What Must Health and Care Employers Know About UK Sponsor Licences?

Key Points

• A Sponsor Licence from the Home Office is the legal gateway for any health or care employer in the UK that wants to recruit workers from overseas; without one, no overseas hire can take place, and any attempt to employ a worker without lawful sponsorship carries serious criminal and civil consequences.
• The rules changed fundamentally in July 2025: the care worker visa route is now closed to new applicants from overseas, meaning care providers can only sponsor care workers (SOC codes 6135 and 6136) who are already lawfully present in the UK, and only if those workers have been legally employed by the sponsor for at least three months before a Certificate of Sponsorship is assigned.
• The costs of running a Sponsor Licence have increased significantly since April 2025, with the Certificate of Sponsorship fee rising to £525, the Immigration Skills Charge increasing to £1,320 per year per worker for medium and large sponsors, and all clawback of those costs from workers now prohibited.
• Home Office enforcement has accelerated sharply: nearly 2,000 sponsor licences were revoked between July 2024 and June 2025, more than double the previous year, with salary discrepancies now automatically detected by cross-referencing PAYE data against Certificate of Sponsorship declarations.
• Compliance is an ongoing obligation; sponsors must use the Sponsorship Management System to report changes to roles, salaries, working locations, and absences, and must keep detailed HR records ready for inspection at any time.

Health and care employers in England face a more demanding sponsorship environment in 2026 than at any point in the past decade. The combination of post-Brexit reliance on international recruitment, a series of significant rule changes from July 2025, and a marked increase in Home Office enforcement has created a compliance picture that every HR director, care home manager, and NHS trust administrator needs to understand clearly.

Getting the process right is entirely achievable, provided the rules are followed from the start. Getting them wrong carries severe consequences, including licence revocation, criminal liability, and an immediate loss of the right to employ the overseas workforce the organisation depends on.

What a Sponsor Licence Does

A Sponsor Licence is an authorisation from UK Visas and Immigration (UKVI), a division of the Home Office, that permits an employer to recruit and employ workers from outside the UK under immigration routes that require sponsorship. For health and care employers, the relevant route is the Health and Care Worker visa, which sits within the Skilled Worker framework and carries specific advantages: visa application fees are reduced, and workers are exempt from the Immigration Health Surcharge.

The licence itself does not authorise any particular worker. Each sponsored employee requires a Certificate of Sponsorship (CoS), which is an electronic record generated through the Sponsorship Management System (SMS). That CoS contains the details of the role, salary, start date, and occupation code, and it is the document the worker uses to support their visa application. In most cases, your licence remains active for as long as you continue to satisfy the relevant eligibility criteria. However, if your licence covers Scale-up Workers or UK Expansion Workers, a fixed term of 4 years applies.

Which Organisations Can Apply

The following types of health and care organisations are eligible to apply for a Worker sponsor licence:

• NHS trusts and NHS foundation trusts
• Clinical commissioning groups and integrated care systems
• Care Quality Commission (CQC)-registered providers of regulated activities
• Local authorities providing adult social care services
• Private medical and dental practices registered with the GMC, NMC, or HCPC
• GP federations and organisations providing services under NHS contracts
• Independent hospitals and private care homes

To be eligible, an organisation must operate as a genuine business with a trading presence in the UK. It must have HR systems capable of meeting ongoing compliance duties, genuine vacancies at the required skill and salary levels, and no adverse history of immigration offences, unpaid civil penalties, or conduct considered not conducive to the public good. The full list of disqualifying factors is set out in Annexes L1 to L4 of the Workers and Temporary Workers sponsor guidance.

Key Personnel You Must Appoint

Before applying, you must appoint three named individuals to specific roles within your organisation. These roles carry real responsibility and accountability in the eyes of the Home Office.

• Authorising Officer (AO): a senior executive or director who takes overall responsibility for the organisation’s sponsorship obligations. The AO is personally accountable for compliance and must not have any relevant criminal convictions or adverse immigration history.
• Key Contact: the main point of contact for the Home Office on sponsorship matters. This role can be held by the same person as the AO.
• Level 1 User: the person who manages the Sponsorship Management System on a day-to-day basis, assigns Certificates of Sponsorship, and submits reports. This person must be a settled UK worker with a National Insurance number.

All key personnel must be UK-based and free of relevant convictions. The Home Office assesses them as part of the licence application, and they remain subject to scrutiny throughout the period of the licence.

Applying for a Licence

The application is made online through the Sponsorship Management and Applications portal. Select the Worker licence category and the Health and Care Worker visa route. The steps below set out the process in full.

1. Check eligibility and HR readiness: confirm that your organisation meets the eligibility requirements, that your HR policies and record-keeping systems are fit for purpose, and that no key personnel have adverse histories that would disqualify them.
2. Appoint your Authorising Officer, Key Contact, and Level 1 User: identify the right individuals and ensure they understand what their roles involve. The Home Office will scrutinise these appointments.
3. Gather your supporting documents: most organisations need to submit at least four documents from the list in Appendix A of the sponsor guidance. Typical documents include your latest annual accounts, evidence of HMRC PAYE and National Insurance registration, a recent business bank statement, and evidence of your business premises. Care providers should also include CQC registration or evidence of NHS contract arrangements.
4. Decide on your licence structure: if you operate across multiple sites, decide whether to apply for a single licence covering all locations or separate licences per entity. You will need to provide ownership evidence for multi-site structures.
5. Estimate your Certificate of Sponsorship allocation: you must declare how many CoS you anticipate needing in year one. It is better to overestimate slightly; adding to your allocation later requires a separate application.
6. Complete and submit the online application: fill in the application form via the SMS portal, pay the application fee, and submit.
7. Send supporting documents within five working days: email scanned copies of your supporting documents to the Home Office within five working days of submitting your online application. Late documents will not be accepted, and your application may be rejected.
8. Prepare for a compliance visit: the Home Office may conduct a pre-licence compliance visit, announced or unannounced, to verify your HR systems and the genuineness of your vacancies. Ensure your policies are documented, your key personnel understand their responsibilities, and you can demonstrate your processes clearly.
9. Receive your decision: if approved, you receive an A-rating (full operational status), your Sponsor Licence Number, and access to the SMS. If concerns arise, the Home Office may grant a B-rating with an action plan or refuse the application entirely.

The Cost of Sponsorship

The fees involved in health and care sponsorship have increased substantially in recent years, and employers should budget carefully. The main costs are as follows.

• Sponsor licence application fee: £574 for small or charitable sponsors; £1,579 for medium or large sponsors. A small sponsor is one that satisfies at least two of these conditions: annual turnover of no more than £15 million, total assets of no more than £7.5 million, or a workforce of 50 or fewer employees.
• Priority processing: £500 for expedited processing in approximately one week, against the standard eight-week timescale.
• Certificate of Sponsorship: £525 per worker, payable each time a CoS is assigned. This fee increased from £239 on 9th April 2025.
• Immigration Skills Charge: from 16th December 2025, the rate is £1,320 per year per sponsored worker for medium and large sponsors, and £480 per year for small and charitable sponsors. The charge is calculated in 12-month blocks for the first year and six-month blocks thereafter. It cannot be recovered from the sponsored worker.
• Visa application fee: paid by the worker, not the employer. Skilled Worker visa fees range from £769 (up to three years, outside the UK) to £1,751 (up to five years, inside the UK). Health and Care Worker visa holders are exempt from the Immigration Health Surcharge.

From 9th April 2025, employers are prohibited from recovering from sponsored workers the cost of the Sponsor Licence application, the Certificate of Sponsorship fee, the Immigration Skills Charge, or any associated administrative costs. Clawback clauses in employment contracts that cover those costs incurred from that date are non-compliant with Home Office guidance, regardless of when the contract was signed. Any employer still operating such clauses should take urgent advice.

The 2025 Rule Changes

The 2025 Immigration White Paper introduced the most significant changes to the health and care sponsorship framework since the Health and Care Worker visa was created in 2021. Employers who have not reviewed their recruitment processes and existing sponsorship arrangements against these changes are at risk.

The Overseas Care Worker Route Is Closed

From 22nd July 2025, employers can no longer recruit care workers (SOC code 6135) or senior care workers (SOC code 6136) from overseas. Those occupation codes are no longer eligible for new Skilled Worker applications by people outside the UK. For many adult social care providers, particularly care homes and home care agencies, this is a fundamental change to their international recruitment model.

A transition period applies until 22^nd July 2028, subject to review. During that period, employers can still sponsor care workers and senior care workers who are already in the UK, provided that the worker has been legally employed by the sponsoring employer for at least three months before the Certificate of Sponsorship is assigned. Workers switching from other immigration routes into care worker roles after 22nd July 2025 cannot bring dependants to the UK.

The Domestic Recruitment Requirement

From 9^th April 2025, care providers in England that want to sponsor workers already in the UK under SOC codes 6135 or 6136 must first demonstrate that they have genuinely tried to recruit domestically. This means advertising the vacancy and showing that no suitable candidate was found among workers already present in England. The Home Office will review this evidence before granting a defined Certificate of Sponsorship. Providers must keep detailed records of their recruitment process, including advertisements, agency contacts, and assessments of candidates.

The Increase in Minimum Skill Level

From 22nd July 2025, the minimum skill level for new overseas sponsored workers increased from RQF Level 3 (A-level equivalent) to RQF Level 6 (degree level) for the Skilled Worker route. A number of roles that were previously eligible for overseas sponsorship, including some clinical support and technical roles, are no longer sponsorable on the Health and Care Worker visa unless the worker was already in the route before that date. Employers should review their role requirements against the current Immigration Salary List to confirm which occupations remain eligible.

HMRC Payroll Cross-Checking

One of the most significant compliance developments in 2026 is the integration of HMRC Real Time Information (RTI) payroll data with Home Office compliance systems. When your PAYE submissions show a salary that differs from the salary declared on a Certificate of Sponsorship, that discrepancy is now automatically flagged. Employers across the care sector have already received enforcement letters as a result, in some cases without any prior compliance visit. If your payroll does not match your CoS declarations, the Home Office already knows.

Which Roles Remain Eligible

Despite the July 2025 changes, a wide range of health and care roles remain fully eligible for overseas sponsorship under the Health and Care Worker visa. The Health and Care Worker visa guidance  sets out the eligible occupation codes, which include:

• Doctors (all specialisms) and surgeons
• Nurses and midwives
• Psychologists and therapists
• Physiotherapists, occupational therapists, and radiographers
• Pharmacists and pharmacy technicians
• Paramedics
• Social workers (in health settings)
• Healthcare scientists and medical laboratory technicians (at degree level)

For care workers under SOC codes 6135 and 6136, the position is as described above: new overseas applications closed on 22nd July 2025, but in-UK switching remains possible within the transition period. Employers should verify each role against the current Register of Licensed Sponsors and the Immigration Salary List before assigning any Certificate of Sponsorship.

Your Ongoing Compliance Duties

Obtaining a licence is not the end of the process; it is the beginning of an ongoing compliance commitment. The Home Office conducts announced and unannounced visits, and with nearly 2,000 sponsor licences revoked between July 2024 and June 2025 across all sectors, the enforcement environment is significantly more active than it was even two years ago.

Your compliance obligations fall into three broad categories.

Reporting via the SMS

You must report the following events via the Sponsorship Management System, within the timeframes specified in the sponsor guidance:

• Changes to a sponsored worker’s job title, duties, or salary
• Changes to working hours
• Changes to the worker’s work location, including moves to hybrid or remote working, where the main office address changes
• Unauthorised absences of 10 or more consecutive working days
• Business changes such as mergers, acquisitions, changes of trading address, or new branch openings
• A sponsored worker ceasing employment
• Reasonable grounds to believe a worker is breaching their visa conditions

Record Keeping

You must keep and maintain the following records for each sponsored worker throughout their employment and for a period after it ends:

• A copy of the worker’s passport and visa documentation
• National Insurance number
• Payslips and employment contracts showing salary, tax code, and deductions
• Right-to-work check records and their dates
• Attendance and absence records
• Current UK address, personal email, and telephone number
• Any permission to work documents issued during the worker’s stay

Ensuring Salary Compliance

Every sponsored worker must be paid at least the salary declared on their Certificate of Sponsorship and the minimum salary threshold for their occupation code, whichever is higher. With HMRC RTI data now automatically cross-referenced against CoS declarations, any reduction in salary that is not reported to UKVI via the SMS creates an immediate compliance risk.

Why Licences Are Revoked

The most common reasons for licence suspension or revocation include salary discrepancies between the CoS and actual payroll, failure to report worker absences or role changes, inadequate right-to-work checking, and cost clawback clauses in employment contracts. In the care sector, the Home Office has also focused on employers found to be exploiting sponsored workers, including those charging workers for visa and recruitment costs.

Revocation has severe consequences. Your sponsored workforce immediately loses its lawful basis to work. Workers have 60 days to find a new sponsor or leave the UK. Your organisation is barred from re-applying for a licence for a period specified by the Home Office and may face civil penalties or prosecution depending on the nature of the breach.

Protecting your licence requires treating compliance as a standing operational priority rather than an annual review. Practical steps include conducting regular internal audits of your SMS records against your payroll, briefing HR staff on reporting obligations, reviewing employment contracts to remove any prohibited clawback clauses, and keeping worker contact details up to date at all times. If the Home Office notifies you of a compliance concern, take legal advice immediately.

How We Can Help

At Law Lane Solicitors, our immigration team assists health and care employers at every stage of the sponsorship process. We handle new licence applications, guide employers through compliance visits, advise on the impact of the 2025 rule changes on existing sponsorship arrangements, and represent organisations whose licences have been suspended or revoked.

Our reported cases in the Court of Appeal include London St Andrew’s College, R (On the Application Of) v Secretary of State for the Home Department [2018] EWCA Civ 2496, which concerned the proper interpretation of sponsor guidance in the context of licence revocation. We understand how the Home Office approaches these decisions, and we know how to challenge them when they are wrong.

If you are applying for a Sponsor Licence for the first time, reviewing your compliance position, or responding to a Home Office suspension or revocation, speak to us. We offer a free initial assessment and will give you a clear, direct view of your position.

Health and Care Sponsor Licence FAQs