UK Sponsor Licence Applications
The Process, the Evidence, and Why Nearly Half of Applications Fail
The Uncomfortable Truth
Most guides to sponsor licence applications read like government forms rewritten by marketing departments. They tell you what documents you need. They explain the process. And then your application joins the pile that gets refused.
We think you deserve better than that. So before we explain how to make a successful sponsor licence application, we need to tell you why nearly half of all applications fail — and why the Home Office has doubled the rate at which it revokes licences from employers who managed to get one.
44% of sponsor licence applications failed or were withdrawn in the year to June 2025
That statistic should change how you think about this process. A sponsor licence application is not a form-filling exercise. It is the Home Office deciding whether to trust you with a slice of immigration enforcement. They are not looking for reasons to approve you. They are looking for reasons to refuse.
Why the Home Office is Getting Serious
Between July 2024 and June 2025, the Home Office revoked 1,948 sponsor licences—more than double the previous year, and seven times more than in 2021-22. The sectors hit hardest were adult social care, hospitality, retail, and construction.
This is not random enforcement. It reflects genuine abuse of the system—employers who underpaid workers, created fictitious vacancies, or used sponsorship to circumvent immigration rules. The political pressure to crack down is intense, and improved data sharing between government departments means problems that once went unnoticed now trigger investigations.
What this means for you: even if you are a legitimate employer with genuine vacancies, you are applying into an environment of heightened scrutiny. The Home Office is not assuming good faith. You need to prove it.
What the Home Office is Actually Looking For
The formal eligibility criteria are straightforward. You must be a genuine organisation operating lawfully in the UK. You must have genuine vacancies that meet skill and salary thresholds. You must be capable of meeting your compliance duties.
But here is what those criteria actually mean in practice.
The Genuine Organisation Test
The Home Office wants evidence that you are a real, trading business—not a shell company, not a dormant entity, and not a vehicle created primarily to sponsor visas. They will check Companies House, your bank statements, your PAYE records, and your physical premises.
If you are a new business, this is harder. Startups without 18 months of trading history face additional scrutiny. You can still apply, but expect more questions and potentially a pre-licence compliance visit.
The Genuine Vacancy Test
This is where many applications fail. The Home Office is specifically looking for roles that appear to have been created solely to obtain visas. Red flags include:
- Job descriptions that look like generic templates
- Roles that do not clearly fit into your business operations
- Salaries that exactly match minimum thresholds with no business justification
- Multiple vacancies for the same role with no explanation of business need
- Sponsored workers placed with third parties rather than working for you directly
For every role you intend to sponsor, you should be able to explain—with evidence—why this role exists, why you cannot fill it from the resident labour market, and exactly what the sponsored worker will do day-to-day.
The Compliance Capability Test
A sponsor licence is not a one-time approval. It is a commitment to act as a compliance partner with the Home Office for up to ten years. You must demonstrate that you have the HR systems, processes, and personnel to meet your ongoing duties.
This means:
- Recording and retaining documents for every sponsored worker
- Tracking attendance, absences, and changes in circumstances
- Reporting to the Home Office within strict timeframes when things change
- Being ready for an unannounced compliance visit at any time
The Home Office will assess whether your systems are up to this. If they are not confident, they will refuse your application—even if everything else is in order.
The Evidence That Actually Matters
There is no standard checklist. The documents you need depend on your organisation type, sector, and the visa routes you are applying for. But you will typically need to provide at least four pieces of evidence, and you have only five working days to submit them after completing the online form.
This is not the time to scramble. You should have everything ready before you start the application.
Core Documents
Bank statements: From a UK business bank account, covering the last three months, showing your business name and regular trading activity.
PAYE evidence: Recent payslips, P60s, or HMRC correspondence showing you have employees on the payroll. If you use a payroll bureau, you need their headed letter confirming arrangements.
Employer’s liability insurance: A current certificate showing at least £5 million cover. This is a legal requirement for most UK employers and non-negotiable for sponsorship.
Premises evidence: A lease, utility bill, or business rates statement showing your UK address. Virtual offices are generally not acceptable.
Sector-Specific Requirements
Some sectors require additional evidence. Care homes need CQC registration. Educational institutions need relevant accreditation. Regulated professions may need evidence of professional body membership or licensing.
If you deploy workers to client sites—common in IT, consulting, and construction—expect additional scrutiny. You may need to provide client contracts, statements of work, and evidence that you (not the client) maintain day-to-day control over the worker.
What Good Evidence Looks Like
The Home Office is reading your documents as a sceptic. They want to see consistency across sources—your bank statements should match your claimed business activity, your premises should be appropriate for your stated operations, your job descriptions should match genuine business needs.
Discrepancies get noticed. A software company operating from a residential address raises questions. A small business seeking to sponsor ten workers with identical job descriptions looks suspicious. Evidence that contradicts your application narrative will likely result in refusal.
Key Personnel: Your Weakest Link
Every sponsor licence must name specific individuals who will be responsible for managing it. These are not ceremonial roles. The Home Office holds them personally accountable for compliance, and problems with key personnel are a common reason for refusal.
The Roles You Must Fill
Authorising Officer: A senior person with ultimate responsibility for the licence and all immigration compliance. This should be a director, owner, or senior manager—someone with real authority in the organisation.
Key Contact: The main point of communication with the Home Office. Can be the same person as the Authorising Officer in smaller organisations.
Level 1 User: Responsible for daily management of the Sponsorship Management System (SMS). Can assign Certificates of Sponsorship and submit reports.
The Requirements That Trip People Up
Key personnel must:
- Be based in the UK
- Have no unspent criminal convictions for immigration offences, fraud, or dishonesty
- Be on your payroll (not external consultants, with limited exceptions)
- Not be related to any worker you intend to sponsor
That last point catches people. If your business is family-run and you want to sponsor a relative, you cannot also be a key person on the licence. The Home Office will check.
Appointing unsuitable key personnel is one of the most common reasons for refusal. Before you apply, verify that everyone you intend to name actually meets these requirements.
Why Applications Get Refused
Understanding the common failure modes helps you avoid them. Based on Home Office data and our experience, these are the issues that sink applications:
Documentation Failures
- Submitting fewer than four supporting documents
- Documents that are outdated, illegible, or in the wrong format
- Evidence that does not match your stated business activities
- Missing translations for documents not in English
- Bank statements from personal rather than business accounts
HR System Failures
- No clear process for right-to-work checks
- No system for tracking sponsored worker attendance
- No procedure for reporting changes to the Home Office
- Records that would not survive an audit
Business Credibility Failures
- Insufficient evidence of genuine UK trading
- Premises that do not match claimed business operations
- Job descriptions that appear designed to meet visa requirements rather than business needs
- No clear explanation of why roles cannot be filled locally
Personnel Failures
- Key personnel with relevant criminal convictions
- Key personnel who are not genuinely based in the UK
- Key personnel who are related to proposed sponsored workers
- Previous non-compliance by individuals named in the application
What Happens If You Are Refused
There is no right of appeal against a sponsor licence refusal. No administrative review. If your application is refused, your options are limited:
- If the refusal was due to a minor administrative error, you may be able to reapply immediately
- For substantive refusals, a cooling-off period applies—typically six months
- For serious non-compliance issues, bans of up to five years can be imposed
- You lose the entire application fee regardless of the reason for refusal
Judicial review is theoretically possible but rarely practical. The better strategy is to get the application right first time.
£536 – £1,476 Application fee lost if refused (depending on organisation size)
A refusal also goes on your record. If you reapply later, the Home Office will see the previous refusal and may apply greater scrutiny. First applications that fail make second applications harder.
The Compliance Commitment
If your application succeeds, your obligations are just beginning. A sponsor licence is valid for up to ten years, and throughout that period you must:
Record-Keeping Duties
- Maintain copies of passports, visas, and right-to-work evidence for all sponsored workers
- Keep records of contact details, job titles, salaries, and working hours
- Retain evidence of recruitment processes and genuine vacancy assessments
- Store records securely and make them available on request
Reporting Duties
- Report within 10 working days if a sponsored worker does not start work, stops attending, or leaves employment
- Report changes to sponsored worker details—address, job title, salary, work location
- Report changes to your organisation—new addresses, ownership changes, mergers
- Report if you suspect a sponsored worker is breaching visa conditions
Compliance Visit Readiness
The Home Office can visit your premises at any time, without notice. During a visit, they may ask to see:
- Personnel files for sponsored workers
- Evidence of right-to-work checks
- Records of absences and attendance
- Your HR systems and processes
- Physical working conditions
If a visit reveals non-compliance, your licence can be suspended immediately. You then have a limited window to address the issues before revocation.
The Rule That Catches Employers Out
From 1 January 2025, any attempt to recover sponsorship costs from sponsored workers—including the licence fee, Certificate of Sponsorship fee, or Immigration Skills Charge—will result in automatic licence revocation.
This is not negotiable. Passing these costs to workers, whether through salary deductions, contractual terms, or any other mechanism, will cost you your licence.
How We Can Help
At Migrant Law Partnership, we guide employers through the sponsor licence process from initial assessment to successful grant. Our service includes:
- Comprehensive eligibility assessment before you commit to an application
- Document review and gap analysis to ensure your evidence meets Home Office standards
- Application preparation and submission management
- Key personnel briefing on their roles and responsibilities
- HR systems review to ensure compliance readiness
- Guidance on post-grant obligations and compliance management
We also offer ongoing compliance support for organisations that want expert oversight of their sponsor licence duties—reducing the risk of the mistakes that lead to suspension or revocation.
Get in Touch
If you are considering applying for a sponsor licence, or if you have questions about your eligibility or the process, contact us for an initial consultation.
Migrant Law Partnership
Email: hello@migrantlaw.co.uk
Web: www.migrantlaw.co.uk
This guide is for general information only and does not constitute legal advice. Immigration rules change frequently, and the information here may not reflect the most recent updates. For advice specific to your circumstances, please contact us directly.
© Migrant Law Partnership 2026