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Employer guide

Sponsor licence suspension

What sponsor licence suspension means, when the Home Office uses it, the 20 working day response window and the possible outcomes.

Written by SkilledJobs from the Home Office sponsor guidance. General information, not legal advice. Checked against GOV.UK

Suspension is the step the Home Office can take while it investigates a sponsor. It is set out in section C9 of Part 3 of the sponsor guidance (version 08/26, valid from 28 August 2026). This guide summarises the process, with paragraph references.

It explains the published process. It does not assess any organisation's position or predict an outcome. A sponsor facing suspension should speak to a regulated adviser about its circumstances.

What suspension is

If the Home Office believes a sponsor is breaching its duties, poses a threat to immigration control, or is behaving in a way that is not conducive to the public good, it may suspend the licence while it makes further enquiries (C9.1).

Suspension is not the end of the licence. The case can end with the licence reinstated, reinstated with a B-rating, or with revocation (C9.16).

When the Home Office suspends

The guidance links suspension to the three annexes of revocation grounds:

  • Annex C1 (mandatory grounds): the Home Office will either revoke immediately or may suspend while it investigates (C9.7).
  • Annex C2 and Annex C3: it will first consider a downgrade to a B-rating, but may suspend without one (C9.8). Examples given are sustained non-compliance over time, or several minor breaches that together suggest a more serious or systematic failing.

There is one more route into suspension in Part 1. If a sponsor fails to act on the inactive SMS user process and is left with no active Level 1 User, the Home Office will suspend the licence. It then gives 28 days to nominate an eligible Level 1 User (Part 1, L4.78).

What changes during suspension

While the licence is suspended:

  • you cannot assign any Certificates of Sponsorship (CoS) (C9.2 and C9.19)
  • you must keep meeting every sponsor duty (C9.2)
  • the suspension covers every route on the licence (C9.3)
  • your organisation no longer appears on the public register of sponsors for the period of the suspension (C9.3)
  • any automatic provision to replace your Authorising Officer or Key Contact, or add Level 1 Users, is also suspended (C9.22)

You can see whether an organisation currently appears on the register with our sponsor licence check.

What happens to sponsored workers

Workers you sponsor who already hold valid permission are not affected unless and until the licence ends through revocation (C9.4).

If a worker applies using a CoS you assigned before the suspension, or you support their settlement application, the Home Office will not decide it until the suspension is resolved, unless it falls for refusal on other grounds (C9.20). A worker already granted entry clearance can still travel and start work, provided the licence has not ended through revocation by the time they travel (C9.21).

The process

Where the Home Office has enough evidence already, it writes giving the reasons for suspension (C9.9). Where it needs a full investigation, it writes with its initial reasons and says an investigation will follow (C9.10).

You have 20 working days from the date of the written notice to respond (C9.11). The guidance describes this as your opportunity to seek a review and set out any mitigating arguments. The response must be in writing, say which grounds you believe are wrong and why, and include supporting evidence. There is no oral hearing.

The guidance says it is essential to send everything you wish to rely on within this window (C9.12). The Home Office may allow more time in exceptional circumstances, and may interview you. If it finds further reasons during the 20 days, it writes again and gives another 20 working days for those (C9.13).

If no response arrives in time, it goes ahead with the action it considers appropriate (C9.15).

The decision

The Home Office aims to decide within 20 working days of receiving your response, unless the case is exceptionally complex or it is waiting for a third party (C9.17). The decision takes effect from the date of the letter (C9.18).

The possible outcomes in C9.16 are:

  • reinstatement with an A-rating
  • reinstatement with a B-rating and an action plan
  • preventing you from assigning any new CoS
  • preventing the use of assigned but unused CoS
  • revocation of the licence

If the licence is reinstated, the organisation's entry goes back on the register (C9.6). If it is reinstated with a B-rating, there is no further 20-day window, and the CoS allocation may be reduced or set to zero (C9.24 and C9.25). The action plan fee is £1,579 as published on GOV.UK (3 Oct 2026).

If the outcome is revocation, there is no right of appeal. A new application cannot be made until at least 12 months after notice of the revocation, or 24 months if a licence has ended through revocation more than once (C9.5).

Common questions

Does suspension stop our current workers working?

Not by itself. C9.4 says workers with valid permission are unaffected unless and until the licence ends through revocation.

Can we keep assigning certificates while we respond?

No. C9.19 says no CoS can be assigned while the licence is suspended.

How long does a suspension last?

The guidance does not set a fixed length. Where there is an investigation, it says it may not be possible to say how long it will take, and the Home Office will give regular updates (C9.10).

Can we talk to someone about our situation?

You can tell us about your situation. We do not assess cases or help with forms.

Sources

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