A Sponsor Action Plan is a corrective measure issued by the Home Office when a sponsor licence holder fails to meet their sponsorship duties. If the Home Office identifies compliance breaches, the sponsor’s A-rating may be downgraded to a B-rating, requiring the business to follow a structured action plan to regain compliance.
This guide explains what a Sponsor Action Plan is, how it affects employers, the associated costs, and the steps to regain an A-rated sponsor licence.
What Is a Home Office Sponsor Action Plan?
When a UK employer is granted a sponsor licence, they are assigned an A-rating, allowing them to assign Certificates of Sponsorship (CoS) to overseas workers. However, if the Home Office finds compliance failures, it may downgrade the licence to a B-rating and require the employer to follow a Sponsor Action Plan (SAP).
A Sponsor Action Plan is designed to help businesses:
- Rectify minor sponsorship compliance breaches
- Strengthen HR and immigration compliance processes
- Demonstrate full compliance with Home Office regulations
While on a B-rating, the business cannot issue new CoS to overseas workers until compliance is restored and the A-rating is reinstated.
Further details on sponsorship compliance requirements can be found in the official Home Office guidance:
Home Office Sponsor Guidance
Common Reasons for a Sponsor Action Plan
A Sponsor Action Plan is typically issued following a compliance visit by the Home Office. Some common reasons for a B-rating include:
- Failure to Maintain Accurate Records
- Missing or incomplete right to work checks
- Failure to keep up-to-date records for sponsored workers
- Failure to Meet Reporting Duties
- Late reporting of worker resignations, absences, or status changes
- Delayed or inaccurate updates in the Sponsor Management System (SMS)
- Non-Compliance with Job Role Requirements
- Assigning a CoS for a job that does not meet Skilled Worker visa criteria
- Poor HR Systems
- Lack of internal processes for monitoring visa expiry dates and reporting obligations
- Failure to Cooperate with the Home Office
- Inability to provide requested compliance documents or providing incorrect information
If the Home Office considers the breaches to be serious or repeated, they may suspend or revoke the sponsor licence instead of issuing a Sponsor Action Plan.
Impact of a Sponsor Action Plan on Your Business
Restricted Ability to Sponsor New Workers
While on a B-rating, employers:
- Cannot issue new CoS to overseas recruits
- Can only extend visas for existing sponsored employees
- Must correct compliance issues within the Sponsor Action Plan timeframe
Reputation and Compliance Risks
A Sponsor Action Plan places public scrutiny on a business’s compliance record and can:
- Delay international hiring processes
- Damage an employer’s reputation with Home Office and immigration authorities
- Increase the risk of further Home Office audits
Potential Licence Revocation
If compliance issues are not fully addressed, the employer may:
- Receive a second Sponsor Action Plan
- Have their sponsor licence revoked
- Face visa curtailment for existing sponsored workers
Costs and Timescales of a Sponsor Action Plan
A Sponsor Action Plan is subject to a Home Office fee of £1,476, which must be paid within 10 working days. Failure to pay this fee will result in automatic licence revocation.
A Sponsor Action Plan typically lasts three months, during which the employer must:
- Implement corrective actions outlined in the plan
- Provide evidence of compliance improvements
- Pass a Home Office re-evaluation to regain an A-rating
If the Home Office determines that compliance issues persist, the employer may be:
- Issued a second Sponsor Action Plan
- Subject to sponsor licence revocation
If a sponsor licence is revoked, the employer cannot appeal and must wait 12 months before reapplying.
Read more: How Long Does a Sponsor Licence Take?
Other Penalties for Non-Compliance
If the Home Office determines that breaches are severe or systemic, additional penalties may apply:
Sponsor Licence Suspension
- Temporary removal from the register of licensed sponsors
- Restriction from issuing new CoS during the investigation
Sponsor Licence Revocation
- Permanent loss of sponsorship privileges
- Termination of all existing sponsored worker visas
- Minimum 12-month cooling-off period before reapplying
Financial and Criminal Penalties
- Civil penalty of up to £20,000 per illegal worker
- Criminal charges and potential five-year imprisonment for knowingly employing illegal workers
Read more: Right to Work Checks: Employer Guide
How to Avoid a Home Office Sponsor Action Plan
To maintain full compliance and avoid a Sponsor Action Plan, employers should:
Strengthen HR and Compliance Systems
- Keep detailed records of all sponsored workers
- Regularly review visa expiry dates and renewals
- Ensure HR teams are trained on sponsor duties
Conduct Regular Right to Work Checks
- Verify passports, visas, and work permits before employment
- Maintain up-to-date records for all employees
- Repeat follow-up checks for workers on time-limited visas
Ensure Compliance with the Sponsor Management System (SMS)
- Assign CoS only for eligible job roles
- Report worker resignations, absences, or status changes within the required timeframe
- Maintain accurate details on sponsor licence key personnel
Prepare for Home Office Compliance Audits
- Conduct internal audits to ensure adherence to sponsorship duties
- Appoint a dedicated compliance officer to oversee sponsor licence requirements
- Seek expert immigration advice for risk mitigation
How Borderless Can Help with Sponsor Licence Compliance
Ensuring ongoing compliance with Home Office sponsorship rules can be complex. Borderless offers expert support to help businesses:
- Avoid Sponsor Action Plans by strengthening compliance procedures
- Prepare for Home Office audits and compliance visits
- Implement best practices for sponsor licence management
- Navigate Sponsor Action Plan requirements and regain A-rating
For specialist sponsor licence compliance support, contact Borderless today.
Conclusion
A Sponsor Action Plan serves as a serious warning from the Home Office that a business is failing in its sponsorship duties. While it provides an opportunity to regain full compliance, failure to meet the corrective actions can lead to sponsor licence revocation.
By maintaining robust HR systems, accurate reporting, and compliance with Home Office rules, businesses can avoid enforcement actions and continue sponsoring skilled workers effectively.
For expert guidance, speak to our compliance specialists.
.png)