Sponsor Licence Action Plan: What a B-Rating Requires
An action plan is not a warning before a downgrade. It is the thing a downgrade to a B-rating obliges you to buy and follow: £1,579, payable within 10 working days, running for a fixed 3 months, during which no new worker can be sponsored. This guide sets out the published terms and the three ways it can end.
- Section
- Employers & Sponsors
- Reading time
- 10 min
- Last checked
- 17 March 2026
- Source
- The published Immigration Rules and GOV.UK guidance, linked throughout this guide.
- Rowan does not
- Look at your own case, tell you which route to choose, or say what the Home Office will decide. This guide shows the published rules and where to read them.
In short
- An action plan comes with a B-rating; the downgrade has already happened.
- The fee is £1,579, payable within 10 working days of the notification.
- Not paying, or ignoring the notification, means the licence is revoked.
- Every action plan runs for a fixed 3 months. There is no longer period.
- No certificates for new workers during the plan — existing workers extending only.
- B-rating is available twice in a rolling 4-year period; a third time is revocation.
An action plan follows a downgrade to a B-rating. The fee is £1,579 and must be paid within 10 working days of the notification, or the licence is revoked. The plan runs for a fixed 3 months, during which the sponsor cannot assign certificates to new workers. At the end, a compliance check restores the A-rating, requires a second plan and a second fee, or revokes the licence.
An Action Plan Comes With a Downgrade
It is easy to read an action plan as a warning that arrives before anything happens to the licence. It is not. Part 3 of the sponsor guidance ties the two together: “If you are downgraded to a B-rating, you must adhere to an action plan, which will set out the steps you must take to return to, or achieve, an A-rating.” The rating has already changed by the time the plan exists.
The guidance calls a B-rating “a transitional rating”: the sponsor must improve enough to be upgraded “within a specified time limit, not exceeding 3 months”, and if it does not, “your licence will be revoked”.
Not every failure gets a plan. The guidance says that in more serious cases the Home Office will suspend or revoke the licence instead, without offering one. See part 3 of the sponsor guidance for the compliance duties themselves.
The Fee, and the 10 Working Days
The action plan fee is £1,579. The Home Office notifies the B-rating in writing and requests payment. The guidance sets out three possible responses:
- Pay within 10 working days, through the ‘Action plan details’ function in the sponsorship management system. The sponsor stays licensed and the plan begins
- Decline to pay. A sponsor that is not sponsoring any workers can surrender its licence instead: select ‘decline’ in the ‘Action plan payments’ function, and return the signed declaration attached to the decision letter within 10 working days. Declining without returning the declaration means revocation
- Do nothing. The guidance is blunt: ignoring the notification, or not paying within 10 working days, means “we will revoke your licence”
The plan itself is sent after the fee is paid, not before. It sets out the steps required — the guidance gives improving record-keeping, tightening control over who assigns certificates, and improving communication between branches so the organisation knows when a sponsored worker has not turned up, as examples.
What Gets Put on One
The steps address the failures found. The recurring categories:
Record-Keeping Failures
- Missing copies of passports, visas, or right-to-work documents
- No records of employees' contact details or attendance
- Failure to maintain copies of Certificates of Sponsorship
Reporting Failures
- Not reporting an absence from work without permission of more than 10 consecutive working days
- Not reporting changes to a sponsored worker's job title, salary, or work location
- Not reporting when a sponsored worker leaves the organisation
HR System Deficiencies
- No system for tracking visa expiry dates
- No process for conducting right-to-work checks
- No designated person responsible for compliance duties
What You Cannot Do While the Plan Runs
The guidance restricts the licence for the 3 months:
- No new branches, and no new route added to the licence
- No certificate of sponsorship for any new worker. Assigning one anyway means revocation — the guidance says the Home Office “will closely monitor” certificates assigned while B-rated, whether during the plan or afterwards
- Certificates for workers already being sponsored on a Worker or Temporary Worker route, who need to apply for permission to stay, are still allowed. The Home Office sets how many under the terms of the plan
Overdue reports still have to be made. The sponsorship management system stays available for the reporting duties throughout — see our guide to the sponsorship management system.
How It Ends: Three Outcomes
The 3 months are followed by a compliance check. The guidance lists exactly three results:
- A-rating restored. Every requirement met and no other concerns. The certificate allocation is reviewed so the sponsor can sponsor new workers again
- A second action plan, and a second fee. Where other areas of non-compliance have appeared that the current plan does not cover, and they do not warrant suspension or revocation
- Revocation. Where the requirements of the plan were not met, or more serious non-compliance is found. See our guides on suspension and revocation
A sponsor can ask for the compliance check before the 3 months are up. The guidance warns that the same three outcomes apply to an early check, whether or not the period has ended, so asking early when the requirements are not yet met invites the revocation outcome rather than deferring it.
How Often This Can Happen
A sponsor can be B-rated and on an action plan for a maximum of 3 months at a time, and twice in any rolling 4-year period. The 4-year period runs from the date the licence was first granted, and then in successive 4-year blocks. If the grounds for a downgrade are met a third time within one of those periods, the guidance says the licence is revoked rather than downgraded again.
The Duties the Plan Measures You Against
An action plan does not invent new obligations; it names the ones already being missed. The published deadlines are:
- 10 working days to report a change affecting a worker — not starting within 28 days, an unauthorised absence of more than 10 consecutive working days, more than 4 weeks unpaid or reduced pay in a calendar year, a change of role, salary or location, or sponsorship ending
- 20 working days to report a change to the organisation
- The right to work check before the worker starts, with records kept for the whole of the employment and 2 years after it ends
- Appendix D records kept throughout the sponsorship and until a year after it ends, or until a compliance officer has examined and approved them
Our compliance duties guide sets these out in full.
Next Steps
The two dates that matter first are the 10 working days for the fee and the 3 months of the plan. An adviser regulated by the Immigration Advice Authority, or a solicitor, can act on a particular case; Rowan sets out the published rules only.
Related guides:
Questions and answers
What is a sponsor licence action plan?
It is what comes with a B-rating. The sponsor guidance says: "If you are downgraded to a B-rating, you must adhere to an action plan, which will set out the steps you must take to return to, or achieve, an A-rating." It is not a warning issued before a downgrade — the downgrade has already happened.
How much does an action plan cost, and when is it due?
£1,579. The Home Office notifies the B-rating in writing and requests the fee, which must be paid within 10 working days through the sponsorship management system. Ignoring the notification, or not paying in time, means the licence is revoked.
How long does an action plan last?
The guidance is exact: "All action plans are set for a fixed period of 3 months." There is no extension. A compliance check follows at the end, or earlier if the sponsor asks for one — and an early check produces the same three outcomes as an end-of-period check, whether or not the 3 months have run.
Can I sponsor new workers during the action plan?
No. During the action plan you cannot assign a certificate of sponsorship to any new worker, and you cannot add branches or a new route to the licence. You can assign certificates to workers you were already sponsoring who need to apply to stay, within an allocation the Home Office sets under the plan's terms. Using one of those certificates for a new worker means revocation.
How many times can this happen?
Twice in any rolling 4-year period, counted from the date the licence was first granted. If the grounds for a downgrade are met a third time in that period, the licence is revoked instead.
This guide is general information about published immigration rules. It is not advice about an individual application under s.82 Immigration and Asylum Act 1999, and Rowan is not regulated by the Immigration Advice Authority. Immigration rules change several times a year. For advice on a particular situation, contact an adviser authorised by the Immigration Advice Authority or an immigration solicitor. Always check GOV.UK for the authoritative current rules.