Disclaimer: The information provided in this blog is accurate as of October 2025. Any updates after this date will not be reflected here. For the latest updates, please consult official UK Government sources or contact us.
Sponsor Management System (SMS) and Certificate of Sponsorship (CoS):
UK sponsors have access to an online “portal” known as the Sponsor Management System (SMS), where they can assign Certificates of Sponsorship (CoS)—virtual documents necessary for employees to make a sponsored work visa application. A valid sponsor licence is required to assign CoS.
A UK employer cannot assign “CoS” unless they hold a valid sponsor licence.
In order to obtain and maintain a valid sponsor licence, employers must comply with specific duties during the license’s tenure. Failing to uphold these duties or posing a threat to UK immigration control could result in the Home Office suspending the licence while further investigations are conducted.
The Home Office is increasingly undertaking visits to businesses, to check on compliance with the duties that need to be fulfilled by the sponsor.
Failure to pass such a visit could lead to the sponsor licence being suspended.
What are the sponsor’s duties while holding a sponsored licence?
To obtain and maintain a valid sponsor licence, employers must fulfill specific duties throughout the duration of the licence. Failing to meet these duties or posing a threat to UK immigration control could result in the Home Office suspending the licence for further investigation.
The Home Office regularly conducts visits to businesses to ensure compliance with sponsor duties. If your business fails a compliance visit, your sponsor licence could be suspended.
Key Sponsor Licence Duties:
- Monitor Immigration Status: Conduct “right to work” checks for all employees.
- Maintain Contact Details: Keep up-to-date records of your sponsored migrants.
- Record Keeping: Maintain appropriate records for each sponsored worker, such as job descriptions, contracts, and contact details.
- Track Absences: Monitor annual leave and absences of sponsored workers.
- Compliance with UK Laws: Ensure all business operations, recruitment practices, and sponsored worker placements are in line with UK laws and immigration regulations.
Under what circumstances would your licence be suspended
Your licence would potentially be suspended following a failed compliance visit from the Home Office. Visits can be physical but could also be remotely undertaken (such as a virtual call).
At a compliance visit, Home Office compliance officers would interview your key personnel and ask questions to determine whether your business operations, recruitment practices, sponsorship plans and records meet the appropriate requirements.
You can find more detailed information on sponsor compliance in some of our other A Y & J blogs.
If you prepare thoroughly for a visit, the likelihood of a suspension should be greatly diminished.
However, it is always worth understanding what a suspension would mean for you, if you received such a notification.
What does the suspension of a licence mean?
If your licence is suspended:
- You cannot assign any new Certificates of Sponsorship (CoS).
- Your business will be removed from the register of sponsors.
- Any pending visa applications for workers already sponsored by you will be put on hold until the suspension outcome is determined.
While your licence is suspended, you must continue to fulfill all duties required under the licence. However, if the suspension leads to a revocation, current sponsored workers may lose their status, and you could face penalties.
If your licence renewal is due during the suspension period, you should still proceed with the renewal application.
What are the most common reasons for a licence to be suspended?
A licence suspension typically follows a Home Office compliance visit, either announced or unannounced. The most common reasons for suspension include:
- Employment of illegal workers.
- Concerns regarding the genuineness of the job vacancy being sponsored.
- False information provided on a CoS.
- Failure to meet salary obligations or pay employees as per sponsorship guidelines.
- Inadequate HR procedures—particularly for right-to-work checks.
- Failure to maintain required records such as recruitment evidence and contact details.
- Failure to report changes in circumstances for sponsored workers (e.g., changes in job title) or the sponsoring organisation (e.g., address changes).
- Failure to cooperate during a Home Office visit, including refusing to provide requested information or documentation.
Can the decision be challenged?
If you receive a suspension notice, you have 20 working days to challenge the decision by filing representations with the Home Office.
Legal advice will help you identify any factual errors or procedural issues and guide you through the process of submitting your challenge. Your written representations should include all relevant evidence to counter the concerns raised by the Home Office.
Following your representations, the Home Office will assess the situation, and the outcome could result in the suspension being either reinstated, downgraded, or revoked.
What Happens After a Successful Challenge?
If the Home Office is satisfied that any breaches have been corrected and procedures changed in order to ensure the same issues do not arise again, the Home Office may reinstate your licence with an A rating. If, however, they reinstate with a B rating, this will be combined with a Home Office action plan; this will need to be paid for by your business and will need to be complied with within three months. Action plans will not be extended.
What happens if the licence is then cancelled?
If the breach is severe or falls under mandatory grounds for revocation, your sponsor licence will be revoked. A revoked licence results in the complete removal of your business from the register of sponsors. Sponsored workers will be given 60 days to leave the UK (or shorter, depending on their leave).
Once revoked, sponsor licences cannot be appealed, and your business will need to wait for the cooling-off period (usually 12 months) before applying for a new licence.
Conclusion
If your sponsor licence is suspended, it is critical to respond within 20 working days to file a challenge. Strong evidence and proper legal guidance will be essential to convince the Home Office to reinstate your licence. If your licence is revoked, you must ensure that any issues are rectified before you can reapply after the cooling-off period.
A Y & J Solicitors is a specialist immigration law firm, with extensive experience with sponsor licence suspensions. We have an in-depth understanding of immigration law and are professional and results-focused. For assistance with your application or any other UK immigration law concerns, please contact us on +44 20 7404 7933 or at Contact US today. We’re here to help!
