Guide

Why are care providers losing their sponsor licences, and what can we check now?

By Sponsor ComplIANS · 12 November 2026 · 8 min read

Why are care providers losing their sponsor licences, and what can we check now?

Most care providers that lose a sponsor licence did not set out to break the rules. The problems usually sit between teams: payroll pays what the rota shows rather than the salary on the Certificate of Sponsorship, a coordinator covers an absence that HR never hears about, or a right to work follow-up date sits in one worker's file with nobody watching it. The Home Office expects a sponsor to have systems that catch these things and records that prove it. The useful question is not "are we compliant?" but "could we show it, for any worker, tomorrow?"

What does the Home Office expect from a sponsor?

The sponsor guidance treats a licence as a matter of trust. You are expected to have processes that let you meet every sponsor duty, and to keep the records that show you have done so. If you do not have those processes, that is itself a ground for revocation (Part 3, Annex C2(b)).

The duties are not complicated one by one. Pay each worker at least the salary on their CoS. Check right to work before they start, and again before time-limited permission ends. Report the changes the guidance lists, on time. Keep the records in Appendix D and produce them when asked. Make sure each worker is doing the job, hours and location on their CoS. The difficulty for a care provider is that each duty is held by a different team.

Which failures lead to revocation most often?

The guidance groups the grounds for revocation into three annexes: mandatory grounds (Annex C1), grounds where the licence will normally be revoked (Annex C2) and grounds where it may be revoked (Annex C3). For care providers, the same handful come up again and again:

  • Pay

    Paying less than the CoS salary

    Paying a worker less than the salary on their CoS, without a permitted reason or a report, is a mandatory ground (Annex C1(aa)).

  • Role

    Job, hours or location not as on the CoS

    A role that is not genuine, or does not match the CoS, is a mandatory ground (Annex C1(r), (s) and (w)).

  • Processes and records

    No system, or records not produced

    Having no processes to meet sponsor duties, or not producing Appendix D documents in time, are normal revocation grounds (Annex C2(b) and (g)).

Others sit close behind: sponsoring a worker without permission after failing to do checks (Annex C2(d)), not co-operating with a compliance check (Annex C2(e)) and paying a sponsored worker in cash (Annex C2(p)). Reporting failures matter too: a change that should have been reported and was not is a breach of a sponsor duty in its own right.

Why do these problems start between teams?

Because the information is split. In most care providers, HR holds the right to work checks and contracts, payroll holds the pay, coordinators hold the rota and absences, and recruitment holds the CoS. Each team does its own job well. What goes missing is the handover.

  1. Rota to payrollVisits are cancelled and the rota shows fewer hours. Payroll pays the rota, and nobody checks the pay against the CoS.
  2. Coordinator to HRA worker phones in sick and the visits are covered. HR is not told, so nobody counts the days or decides whether a report is due.
  3. File to diaryA follow-up right to work date is noted in one worker's file. It is not in any shared list, so the date passes.
  4. Change to reportHours, location or a key person changes. Each team assumes another has dealt with the reporting.
  5. Request to evidenceAn officer asks for a worker's file. The records exist, but in four systems, and nobody can explain them on the day.

None of these is a single person's mistake. Each is a gap in who owns the handover.

What has changed for care providers?

Three things make this more pressing than it was. 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 hold active CQC registration and be carrying on at least one regulated activity (Sponsor a Skilled Worker, SK4.41). And the cooling-off periods after a revocation are longer than they were, including where key personnel were linked to a revoked licence (Part 1, L4.26 and L9.13 to L9.22).

The response to the Home Office concerns was detailed and strategic. We felt heard, represented and properly defended.

Client experience · Home Office concerns responseAndrew MagurausheDirector, Leelin Ltd

What can we check this month?

Pick two or three sponsored workers at random and try to answer these questions for each of them, with the evidence in front of you:

Five questions to start with

  1. Was each worker paid at least the salary on their CoS for each of the last three pay periods?
  2. When is each worker's next right to work follow-up check due, and who will do it?
  3. Has every absence this year been recorded, with a decision on whether it was permitted?
  4. For every change this year, is there a reporting decision, with a deadline and any SMS reference?
  5. Could someone other than the usual person find and explain each worker's file today?

If any answer is "not sure", that is where to start. The readiness check covers ten questions in more detail, and each of the ten Working Packs below gives a worksheet for one area.

Free Working Packs for each area

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 10: "Could we prove it tomorrow?" readiness check

Ten questions that test whether your team can find and explain the evidence for any sponsored worker, today, without warning. It is not a pass or fail test and not a certificate. It covers:

  1. Worker files and right to work checks.
  2. Pay against the contract and the salary on the CoS.
  3. Contracted, planned and worked hours.
  4. Absences, reporting decisions and changes to job or location.
  5. Owners, deputies and what happens when the usual person is away.

Get free Working Pack 10

Sponsor ComplIANS Live, 26 November 2026

Sponsor ComplIANS Live is a practical day for payroll, HR, coordinators and managers in care providers that sponsor workers. It covers why care providers are losing sponsor licences, 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 does not guarantee compliance or any outcome with the Home Office.

Book your place

In the Sponsor ComplIANS Hub, each sponsored worker's record brings together pay, absences, Right to Work, documents and reporting duties on one page (Sponsor Compliance Core). The Hub supports your checks; it does not replace them or guarantee compliance, and it does not submit anything to the Home Office. See the Compliance Hub

Related reading

What is the most common reason care providers lose a sponsor licence?

There is no single reason, and we do not rely on unpublished statistics. The grounds that come up most often for care providers are pay below the CoS salary, roles or hours that do not match the CoS, missing right to work follow-up checks, unreported changes and records that cannot be produced.

Can a licence be revoked without a warning first?

Yes. Annex C1 grounds are mandatory, and the Home Office can revoke without suspending first. Annex C2 grounds normally lead to revocation unless there are exceptional circumstances.

Can we still recruit care workers from overseas?

No. Since 22 July 2025, entry clearance is not available for care workers or senior care workers. Sponsorship is limited to people already in the UK who meet the transitional conditions, currently until 22 July 2028.