What does a second sponsor licence revocation mean for our care business?

A second sponsor licence revocation can produce a longer minimum cooling-off period before a new application. The current sponsor guidance states at least 24 months where a licence has been revoked more than once. It also affects sponsored workers and assigned CoS. Analyse each decision separately because different evidence or grounds may require different responses.

Confirm whether there are separate decisions

Obtain every revocation, suspension and compliance-check letter. Record the organisation, licence, decision date, grounds, evidence, workers and period covered by each. Do not rely on the description that the licence was revoked twice without reading the decisions.

Where the business structure or licence changed between decisions, map the entities and key personnel carefully. Obtain advice on which decision and cooling-off provision applies.

Understand the longer cooling-off period

Sponsor Guidance Part 3, paragraph C10.3 says the minimum cooling-off period increases to at least 24 months if the sponsor has had its licence revoked on more than one occasion.

Paragraph C10.16 explains that a new application made before the applicable cooling-off period has passed will be refused, unless the earlier licence was revoked in error and the Home Office arranges reinstatement.

Address every revocation ground

Part 3, paragraph C10.18 says a later application is treated as a new application and the organisation must demonstrate that it has addressed all reasons for the previous revocation.

Build a matrix with each ground, source evidence, current provision, factual finding, corrective action, control owner and proof of sustained operation. Do not merge different grounds into a general statement that systems have improved.

Separate document-led and visit-led evidence

Part 3, paragraphs C7.15 to C7.17 allow the Home Office to inspect systems and records, interview workers and staff, request evidence remotely and check information with other government departments.

Place documentary findings and visit findings in separate sections, then identify where they overlap. A payroll discrepancy and a weak HR control may be related, but they are not the same allegation.

Map the worker and CoS consequences

Part 3, paragraphs C10.10 to C10.15 explain possible shortening or cancellation of sponsored workers' permission, invalidation of assigned CoS and effects on pending applications and workers who have not travelled.

Give affected workers factual information and access to independent advice. Record communications and avoid promising a standard 60-day outcome without checking the worker's circumstances and the Home Office action.

Preserve records for any challenge or future application

Keep the decisions, correspondence, response packs, source records, calculations, visit notes, corrective-action evidence and governance approvals. Appendix D, version 08/26 identifies the worker records that should form part of that evidence base.

Do not create retrospective records to fill a gap. Preserve originals and document later corrections with dates, reasons and approvers.

Plan only from the current legal and operational position

There is no right of appeal against a revocation decision under Part 3, C10.3. Obtain prompt legal advice on any other available remedy and deadlines. Keep legal challenge, service continuity, worker support and future sponsor-readiness as separate workstreams.

This article provides general information, not legal advice.

Related questions

How long is the cooling-off period after a second revocation?

Part 3, C10.3 states a minimum of at least 24 months where a sponsor licence has been revoked on more than one occasion.

Can we submit a new licence application during the cooling-off period?

C10.16 says an application made before the applicable cooling-off period ends will be refused, except where the earlier revocation was in error and reinstatement is arranged.

Do we need to address both revocation decisions?

Yes. C10.18 requires a later applicant to demonstrate that all reasons for previous revocation have been addressed.

Will every sponsored worker receive 60 days after revocation?

No standard outcome should be promised. C10.10 distinguishes different circumstances and considers how much permission remains.

Can UKVI rely on both documents and visit evidence?

Yes. Part 3, C7.15 to C7.17 allow record and system inspection, interviews, remote evidence requests and checks with other departments.