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

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 In fact, the Home Office recently announced that double the number of licences has been revoked between July 2024 and June 2025 compared to the previous 12 months, which is almost ten times many licences as were revoked in 2021/22 or 2022/23.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.