Sponsor Licence Suspension or Revocation: Employer Response Guide

If the Home Office has suspended your sponsor licence, the current sponsor guidance normally gives you 20 working days from the date of the written notification to respond. The letter and its stated deadline must be checked immediately. Suspension, a B-rating and revocation are different outcomes, and the evidence needed depends on the precise allegations.

This page is the detailed employer guide to the suspension and revocation process. For urgent representation after receiving a Home Office letter, see our sponsor licence emergency-response service.

What should an employer do after receiving a suspension letter?

Suspension, B-rating and revocation are not the same

Sponsor licence suspension

The Home Office may suspend a licence while it makes further enquiries where it believes that sponsor duties may have been breached, immigration control may be at risk, or conduct may not be conducive to the public good. During suspension, the sponsor cannot assign a new Certificate of Sponsorship. Existing sponsored workers with valid permission are not affected solely by the suspension unless and until the licence is revoked, although some pending applications may be placed on hold.

The sponsor must continue to comply with all sponsor duties during the suspension. The public register entry is removed for the suspension period.

Downgrade to a B-rating

A B-rating is a separate compliance outcome. A sponsor that is downgraded must normally pay for and follow an action plan designed to restore its A-rating within a fixed three-month period. A B-rating is not another name for suspension. The Home Office may reinstate a suspended licence with either an A-rating or a B-rating, depending on the outcome.

Sponsor licence revocation

Revocation ends the licence in every route for which the organisation is licensed. The business cannot sponsor further workers, assigned but unused Certificates of Sponsorship become invalid, and the Home Office will normally cancel or shorten the permission of existing sponsored workers. The organisation is removed from the public register of licensed sponsors.

There is no right of appeal against revocation under the sponsor-licence scheme. A fresh licence application is normally barred for at least 12 months and may be barred for longer in some cases, including repeat revocation. Whether judicial review is available is a separate public-law question requiring case-specific advice; it is not a routine appeal on the merits.

How long is the response period?

Under version 05/26 of the Home Office sponsor guidance, a sponsor normally has 20 working days from the date of the written suspension notification to provide written representations and supporting evidence. If the Home Office identifies additional grounds during that period, it should write again and give a further opportunity to respond to the additional reasons.

The Home Office guidance says it will normally notify the sponsor of its final decision within 20 working days after receiving the response, unless the case is exceptionally complex or information is awaited from a third party. These periods must not be substituted for the dates in the actual correspondence.

What allegations commonly require an evidence-led response?

Role, occupation code and genuine vacancy concerns

The duties performed in practice must correspond with the occupation code and job description stated on the Certificate of Sponsorship. An organisational chart, job description, work product, supervision arrangements and recruitment records may be relevant, but they must tell one consistent story.

Salary, payroll and working hours

For most Skilled Worker applications under the current rules, salary must meet both the applicable general threshold and the applicable going rate. The general threshold is not always £41,700: lower thresholds can apply under specific points options, health and education occupations or transitional provisions. Hours, deductions, unpaid absence and the actual PAYE record must also be checked before making a broad assertion that salary compliance has been met.

SMS reporting

Changes to a sponsored worker’s circumstances must generally be reported within 10 working days unless the guidance specifies otherwise. Changes to the sponsor organisation are generally reportable within 20 working days. The correct period depends on the event. For example, an unauthorised absence of more than 10 consecutive working days must be reported no later than 10 working days after the tenth day of absence.

Record keeping and right-to-work checks

Sponsors must retain the records specified in Appendix D and carry out compliant right-to-work checks. A right-to-work check and a sponsor-compliance record are related but not interchangeable. The response should show what was checked, when it was checked, how the worker’s identity was verified and whether any follow-up check was required.

Corporate changes and key personnel

Changes of ownership, mergers, takeovers, addresses and key personnel can create separate reporting or fresh-licence issues. The legal entity holding the licence and the employing entity shown in payroll and contractual records should be reconciled before responding.

What evidence should be collected?

The correct evidence depends on the allegations. A controlled initial collection may include:

• the suspension, minded-to-revoke or revocation letter and proof of the notification date;
• the compliance-visit record, interview notes and any document request;
• the licence summary, key-personnel details and relevant SMS reporting history;
• Certificates of Sponsorship, job descriptions, contracts, rotas, attendance and work-location records;
• payroll, payslips, bank evidence and HMRC records capable of explaining the salary position;
• right-to-work evidence and the relevant Appendix D documents;
• recruitment and genuine-vacancy evidence; and
• policies, training and audit records that genuinely existed at the relevant time.

Do not alter historic records or create retrospective dates. Remedial action can be important, but it should be identified honestly as action taken after the issue was discovered.

How should written representations be organised?

A useful response normally starts with the Home Office’s own numbered allegations. For each allegation it should identify the factual position, the applicable sponsor-guidance provision, the evidence relied on and any genuine corrective action. Documents should be indexed and cross-referenced so that the decision-maker can follow the position without guessing.

A response should also deal with contradictions. If the Certificate of Sponsorship, contract, payroll record and manager’s explanation do not match, submitting all four without analysis may reinforce the Home Office concern.

What happens to sponsored workers?

Suspension alone does not normally cancel an existing worker’s permission. If the licence is revoked, the Home Office may cancel or shorten permission. A worker who was not involved in the reasons for revocation will normally be left with 60 calendar days, unless less than 60 days remained already. A worker who was actively and knowingly involved may have all remaining permission cancelled.

The sponsor and each worker should obtain separate advice where their interests may differ. The employer should not give immigration assurances to workers that go beyond the Home Office decision and the worker’s individual position.

Frequently asked questions

Can a sponsor assign Certificates of Sponsorship while suspended?

No. The sponsor cannot assign new Certificates of Sponsorship while the licence is suspended.

Does suspension automatically mean revocation?

No. The Home Office may reinstate the licence with an A-rating or B-rating, impose restrictions, or revoke it. The outcome depends on the grounds, the evidence and the applicable guidance.

Is a B-rating the same as suspension?

No. A B-rating is a downgrade linked to a paid action plan. Suspension is an investigatory enforcement step. A suspended licence may later be reinstated with a B-rating, but the two are not interchangeable.

Can the employer make representations or appeal after revocation?

The 20-working-day written-representations period applies to the suspension notification, before the Home Office makes its final decision. If the licence has already been revoked, there is no appeal under the sponsor-licence scheme and no further representations stage under that scheme. Public-law remedies, including urgent judicial review advice, may be considered in an appropriate case, but the grounds and deadline require individual assessment.

Should the employer send evidence as soon as it is found?

The deadline must be protected, but evidence should normally be reviewed, indexed and explained before submission. Unstructured documents can create new inconsistencies.

Official sources

• Home Office sponsor guidance Part 3: sponsor duties and compliance, version 05/26
• Home Office guidance: sponsor a Skilled Worker
• Appendix D: keeping records for sponsorship

Last legally reviewed: 6 August 2026. This page provides general information and does not replace advice on a particular Home Office letter.