Sponsor licence compliance in 2026: what the record revocation figures mean for UK employers

In 2025, the Home Office revoked 3,100 sponsor licences, the highest annual figure since the sponsorship system was introduced. In the final quarter of 2025 alone, the number of revocations tripled compared to the previous quarter. This reflects a deliberate and sustained intensification of enforcement activity that shows no sign of slowing in 2026.

Why revocations are rising: the data-sharing factor

The sharp rise in revocations is driven by increased data-sharing between the Home Office and HMRC. This means the Home Office can now identify discrepancies between the salary declared on a Certificate of Sponsorship and the wages actually paid to a sponsored worker, without needing to visit the employer’s premises at all. 

From 8 April 2026, salary compliance has been tightened further, sponsors must now ensure that the required salary is met in each individual pay period, not just as an annual average.

Which sectors are most affected

The sectors most heavily targeted in the Home Office’s enforcement surge were social care, hospitality, retail, and construction. These are sectors with variable pay, high staff turnover, irregular working patterns, and significant reliance on overseas recruitment, precisely the circumstances where the gap between CoS salary and actual pay is most likely to arise.

The new salary compliance rules in detail

Under the new rules:

• Sponsors must ensure the required salary is paid in each pay period, not merely across the year as a whole
• For monthly-paid workers, UKVI will check that total pay in any three-month rolling period meets at least 25% of the annual CoS salary
• Variable pay, shift patterns, and irregular earnings will all be examined more closely
• Deductions that reduce pay below the CoS minimum in any single period can constitute a compliance breach

Record-keeping: the most avoidable compliance failure

Poor record-keeping remains the single most common reason cited in suspension and revocation decisions. The Home Office expects sponsors to maintain:

• Right-to-work check records, properly dated and signed, for every sponsored worker
• Evidence that salary payments match the CoS declaration, for each pay period
• Contact details for all sponsored workers, updated within 10 working days of any change
• Absence records including all periods of authorised and unauthorised absence

Updated sponsor guidance from March 2026 also introduced a new requirement: sponsors must now retain evidence that they have provided sponsored workers with information about their employment rights in the UK.

What proactive sponsors should be doing now

• Carry out a full audit of your sponsored workers’ payroll records against their CoS salary declarations
• Review the per-pay-period position for any worker on variable hours or irregular pay
• Ensure your Sponsor Management System records are fully up to date for every sponsored worker
• Train your Level 1 and Level 2 SMS users on the updated compliance requirements
• Consider whether a formal immigration audit is warranted

How Davenport Solicitors can help

At Davenport Solicitors, we provide sponsor licence compliance reviews, immigration audits, and SMS Level 1 and Level 2 User Training for employers across all sectors. We also advise on sponsor licence suspension and revocation, and represent employers in Home Office proceedings. Call us on 020 7903 6888 or email contact@davenportsolicitors.com