Over the last 12 months, UK Visas and Immigration (UKVI) has intensified its enforcement activity to unprecedented levels, with 1,948 sponsor licences revoked between July 2024 and June 2025—more than double the previous year’s total of 937. The Home Office has made clear that they are seeking to double these numbers over the next 12 months. This surge reflects a strategic shift toward intelligence led compliance, where HMRC, PAYE, Companies House and SMS data are actively monitored to identify salary discrepancies, unreported changes, and gaps in record keeping. Issues such as underpayments and failure to provide promised work remain common drivers of revocation. With illegal working arrests also rising by 51% year on year, it is clear that enforcement will continue at this heightened level.
Organisations undergoing corporate change are facing particular sponsor compliance risks and schools and trusts need to be alert to this as well. Sponsor licences cannot be transferred between entities, meaning mergers, acquisitions, and group restructures often trigger Home Office reviews and, in some cases, suspensions. In the education context, this could apply, for example, if a multi-academy trust is being established or there is a merger between MATs or independent schools. TUPE protects employees, but it does not preserve the sponsor licence, requiring sponsors to report changes within 20 working days or risk enforcement action, including curtailment of workers’ visas. In a school context, TUPE may apply when a school joins or leaves a MAT or, for example, if a catering, cleaning or wraparound care service is brought in-house. If a service is outsourced, then it is the contractor’s obligation to ensure that they have an appropriate sponsor licence in place for acquired sponsored workers but the school should make appropriate enquiries to ensure this is in place as part of the tender process and in the contractual arrangements (alongside DBS, barred list, identity and right to work checks as appropriate). There is a risk of reputational damage and operational risk to a school if it transpires that the contractor did not comply with sponsor duties and obligations in a timely manner.
Pay structure changes—such as adjustments to allowances, hours or locations—continue to be a leading source of breaches, as even technical underpayments can result in sanctions under the current low tolerance regime. To stay compliant, sponsors must treat licence management as an ongoing obligation, particularly during periods of operational or structural change.