UK sponsor licence holders are increasingly receiving emails from the Home Office alleging that sponsored workers may have been underpaid.
While this issue can affect any sponsored business, we are seeing a clear pattern of care providers being specifically targeted – in what seems a sector specific crack-down. However, this is not limited to the care sector.
If you receive one of these emails, it is critical that you treat it as urgent.
In many recent cases, the Home Office has moved quickly from enquiry to revocation.
Below, we explain what these emails mean, why they are more serious than they appear, and what you should do immediately. Or alternatively you can find out more in video format via our TikTok.
What Does the Home Office Email Say?
The email typically states that the Home Office is investigating concerns that sponsored workers “may not be receiving a salary that matches the salary stated on their Certificate of Sponsorship”.
It then refers to Annex C1(aa) of the sponsor guidance and warns that a sponsor licence may be revoked if:
- A sponsored worker is paid less than stated on the CoS; and
- The sponsor has not reported the change; or
- The reduction is not otherwise permitted under the Immigration Rules.
Sponsors are usually given just 10 working days to provide documents.
Sometimes individual workers are named. Sometimes they are not.
The Documents Requested
The request often includes:
- Signed contracts of employment
- Six months of payslips
- National Insurance numbers
- Six months of business bank statements (all accounts)
- Payroll summaries / RTI reports
- Evidence of payments where bulk payroll is used
- Evidence of prepaid card payments (e.g. FOREX cards)
- Evidence of cheque clearance
On the surface, this looks like a payroll verification exercise.
In reality, it is far more serious.
Why This Is Not Just a Payroll Exercise
Although the Home Office asks for general pay information, in practice a comprehensive legal response is usually required.
Common underlying issues we see include:
- Salary thresholds misunderstood after April 2024 rule changes
- Hourly rate compliance but average hours falling below CoS expectations
- Unpaid leave not properly reported
- Reduced hours due to sickness or maternity
- Payroll timing differences
- Deductions affecting minimum salary compliance
- Inconsistent HR record-keeping
In many cases, there are lawful explanations. But unless they are clearly set out, supported with evidence, and framed correctly within sponsor guidance and the Immigration Rules, the Home Office may interpret the situation as a “serious or systematic breach”.
We are increasingly seeing the Home Office move straight to revocation without first downgrading the licence or issuing an action plan.
The Consequences of Sponsor Licence Revocation
Revocation is devastating.
If your sponsor licence is revoked:
- All sponsored workers have their visas curtailed
- You lose the ability to sponsor new workers
- Recruitment pipelines collapse
- Commercial contracts may be affected
- Reputational damage follows
For care providers in particular, the operational impact can be immediate and severe.
This is why speed is critical.
Why You Should Not Respond Without Expert Advice
It is a mistake to treat this as a purely administrative request.
A proper response should:
- Audit salary compliance against the CoS and Immigration Rules
- Identify any technical breaches
- Provide mitigation and legal explanation
- Demonstrate corrective action
- Show strengthened HR systems and compliance controls
- Frame the evidence within the sponsor guidance
This is not simply about sending documents. It is about controlling the narrative before the Home Office reaches a decision.
How Truth Legal Can Help
At Truth Legal, we specialise in sponsor licence compliance and enforcement.
We assist sponsor licence holders by:
-
Preparing a Comprehensive Response
- We review payroll data, contracts, and reporting history.
- We identify risks.
- We draft a structured legal response addressing the Home Office concerns head-on.
-
Mitigating and Strengthening Compliance
- Where issues exist, we help you implement immediate HR system improvements and demonstrate proactive compliance.
-
Challenging Revocation
- If revocation occurs, all is not necessarily lost.
We regularly assist with:
- Pre-Action Protocol (PAP) letters
- Judicial Review proceedings
We are currently assisting a sponsor in ongoing Judicial Review proceedings following licence revocation based on alleged underpayment.
Time limits are strict. Acting quickly can make the difference between survival and collapse.
If You Receive One of These Emails – What To Do Immediately
- Do not ignore it.
- Do not respond hastily with documents alone.
- Do not assume the issue is minor.
- Seek urgent specialist advice.
You typically have only 10 working days.
Early, strategic intervention can prevent revocation.
A Final Word
The Home Office is clearly conducting targeted compliance activity in relation to sponsored worker pay. Care providers appear to be under particular scrutiny, but all sponsor licence holders should remain alert.
If you have received an underpayment allegation email, or if you are concerned about salary compliance under your sponsor licence, contact our immigration team immediately.
We are genuine specialists in sponsor licence defence, compliance and judicial review.
