Sponsor Licence Revocation Case Study: How a Care Provider Challenged a Home Office Decision

What happened to Stone House Care and Medical Limited?

Stone House Care and Medical Limited is a domiciliary care provider delivering care to people in their own homes.

Like many UK care providers, Stone House relied heavily on sponsored workers. It had 27 sponsored workers, and the Home Office recorded approximately 1,012.5 sponsored-worker hours each week against approximately 1,045.5 allocated care hours. Its sponsor licence was therefore closely connected not only to recruitment, but to staffing, care packages and continuity of care.

On 29 April 2026, Home Office compliance officers attended Stone House.

The visit was unannounced.

Current Home Office sponsor guidance expressly provides that compliance checks can take place on either an announced or unannounced basis. Home Office sponsor guidance, Part 3.

For Stone House, that visit was the start of a process that would lead to suspension and then revocation of the sponsor licence.

What can the Home Office examine during a sponsor compliance visit?

A sponsor compliance visit is not limited to checking whether employees have visas.

Officers can look at whether sponsored workers are actually performing the jobs for which they were sponsored, whether the sponsor's records are accurate, whether salaries and hours correspond with sponsorship information, and whether appropriate right-to-work and immigration-monitoring systems are in place.

In Stone House's case, the areas considered included:

• what sponsored workers were actually doing;
• whether duties matched their Certificates of Sponsorship;
• payroll and salary records;
• working hours;
• rotas;
• client records;
• Right to Work evidence;
• immigration monitoring;
• recruitment records;
• reporting procedures; and
• management systems.

This is why a business can appear to be operating normally while still having sponsor-compliance vulnerabilities.

Being compliant and being able to prove compliance to the Home Office are not always the same thing.

Why was the Stone House sponsor licence suspended?

On 5 June 2026, 37 days after the visit, the Home Office suspended Stone House's sponsor licence.

The suspension raised concerns in four broad areas:

• the duties being carried out by sponsored workers;
• salary and mileage payments;
• an undisclosed family relationship; and
• Right to Work and immigration monitoring.

One issue illustrates how something that may appear minor internally can become significant during a Home Office investigation.

Stone House's website contained the wording:

“Housekeeping Support Services”

The Home Office also held a client-hours spreadsheet identifying workers and hours but which did not clearly identify the services being delivered.

The Home Office said it could not be satisfied that sponsored Care Workers were not carrying out housekeeping work rather than the eligible care duties for which they had been sponsored.

That concern did not exist in isolation.

Other issues included an incomplete Right to Work record, weaknesses in monitoring and questions over whether job descriptions and actual duties aligned. Taken together, seemingly manageable issues can put a sponsor licence at risk.

What should a sponsor do after receiving a suspension letter?

The answer is not simply to deny every allegation.

The business needs to establish:

• which allegations are factually wrong;
• which concerns are supported by evidence;
• whether genuine compliance failures exist;
• what can and should be corrected immediately;
• what the Sponsor Guidance required at the relevant time; and
• what evidence is needed to answer each allegation properly.

That was the approach taken with Stone House.

Detailed representations were submitted on 3 July 2026, 28 days after the suspension.

The response comprised more than 200 paragraphs supported by more than 40 enclosures.

The evidence included:

• client information and service schedules;
• local authority care and support plans;
• care plans and daily notes;
• rotas and care schedules;
• payroll records;
• banking evidence;
• Certificates of Sponsorship;
• Right to Work records;
• immigration records; and
• evidence relating to individual sponsored workers.

Did Stone House have genuine compliance problems?

Yes.

That is an important part of this case.

The review identified historic problems with some prescribed online Right to Work checks. Those weaknesses were not ignored or presented as though they had never occurred.

Corrective work included:

• completing outstanding Right to Work checks;
• reviewing sponsored-worker files;
• correcting immigration dates;
• introducing a revised Right to Work procedure;
• correcting the immigration-monitoring spreadsheet;
• adding management verification; and
• introducing a conflict-of-interest process.

This is an important distinction for sponsors.

Sponsor compliance is not about pretending that no mistake has ever occurred.

It is about identifying weaknesses, understanding their seriousness, correcting them properly and putting systems in place to reduce the risk of repetition.

Ideally, that work happens before a Home Office compliance officer arrives.

What did the Home Office accept?

When the Home Office made its decision, several of the original concerns had been answered.

It accepted that:

• mileage payments had been made;
• the family-relationship issue had been addressed and was not considered a threat to the immigration system;
• two sponsored workers specifically identified by the Home Office were carrying out the duties on their Certificates of Sponsorship; and
• parts of Stone House's Right to Work evidence were accepted.

Despite this, the sponsor licence was revoked on 20 July 2026.

The revocation took immediate effect.

That was 82 days after the unannounced compliance visit.

What happens when a care provider loses its sponsor licence?

For a care provider that relies heavily on sponsored workers, sponsor licence revocation can become much more than an immigration problem.

In Stone House's case, the immediate factual exposure included 27 sponsored workers and approximately 1,012.5 sponsored-worker hours every week.

Current Home Office sponsor guidance says that where a sponsor licence is revoked, the organisation can no longer sponsor workers and the Home Office will normally take action in relation to the permission of workers sponsored by that organisation. Home Office sponsor guidance, Part 3.

The potential consequences for a care provider can extend through the whole operation.

Sponsored workers and their families

Loss of the sponsoring employer can create serious uncertainty over a sponsored worker's continued immigration position. Dependants may also be affected where their immigration status is linked to the main applicant.

In Stone House's case, the publication carefully distinguishes these potential consequences from outcomes actually found to have occurred.

Service users and continuity of care

If substantial workforce capacity is lost, care visits may need to be rescheduled, redistributed or transferred to other providers.

That can affect continuity of care, particularly where service users have established relationships and routines with their regular carers.

Local authorities and commissioners

Stone House's revocation letter recorded that relevant public bodies had been notified so that local authorities could identify potential disruption to care.

Where a provider loses significant capacity, commissioners may need to identify alternative provision and care packages may need to be transferred or recommissioned.

Revenue and business viability

Fewer available workers can mean fewer care hours delivered.

Fewer billable care hours can mean lower revenue while wages, premises, systems, management costs and other fixed costs continue.

Revocation does not automatically close a business, but sustained loss of workforce and care-delivery capacity can threaten viability.

For a heavily sponsored care provider, sponsor compliance is therefore also a form of business-continuity protection.

Can a sponsor licence revocation be challenged?

Home Office sponsor guidance states that there is no right of appeal against sponsor licence revocation. Home Office sponsor guidance, Part 3.

That does not mean every revocation decision is beyond scrutiny.

Stone House therefore examined whether the Home Office's decision had been reached lawfully.

The review looked at questions including:

• What exactly had the Home Office alleged?
• What evidence had it requested?
• What had Stone House supplied?
• Which explanations had been accepted?
• Which allegations remained?
• Had the case changed between suspension and revocation?
• Had the correct Sponsor Guidance been applied?
• Had corrective action already taken by Stone House been properly considered?

What was the problem with the Home Office's reasoning?

One issue concerned two sponsored workers whom the Home Office had specifically asked Stone House to evidence.

Stone House supplied the requested evidence.

The Home Office accepted it.

But the eventual decision then relied on the absence of equivalent evidence relating to other workers whom Stone House had not been asked to evidence in the same way.

The decision also raised questions over the legal basis relied upon. One part referred to an Annex C1 ground, while the operative section referred to Annex C2 grounds.

These matters formed part of the challenge to the lawfulness of the revocation decision.

What happened after the sponsor licence was revoked?

On 12 August 2026, a detailed Pre-Action Protocol Letter was served on the Home Office.

The challenge was not simply that the decision was unfair.

Nor was it based simply on the fact that workers might lose their jobs.

The question was whether the Home Office had lawfully reached the revocation decision when the allegations, evidence, explanations, Sponsor Guidance and corrective measures were considered together.

What did the Home Office say?

On 3 September 2026, the Home Office responded.

It reviewed the decision to revoke Stone House's Skilled Worker sponsor licence and confirmed that the decision had been:

“incorrectly reached”

The case was referred to the Sponsor Licence Post Decision Team for fresh reconsideration.

The Home Office also confirmed that the sponsor licence was to be reinstated while that reconsideration took place.

Judicial Review proceedings did not need to be issued at that stage.

The substantive reconsideration remained ongoing at the time this case study was published.

This is therefore not being presented as a final determination following reconsideration.

Stone House sponsor licence case: full timeline

From the unannounced visit to the Home Office response: 127 days.

What does this case teach other sponsor licence holders?

The most important lesson is not what happened after Stone House's licence was revoked.

It is what another sponsor can do before reaching that point.

Stone House was able to investigate systems, correct compliance weaknesses and assemble substantial evidence after the Home Office had already visited.

Doing that under suspension is much harder than finding the same weaknesses through a proper sponsor-compliance audit before a compliance officer arrives.

A licensed sponsor should be able to answer questions such as:

• Can we immediately produce every sponsored worker file?
• Can we prove each sponsored worker is carrying out the sponsored role?
• Do our rotas, payroll, care records and Certificates of Sponsorship tell the same story?
• Can we evidence working hours and salary payments?
• Are our Right to Work checks correct?
• Are visa-expiry dates monitored properly?
• Have reportable changes been reported?
• Can our Authorising Officer explain our sponsor-compliance systems?
• Do our website, adverts and job descriptions reflect what workers actually do?
• Would managers and sponsored workers give answers consistent with our records?

If any answer is uncertain, the time to investigate it is before the Home Office arrives.

What should you do depending on where you are in the process?

1. The Home Office has not visited you

Do not assume that means everything is compliant.

A sponsor-compliance audit can test worker files, Certificates of Sponsorship, Right to Work records, salary, hours, duties, reporting processes and management controls before weaknesses become allegations.

Find the problems before the Home Office does.

Arrange a Sponsor Licence Compliance Audit

2. The Home Office has already visited

Do not simply wait for a suspension letter.

Record what officers asked.

Identify the documents requested.

Review what was said during interviews.

Investigate potential weaknesses and preserve relevant evidence.

If something is wrong, it is better to understand it before the Home Office writes its decision.

Talk to us after a Home Office visit

3. Your sponsor licence has been suspended

The response period is critical.

A suspension response requires investigation and evidence, not just explanations.

A sponsor should establish:

• which allegations are serious;
• which allegations can be disproved;
• what genuine problems exist;
• what must be corrected immediately;
• what evidence is required; and
• what the Sponsor Guidance requires.

Get help with a sponsor licence suspension

4. Your sponsor licence has been revoked

Do not assume the case is necessarily over.

The suspension letter, representations, supporting evidence, Sponsor Guidance and final decision should be examined together.

Current Home Office guidance confirms that a revoked sponsor has no statutory right of appeal, making early specialist review particularly important. Home Office sponsor guidance, Part 3.

Request an urgent sponsor licence revocation review

Frequently asked questions about sponsor licence suspension and revocation

Can the Home Office carry out an unannounced sponsor compliance visit?

Yes. Current sponsor guidance states that compliance checks involving a visit or interview may be conducted on either an announced or unannounced basis. Home Office sponsor guidance, Part 3.

What can the Home Office check during a compliance visit?

A compliance visit can examine whether the sponsor is genuinely operating, whether sponsored roles are genuine and eligible, whether workers are carrying out the roles for which they were sponsored and whether the organisation has appropriate HR, record-keeping, reporting and immigration-compliance systems. Home Office sponsor guidance, Part 3.

What happens if a sponsor licence is revoked?

A revoked sponsor can no longer sponsor workers. Current Home Office guidance says sponsored workers' permission may be cancelled or shortened depending on the circumstances. The sponsor is also removed from the register of licensed sponsors. Home Office sponsor guidance, Part 3.

Is there a right of appeal against sponsor licence revocation?

The current Sponsor Guidance states that there is no right of appeal against a revocation decision. Home Office sponsor guidance, Part 3.

Stone House's case proceeded through the Judicial Review Pre-Action Protocol process rather than a statutory appeal.

Can a sponsor licence revocation decision be challenged?

Depending on the facts, the lawfulness of a decision may need to be considered through the Pre-Action Protocol and Judicial Review process.

Whether there are arguable grounds depends on the individual decision, evidence, applicable Sponsor Guidance and procedural history.

Stone House's case resulted in the Home Office confirming that its earlier revocation decision had been “incorrectly reached” and that the licence was to be reinstated while reconsideration took place.

Should a care provider wait for a Home Office visit before auditing sponsor compliance?

No business needs to wait for an investigation before reviewing its own systems.

For a care provider dependent on sponsored workers, weaknesses in sponsor compliance can become workforce, care-delivery and business-continuity risks very quickly.