The past year has seen an unprecedented escalation in UK Visas and Immigration (UKVI) enforcement activity. Sponsor licence holders across all sectors are now facing the most intensive compliance scrutiny on record. As the UK government continues its drive to reduce net migration and combat exploitation, businesses must fully understand the emerging trends in enforcement, including suspensions and revocations as well as the heightened monitoring around organisational change, TUPE transfers, and pay structure adjustments.
Record-Breaking Sponsor Licence Revocations and Suspensions
Home Office statistics confirm that enforcement has reached an all-time high, a pattern which will continue, as expressly confirmed by Home Office sources. Between July 2024 and June 2025, the Home Office revoked 1,948 sponsor licences, more than double the 937 revoked in the previous 12 months. This figure—consistently repeated across official releases and legal commentary—marks the highest number on record and is indicative of an expanded, intelligence-led enforcement strategy.
Revocations were concentrated in high-risk sectors including adult social care, hospitality, retail, and construction, reflecting persistent concerns around underpayment, poor record-keeping and exploitation. Compliance action is expected to increase again in the coming year, with government sources signalling continued investment in cross-departmental data-sharing.
This surge has also been accompanied by a 51% increase in illegal working arrests, demonstrating wider enforcement consistency across immigration operations.
A Shift Toward Data-Led, Intelligence-Based Enforcement
The Home Office has increasingly moved away from traditional in‑person compliance visits toward data-driven oversight, drawing from HMRC, PAYE, Companies House and Sponsor Management System (SMS) activity to identify anomalies.
This shift has several implications:
- Lower tolerance for technical breaches, with even minor delays in reporting changes triggering suspensions or revocations.
- Greater monitoring of pay structures, including underpayments resulting from miscalculated allowances, deductions, or hours—issues that remain a major driver of enforcement action.
- Increased use of civil penalties, business closure orders, and potential prosecutions in serious cases.
The scale of enforcement activity further reflects the Home Office’s “zero‑tolerance” approach, reaffirmed in multiple ministerial statements.
Corporate Change as a Compliance Risk: Ownership Changes, Mergers & Acquisitions
One of the most significant risk areas emerging from recent casework involves the lack of compliance actions where there have been organisational changes, including:
- Changes in ownership or shareholding
- Mergers and acquisitions
- Group restructures
- De-mergers and the creation of new legal entities
A consistent theme across Home Office guidance and legal commentary is that sponsor licences are not transferable between legal entities. When a company is acquired, the sponsor licence of the acquired entity cannot simply be passed to the buyer.
Sponsors must report such changes within 20 working days, and failure to do so may result in suspension or revocation. The Home Office is now routinely picking up corporate changes when processing routine SMS requests such as additional COS’ requests and requests for defined COS’. We have seen decisions to immediately revoke a sponsor licence due to delays in compliance action. It is therefore growing increasingly important for sponsors to be fully aware of ongoing duties and compliance triggers.
Additionally, recent enforcement patterns show that corporate transactions frequently trigger Home Office audits, particularly where oversight of HR files, right‑to‑work checks, and SMS reporting has weakened during organisational transition.
TUPE Transfers: Protecting Workers, Not the Licence
Although the Transfer of Undertakings (Protection of Employment) Regulations 2006 (TUPE) protect employees’ contractual rights during business transfers, they do not preserve the sponsor licence.
Key risks include:
- Sponsored workers transferring without the receiving entity holding a valid licence
- Gaps in sponsorship and migrant reporting obligations during the transition period
- Loss of sponsorship leading to visa curtailment of sponsored workers, often within 60 days of licence revocation in affected companies.
Sponsors must notify UKVI within 20 working days of any TUPE event, confirming which legal entity will assume sponsorship responsibilities. There may also be a need to carry out fresh right to work checks, an audit of sponsored workers and notifications to the Home Office of acquired sponsored workers. Failure to do so can automatically trigger licence suspension.
This is particularly important in group-level restructures where new entities are created, or existing ones dissolved—situations found to be a common source of non-compliance in recent enforcement data and matters which are not always made aware to HR teams responsible for sponsorship until outside the compliance timeframes.
Pay Structure Changes and Salary Compliance
Salary-related breaches continue to be one of the top reasons for licence revocations, particularly where:
- Salary falls below the appropriate going rate
- Employers fail to adjust pay following changes in role, hours, or location
- Complex allowance structures or deductions reduce take‑home pay below required thresholds
Home Office intelligence-led monitoring of PAYE and HMRC returns frequently identifies discrepancies, and recent commentary confirms that sponsors are now penalised even for technical underpayments. Given the government’s focus on protecting both migrant and domestic workers, salary compliance is expected to remain a primary enforcement focus throughout 2026
Recommended actions for sponsors
The past year’s enforcement patterns demonstrate that the UKVI expects continuous, proactive compliance, not reactive correction. Businesses should anticipate further increases in revocations, ongoing expansion of data-led enforcement tools, and stricter oversight of corporate restructuring events.
Some key action points include:
- Conduct regular internal compliance audits with specific focus on SMS reporting, record‑keeping, right‑to‑work checks and salary accuracy.
- Advanced map out immigration implications in advance of organisational changes including obtaining new licences where needed.
- Apply TUPE and sponsorship rules in parallel ensuring visas and compliance duties are not overlooked during corporate transitions.
- Ensure transparent pay structures and review remuneration whenever job duties or working patterns change.
- Train HR and compliance personnel to recognise reportable events and act within prescribed timelines.
Conclusion
UKVI’s enforcement posture in 2025–26 reflects a decisive shift toward high-volume, intelligence-led intervention. With nearly 2,000 sponsor licences revoked in the past year alone and further increases anticipated, sponsors cannot afford complacency. By embedding robust compliance processes and adopting a proactive approach to managing organisational and pay-related changes, businesses can significantly reduce their risk exposure and maintain the ability to sponsor skilled workers in an increasingly regulated environment.
If your organisation requires support with sponsor licence management, corporate restructuring, TUPE-related implications, or compliance audits, the specialist UK immigration team at Winckworth Sherwood can assist.