Office give us our licence back if we fix everything?
There is no guarantee. Fixing the causes, and keeping evidence that the fixes work, puts you in a better position for a future application. It does not promise an outcome.