Unannounced Home Office Compliance Visit: Sponsor Licence Suspension Case Study

Unannounced Home Office Compliance Visit and Sponsor Licence Suspension: A Care Provider Case Study

It is easy to assume the Home Office has eased off on unannounced sponsor compliance visits. In practice, they are still happening.

In this case, a care provider contacted me the day they received a sponsor licence suspension letter. The suspension followed an unannounced Home Office compliance visit that took place a few months earlier.

Case Overview

The key point is that, once the visit has already happened, the Home Office has formed initial views based on what was seen, what was said on the day, and what records were immediately available.

What the Home Office Raised in the Suspension Decision

The suspension reasons set out in the letter were familiar compliance themes that show up repeatedly in sponsor enforcement action. In this matter, the suspension reasons included:

• Underpayment of sponsored workers
• Failure to report absences or late start dates
• Late right to work checks

Those issues alone can be serious, depending on the facts and how they are evidenced.

The Two Points That Stood Out

Two sponsored workers were found working on site in reception and HR-type roles, despite being sponsored in different roles:

• One sponsored as a senior carer
• One sponsored as a care assistant

Because the workers were physically present, the compliance officer interviewed them during the visit. The interviews were then used as part of what the Home Office relied on when documenting the alleged breaches in the suspension decision.

In other words, the role being carried out day to day, and the role stated on sponsorship records, did not appear to match.

What We Did Once Instructed

Once the sponsor approached us, our work focused on responding to the suspension grounds as they were set out, using records, documentation, and a clear narrative that addressed each point directly.

1) Triage and Issue Mapping Against the Suspension Letter

We broke the suspension reasons down into individual points so that each issue could be handled with its own evidence and explanation, rather than responding in general terms.

This included separating issues related to pay, reporting, right to work checks, and the duties actually being carried out by the sponsored workers.

2) Evidence Gathering and Document Review

We examined the sponsor's documentation and internal records that were relevant to the suspension points, including:

• Payroll and pay-related records relevant to the underpayment concern
• Attendance, absence, and start date records relevant to reporting concerns
• Right to work documentation, including dates and audit trails
• Role information for the sponsored workers, including what was assigned on sponsorship documentation versus what was being carried out on site

The goal was to create a clear, cross-referenced evidence pack that matched the Home Office concerns point by point.

3) Role and Duty Analysis for the Sponsored Workers

Because the on-site roles were central to the suspension narrative, we focused on documenting what duties were carried out in practice, how those duties were recorded internally, and how they aligned with the sponsorship records.

Why This Case is Worth Documenting

This case illustrates a dynamic that comes up repeatedly in unannounced compliance visits:

• The Home Office observes how records are held in real time
• Staff are asked questions without preparation time
• The sponsor's day-to-day operational reality becomes part of the evidence base

That combination often shapes what appears in the suspension decision letter.

Book a Call

If you are dealing with a sponsor licence suspension letter, a compliance visit has already happened, or you are in the period where you are waiting for a decision, you can discuss it with us on a confidential call.