Sponsor Licence Revocation: What Happens and How to Respond

Why Licences Are Revoked

The Home Office revokes sponsor licences for serious or sustained non-compliance. The most common triggers include:

• Employing illegal workers. If the Home Office discovers you have employees without the right to work, this is one of the most serious offences.
• Sustained failure to meet sponsor duties. Repeated failures to report changes, keep records, or conduct right-to-work checks can result in revocation even without a single catastrophic event.
• Providing false information. If the licence application contained false or misleading information, the Home Office can revoke on discovery.
• Failure to cooperate with compliance visits. Refusing access to Home Office compliance officers or obstructing a visit is grounds for revocation.
• Business ceasing to operate. If the business closes, becomes insolvent, or stops trading, the licence is revoked.
• Having no active Level 1 User. The guidance describes a process for inactive system accounts, and a licence can be revoked for the sole reason that no active Level 1 User remains. This one carries no cooling-off period, so a new application can be made straight away.
• Sham employment. If the Home Office determines that sponsored roles are not genuine, the licence will be revoked.

The full grounds are set out in the sponsor duties and compliance guidance on GOV.UK.

The Revocation Process

Revocation usually follows one of two paths:

Revocation After Suspension

In many cases, the Home Office first suspends the licence while it investigates. No certificate of sponsorship can be assigned during a suspension, but the workers already sponsored keep their permission. If the investigation finds the failures serious enough, the licence is revoked; if it does not, the licence is reinstated.

Immediate Revocation

In the most serious cases, the Home Office may revoke without prior suspension. This typically happens when there is evidence of fraud, illegal working, or other serious criminal conduct.

The 20 Working Days

The suspension letter sets the deadline. Part 3 of the sponsor guidance: “You have 20 working days from the date of the written notification to respond to our letter. This is your opportunity to seek a review of our decision and to set out any mitigating arguments you believe exist.” The response must be in writing, must say which grounds are thought incorrect and why, and must come with the supporting evidence. The guidance adds: “We will not hold an oral hearing.”

If the Home Office identifies additional reasons during that period, it writes again and gives another 20 working days for those. More time is given only where it is satisfied there are exceptional circumstances. If no response arrives in time, the guidance says it will “go ahead with whatever action we believe is appropriate”.

Impact on Sponsored Workers

Revocation has an immediate and serious impact on every worker you sponsor:

• Every sponsored worker’s permission is shortened, normally to 60 calendar days from the date of the curtailment letter — or left as it is, where less than 60 days remained.
• Workers must find a new employer with a sponsor licence willing to sponsor them, switch to a different visa route (if eligible), or leave the UK.
• Workers' dependants are also affected — their visas are linked to the main applicant's.

The workers have done nothing wrong, and the shortening does not depend on anything they did. Our compliance duties guide sets out the duties whose failure leads here.

For workers whose employer's licence has been revoked, see our guide on what to do when your sponsor withdraws or is revoked.

Challenging the Decision

There is no right of appeal against revocation. Your options are:

Pre-Decision Representations

The 20 working days after a suspension letter is the point at which the decision is still open. The guidance calls it the opportunity to seek a review and set out mitigating arguments, and says it is “essential” that all representations relied on, with supporting evidence, are sent in that period.

Judicial Review

You can challenge a revocation by applying for judicial review in the High Court. Judicial review does not reconsider the merits of the decision — it examines whether the Home Office followed the correct process, applied the law correctly, and reached a decision that was not unreasonable. In England and Wales a claim must be filed promptly, and in any event within 3 months of the grounds for the claim arising.

Judicial review is court litigation and needs a solicitor. Rowan sets out published rules; it cannot advise on whether a particular decision is challengeable.

Reapplying After Revocation

Part 1 of the sponsor guidance sets the cooling-off periods. The ones that follow a revocation:

• 12 months from the date of the notice of revocation, for a first revocation — or a licence surrendered while compliance action was under way that would have led to revocation
• 24 months from the most recent such notice, where a licence has been revoked more than once
• No cooling-off period where the sole reason for revocation was the inactive system user account process
• 12 months from the date a civil penalty for employing an illegal worker was paid in full — and an application is always refused while such a penalty is unpaid

The guidance is unforgiving about timing: applying during a cooling-off period means the application is “automatically refused”, even if the reasons behind the period no longer apply. There is no right of appeal against a refusal, though an error correction request can be sent within 14 calendar days where the refusal came from a caseworker error or from evidence not being considered. See our requirements guide for what a fresh application has to show.

The Steps Before Revocation

Revocation is the end of a sequence the guidance sets out, and each earlier step has its own deadline:

• A B-rating and an action plan. £1,579, payable within 10 working days of the notification, then a fixed 3 months. Not paying means revocation
• A limit of two. A sponsor can be B-rated twice in a rolling 4-year period. Meeting the downgrade criteria a third time means revocation instead
• Suspension. Certificates cannot be assigned, and the sponsor has 20 working days to respond in writing
• The duties themselves. 10 working days to report a change affecting a worker, 20 for a change to the organisation, right to work checks before employment starts, and Appendix D records available on request

Next Steps

The deadlines set out above are the ones a sponsor can act on: 10 working days for an action plan fee, 20 working days to respond to a suspension, 14 calendar days for an error correction request after a refusal. The full grounds are in the Home Office guidance and address any gaps before they become problems.

Related guides:

• Sponsor Licence Suspension
• Compliance Duties
• Action Plan Guide
• When Your Sponsor Is Revoked
• Sponsor Licence: Complete Guide

Questions and answers