UKVI Sponsor Compliance Is Tightening: Why Care Providers Can’t Afford to “Hope for the Best”

If you sponsor overseas employees in the UK care sector, the compliance landscape has changed. UK Visas and Immigration (UKVI) is conducting more checks, enforcement action has risen sharply, and the consequences of getting it wrong are now far more likely to land on your doorstep.

Between July 2024 and June 2025, the Home Office reported 1,948 sponsor licences revoked - more than double the previous 12 months (937). (GOV.UK)For care providers and social care companies - often operating multi-site, high-turnover, 24/7 services - this enforcement environment creates a simple reality:

The more sponsored employees you have, the greater your risk exposure - because you have more files, more changes, more reporting triggers, and more opportunities for one small oversight to become a major breach.

What’s driving the increase in scrutiny?

Several factors are converging:

1) A clear enforcement uplift

Legal and advisory firms are openly warning that the Home Office has intensified compliance action through 2024 into 2025. (knowledge.dlapiper.com)

2) High-risk sector focus (including care)

The care sector has faced sustained attention due to widely reported abuse and sponsor failures, with significant numbers of sponsors losing licences and large numbers of workers affected. (The Guardian)

3) “Always audit-ready” is now the expectation

The official sponsor guidance makes it clear sponsors must meet ongoing duties - and UKVI can take action if you can’t demonstrate compliance. (GOV.UK)

The business-critical risks of failing a UKVI compliance visit

A failed UKVI compliance visit doesn’t just create “paperwork problems.” It can trigger outcomes that are operationally and financially severe:

• Licence suspension or revocation (which can halt sponsorship capability and disrupt staffing plans) (GOV.UK)

• Inability to issue CoS, leading to recruitment delays or freezes

• Sponsored worker disruption, including curtailed visas or urgent re-sponsorship needs (depending on circumstances)

• Reputational damage with regulators, commissioners, partners, and potential recruits

• Significant management time diverted into urgent remediation, HR triage, legal support, and business continuity planning.

  
  

For a care home group, this isn’t abstract. If your ability to sponsor is impacted, rotas, occupancy, service continuity, and growth plans can be hit at once.

Why bigger sponsor headcounts increase risk (even for good employers)

When you sponsor 5 people, you may be able to personally “eyeball” compliance. When you sponsor 50, 100, or 300+ across multiple sites, risk becomes systemic.

Here’s why scale increases exposure:

More sponsored workers = more compliance events

Every sponsored employee creates potential reporting triggers:

• changes to role duties, pay, hours, location

• delayed starts, no-shows, changes to contract terms

• absences, unpaid leave, patterns that need monitoring

• address/contact changes and right-to-work evidence

  
  

More sites = more inconsistency

In multi-site groups, processes drift:

• managers use different onboarding checklists

• documents are stored in different places

• reporting decisions are made inconsistently

• audit trails are incomplete (“we did it” but can’t prove it)

  
  

More volume = higher chance of “one weak link”

UKVI doesn’t need to find fraud to take action. In many cases, action follows from poor evidence, weak systems, or non-compliant reporting and record-keeping - often caused by workload and fragmentation.

What UKVI typically looks for (and where care providers get caught out)

While every visit differs, recurring pressure points include:

1) Record-keeping and evidence packs

UKVI’s Appendix D sets out the types of documents sponsors must keep. In practice, the failure isn’t always that documents don’t exist - it’s that they’re incomplete, inconsistent, or not quickly retrievable. (GOV.UK)

2) Right to Work checking

Incorrectly conducted checks, missing evidence, or weak processes around repeat checks can become a critical finding. (Fragomen)

3) Monitoring and reporting

Sponsors must track and report relevant changes through the Sponsorship Management System (SMS) within the required timeframes and be able to evidence those decisions. (GOV.UK)

4) “Genuine vacancy” and role integrity

Care sponsors can be challenged where roles, duties, hours, or working arrangements drift from what was sponsored - especially during growth, reshuffles, or site pressure. A published case study in the care sector highlights issues such as alleged non-genuine vacancies and failures to report changes. (chambers.com)

“We’ll do it in-house”  -  the hidden costs and risks

Many providers attempt to manage compliance internally - and it can be done well. But high-volume sponsorship creates three hard problems:

1) The expertise gap

Sponsor compliance isn’t just HR admin. It’s a specialist area where errors are often technical:

• what’s reportable vs what’s not

• what evidence is sufficient vs “nice to have”

• how UKVI interprets controls in real-world operations

• how to build defensible audit trails that stand up to scrutiny

  
  

2) The time and distraction cost

A real audit-standard review means:

• sampling files across sites

• testing process walkthroughs (not just policies)

• examining evidence quality, accessibility, and consistency

• stress-testing reporting triggers and decision logs

  
  

That’s senior HR and operational time pulled away from recruitment, retention, and service delivery - exactly where you can’t afford distraction.

3) The independence problem

Internal teams are too close to the day-to-day reality. Familiarity creates blind spots:

• “we always do that” (but where’s the evidence?)

• “that’s how that site operates” (but does it meet sponsor duties?)

• “we’ll tidy it up later” (later becomes “during a visit”)

In-house reviews also struggle to replicate the “UKVI mindset” - how an external inspector will interpret the same evidence under time pressure.

Why an experienced audit partner is the common-sense move

Engaging an experienced sponsor compliance audit company isn’t about outsourcing responsibility - it’s about reducing risk intelligently.

A strong audit partner brings:

• A proven methodology to assess systems, evidence, and site-level consistency

• A clear RAG-rated risk picture senior leaders can act on fast

• Practical remediation, not theory (what to fix first, who owns it, what “good” looks like)

• Mock-visit readiness: can you produce evidence on demand, quickly, across sites?

• Independence and credibility - especially valuable if you’re reporting to boards, investors, or group leadership

Harley Medical's UKVI audit service will also support your full compliance within a CQC or Ofsted inspection. Having exemplary sponsorship employment records can often be the difference between a “Good” and an “Outstanding” rating.

The “insurance” argument: audit cost vs failure cost

Most care operators understand insurance: you don’t buy it hoping to claim - you buy it to protect the business from events that are costly, disruptive, and sometimes existential.

A UKVI compliance audit works the same way.

The cost of a structured audit is usually small compared with:

• the operational fallout of a licence issue

• emergency legal and remediation spend

• recruitment delays

• loss of management bandwidth

• reputational and regulatory risk

• the human impact on sponsored staff and service continuity

  
  

In a tougher enforcement era, “we’ll sort it if we’re visited” is no longer a strategy. It’s a risk.

What a proper UKVI compliance audit should include

If you’re commissioning an audit, look for one that covers:

1. Sponsor duties and governance (roles, accountability, escalation)

2. Right to Work process testing and evidence review

3. Sponsored worker file sampling across sites (not just head office)

4. Monitoring systems for absences, role/location/pay changes

5. SMS reporting: triggers, decisions, evidence, timeliness

6. Evidence pack readiness: can you retrieve what UKVI asks for - fast?

7. Action plan: prioritised fixes, owners, timelines, and templates/SOPs where needed

   
   

And finally . . . audit readiness is now a business-critical capability

If you’re sponsoring overseas employees, compliance is not a back-office detail. It’s a core operational capability - especially as enforcement increases and revocations have hit record levels. (GOV.UK). And if you sponsor high volumes across multiple sites, your risk exposure grows with every new CoS issued, every new starter, every site manager, and every change that needs monitoring and reporting.

A professional UKVI compliance audit is a common-sense investment - practical insurance against a failure that could cost far more than money.

For information or advice on a UKVI compliance audit please click the button below or call us on 0203 488 4776.

More information

Check out our compliance audit service at: https://www.harleymedicalservices.co.uk/ho-compliance-audits