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In a recent decision from the King’s Bench Division (Administrative Court) dated 18 February 2026, the court dismissed the judicial review brought by Southcroft Healthcare Lodge Limited, challenging the Secretary of State for the Home Department’s revocation of its sponsor licence. The case highlights the strict obligations imposed on UK sponsors and the serious consequences of non-compliance.

The court confirmed that the Secretary of State was entitled to revoke the licence on three independent grounds, each of which alone would have justified the decision.

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Misuse of Certificates of Sponsorship

The first ground related to the assignment of 97 Certificates of Sponsorship (CoS) under SOC code 6145 care workers and home carers (now 6135) for roles that did not match the occupational classification. The code in question covers roles involving significant personal care services, which the claimant’s support workers did not provide. This breach of Annex C1(s) of the Sponsor Guidance is considered a mandatory ground for licence revocation.

 

Failure to Pay Salaries and Notify Changes

The second ground concerned salary issues. Four sponsored workers were not paid the annual salary specified on their CoS, and the Home Office was not notified of these reductions. This contravened Annex C1(aa), another mandatory revocation ground, emphasising that accurate and timely reporting of pay is central to compliance.

 

Failure to Provide Requested Documentation

Finally, the claimant failed to provide requested documentation for two sponsored workers, in breach of paragraph C1.34 and Annex C2(a) of the Guidance. Such failures typically result in licence revocation.

The court also noted additional failings, including password sharing and monitoring system weaknesses, which, while not independently sufficient for revocation, contributed to the overall assessment of non-compliance. The Administrative Court rejected all seven grounds brought by Southcroft Healthcare Lodge Ltd, holding that the Secretary of State’s reasoning was rational and adequate.

 

Implications for Sponsors

This case underscores the importance of strict adherence to the Home Office’s Sponsor Guidance. Employers must ensure that:

  • CoS are assigned accurately according to the correct SOC codes;
  • Salaries specified on CoS are paid, and any permitted reductions (e.g., for maternity leave and sick leave) are reported promptly;
  • Requested documentation is provided fully and on time;
  • Internal compliance systems, including monitoring and access controls, are robust.

Even minor or cumulative failings can lead to licence revocation, with serious implications for the ability to sponsor workers and maintain operational continuity.

 

Our thoughts

This decision reinforces the principle that compliance is not optional and that the Home Office will enforce obligations rigorously. Regular audits, staff training, and careful record-keeping are essential to mitigate the risk of revocation. Employers should take a proactive approach to sponsorship duties, recognising that failures, even if unintentional, can have substantial legal and operational consequences.

 

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author avatar
James Cook

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