The UK's immigration enforcement landscape has shifted dramatically in recent months. Sponsorship licence revocations are rising sharply, the Home Office is taking a more proactive approach to compliance, and — critically — several very large care providers have lost their licences. This isn't just an issue for small operators cutting corners. It's a sector-wide risk that every care provider with sponsored workers needs to take seriously.
With significant regulatory changes taking effect in April 2026, now is the time to review your compliance position. This article breaks down what's changed, what the Home Office is looking for, and the practical steps you can take to protect your licence.
The new HMRC–UKVI live data feed changes everything
From 1 April 2026, UKVI now receives live payroll data directly from HMRC for every sponsored worker. This is a fundamental shift in how enforcement operates. Previously, income discrepancies might only surface during a compliance visit or document review. Now, if actual pay doesn't match the salary stated on a worker's Certificate of Sponsorship, UKVI will see it automatically — potentially before you do.
This makes earnings compliance the single most important area for care providers to get right. Income reporting errors are already the most common reason for licence revocation, and the new data feed removes any margin for error.
The practical actions here are clear: confirm that every sponsored worker is being paid at least the salary stated on their CoS, check anyone whose hours have changed or dropped, and ensure your payroll and HR records are aligned. Discrepancies between the two are a red flag. If you find errors, report them proactively through the Sponsorship Management System before UKVI raises them with you.
Earnings rules: what you need to know
The earnings rules themselves have also been reinforced, with enforcement from 8 April 2026. There are three key principles to understand.
- If the role explicitly involves irregular hours, you can average income over a 17-week period. If not, income must meet the monthly total and one quarter of the annual salary over any rolling 12-week period.
- Every sponsored worker must be paid at least the sponsored minimum wage stated on their CoS, or the national living wage — whichever is higher — for every working hour.
- "Working hours" includes not just contact time but also travel time between appointments and mandatory training time. This last point catches many providers out. Paying a lower rate for travel time, or not paying for training, can push a worker below the minimum threshold. Care providers should also be aware that zero-hour contracts and variable hourly pay rates for travel versus contact time are now explicitly prohibited for sponsored workers. Review all contracts to ensure they comply.
New duty: providing employment rights information
Another change enforced from 6 March is a new obligation on sponsors to actively provide sponsored workers with information about their UK employment rights. This covers areas including national minimum wage, working time regulations, pension auto-enrolment, statutory leave and pay, health and safety, trade union membership, Equality Act duties, and how to raise grievances.
This isn't optional. It must be evidenced and retained under Appendix D of the sponsor licence guidance, and it will be checked during compliance visits. Best practice is to prepare a sponsorship agreement that each worker signs, clearly setting out this information. A signed acknowledgement provides the evidence you need.
Job descriptions must match the CoS
The Home Office has reinforced the importance of job descriptions as a key compliance document. Every sponsored worker must have a full, up-to-date job description that matches their Certificate of Sponsorship and is included in their contract. The description must also align with the activities permitted under the relevant Standard Occupation Classification code.
If a worker's role changes — even through something as positive as a promotion — you may need a new CoS, a new SOC code, and a new visa. If the job description doesn't match what the worker is actually doing, they are technically working illegally. One real-world example: a worker with a CoS under occupation code 6135 (care worker) had the job title "senior care worker." That mismatch alone constituted non-compliance.
The most common reasons providers lose their licences
Analysis of care provider licence revocations reveals a consistent pattern. The most frequent causes are concerns about the genuineness of vacancies (now termed "eligible role"), salary underpayments, sponsor reporting issues, supplying workers to third parties, failure to retain required documents, and monitoring failures.
On the genuineness front, the Home Office checks whether the job description on the CoS matches the tasks the worker actually performs, whether hours match, whether the skill level is accurate, and whether any changes have been properly reported. If a "senior care worker" is doing the same work as a standard care worker, that's a problem.
Salary underpayments are scrutinised in detail: does the payslip match the CoS? Are there deductions that bring pay below the threshold? Is the provider relying on allowances to meet minimums? Are costs like uniform, mileage, or unpaid training eroding take-home pay below the required level? For anyone assigned a CoS after 1 April 2025, the minimum rate is £12.82 per hour for every working hour. Any charges to the worker must be separate from salary and cannot reduce it below the threshold.
The consequences of getting this wrong are severe. One recent case involves a provider with 100s of sponsored care workers who lost their licence after three UKVI visits — revoked for minor salary underpayments and failure to report maternity leave. In another case, a single mention during a worker interview of non-payment of travel time triggered a detailed document review, resulting in licence suspension and thousands in legal costs.
Don't ignore UKVI correspondence
It sounds obvious, but failing to respond to UKVI communications is a surprisingly common cause of revocation. In one case, a provider received a letter about income inconsistencies with a 10-working-day response deadline. The key contact was on holiday. No one replied. The licence was revoked. The cost of getting it reinstated ran into thousands.
Ensure that more than one person in your organisation monitors UKVI correspondence and that there are clear processes for responding within deadlines, even during holiday periods.
Other compliance risks to watch
Several other areas regularly trip providers up. Sharing or "lending" sponsored staff to another company is a serious breach — sponsored workers must work under their sponsor's direct supervision for all minimum sponsored hours. While they can work up to 20 supplementary hours for another care employer, this is only permitted if they're fulfilling their primary hours first. The receiving company faces fines of up to £60,000 per worker for illegal working.
Right-to-work checks must be completed correctly every time: signed or appearance-confirmed, repeated after each new visa, conducted in your company name, dated, completed before the worker starts work on that visa, and with a record of every historical check retained. One provider was fined £40,000 because a right-to-work check wasn't redone after a visa renewal — the worker had delayed providing their share code, and in the interim was found to have been working illegally.
Finally, SMS (Sponsorship Management System) security is increasingly important. Phishing attacks targeting sponsor accounts are on the rise, and a single CoS can be worth over £20,000 on the black market. Log into your SMS monthly and ensure your team can recognise phishing attempts.
Building a compliance-first approach
The regulatory direction is clear: enforcement is becoming more automated, more proactive, and more data-driven. Providers who rely on manual processes, spreadsheets, or the assumption that problems won't surface are increasingly exposed. A robust system for tracking earnings, documents, right-to-work checks, and reporting deadlines is no longer a nice-to-have — it's essential to protecting your licence, your workforce, and your business.
The time to act is now, before the new HMRC data feed surfaces issues you didn't know you had.