The New Sponsor Licence Reality in the Care Sector

For many care providers, sponsor licences have become an essential part of workforce planning. International recruitment has helped fill persistent vacancies and maintain service delivery in a sector under significant operational and financial pressure.  

Against that backdrop, UKVI compliance activity in the care sector has intensified and is taking multiple forms from licence suspensions, revocations, information requests to compliance audits and increasingly detailed scrutiny of routine CoS allocations. Different providers may experience this in different ways, but the underlying character is consistent: forensic scrutiny, a higher evidential bar than many providers are set up to meet, and a markedly lower tolerance for administrative gaps or unexplained inconsistencies.

Of these, information requests have been a particularly regular feature recently, and what they ask for is indicative of the level of scrutiny providers should expect more generally.

What the current information requests demand

The information request letters we are currently seeing focus on whether sponsored workers are being paid in line with the salary stated on their Certificate of Sponsorship. They open by citing UKVI’s right to revoke for serious or systematic breach, close by warning that failure to respond within ten working days is likely to lead to revocation, and, in between, require full document sets including contracts, six months of payslips, bank statements, RTI and payroll data, NI numbers and P60s, often across the entire sponsored workforce.

UKVI will also interrogate working patterns. A sponsor with unreported irregular hours may therefore be left in a difficult position: confirming those working arrangements may expose a separate reporting breach, while silence leaves UKVI to infer the position from the documents provided.

Care sector payroll will not always look straightforward. Rota-based shifts, fluctuating hours, statutory leave, mid-period starts and family-related leave can all make the numbers appear to show underpayment against a flat CoS figure. The difficulty is not necessarily whether explanations exist, but whether the sponsor can evidence them within UKVI’s framework and within the timeframe given.

Where there is a small underpayment for an unexplained reason, UKVI is currently showing limited tolerance. Even one or two workers in an otherwise compliant cohort can be enough to prompt action.

The post-April 2026 framework

Under the previous framework, salary compliance was more commonly understood and assessed by reference to the annual salary position, meaning short-term fluctuations in any given month were less likely to be determinative where the annualised position remained compliant.

The new pay-period rules require salary compliance to be demonstrated within shorter windows. For workers paid monthly, or less frequently than monthly, pay over any three-month period must be at least a quarter of the required annual salary. Where workers are paid more frequently than monthly, pay over any 12-week period must be at least 12/52 of the required annual salary. For workers with irregular weekly hours resulting in uneven pay, salary over any 17-week period must be at least 17/52 of the required annual salary. These rules formally apply to CoS assigned on or after 8 April 2026.

The position is more nuanced in practice. Sponsors will have a mixed workforce: some workers sponsored under the previous framework, and others falling within the new regime, whether through new hires or extensions after 8 April 2026. We are already seeing UKVI reference this newer framework in circumstances where it does not strictly apply, requiring sponsors to engage with both approaches in parallel.

Layered onto a typical care sector payroll, this makes a clean reconciliation materially harder to construct and increases the risk of discrepancies being interpreted unfavourably where they are not fully explained.

Practical considerations in any response

Providing the data UKVI asks for, without managing the analysis around it, can be risky. UKVI will draw its own inferences from the underlying documents provided, and those inferences can be detrimental without clear explanation.

For example:

• A worker with multiple CoS during the assessment window needs each period assessed against the CoS in force at the time. UKVI may otherwise default to the most recent CoS.  
• Where National Minimum Wage has risen above the rate stated on a CoS, it is not always clear how far UKVI will look at wider NMW compliance.  
• An apparent underpayment, such as where a worker starts mid-month, should not be left for UKVI to infer from the documents alone. It should be identified and clearly explained in the response.
• Periods of statutory leave, reduced hours, unpaid leave or family-related absence may need to be separated from ordinary working periods and explained clearly.  
• Payroll records, RTI data and bank statements may not always align neatly unless the timing of payments and deductions is carefully reconciled.  

These are just some examples of the issues that may need addressing in a response of this kind. Others will arise depending on the facts. The underlying point is that each variance must be identified and explained. Otherwise, an unexplained discrepancy can be read as underpayment in its own right.

What is at stake and why preparation matters now

Licence suspension or revocation will have an immediate impact on operations, CQC standing, commissioning relationships and the ability to deliver care. The providers best placed to navigate this scrutiny are those who have proactively reconciled their sponsored workforce against the salary commitments on each CoS, mapped how the pre- and post-April 2026 frameworks apply across their cohort, identified the variances in their payroll data, and worked out how to explain them.

In practical terms, that means checking each sponsored worker against the CoS in force at the relevant time, reconciling contractual hours against actual hours worked, identifying any periods of reduced pay or statutory leave, matching payroll records to bank payments and RTI data, and preparing clear explanations for any variance before UKVI asks the question.

That kind of preparation takes time and careful analysis. It is significantly harder to do well under the pressure of a ten-working-day deadline than it is in advance.

There is little to suggest that this level of scrutiny will reduce in the near term. If anything, the trajectory points towards wider targeted activity across the sector

If you hold a sponsor licence in the care sector and have not stress-tested your payroll and processes against the way UKVI is now assessing compliance, that exercise is worth undertaking proactively, rather than once UKVI has started doing it for you.

For a confidential review of your position, please get in touch.

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