If the Home Office suspends your sponsor licence, you have 20 working days to respond in writing and send supporting evidence. Sponsored workers keep their permission during the suspension, but you cannot assign any new Certificates of Sponsorship. If the licence is revoked, workers who were not involved in the breaches will normally have their permission shortened to 60 calendar days, during which they need to find a new sponsor or another route to stay.
This page explains what happens on a downgrade, a suspension and a revocation, which deadlines apply at each stage, how to prepare strong written representations and what it means for your overseas staff. The rules reflect the current Home Office sponsor guidance (version 08/26) and the cancellation and curtailment caseworker guidance (version 12.0, published 11 September 2026).
Suspension, downgrade and revocation: the key differences
The Home Office has three main compliance measures for sponsors, and their consequences differ sharply. Knowing which measure you face matters from day one, because it decides the deadline, the options open to you and the position of your workers.
Downgrade to a B-rating
A B-rating is a transitional rating for relatively minor breaches that the Home Office believes can be put right through an action plan. Before downgrading, it writes to you with the proposed action and gives you 20 working days to respond in writing. Once downgraded, you cannot assign a Certificate of Sponsorship (CoS) to any new worker until you have signed up to the action plan, paid the fee and had your A-rating restored.
Suspension
A suspension is used where the Home Office believes you are breaching your sponsor duties or pose a threat to immigration control. The licence is suspended in every route at once, and your entry is removed from the public register of licensed sponsors for the duration. You cannot assign any CoS, but all of your sponsor duties continue to apply.
Revocation
Revocation is the most serious outcome. The licence ends in all routes, any CoS you have assigned become invalid, and your workers’ permission will normally be cancelled or shortened. There is no right of appeal, and you cannot apply for a new licence for at least 12 months. These rules are set out in sections C8 to C10 of the Home Office guidance for sponsors, part 3.
| Measure | New CoS | Current workers | Time to respond | Possible outcome |
|---|---|---|---|---|
| B-rating | Not allowed, except extensions for existing sponsored workers | Continue working | 20 working days to respond, 10 working days to pay for the action plan | A-rating restored, second action plan or revocation |
| Suspension | Not allowed | Not affected unless the licence is revoked | 20 working days from the date of the letter | A-rating, B-rating or revocation |
| Revocation | Not allowed, assigned CoS become invalid | Permission normally shortened to 60 days | No appeal, judicial review only | New application after at least 12 months |
Note that the Home Office does not have to apply these measures in sequence. It may suspend a licence without downgrading it first and, where the circumstances in Annex C1 arise, revoke it immediately and without warning.
Why the Home Office suspends or revokes a licence
The grounds are listed in three annexes to the guidance. Annex C1 covers circumstances in which the Home Office will revoke a licence, for example where it finds that a sponsor knowingly gave false information in its application. Annex C2 covers circumstances in which it will normally revoke unless there are exceptional circumstances. Annex C3 covers breaches that may lead to revocation: a single one rarely does, but the more of them there are, the higher the risk.
In practice, a suspension usually follows a compliance visit or a request for documents. Typical problems that a visit uncovers include:
- a worker doing a job that does not match the occupation code or job description on the CoS, which the guidance treats as a mandatory ground for revocation;
- pay below the salary stated on the certificate or below the threshold for the route;
- failing to report a worker leaving, a long absence or changes to the organisation within the required time;
- incomplete HR records or missing right to work checks;
- weak control over users of the Sponsorship Management System (SMS).
SMS requirements are tightening: Annex C3 of the current guidance now refers to mandatory multi-factor authentication for SMS users from 3 September 2026, so even system access issues are worth checking in advance. For a broader overview of how sponsorship works, see the guide on how to obtain a UK sponsorship licence and what it is for.
Once a suspension letter has arrived, the priority is to assess each allegation on its merits rather than react to the letter as a whole. Some allegations may be based on incomplete information, and that is exactly what the response needs to show.
Benefits of seeking support to protect your UK sponsor licence
- Review of the Home Office letter and every allegation within days
- Assessment of the risks to the licence and to each worker’s visa
- Audit of HR records and sponsor duties before you respond
- Preparation of written representations with evidence
- Support through the action plan and the follow-up check
- Advice for workers on changing sponsor or visa route
- Assessment of grounds for judicial review of a revocation
Deadlines after a Home Office letter
Time is the tightest constraint in the whole process. You have 20 working days from the date of the written notification to respond to a suspension, and this period is not extended automatically. The Home Office gives more time only where it is satisfied there are exceptional circumstances, so any request must be made well before the deadline. If new grounds come to light during the investigation, it will write again and give another 20 working days to respond to them.
If you do not respond, the Home Office will decide without your input. If you do, it normally tells you its decision within 20 working days of receiving your response, although complex cases or cases awaiting information from other bodies can take longer. The key dates at a glance:
| Event | Deadline | Source |
|---|---|---|
| Response to a suspension letter | 20 working days from notification | C9.11 |
| Response to additional grounds for suspension | A further 20 working days | C9.13 |
| Response to a proposed downgrade | 20 working days | C8.6 |
| Accepting the action plan and paying the fee | 10 working days | C8.14 |
| Length of the action plan | 3 months | C8.17 |
| Decision after your response | Normally 20 working days | C9.17 |
| Worker’s shortened permission after revocation | Normally 60 calendar days | C10.10 |
| Claim for judicial review | Promptly, and within 3 months at the latest | CPR 54.5 |
| New licence application after revocation | No earlier than 12 months (24 after more than one revocation) | C10.16 |
Working days exclude weekends and bank holidays, and the clock runs from the date of the letter, not from the day someone reads it. A Home Office letter that lands in a shared inbox or the SMS account should be passed to the responsible people the same day.
How to prepare written representations
Your response to a suspension is not a formality but your only real opportunity to influence the decision. There will be no oral hearing: the Home Office states plainly that it decides on the written material. The response must show, point by point, which grounds you believe are incorrect and why, with supporting evidence for each one. Everything you want to rely on must be sent within the deadline, as later material may not be taken into account.
Good representations do not argue with every word of the compliance officer. Where a breach did happen, it is more persuasive to accept it, explain why it occurred and show what has already been done to fix it than to deny the obvious. Where an allegation rests on a mistake or an incomplete picture, you need specific evidence: employment contracts, timesheets, payroll records and correspondence with the worker.
What a strong response to a sponsor licence suspension includes
- Separate analysis of each ground in the Home Office letter
- Evidence for each point: contracts, timesheets, payroll
- Acknowledgement of genuine errors and their causes
- Description of the corrective steps already taken
- Updated internal procedures for monitoring sponsor duties
- Mitigating circumstances and the compliance history
- A clear request to reinstate the licence with an A-rating
It is also worth thinking about how the response affects your workers. If the Home Office interviewed staff, their answers form part of the evidence, so your position should not contradict what they have already told the compliance officers. Checking that all documents are consistent before you submit is time well spent.
Action plans and the B-rating: getting back to an A-rating
If, after considering your representations, the Home Office reinstates the licence with a B-rating, you must comply with an action plan. You will not be given a further 20 working days to reply in this case, as that stage is treated as completed during the suspension. The Home Office may also reduce, or set to zero, the number of CoS you can assign.
The action plan fee is paid within 10 working days using the ‘Action plan details’ function in your SMS account. According to the Home Office fees table, it is £1,579. If you ignore the notification or do not pay in time, the licence will be revoked. You can only decline the plan and surrender the licence if you are not sponsoring any workers.
All action plans run for a fixed period of 3 months. During that time you cannot add branches or new routes, or assign a CoS to any new worker. The exception is extensions for workers you were already sponsoring before the downgrade, within the allocation the Home Office sets. At the end of the period it checks compliance: the outcome may be a restored A-rating, a second action plan with a new fee, or revocation.
There is also a limit on the number of attempts: a sponsor can be B-rated and subject to an action plan no more than twice in any rolling 4-year period. If the criteria for a downgrade are met a third time, the licence will be revoked. That is another reason to build a robust compliance system once the A-rating is back, rather than simply closing the current findings.
Sponsor licence protection
Support with sponsor licence suspension and revocation
Home Office letter review
Analysis of allegations and risks to the licence and staff
Representations
Arguments and evidence for each ground, filed on time
Compliance audit
Checks of HR records, pay and reporting in the SMS
Action plan support
Meeting the action plan and preparing for the recheck
What happens to sponsored workers: the 60-day rule
For overseas staff, the crucial distinction is between suspension and revocation. While a licence is suspended, workers with valid permission carry on working as normal. The only change is that the Home Office puts on hold decisions on their applications made with a CoS assigned before the suspension, as well as settlement (ILR) applications you support, until the suspension is resolved.
During a suspension
A worker who has already been granted entry clearance on a CoS assigned before the suspension can still travel to the UK and start work, provided the licence has not been revoked by the time they travel. The Home Office advises all workers to check their sponsor’s status on the register before travelling. Workers already in the UK are best advised not to change or leave their job without advice, as leaving suddenly can itself become a ground for cancelling their permission.
After a revocation
When a licence is revoked, the Home Office notifies all sponsored workers itself but does not tell them the reasons. What happens next depends on whether the worker was involved in the breaches:
- a worker who was actively and knowingly involved (for example, by agreeing to a non-existent job) will normally have all remaining permission cancelled and must leave the UK immediately;
- a worker who was not involved will normally have their permission shortened so that 60 calendar days remain;
- a worker with no more than 60 days of permission left will not normally have it shortened.
Within those 60 days the worker can apply on a route they qualify for, most often by moving to a new sponsor with a new CoS. A Skilled Worker cannot change employer without applying to update their visa, as the official GOV.UK visa page makes clear. More on the requirements for a new work visa is available on the UK Skilled Worker visa page. If a worker has a pending application and does not vary its basis before a decision is made, the Home Office will refuse it.
Exceptions and special cases
The Home Office cancellation guidance allows a worker to be left with more than 60 days only in exceptional compassionate circumstances, such as late pregnancy, serious illness, or protecting the welfare of a child who is completing medical treatment or exams. These decisions require authorisation from a senior caseworker.
Since September 2026 a temporary arrangement applies in adult social care. Under the cancellation and curtailment of permission guidance, permission must not be cancelled where a person holds Skilled Worker or Health and Care Worker permission as a care worker or senior care worker (SOC codes 6135, 6145, 6136 or 6146) and the sole reason for cancellation would be the revocation of their sponsor’s licence. The arrangement is temporary and subject to regular review. It does not give a right to work for another employer: changing sponsor still requires a new application.
If a worker has been granted entry clearance but has not yet travelled when the licence is revoked, their entry clearance will be cancelled. Any CoS assigned but not yet used become invalid on revocation, and visa applications based on them will be refused.
If your licence is revoked: judicial review and reapplying
There is no right of appeal against the revocation of a sponsor licence, as the guidance states expressly. The only way to challenge the decision is judicial review in the High Court. The court looks at the lawfulness of the decision rather than re-examining every fact: whether the procedure was followed, whether the evidence submitted was considered, and whether the decision was rational and proportionate.
Under Civil Procedure Rule 54.5, a claim must be filed promptly and in any event no later than three months after the grounds first arose. Before issuing, a letter is normally sent under the Pre-Action Protocol for Judicial Review, to which the Home Office should normally respond within 14 days. Sometimes the decision is reconsidered at this stage if the letter exposes a clear factual error. Bear in mind that judicial review does not extend workers’ 60 days, so their visa options need to be dealt with in parallel.
If a challenge is not worthwhile, the remaining option is a fresh application. It can be made no earlier than 12 months after the date you were notified of the revocation, or 24 months if your licence has been revoked more than once. The period can be longer in some cases, for example where certain civil penalties or criminal convictions are involved. The same cooling-off period applies if you surrender the licence while the Home Office is taking compliance action. A new application must show that every reason for the revocation has been addressed and, where the revocation involved dishonesty, include compelling evidence that you are now suitable to be a sponsor.
During the cooling-off period some needs can be met in other ways, for example through visa routes that do not require sponsorship by a particular employer, or by restructuring a group of companies. These options need an individual assessment.
How sponsor licence protection works: 5 stages
Work on a suspended licence is driven by the Home Office deadlines. Below is a typical sequence of stages worth keeping in mind from the moment the letter arrives. Actual timings depend on the complexity of the case and how long the Home Office takes to decide.
Urgent review of the Home Office letter
Internal audit of sponsor duties and records
Preparing and submitting written representations
Home Office decision and the action plan
Restoring the A-rating and protecting staff
Costs and timeframes
The direct costs of a licence problem are made up of government fees and the internal work needed to fix the breaches. Responding to a suspension carries no fee in itself, but the outcome can be expensive, both through the action plan fee and through losing the ability to hire overseas specialists for a year or more.
| Item | Amount | When it applies |
|---|---|---|
| Action plan fee | £1,579 | On a downgrade to a B-rating, paid within 10 working days |
| New licence application: small sponsor or charity | £611 | After the cooling-off period following revocation |
| New licence application: medium or large sponsor | £1,682 | After the cooling-off period following revocation |
| Skilled Worker Certificate of Sponsorship | £525 | When hiring a new worker or when a worker moves to a new sponsor (paid by the new sponsor) |
The figures come from the Home Office fees table taking effect on 8 October 2026, which shows no change to these fees compared with the current ones. Check the latest amounts on GOV.UK before paying. Judicial review requires a separate budget for court fees and representation and is discussed case by case. The licence application process is covered in detail on the UK sponsor licence for employers page.
Common mistakes employers make
Many businesses lose their licence not because the original breaches were so serious, but because of how they respond to the Home Office letter. The same mistakes come up again and again:
- missing the 20-day deadline or sending a response on the last day without evidence;
- an emotional reply with general statements instead of addressing each ground;
- denying breaches that are confirmed by documents or by workers’ interviews;
- ignoring a B-rating notice or not paying for the action plan within 10 working days;
- assigning a CoS to a new worker while B-rated, which is a direct ground for revocation;
- having no plan for staff and only thinking about the 60 days once cancellation letters arrive;
- surrendering the licence during a compliance check in the hope of avoiding revocation, even though the cooling-off period still applies.
Most of these mistakes can be avoided by working to a clear plan from day one and checking every document before it is sent. Regular internal audits also reduce the risk of suspension itself, because many breaches can be spotted long before a compliance visit.
Practical examples
To make the rules more concrete, here are three typical scenarios. They are general illustrations rather than descriptions of specific cases: the outcome in each situation depends on the facts and the evidence.
Scenario 1. Suspension after a compliance visit
A restaurant sponsors two chefs. A visit finds that one of them sometimes works shifts as a waiter, and that a cut in the other’s hours was never reported to the Home Office. The licence is suspended. In its response the business accepts the reporting gap, provides timesheets and updated job duties, explains that the extra role was occasional and describes its new monitoring process. A possible outcome is reinstatement with a B-rating and a 3-month action plan.
Scenario 2. Revocation and the 60-day rule
An IT company’s licence is revoked for systematic record-keeping failures. A developer who had no part in the breaches has his visa shortened to 60 calendar days. In that time he finds a new licensed employer, obtains a new CoS and applies to update his visa. Had he waited for the outcome of his former employer’s dispute with the Home Office, the window could have closed.
Scenario 3. A group with several routes
An international group sponsors staff on the Skilled Worker route and on one of the Global Business Mobility routes. A suspension applies to every route at once, so intra-group transfers are also at risk. The group needs not only to respond to the Home Office but also to plan in advance how key staff will keep working if the response does not succeed.
Similar situations come up in Imperial & Legal’s own work. Below are real stories of employers and workers who faced a suspended licence or its consequences.
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For a worker, a revocation or restructuring at the employer often comes as a complete surprise. One client described how it looked from his side.
Back in China, I spent years polishing my culinary skills before thinking of relocating abroad. My goal was to see the world but also to share the flavours of our national cuisine with the world. I got a job at a famous London restaurant. Eventually, the owner decided to change the managing company of the restaurant, so I could not go on working on my visa. I felt down. Fortunately, Imperial & Legal’s immigration advisors solved the problem.
Key points on sponsor licence suspension and revocation
A suspended sponsor licence is a serious warning, but not the end of the road. You have 20 working days to show the Home Office in writing that the breaches have been fixed or that the allegations are unfounded, and that window shapes the outcome more than any later step. A revocation, by contrast, leaves little room for manoeuvre: there is no appeal, workers are left with around 60 days, and a new application is only possible after a year.
Key takeaways
- The deadline to respond to a suspension is 20 working days from the date of the letter, extended only in exceptional circumstances.
- During a suspension, workers carry on working, but no new CoS can be assigned.
- With a B-rating, the action plan must be accepted and paid for (£1,579) within 10 working days, and it lasts 3 months.
- After a revocation, uninvolved workers’ permission is normally shortened to 60 calendar days; a temporary exception for care workers applies from September 2026.
- There is no appeal against revocation; judicial review must be brought within three months at the latest.
- A new application is possible after at least 12 months, or 24 months after a second revocation.
This page is for general information only and does not constitute individual legal advice. Home Office rules change regularly and every case turns on its own facts, so decisions about your licence and your workers’ visas should be made after a review of your circumstances. For other immigration routes, see UK immigration and visas.
