Sponsor Licence Renewal

As of 6 April 2024, sponsor licenses no longer need to be renewed every four years. The UK Visas & Immigration (UKVI) initially extended licenses expiring on or after this date by 10 years. Under current Home Office guidance, most sponsor licenses remain valid until they are surrendered or revoked due to non-compliance.

There is no application or fee required for sponsor license renewal. This change was announced on the Sponsorship Management System (SMS) in January 2024 and applies to both existing sponsors with valid licenses and new licenses granted on or after 6 April 2024. However, sponsors must still manage and update their license via the SMS where required to ensure continued eligibility and full compliance with UKVI requirements. Since April 2024, UKVI has focused more on compliance enforcement, with sponsors remaining subject to compliance checks and enforcement action, including suspension and revocation.

When Will the Home Office Require Sponsor License Action?

Since 6 April 2024, most sponsor licenses no longer require renewal every four years. Licenses due to expire on or after this date have been automatically extended for ten years, with no application or fee required. Most sponsor licenses are now valid indefinitely unless surrendered or revoked by the Home Office. In most cases, a sponsor license will remain valid unless it is surrendered or revoked due to non-compliance. 

The removal of routine renewals does not remove all obligations. Sponsors must continue to meet compliance duties and should be aware that certain license types still have shorter validity periods or cannot be renewed.

When action may still be required: 

• Your license type has a fixed maximum validity shorter than ten years (e.g. UK Expansion Worker or Scale-up routes). 

• The Home Office identifies compliance concerns relating to your business. 

• A Home Office compliance check identifies possible breaches. 

• Significant changes in your business could affect license validity (e.g. mergers, ownership changes). 

Current sponsor license validity by route: 

What Are the Risks of Non-Compliance?

Non-compliance with sponsor licence duties carries significant risks for organisations. While the removal of routine licence renewals has reduced administrative work, sponsors must still meet all legal obligations. The removal of routine renewal requirements does not eliminate these duties, and the Home Office retains the power to carry out audits and request records at any time. 

Failure to comply can lead to serious consequences such as suspension, revocation, or a downgraded licence rating. Licence revocation can directly impact sponsored workers, including the cancellation or shortening of their permission, which may require them to find a new sponsor or leave the UK. 

Common breaches include failing to report changes, inadequate record-keeping, assigning non-compliant roles, paying below the required salary threshold, or providing false information. Depending on the nature of the breach, such failures can expose sponsors to civil penalties and potential criminal investigations and can also lead to unannounced compliance visits. In practice, compliance lapse can trigger an audit or inspection, placing ongoing pressure on sponsors to always remain fully audit ready.

Are There Any Fees for Renewal or Related Actions?

Since 6 April 2024, most sponsor licenses no longer require routine renewal, so no routine sponsor license renewal fee applies. This change has removed the need for regular renewal payments for many organisations. If an organisation needs to make a new sponsor licence application, the applicable fee depends on the type of licence and the size of the organisation. A Worker sponsor licence currently costs £611 for a small or charitable sponsor and £1,682 for a medium or large sponsor. 

While there is generally no Home Office fee for submitting additional documents, updating details, or responding to compliance checks as part of your ongoing duties, certain services and situations may lead to extra costs. If your licence is downgraded to a B-rating due to compliance issues, you will be required to pay an action plan fee. If your licence is revoked and you later become eligible to reapply, you will need to submit a new application and pay the applicable sponsor licence fee. Additionally, many employers choose to seek legal or advisory support when resolving compliance failures, which can add to the overall employer sponsorship licence UK cost. 

What If a Certificate of Sponsorship (CoS) Expires?

Understanding what happens when a Certificate of Sponsorship (CoS) expires is crucial to avoid compliance issues and recruitment delays. A CoS has its own validity rules, separate from the sponsor licence. Once assigned to a worker, they must apply for their visa within three months of the assignment date. If the CoS isn’t used within this period, it expires automatically. An expired CoS cannot be reactivated or reassigned to another person. In this case, the sponsored worker will need a new CoS to proceed with their visa application. In the context of CoS renewal UK, this means assigning a completely new certificate, rather than extending the expired one. 

What to do if a Certificate of Sponsorship expires: 

• Identify why the original CoS was unused; this may require changes to the role or candidate details if those details have changed. 

• Assign a new CoS via the Sponsorship Management System (SMS) as soon as possible. 

• If you’ve reached your Undefined CoS annual allocation, request an increase from the Home Office through the SMS before assigning a new CoS. Defined CoS must be requested separately as needed. 

• Time the new CoS assignment date to align with the visa application, ensuring maximum validity within the three-month window. 

• Keep accurate internal tracking of all CoS assignment and expiry dates to prevent future lapses. 

When Do You Need to Apply for a New Licence?

In certain circumstances, you will need to apply for a new sponsor licence rather than continue using your current one. This is typically necessary if your licence has been revoked, there have been significant changes to your business structure, or if your licence lapsed before April 2024. 

Cases when you need to apply for a new sponsor licence: 

• Licence revoked: If your sponsor licence is revoked due to non-compliance or other issues, you must normally wait at least 12 months before applying for a new licence, and the cooling-off period may be longer in some circumstances. 

• Business changes: If your business undergoes a legal change, such as a merger or incorporation of a new company, a new licence may be required. 

• Lapsed licence before April 2024: If your licence expired before April 2024, you will need to reapply for a new sponsor licence, as routine renewals no longer apply. 

• Licence transfer: A sponsor licence cannot be transferred to another organisation. If there is a change in direct ownership, the new owner may need to apply for a sponsor licence if it does not already hold the relevant licence. 

What the reapplication process involves: 

• Complete a new online sponsor licence application. 

• Submit the relevant supporting documents required under Appendix A for your organisation and the route you are applying for. 

• Pay the applicable sponsor licence application fee. 

• Wait for the Home Office to process the application. Most applications are dealt with in less than 8 weeks. 

How Can We Help With Renewal Of Sponsor Licence?

Our sponsor licence specialists can provide all the required help and guidance and free advice for renewal of your sponsor licence. Helping carry out all the work until decision is made by the Home Office on the renewal application. As part of our professional legal services for sponsor licence renewal, our work will entail the following:

• Advising you on the relevant criteria for the renewal of the sponsor licence;
• Advising on the relevant procedures to be followed for sponsor licence renewal;
• Helping you with the completion of the online form for renewal of the sponsor licence;
• Helping with payment of the Home Office UKVI fee for the renewal of the sponsor licence;
• Assisting you with Home Office Compliance visit, if the Home Office UKVI decides to conduct a compliance visit before deciding the sponsor licence renewal application;
• Doing all the follow-up work until decision is reached on sponsor licence renewal application by the Home Office, UKVI.