Important Updates
Important Updates
February 26, 2026 | Hong Kong SARHong Kong SAR: Earlier Extension Filing Announced
February 28, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
February 27, 2026 | JapanJapan: New Compliance Requirement for Dispatch and Employer of Record Visa Applications Forthcoming
February 27, 2026 | New ZealandNew Zealand: Median Wage Increased for AEVW Program and AEWV-linked Visas
February 27, 2026 | United StatesUnited States: Reminder – Premium Processing Fees Increase Effective March 1
February 26, 2026 | Hong Kong SARHong Kong SAR: Earlier Extension Filing Announced
February 28, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
February 27, 2026 | JapanJapan: New Compliance Requirement for Dispatch and Employer of Record Visa Applications Forthcoming
February 27, 2026 | New ZealandNew Zealand: Median Wage Increased for AEVW Program and AEWV-linked Visas
February 27, 2026 | United StatesUnited States: Reminder – Premium Processing Fees Increase Effective March 1
February 26, 2026 | Hong Kong SARHong Kong SAR: Earlier Extension Filing Announced
Subscribe
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
  • Insights

Under the Microscope: How UK Care Providers Can Prepare for Home Office Compliance Checks

September 15, 2025

Under the Microscope: How UK Care Providers Can Prepare for Home Office Compliance Checks

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Evan Tutton - web porthole

Evan Tutton

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0) 207 090 9223

Naomi Nyamaah

Naomi Nyamaah

Associate

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9309

Related insights

  • School’s Out: 5 Steps for Compliant Employment of Student Visa Holders

Related offices

  • London

Related content

  • WorkRight: UK Right to Work Technology

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Evan Tutton - web porthole

Evan Tutton

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0) 207 090 9223

Naomi Nyamaah

Naomi Nyamaah

Associate

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9309

Related insights

  • School’s Out: 5 Steps for Compliant Employment of Student Visa Holders

Related offices

  • London

Related content

  • WorkRight: UK Right to Work Technology

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Evan Tutton - web porthole

Evan Tutton

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0) 207 090 9223

Naomi Nyamaah

Naomi Nyamaah

Associate

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9309

Related insights

  • School’s Out: 5 Steps for Compliant Employment of Student Visa Holders

Related offices

  • London

Related content

  • WorkRight: UK Right to Work Technology

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Evan Tutton, Naomi Nyamaah

The Home Office has increased scrutiny of the UK care sector after identifying cases of non-compliance and exploitation by some providers. This has resulted in more sponsor licence compliance checks (sometimes referred to as ‘audits’) and targeted visits from UK Immigration Enforcement. In fact, the Home Office recently announced that double the number of licences has been revoked between July 2024 and June 2025 compared to the previous 12 months, which is almost ten times many licences as were revoked in 2021/22 or 2022/23.

While most providers are compliant, the actions of a few have placed the entire sector under scrutiny. Care providers were already facing extremely challenging operating conditions leading to the sector’s increased reliance on international recruitment. When this is combined with the complexity of sponsor duties, care providers are now facing an increasingly challenging compliance environment.

This blog explores the Home Office’s growing focus on the sector, the risks associated with non-compliance, and practical steps care providers can take to mitigate these risks and ensure they are ready for a compliance visit.

Home Office Scrutiny in the UK Care Sector: What’s Happening?

The Home Office has stepped up compliance checks in sectors it considers high risk for exploitation and modern slavery. The care sector with its heavy reliance on foreign workers, has become a particular focus.  Although most aged and social care providers are well-intentioned, the sector's reliance on international recruitment, shift work patterns and the complexity of the right to work (RTW) and sponsor compliance regimes can make care providers prone to compliance issues.

A Sector Under Pressure

Chronic staff shortages, an ageing population and the strain of COVID-19 created an urgent demand for care workers. The expansion of the Health and Care Worker visa in 2022 gave providers the ability to sponsor international staff, leading to a sharp rise in international recruitment. The result was an immediate surge in international recruitment by providers who did not have the infrastructure in place to ensure it was done compliantly. This surge is reflected in the Home Office's report that the number of worker visas granted in the UK more than doubled in a year, reaching 336,007 in 2023, with 114,023 issued as ‘Health and Care Worker’ visas. This rapid growth has created risks. High turnover and the administrative demands of sponsorship have led some providers to face licence suspension or revocation.

In May 2025 the Home Office published “Restoring control over the immigration system: white paper”. It stated that overseas recruitment for social care visas will close starting 22 July 2025, citing exploitation and abuse in the sector and aligning with the Government’s wider strategy to reduce net migration. Extensions and in-country switching for those already in the UK will be permitted for a transitional period expected to run until 2028, though these arrangements remain under review.

The Health and Care Worker visa has become a lifeline for many providers, leaving them reliant on foreign workers to fill critical vacancies. This creates additional responsibilities, as providers must manage complex sponsor duties while often having limited HR capacity or experience in immigration compliance.

Compliance Risks

In this environment, employers sponsoring care workers must carefully navigate the compliance obligations set by the Home Office to ensure that they are prepared for a Home Office compliance check. Below are common issues and steps to address them.

Work Restrictions

Student visa holders and sponsored workers performing supplementary work within the care sector are higher risk cohorts as they have strict limits on their working hours and are subject to other work conditions. Students may work up to 10 or 20 hours per week during term time, while supplementary workers can work up to 20 hours per week outside their contracted hours.

Employers must record working hours accurately and implement monitoring systems to remain compliant.

Common issues include:

      • No system to limit working hours
      • Missing evidence of university term dates or course completion
      • Assigning roles not permitted as supplementary work

To maintain compliance, employers should track working hours, maintain schedules, cross reference term dates, check and enforce work restrictions, and regularly review the Employer’s guide to right to work checks. For additional guidance on student visa holders, see our previous blog on employing student visa holders.

Salary Issues

Sponsors must pay workers the salary stated on their certificate of sponsorship. Problems often arise when:

      • Hours are reduced so pay falls below the required threshold
      • Prohibited deductions are made
      • Recoupments reduce pay below the required threshold
      • Salaries are not updated in line with Home Office guidance

Regular reviews and staff education are critical. Care providers must ensure staff responsible for creating rotas understand the requirements for sponsored workers, including allocating sufficient hours to maintain the salary stated in their certificate of sponsorship.

Sponsor Licence Compliance

The UK sponsor licence regime places clear obligations on providers, and failure to comply can lead to sponsor license suspension or revocation. Common issues include:

      • Missing or incomplete staff records
      • Performing right to work checks incorrectly
      • Failing to report changes in workers’ circumstances

The Home Office is increasing the number of sponsor compliance checks.  Sponsor licence holders must be audit ready at all times, with records organised, up to date and easy to access.  

Preparing for a Home Office Compliance Check

Given the increased scrutiny, providers should take proactive steps to strengthen their compliance and ensure they are ready for a compliance check. Key actions include:

      • Conduct regular internal audits to identify potential compliance issues early and address them before they become problems.
      • Consider engaging an immigration service provider to deliver a simulated Home Office compliance check to test systems and record keeping.
      • Provide comprehensive training to staff responsible for sponsorship duties, right to work checks and record keeping, ensuring they understand their responsibilities and can apply procedures consistently.
      • Consider using a Digital Verification Service, such as Fragomen’s WorkRight to streamline RTW checks.
      • Establish effective controls to monitor working-hour limits and other visa conditions.

UK immigration law changes frequently, and providers must remain informed about updates that affect sponsor duties or worker eligibility. Providers can stay up to date on changes to immigration rules and sponsor duties by subscribing to Fragomen’s communications.

As Home Office scrutiny intensifies, care providers must proactively manage their compliance obligations to safeguard operations and maintain their ability to sponsor care workers and other staff. By adopting robust compliance practices and providing ongoing staff training, providers can prepare for and respond effectively to a Home Office compliance check.

Need to Know More?

To learn more about assessing your readiness or testing your processes through a simulated compliance check, please contact our Compliance and Audit team at [email protected].

This blog was published on 15 September 2025, and due to the circumstances, there are frequent changes. To keep up to date with all the latest updates on global immigration, please subscribe to our alerts and follow us on LinkedIn, Twitter, Facebook and Instagram. 

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Evan Tutton - web porthole

Evan Tutton

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0) 207 090 9223

Naomi Nyamaah

Naomi Nyamaah

Associate

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9309

Related insights

  • School’s Out: 5 Steps for Compliant Employment of Student Visa Holders

Related offices

  • London

Related content

  • WorkRight: UK Right to Work Technology

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Evan Tutton - web porthole

Evan Tutton

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0) 207 090 9223

Naomi Nyamaah

Naomi Nyamaah

Associate

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9309

Related insights

  • School’s Out: 5 Steps for Compliant Employment of Student Visa Holders

Related offices

  • London

Related content

  • WorkRight: UK Right to Work Technology

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Evan Tutton - web porthole

Evan Tutton

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0) 207 090 9223

Naomi Nyamaah

Naomi Nyamaah

Associate

London, United Kingdom

Email

[email protected]

T:+44 20 7090 9309

Related insights

  • School’s Out: 5 Steps for Compliant Employment of Student Visa Holders

Related offices

  • London

Related content

  • WorkRight: UK Right to Work Technology

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Blog post

Bringing the Indonesian Diaspora Home: Insights on the New Global Citizenship Program

Senior Business Immigration Consultant Ryaihanny Sahrom and Business Immigration Consultant II Fahimah Muhammad examine Indonesia’s newly launched Global Citizenship of Indonesia (GCI) program and its introduction of long-term and indefinite permanent residence pathways for members of the Indonesian diaspora.

Learn more

Media mentions

Times Higher Education: Chaos’ Expected as New Visa Compliance Rules Now Due in June

Senior Immigration Manager Jonathan Hill notes that tighter UK visa compliance rules and new rating measures create additional challenges for universities.

Learn more

Video

Brazil: Early Career Visa

Partner Diana Quintas outlines key early career visa pathways and practical considerations for employers and graduates navigating entry-level immigration options.

Learn more

Fragomen news

Canadian Lawyer Magazine: Fragomen, Immigration Firm, Adds Julie Lessard as Partner in Montréal

The Montreal office has added Partner Julie Lessard and Counsel Elsa Agostinho and Sophia Khanzadian to strengthen its immigration services.

Learn more

Blog post

Housing Market Dynamics in Saudi Arabia: Policy Changes, Rent Stabilization and Cost of Living Implications for Employers

Destination Services Director Christine Sperr examines how housing market reforms, rent stabilization measures and cost-of-living dynamics in Saudi Arabia are influencing workforce mobility, compensation planning and long-term settlement strategies under Vision 2030.

Learn more

Blog post

Under EU Review: Germany’s Visa Requirements Trigger Infringement Proceedings on Vander Elst Compliance

Manager Dr Adela Schmidt and Senior Associate Isabel Schnitzler analyse the European Commission’s infringement proceedings against Germany concerning its Vander Elst visa requirements for third-country nationals providing short-term cross-border services and explain why current compliance obligations remain unchanged.

Learn more

Blog post

Venezuela’s Energy Reset: Unlocking Opportunity, Managing Risk and Deploying Talent Strategically

Latin America & the Caribbean Managing Partner Leonor Echeverria, Senior Associates Sarah Blackmore and Sonya Cole and Senior Regional Knowledge Manager Laura Weingort examine renewed energy interest in Venezuela and outline key immigration pathways, procedural constraints and strategic considerations for compliant talent deployment.

Learn more

Media mentions

Global Mobility Lawyer: EU to Leverage Visas With New “Assertive Migration Diplomacy” Strategy

Senior Manager Andreia Ghimis highlights how the EU’s new migration strategy could create opportunities for employers while increasing compliance requirements.

Learn more

Awards

Spear's 500 Recognises Partner Julia Onslow-Cole

Partner Julia Onslow-Cole is recognised in the Spears 500 guide to leading private client advisers, reflecting her experience advising high-net-worth individuals, families and global businesses on complex UK and European immigration and mobility strategies.

Learn more

Media mentions

Arabian Gulf Business Insight: Saudi Business Visa Rejections Rise as Scrutiny Tightens

Partner Abeer Al Husseini discusses increased scrutiny of Saudi business visas in AGBI, highlighting stricter review of short-term entry used for operational work and the implications for regional employers.

Learn more

Awards

Doyle’s Guide 2026: Fragomen Leaders Recognized as Leading Immigration Lawyers

Australia and New Zealand Managing Partner  Teresa Liu, Partner Charles Johanes, Practice Leaders Hedvika and Leader Ben Lear and Senior Associate Hannah Scanlan are recognized in the 2026 edition of Doyle’s Guide as leading immigration practitioners in Australia.

Learn more

Awards

Fragomen Ranked Band 1 in the Chambers Global 2026 Guide

Fragomen is ranked Band 1 for Immigration: Business in the Chambers Global 2026 Guide, marking two decades of recognition since 2006. The firm is also the only firm ranked Band 1 in the Global: Multi-Jurisdictional Immigration category and receives additional individual recognitions in the USA: Business Immigration rankings.

Learn more

Blog post

Bringing the Indonesian Diaspora Home: Insights on the New Global Citizenship Program

Senior Business Immigration Consultant Ryaihanny Sahrom and Business Immigration Consultant II Fahimah Muhammad examine Indonesia’s newly launched Global Citizenship of Indonesia (GCI) program and its introduction of long-term and indefinite permanent residence pathways for members of the Indonesian diaspora.

Learn more

Media mentions

Times Higher Education: Chaos’ Expected as New Visa Compliance Rules Now Due in June

Senior Immigration Manager Jonathan Hill notes that tighter UK visa compliance rules and new rating measures create additional challenges for universities.

Learn more

Video

Brazil: Early Career Visa

Partner Diana Quintas outlines key early career visa pathways and practical considerations for employers and graduates navigating entry-level immigration options.

Learn more

Fragomen news

Canadian Lawyer Magazine: Fragomen, Immigration Firm, Adds Julie Lessard as Partner in Montréal

The Montreal office has added Partner Julie Lessard and Counsel Elsa Agostinho and Sophia Khanzadian to strengthen its immigration services.

Learn more

Blog post

Housing Market Dynamics in Saudi Arabia: Policy Changes, Rent Stabilization and Cost of Living Implications for Employers

Destination Services Director Christine Sperr examines how housing market reforms, rent stabilization measures and cost-of-living dynamics in Saudi Arabia are influencing workforce mobility, compensation planning and long-term settlement strategies under Vision 2030.

Learn more

Blog post

Under EU Review: Germany’s Visa Requirements Trigger Infringement Proceedings on Vander Elst Compliance

Manager Dr Adela Schmidt and Senior Associate Isabel Schnitzler analyse the European Commission’s infringement proceedings against Germany concerning its Vander Elst visa requirements for third-country nationals providing short-term cross-border services and explain why current compliance obligations remain unchanged.

Learn more

Blog post

Venezuela’s Energy Reset: Unlocking Opportunity, Managing Risk and Deploying Talent Strategically

Latin America & the Caribbean Managing Partner Leonor Echeverria, Senior Associates Sarah Blackmore and Sonya Cole and Senior Regional Knowledge Manager Laura Weingort examine renewed energy interest in Venezuela and outline key immigration pathways, procedural constraints and strategic considerations for compliant talent deployment.

Learn more

Media mentions

Global Mobility Lawyer: EU to Leverage Visas With New “Assertive Migration Diplomacy” Strategy

Senior Manager Andreia Ghimis highlights how the EU’s new migration strategy could create opportunities for employers while increasing compliance requirements.

Learn more

Awards

Spear's 500 Recognises Partner Julia Onslow-Cole

Partner Julia Onslow-Cole is recognised in the Spears 500 guide to leading private client advisers, reflecting her experience advising high-net-worth individuals, families and global businesses on complex UK and European immigration and mobility strategies.

Learn more

Media mentions

Arabian Gulf Business Insight: Saudi Business Visa Rejections Rise as Scrutiny Tightens

Partner Abeer Al Husseini discusses increased scrutiny of Saudi business visas in AGBI, highlighting stricter review of short-term entry used for operational work and the implications for regional employers.

Learn more

Awards

Doyle’s Guide 2026: Fragomen Leaders Recognized as Leading Immigration Lawyers

Australia and New Zealand Managing Partner  Teresa Liu, Partner Charles Johanes, Practice Leaders Hedvika and Leader Ben Lear and Senior Associate Hannah Scanlan are recognized in the 2026 edition of Doyle’s Guide as leading immigration practitioners in Australia.

Learn more

Awards

Fragomen Ranked Band 1 in the Chambers Global 2026 Guide

Fragomen is ranked Band 1 for Immigration: Business in the Chambers Global 2026 Guide, marking two decades of recognition since 2006. The firm is also the only firm ranked Band 1 in the Global: Multi-Jurisdictional Immigration category and receives additional individual recognitions in the USA: Business Immigration rankings.

Learn more

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
  • UK Regulatory Requirements

Our firm

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

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • 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.