The Government has repeatedly stated that its reforms to the immigration system are intended to reduce reliance on overseas recruitment and encourage greater investment in the domestic workforce. Few sectors, however, illustrate the tension between immigration policy and economic reality more starkly than adult social care.

A recent UNISON report warns that the latest immigration changes are already worsening staffing shortages across the care sector, with employers struggling to recruit sufficient workers to meet growing demand. The union argues that restricting overseas recruitment, without first addressing longstanding issues around pay, conditions and retention, risks exacerbating an already fragile workforce crisis.

While the debate often focuses on the closure of overseas recruitment routes, there is another issue receiving far less attention but which is having an equally significant impact: the sharp increase in Home Office compliance action against care sector sponsors.

1. The Care Sector Has Become the Focus of Sponsor Compliance

Over the past 18 months, we have seen an unprecedented increase in sponsor licence compliance activity across the care sector. Care providers are experiencing:

• unannounced compliance audits;
• extensive requests for payroll, rota and HR records;
• suspension of sponsor licences;
• revocation of sponsor licences; and
• increasingly detailed scrutiny of salary calculations, contracted hours, and genuine vacancy / eligible role requirements.

Many of these investigations concern employers who have held sponsor licences for several years and who have continued to provide much-needed care services throughout that period.

A revoked sponsor loses the ability to sponsor migrant workers. Although sponsored employees would ordinarily face cancellation or curtailment of their immigration permission, the Home Office has introduced a temporary exception for eligible care workers and senior care workers where licence revocation is the sole ground for cancellation. Nevertheless, affected workers still face considerable uncertainty about their employment and future sponsorship. Recruitment plans can collapse overnight, leaving providers unable to replace experienced staff.

A temporary reprieve for care workers affected by sponsor licence revocation

In September 2026, the Home Office introduced an important temporary protection for care workers and senior care workers whose employers have had their sponsor licences revoked.

Under the updated Cancellation and Curtailment of Permission guidance, published for Home Office caseworkers on 11 September 2026, caseworkers are instructed not to cancel a worker’s immigration permission where they hold permission under the Skilled Worker or Health and Care Worker route in an eligible care worker or senior care worker occupation, and the sole reason for cancellation would be their employer’s sponsor licence revocation.

The protection applies to care workers under SOC codes 6135 and 6145, and senior care workers under SOC codes 6136 and 6146, reflecting both the current and previous occupational classifications.

This represents a significant departure from the usual position following sponsor licence revocation. Ordinarily, where a sponsored worker has not been complicit in the circumstances leading to revocation, the Home Office will normally shorten their immigration permission to 60 days, requiring them to secure alternative sponsorship, obtain permission under another immigration route or leave the UK.

The temporary arrangement therefore provides important breathing space for affected care workers. Rather than facing automatic cancellation solely because their employer has lost its sponsor licence, eligible workers can retain their existing immigration permission, subject to its original expiry date and the continued application of other cancellation grounds.

However, the protection has important limitations. It does not prevent cancellation where other grounds apply, nor does it reinstate the revoked sponsor licence or authorise the former employer to continue sponsoring workers. The Home Office has also expressly confirmed that the arrangement is temporary and subject to regular review.

The change is nevertheless a welcome acknowledgement of the particular difficulties facing internationally recruited care workers. Many have invested considerable resources in relocating to the UK, only to find their immigration status placed at risk by compliance failures attributable to their employers. It also raises a wider policy question. If the Government recognises that sponsor licence revocations are displacing care workers on such a scale that special immigration protections are necessary, greater consideration must surely be given to the wider consequences of enforcement action for the care sector.

Protecting workers from immediate immigration cancellation is an important step. However, it does not resolve the underlying difficulties facing care providers, nor does it replace the need for a sustainable workforce strategy that balances effective sponsor compliance enforcement with continuity of care.

2. Compliance Readiness is Essential

One of the most common issues we encounter is that providers are unaware of compliance concerns until they receive correspondence from the Home Office. Unfortunately, by that stage, opportunities to resolve issues proactively may be limited. Increasingly, compliance officers are scrutinising:

• whether sponsored workers are receiving the salary stated on their Certificates of Sponsorship;
• whether salaries continue to satisfy the applicable salary thresholds;
• payroll records and HMRC submissions;
• contracted hours and rota records;
• absences, unpaid leave and changes to working patterns;
• reporting on the Sponsor Management System; and
• wider HR systems, right to work records and record-keeping practices.

Many compliance issues do not arise because employers deliberately breach the Rules. Instead, they develop gradually. Payroll calculations may not be reviewed following annual salary increases. Working hours may change without corresponding updates to sponsorship records. Reporting obligations may be overlooked during periods of rapid business growth. Small administrative errors can accumulate over time until they become significant compliance concerns. In an increasingly robust enforcement environment, these issues can have serious consequences.

3. Why Internal Compliance Audits Matter

Too many providers only begin reviewing their systems once the Home Office has already contacted them. By then, the business is often responding to an investigation rather than preventing one. Regular internal compliance audits provide an opportunity to identify and rectify issues before they become the subject of Home Office scrutiny.

A comprehensive audit should review:

• sponsorship records and reporting history;
• payroll systems and salary compliance;
• HR procedures and record keeping;
• right to work processes;
• recruitment practices;
• absences and changes to employment conditions; and
• governance surrounding sponsor licence management.

Compliance should not be viewed as a one-off exercise undertaken when applying for a sponsor licence. It should form part of the organisation’s ongoing governance framework.

Internal compliance audits are therefore an essential part of modern sponsor licence management. However, compliance is no longer simply an issue of regulatory governance for individual providers. When considered alongside recent immigration reforms restricting overseas recruitment, the increasing number of sponsor licence revocations raises broader questions about the future resilience of the adult social care workforce.

4. The Wider Workforce Impact

These developments cannot be viewed in isolation. They interact with wider changes to the immigration system in ways that may have significant consequences for the care sector.

The Government’s immigration reforms have already substantially reduced the number of new overseas care workers entering the UK. At the same time, increasing numbers of existing sponsors are either leaving the sponsorship system voluntarily or losing their licences following compliance action. These developments reinforce one another. Demand for adult social care, however, has not reduced. The UK’s ageing population continues to grow, increasing the need for both residential and domiciliary care services. Yet the pool of employers able to recruit overseas workers is becoming progressively smaller.

These wider consequences should therefore form part of the policy debate when considering how best to balance robust immigration enforcement with the continued delivery of essential care services. 

Every sponsor licence revocation removes another employer from an already stretched sector. Where that provider delivers care to vulnerable individuals, the consequences extend well beyond immigration law. Existing staff may lose their sponsored employment, recruitment becomes more difficult, service users may experience disruption, and local authorities can be required to source alternative provision. These wider consequences should form part of the broader policy discussion.

5. The Reality Facing Care Providers

Many providers are attempting to navigate an increasingly complex operating environment. They face rising employment costs, increasing National Living Wage obligations, significant recruitment challenges and ever more demanding sponsor compliance requirements. At the same time, the Home Office has adopted a markedly more rigorous approach to sponsor compliance.

Providers therefore find themselves under pressure from both directions: fewer opportunities to recruit overseas workers, and greater regulatory risk for those who continue to sponsor them.

6. Looking Ahead

The Government’s objective of reducing reliance on overseas labour is understandable. In the long term, improving pay, conditions and career progression within social care should reduce dependence on international recruitment. The difficulty is that this transition cannot happen overnight.

Until the domestic workforce is able to meet demand, overseas workers remain a critical part of the care sector. Removing recruitment routes while simultaneously reducing the number of licensed sponsors risks creating a gap that the domestic labour market is simply not yet equipped to fill.

The Home Office’s recent decision to temporarily protect care workers from immigration cancellation following sponsor licence revocation demonstrates that the Government is beginning to recognise the human consequences of its enforcement policies. However, protecting an individual’s immigration permission does not, by itself, preserve their employment or ensure continuity of care. The challenge is therefore not simply to protect displaced workers, but to ensure that the immigration system does not inadvertently deepen an existing workforce crisis.

Immigration policy does not operate in a vacuum. It has direct consequences for employers, sponsored workers and, most importantly, the vulnerable people who rely on care services every day.

As compliance activity continues to intensify, policymakers should ensure that enforcement remains proportionate and targeted. Protecting the integrity of the sponsorship system is important. Equally important is ensuring that legitimate care providers are able to continue delivering the essential services upon which thousands of people across the UK depend.

7. Contact our Immigration Barristers

We routinely assist sponsors, particularly in the care industry, with audit readiness and preparation. We can work with your company to ensure that your practices, policies, and procedures are compliant with your duties as sponsors. 

For expert advice regarding managing your sponsor licence, compliance issues, suspension or revocation notices,  contact our immigration barristers on 0203 617 9173 or complete our enquiry form below.

8. Frequently Asked Questions

Can a care worker continue working for an employer whose sponsor licence has been revoked?

The temporary protection prevents eligible care workers from having their permission cancelled solely because of sponsor licence revocation. It does not restore the employer’s licence or allow the employer to continue sponsoring workers.

Can a care worker whose sponsor licence has been revoked move to a new sponsor?

Potentially, yes. The worker will need a new licensed sponsor and must meet the relevant Skilled Worker requirements before moving to the new sponsored employment.

Can UK care providers still sponsor new care workers from overseas?

Generally, no. For care workers and senior care workers in occupation codes 6135 and 6136, applications must now be for permission to stay in the UK and satisfy the applicable transitional requirements.

Does a new sponsor for a care worker need to be registered with the CQC?

In England, a sponsor employing a care worker or senior care worker under occupation code 6135 or 6136 will generally need to be carrying on a regulated activity and hold the required Care Quality Commission registration.

Can a care worker start working for a new sponsor as soon as they receive a Certificate of Sponsorship?

A new Certificate of Sponsorship does not by itself authorise a change of employer. The worker must make the required immigration application and comply with the conditions governing when they may start the new sponsored employment.

What is the difference between sponsor licence suspension and revocation?

Suspension allows the Home Office to investigate while the licence remains suspended, and the sponsor cannot normally assign new Certificates of Sponsorship. Revocation ends the licence and the organisation can no longer sponsor workers.

What happens to a pending visa application if the sponsor’s licence is revoked?

A worker with a pending application may need to vary their application, for example by relying on a different sponsor. If they do not do so before a decision is made, the application may be refused.

Can a care provider appeal against the revocation of its sponsor licence?

There is no right of appeal against sponsor licence revocation. A sponsor will also normally face a cooling-off period of at least 12 months before it can apply for another licence.

Can a care provider recruit workers displaced by another sponsor’s licence revocation?

Potentially, yes. An affected care worker may be able to move to another licensed sponsor if they qualify for further permission under the Skilled Worker route and the new sponsored role meets the applicable requirements.

Does the temporary protection for care workers apply if there are other reasons to cancel their permission?

No. The protection applies where sponsor licence revocation is the sole reason for cancellation. If another cancellation ground applies, the Home Office can consider cancellation under the usual rules.