• Insights

Where Did the Last Four Years Go? Renewing Your Sponsor Licence

August 19, 2016

Naomi-Goldshtein_London

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Naomi Goldshtein

This November marks eight years since the introduction of the Points Based System and the second renewal cycle for those who obtained their sponsor licence at the outset. Due to the large numbers of renewals expected to be filed within the next six months, the UK Visas and Immigration (UKVI )contacted a number of sponsors in July inviting them to submit their sponsor licence renewal from 31st July 2016. With filings well underway, sponsors should be aware that on many occasions post licence audits have been prompted by the filing of a sponsor licence renewal. As tempting as it may be, sponsors should think twice before rushing into the renewal process if they are not confident in their in-house immigration compliance processes as the UKVI can (and often do) undertake on-site audits with minimal or no notice.

If patterns of non-compliance are identified during a post licence audit, a sponsor licence could be downgraded, suspended or revoked. In the event of downgrading or suspension, a sponsor is prevented from issuing any Certificates of Sponsorship until their status as an A rated sponsor has been reinstated. In the event of revocation, a sponsor will be removed from the UKVI register of sponsors resulting in their sponsored migrant population having their visas curtailed.  

Sponsors wanting to avoid this outcome are obligated to take on and maintain certain duties. The main objective being to prevent immigration abuse by ensuring patterns of behaviour are detected and tackled early and possible weaknesses in processes, which can lead to these patterns, are addressed promptly. The actual duties themselves relate to record keeping and reporting as well as compliance with the law in relation to the prevention of illegal working.

Five key areas of compliance

More specifically, sponsors must ensure they are compliant in the following five key areas:

  • Monitoring immigration status and preventing illegal employment;
  • Maintaining migrant contact details;
  • Record keeping and recruitment practices;
  • Migrant tracking and monitoring; and
  • Other general reporting duties.
 
Although many sponsors will not have been through a UKVI audit during the four-year validity of their licence, it is imperative that they continue to uphold their compliance obligations if they wish to compliantly facilitate sponsorship in the UK. Post licence UKVI audits have become more forensic in nature over the last four years and sponsor licence holders do not always succeed in upholding the standards necessary to maintain their licence.
 
I often help clients with their compliance practices by undertaking mock audits and the most common areas of weakness I come across are inadequate right to work check processes, failure to report significant changes in migrant circumstances and little documentation maintained on file to evidence the Resident Labour Market Test having been completed in accordance with UKVI requirements. Although the UKVI is unlikely to undertake action for one late SMS update, action will be taken if there is evidence of any systemic failings. The loss of a Sponsor licence can be damaging in itself; however there can also be civil and criminal penalties in the event of illegal working, plus significant reputational damage if the media become aware.
 
Should you wish to discuss your sponsor compliance obligations, Fragomen have a dedicated Compliance Team who are able to assist with all aspects of maintaining a sponsor licence and the renewal process.
 
For further information, please contact [email protected].

 

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Naomi Goldshtein

Naomi Goldshtein

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9276

Related offices

  • London
  • Sheffield

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Generic Insights

Blog post

2026 Immigration Regulatory Changes: What Academic Medical Centers Need to Know

In this blog, Counsel Christopher Wendt examines four developments AMCs should have on their radar and why preparing for them may require coordination across immigration, GME, research administration, HR, benefits, finance and more.

Learn more

Blog post

Five Questions to Consider Before Seeking Residence or Citizenship in Europe

Senior Manager Andreia Florina Ghimis and Manager Pierangelo D’Errico outline five key questions to ask before seeking residency in Europe.

Learn more

Awards

Fragomen Receives Brandon Hall Group™ Gold HCM Excellence Award® for Leadership Development

Fragomen received a Brandon Hall Group™ Gold HCM Excellence Award® in the Best Leadership Development Program category for The Leadership Lifecycle.

Learn more

Media mentions

People Management: Unpacking the New Overseas Talent ‘Concierge’ Service

Partner Charlotte Wills and Senior Manager Harry Goldstraw discuss the UK’s new overseas talent “concierge” service and what it means for high-growth businesses recruiting international talent.

Learn more

Blog post

A1-Bescheinigung oder Certificate of Coverage (CoC): Welches Dokument wird wann benötigt?

In this blog, Senior Manager Katharina Vorländer explains when A1 certificates and Certificates of Coverage (CoCs) may be required, the key differences between the two documents and what employers should consider before managing international assignments.

Learn more

Awards

Fragomen Attorneys Recognized in the 2027 Edition of The Best Lawyers in America™

Fragomen attorneys are recognized in the 2027 editions of The Best Lawyers in America™ and Best Lawyers: Ones to Watch® in America, including Partner Matthew Phillips and Senior Counsel Mitch Wexler as Lawyer of the Year recipients.

Learn more

Media mentions

Times of India: Trump’s New H-1B Visa Reality for Indians: Unpredictable Costs, Tougher Odds and Greater Risks

Partner K. Edward Raleigh discusses evolving H-1B policies and the importance of long-term immigration planning for Indian professionals and US employers.

Learn more
Generic Insights

Blog post

Die Niederlassungserlaubnis nach § 9 Abs. 3a AufenthG: Ein richtiger Schritt zur schnelleren und dauerhaften Integration von Ehegatten von Fachkräften

In unserem aktuellen Blog erläutert Ruben Fiedler, wer von der Regelung profitieren kann, welche Voraussetzungen gelten und was sie für Fachkräfte und ihre Familien in Deutschland bedeutet.

Learn more

Media mentions

EB5 Investors: Brazil Emerges as One of EB-5’s Fastest-Growing Markets Amid Economic Strain

Partner Gustavo Kanashiro discusses the factors driving Brazilian families’ growing interest in the EB-5 program, including wealth planning and long-term mobility.

Learn more

Blog post

Africa’s Growing Investment Ambitions Are Reshaping Immigration Policy

Partner Lunga Mani discusses how Africa’s growing investment ambitions are reshaping immigration policy, creating new mobility opportunities alongside increasing compliance and localisation requirements.

Learn more

Blog post

Healthcare Horizons: What Healthcare Employers Should Watch in the 2026 Immigration Regulatory Agenda

Counsel Christopher Wendt looks at the 2026 immigration regulatory agenda and three developments that could have a significant impact on healthcare organizations, from hospitals to research institutions and other clinical employers. 

Learn more

Podcast

Immigration in South Africa

Partner Lunga Mani and Director Johannes Kgotso Tiba discuss South Africa’s evolving immigration landscape and key considerations for employers, foreign nationals and global mobility teams.

Learn more
Generic Insights

Blog post

2026 Immigration Regulatory Changes: What Academic Medical Centers Need to Know

In this blog, Counsel Christopher Wendt examines four developments AMCs should have on their radar and why preparing for them may require coordination across immigration, GME, research administration, HR, benefits, finance and more.

Learn more

Blog post

Five Questions to Consider Before Seeking Residence or Citizenship in Europe

Senior Manager Andreia Florina Ghimis and Manager Pierangelo D’Errico outline five key questions to ask before seeking residency in Europe.

Learn more

Awards

Fragomen Receives Brandon Hall Group™ Gold HCM Excellence Award® for Leadership Development

Fragomen received a Brandon Hall Group™ Gold HCM Excellence Award® in the Best Leadership Development Program category for The Leadership Lifecycle.

Learn more

Media mentions

People Management: Unpacking the New Overseas Talent ‘Concierge’ Service

Partner Charlotte Wills and Senior Manager Harry Goldstraw discuss the UK’s new overseas talent “concierge” service and what it means for high-growth businesses recruiting international talent.

Learn more

Blog post

A1-Bescheinigung oder Certificate of Coverage (CoC): Welches Dokument wird wann benötigt?

In this blog, Senior Manager Katharina Vorländer explains when A1 certificates and Certificates of Coverage (CoCs) may be required, the key differences between the two documents and what employers should consider before managing international assignments.

Learn more

Awards

Fragomen Attorneys Recognized in the 2027 Edition of The Best Lawyers in America™

Fragomen attorneys are recognized in the 2027 editions of The Best Lawyers in America™ and Best Lawyers: Ones to Watch® in America, including Partner Matthew Phillips and Senior Counsel Mitch Wexler as Lawyer of the Year recipients.

Learn more

Media mentions

Times of India: Trump’s New H-1B Visa Reality for Indians: Unpredictable Costs, Tougher Odds and Greater Risks

Partner K. Edward Raleigh discusses evolving H-1B policies and the importance of long-term immigration planning for Indian professionals and US employers.

Learn more
Generic Insights

Blog post

Die Niederlassungserlaubnis nach § 9 Abs. 3a AufenthG: Ein richtiger Schritt zur schnelleren und dauerhaften Integration von Ehegatten von Fachkräften

In unserem aktuellen Blog erläutert Ruben Fiedler, wer von der Regelung profitieren kann, welche Voraussetzungen gelten und was sie für Fachkräfte und ihre Familien in Deutschland bedeutet.

Learn more

Media mentions

EB5 Investors: Brazil Emerges as One of EB-5’s Fastest-Growing Markets Amid Economic Strain

Partner Gustavo Kanashiro discusses the factors driving Brazilian families’ growing interest in the EB-5 program, including wealth planning and long-term mobility.

Learn more

Blog post

Africa’s Growing Investment Ambitions Are Reshaping Immigration Policy

Partner Lunga Mani discusses how Africa’s growing investment ambitions are reshaping immigration policy, creating new mobility opportunities alongside increasing compliance and localisation requirements.

Learn more

Blog post

Healthcare Horizons: What Healthcare Employers Should Watch in the 2026 Immigration Regulatory Agenda

Counsel Christopher Wendt looks at the 2026 immigration regulatory agenda and three developments that could have a significant impact on healthcare organizations, from hospitals to research institutions and other clinical employers. 

Learn more

Podcast

Immigration in South Africa

Partner Lunga Mani and Director Johannes Kgotso Tiba discuss South Africa’s evolving immigration landscape and key considerations for employers, foreign nationals and global mobility teams.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • Vietnamese Immigration
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
August 24, 2026 | United StatesUnited States: Federal District Court Vacates State Department’s 75-Country Immigrant Visa Ban
August 24, 2026 | United StatesFragomen Receives Brandon Hall Group™ Gold HCM Excellence Award® for Leadership Development
August 24, 2026 | NamibiaNamibia: New Investor and Business Owner Permit Introduced
August 24, 2026 | United KingdomPeople Management: Unpacking the New Overseas Talent ‘Concierge’ Service
August 24, 2026 | Saudi ArabiaSaudi Arabia: Saudization Requirements Announced for Several Activities and Professions
August 24, 2026 | United StatesUnited States: Federal District Court Vacates State Department’s 75-Country Immigrant Visa Ban
August 24, 2026 | United StatesFragomen Receives Brandon Hall Group™ Gold HCM Excellence Award® for Leadership Development
August 24, 2026 | NamibiaNamibia: New Investor and Business Owner Permit Introduced
August 24, 2026 | United KingdomPeople Management: Unpacking the New Overseas Talent ‘Concierge’ Service
August 24, 2026 | Saudi ArabiaSaudi Arabia: Saudization Requirements Announced for Several Activities and Professions
August 24, 2026 | United StatesUnited States: Federal District Court Vacates State Department’s 75-Country Immigrant Visa Ban
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.