Home Office crackdown on sponsor compliance and illegal working

The Home Office has significantly increased its enforcement activity around sponsor compliance and the prevention of illegal working. In exchange for the ability to sponsor international students, independent schools need to adhere to strict standards set out in the UK’s Immigration Rules and sponsor guidance. Recently released figures show that in the year between June 2024 and June 2025, 16 student Sponsor Licences were revoked (an increase of 60% compared to the previous year) and 1,948 worker Sponsor Licences were revoked (more than double the previous year’s figure). In addition, in the same period, 31 student sponsors were issued with an intention to revoke notice (an increase of around 35% compared to the same period last year).

This sharp rise reflects the Home Office clamping down on the misuse of Sponsor Licences and taking enforcement action against those they consider to be exploiting the system. The practical implication of this is that the Home Office is undertaking more site visits and audits (on employers as a whole and those that hold Sponsor Licences in particular) to assess their compliance with their legal obligations. This includes schools who sponsor international pupils under the Child Student or Student visa routes, or staff under the Skilled Worker route.

Compliance officers aim to visit schools every few years, but we often see audits at certain key moments such as when a school applies for a Sponsor Licence, around annual compliance assessments, and in connection with other inspections (eg an ISI or Ofsted inspection). The Home Office has increasingly been using more sophisticated and improved data and intelligence sharing across government and legal departments to identify the rule breakers. Common issues flagged by the Home Office include incomplete or missing Right to Work or Right to Study checks; sponsored staff working in roles not aligned with their visa conditions; and missing mandatory record-keeping for sponsored students.

The upward trend of licences being revoked is likely to continue, with the Home Office expected to continue to implement increased checks across the sector. Given the potentially far-reaching consequences of non-compliance (which include licence suspension or revocation, reputational damage, business closure, financial penalties or even prosecution in serious cases), we recommend that schools review their procedures to ensure these are fully compliant with Home Office requirements. While the Home Office highlighted certain sectors as having higher levels of abuse (including social care, hospitality, retail and construction), we recommend all schools undertake checks and internal audits of the systems, policies and processes they have in place to meet their obligations as employers and sponsors.

At Farrer & Co, our Immigration team regularly advises schools on student and staff sponsorship; conducts mock audits and compliance reviews to identify vulnerabilities before they become compliance issues; and works closely with admissions and HR teams to ensure their systems are fully compliant. For tailored advice, please contact Elena Hinchin, Partner, or Anjana Daniel, Associate.

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances.

© Farrer & Co LLP, October 2025