Suspension first, usually

UKVI suspends a licence where it has reasonable grounds to suspect a breach of sponsor duties, a threat to immigration control, or non-conducive behaviour, pending investigation.

While suspended:

• No new Certificates of Sponsorship can be assigned
• CoS already assigned remain valid
• Existing workers are unaffected during the suspension

You normally get 20 working days to respond in writing. That response is the whole case — there is no appeal afterwards.

Three outcomes: reinstatement; reinstatement with a downgrade to B-rating and a mandatory action plan, which carries a fee; or revocation.

Revocation: the three annexes

The sponsor guidance groups grounds by how much discretion UKVI has.

Annex C1 — revocation is mandatory. No discretion.

• The sponsored worker's role does not match the occupation code or job description on the CoS
• Evidence of immigration abuse
• Deception or fraud in the application
• Specified criminal convictions

The first of these is the one that catches ordinary, well-meaning employers. A role that drifts from what was described on the CoS, or a job title that does not match the SOC code, is a mandatory revocation ground — not a conversation.

Annex C2 — revocation is likely.

• Serious or systematic failures of sponsor duties
• No longer meeting the eligibility requirements
• Non-conducive behaviour
• Employing illegal workers without proper right-to-work checks

Annex C3 — revocation is possible.

• Minor compliance breaches
• Incomplete or unverifiable information
• Failure to maintain required registration or accreditation

Other recurring grounds

• Failure to maintain Appendix D records or to discharge reporting duties
• Misuse of Certificates of Sponsorship
• Salary or role non-compliance
• Failure to notify organisational change
• Poor engagement with the Home Office
• Ceasing to trade
• Inadequate HR systems
• Passing the sponsor licence fee, CoS fee or Immigration Skills Charge on to the worker

That last one is worth isolating. It is not an obscure technicality — it appears repeatedly in revocation decisions, and a clawback clause in an employment contract is discoverable at a compliance visit.

Compliance visits

Triggers: reasonable suspicion of a breach · verification of information given in a licence or CoS application, including pre-licence visits · a perceived threat to immigration control · suspected non-conducive behaviour · a previous record of poor compliance.

Visits may be announced or unannounced. Officers may:

• Interview your staff and the sponsored workers
• Inspect records and HR systems
• Photograph the premises
• Carry out criminal background checks
• Verify the organisation is genuinely trading and the sponsored roles genuinely exist as described

You must cooperate fully, and you must secure access to third-party premises where sponsored workers are placed. If you supply workers to client sites, that is your obligation to arrange.

What happens to your workers

This is the consequence employers underestimate.

On revocation, sponsored workers' permission is curtailed to 60 days, or to the remainder of their existing leave if that is less than 60 days.

Within that window each worker must find a new licensed sponsor and apply to switch, apply under a different route, or leave the UK. They may continue working for you only while their permission remains valid.

For a business with a dozen sponsored staff, revocation is not a licensing problem. It is the loss of a dozen employees inside two months.

The 60-day figure is well established in practice, though it derives from separate curtailment guidance rather than the sponsor guidance itself.

No appeal

There is no right of appeal against refusal, suspension or revocation.

The only challenge route is judicial review — narrow in scope, and subject to strict time limits: promptly, and in any event within 3 months. A pre-action protocol letter is the usual first step. An internal error-correction process exists for limited circumstances.

This is why the 20-working-day response to a suspension matters so much. It is realistically your only opportunity to put your case.

Cooling-off before reapplying

Circumstance	Period
Standard revocation	12 months
Repeat revocation	24 months
Specified civil penalty scenarios	up to 5 years

Staying compliant

1. Audit annually. Check every sponsored worker's actual role against their CoS.
2. Diary the reporting deadlines — 10 working days for worker changes, 20 for organisational ones.
3. Keep Appendix D records current, not reconstructed after the fact.
4. Run follow-up right-to-work checks before permission expires.
5. Keep key personnel current. A departed Authorising Officer is a visible breach.
6. Never recover any sponsorship cost from a worker, in any form.