Sponsor Licence Suspension Successfully Overturned for a Care Sector Provider

Executive Summary

When a UK care provider received a Sponsor Licence Suspension Notice following a Home Office compliance investigation, the business faced the very real prospect of licence revocation.

The Home Office alleged multiple breaches of sponsor duties, including salary compliance concerns, reporting failures, questions over genuine vacancies and allegations that the business may have been operating as a labour supplier.

At the time, the organisation sponsored 33 migrant workers whose ability to remain employed in the UK depended upon the licence being maintained.

Following several rounds of Home Office scrutiny and increasingly extensive information requests, WestBridge Business Immigration was instructed to prepare a comprehensive defence strategy aimed at protecting both the sponsor licence and the continuity of care services.

After a detailed review of the evidence, multiple rounds of legal representations and implementation of targeted compliance improvements, the Home Office reinstated the sponsor licence in full.

The Problem

The Home Office conducted a sponsor compliance visit in November 2025.

Following its review, the Home Office suspended the sponsor licence in February 2026 and stated that the alleged breaches were sufficiently serious to justify revocation.

The primary allegation centred on one sponsored worker, where the Home Office claimed the worker had not been paid in accordance with the salary stated on their Certificate of Sponsorship (CoS).

However, the investigation quickly expanded beyond a single salary concern.

The Home Office further expanded its investigation and raised additional concerns including:

• alleged salary underpayments identified through P60 analysis

  
  

• concerns regarding reduced working hours and SMS reporting

  
  

• whether sufficient genuine work existed for sponsored workers

  
  

• concerns that the business may have been operating as a labour supplier

  
  

• possible breaches of sponsor guidance relating to third-party working arrangements

  
  

The Home Office specifically questioned whether the business genuinely had sufficient work available for all 33 sponsored workers and argued that the sponsor should have had at least 1,190 worker hours available at the time of the compliance visit.

The Home Office pursued the matter aggressively and repeatedly stated throughout the suspension process that the identified breaches were serious enough on their own to justify revocation of the sponsor licence. Following multiple rounds of compliance scrutiny, further allegations and expanded document requests, WestBridge Business Immigration prepared detailed legal representations, coordinated extensive supporting evidence, and advised on immediate compliance remediation measures. Through a rigorous and strategic defence, we successfully demonstrated that the business remained genuine, operational and compliant in substance, ultimately securing full reinstatement of the sponsor licence.

Revocation would have had severe consequences for the business, its sponsored workers, and vulnerable service users dependent on continuity of care.

How WestBridge Business Immigration Helped

WestBridge Business Immigration conducted a full forensic review of:

• payroll records

• Certificates of Sponsorship

• SMS reporting history

• absence records

• medical evidence

• payslips and bank payment confirmations

• operational staffing records

• care delivery evidence

• local authority remittance and invoice data

  
  

During our review, we identified that the Home Office’s salary calculation had relied upon an incorrect hourly rate assumption for the sponsored worker.

We prepared detailed legal and evidential representations addressing every allegation raised by the Sponsor Compliance Team, including:

Salary Compliance Defence

We demonstrated that:

• the worker’s CoS salary had originally been assigned at £12 per hour for 35 hours per week

  
  

• payroll records showed the worker was actually paid at a higher hourly rate than stated on the CoS

  
  

• salary fluctuations arose from medically evidenced absences and reduced working patterns following a back injury

  
  

• the worker remained genuinely employed and paid through PAYE into their personal bank account

  
  

• there was no evidence of sham employment or fabricated payroll activity

  
  

Sponsor Reporting Defence

We advised on the reporting obligations surrounding reduced working hours and sickness absences and prepared representations explaining:

• the sponsor had reported the worker’s medical condition and gradual return to work

  
  

• intermittent absences had been misunderstood as falling outside mandatory reporting thresholds

  
  

• the issue arose from misunderstanding reporting scope rather than deliberate concealment

  
  

Genuine Vacancy & Labour Supply Defence

The Home Office also questioned whether the business was improperly supplying labour to third parties and whether sufficient genuine work existed for sponsored workers.

WestBridge prepared a comprehensive operational evidence package demonstrating:

• genuine care contracts

• genuine client demand

• supervision structures

• internal workforce management

• care package allocations

• council remittance evidence

• invoice and billing records

• operational deployment data

  
  

We demonstrated that sponsored workers were employed within the sponsor’s own operational structure and were not being supplied as agency labour.

We also successfully demonstrated that the business had sufficient genuine operational demand to support its sponsored workforce despite temporary fluctuations in workload and staffing patterns.

Compliance Improvement Strategy

We also advised the client on implementing strengthened compliance systems, including:

• enhanced payroll and attendance reconciliation

• improved SMS reporting procedures

• internal escalation processes

• sponsor compliance monitoring controls

  
  

The Outcome

Following detailed legal representations and extensive supporting evidence submitted by WestBridge Business Immigration, the Home Office formally reinstated the sponsor licence on 11 May 2026. 

In its reinstatement decision, the Home Office confirmed that it was satisfied that:

• salary concerns had been addressed

• medical evidence and payroll explanations were accepted

• the sponsor had demonstrated genuine operational activity

• the concerns regarding labour supply had been resolved

  
  

The Home Office ultimately concluded:

“We are satisfied this issue has been addressed.”

and confirmed:

“We have reinstated their sponsor licence.”

The outcome was a complete success:

• Sponsor licence successfully reinstated

• Revocation avoided

• 33 sponsored workers protected

• Care operations preserved

• Compliance systems strengthened

• Multiple Home Office allegations successfully rebutted

  
  

How WestBridge Business Immigration Can Help 

Sponsor licence suspensions are often complex, fast-moving and high stakes. In many cases, businesses face multiple allegations that extend beyond immigration compliance and into wider operational issues.

WestBridge Business Immigration supports UK employers with:

• Sponsor Licence Applications

• Sponsor Licence Suspension Responses

• Revocation Defence Representations

• Compliance Audits

• Skilled Worker Sponsorship Strategy

• Home Office Visit Preparation

• SMS Reporting Compliance

• HR and Immigration Compliance Integration

  
  

If your business has received a suspension notice or is facing Home Office compliance action, early strategic intervention can significantly improve the prospects of a successful outcome.