Sponsor licence compliance for care providers.

Who this applies to, and what changed in 2025

This applies to any care provider holding a sponsor licence for overseas staff under the Skilled Worker or Health and Care Worker routes. In England, a provider must be CQC-registered to sponsor care roles.

Two changes reshaped this area:

• New overseas recruitment of care workers and senior care workers ended on 22 July 2025. Limited in-country switching arrangements run transitionally to 22 July 2028, and they are narrow. In practice this means sponsor compliance is now mostly about managing the workers you already sponsor, not bringing in new ones.
• From 9 April 2025 you cannot pass sponsorship costs to the worker. That covers the sponsor licence fee, the Certificate of Sponsorship fee and the Immigration Skills Charge, whether charged directly or recovered later through a clawback clause in a contract.

If your employment contracts still contain a clawback clause covering those costs, that is worth checking now.

The four core sponsor duties

Everything the Home Office expects of you falls into four groups.

Reporting deadlines: 10 and 20 working days

This is where most providers come unstuck, because the clock is short and it runs in working days, not calendar days.

Within 10 working days

• A sponsored worker does not turn up for their first day
• They are absent without permission for more than 10 consecutive working days
• Their employment ends early, or you stop sponsoring them for any reason
• Their job, duties or occupation code changes
• Their salary drops below the level stated on the Certificate of Sponsorship
• Their work location changes
• Unpaid leave or reduced pay exceeding four weeks in a year

Within 20 working days

• Changes to your organisation: trading address, new branches, mergers, takeovers or insolvency
• Changes to key personnel, including your Authorising Officer

As soon as reasonably practicable

• Suspicion that a worker is breaching the conditions of their stay or involved in criminal activity

What happens when you get it wrong

The Home Office carries out announced and unannounced compliance visits, and enforcement in the care sector has been active. Roughly 1,600 to 2,000 sponsor licences were revoked across all sectors between July 2024 and June 2025, with adult social care a significant focus.

The penalty ladder runs in one direction:

Separately, employing someone without a compliant right to work check carries a civil penalty of up to £60,000 per worker.

For a care provider that depends on sponsored staff, revocation is not an administrative inconvenience. It can end the business.

The small things that actually lose licences

Licences are rarely lost through deliberate wrongdoing. They are lost through ordinary administrative slips in a service that was busy delivering care:

• A reportable change noticed late. Someone leaves, or moves site, and the 10 working days pass before anyone logs it in the Sponsorship Management System.
• A right to work follow-up check that lapsed, because nobody was tracking the expiry date of time-limited permission.
• Appendix D records that are incomplete, most often out-of-date contact details, which are easy to overlook and explicitly required.
• Absence not tracked, so the 10-consecutive-working-day threshold is crossed without anyone noticing it became reportable.
• Evidence held by one person. If only the registered manager knows where the sponsor file lives, an unannounced visit during their leave is a problem.

Every one of those is a diary and record-keeping failure rather than a judgement failure. Which is precisely why they are preventable.

A practical monthly checklist

1. Review expiry dates. List every sponsored worker's visa expiry and right to work follow-up date, and look at anything falling due in the next 90 days.
2. Check for unreported changes. Any leavers, role changes, salary changes, site moves or long absences since last month, and whether each was reported in time.
3. Spot-check Appendix D records for two or three workers, especially contact details.
4. Confirm absence records are current, so you would see a 10-day threshold approaching.
5. Check who else can access the sponsor file if your key person is away.

Done monthly, this takes under an hour and catches almost everything that leads to enforcement.