Key updates for sponsor licence holders

April saw a plethora of changes to the immigration rules which affect sponsor licence holders. In addition, there were also important changes to the Home Office sponsor guidance that employers need to be aware of to ensure continued compliance with their sponsor duties. Below is a summary of the key changes, effective from 9th April 2025:

1. Care sector

A new care worker recruitment requirement applies to Certificates of Sponsorship (‘CoS’) assigned on or after 9th April 2025 (England only). English care providers must engage with their regional or sub-regional partnership to demonstrate efforts to recruit from the existing pool of sponsored care workers within the UK before turning to overseas recruitment.

2. Salary thresholds

The minimum salary floor for sponsorship has increased from £23,200 (£11.90 p/hr) to £25,000 (£12.82 p/hr) per annum. This change will largely impact on certain health or education roles e.g. care and senior care workers, but will also apply to some applicants with a CoS assigned before 4th April 2024 when extending or changing employer e.g. those with a PhD in a STEM subject relevant to their role, sponsored in a role on the Immigration Salary List, or new entrants,

3. Passing on or recouping sponsorship costs to workers

Sponsors are prohibited from passing on or recouping the sponsor licence fee, and costs associated with sponsorship. This includes the licence fee, immigration skills charge, certificate of sponsorship fee, as well as associated administrative costs. Clarification has been provided as to the definition of ‘associated administrative costs’, which includes any costs incurred by the business to obtain, use or maintain the licence.

New rules have also been introduced which affect the calculation of a skilled worker’s salary for the purpose of sponsorship. These exclude certain salary deductions, repayment of loans by workers and investments made by workers into the sponsor’s organisation or related organisation from being counted towards meeting skilled worker salary thresholds.

More information on these changes can be found in our recent article.

4. Statutory neonatal care

Skilled workers are not normally permitted to be absent from work for prolonged periods, including absences from work, with or without pay, or on reduced pay for more than four weeks (according to the worker’s normal working pattern). There is however a list of valid exceptions to this rule, to which periods of statutory neonatal care leave have been added.

5. Sponsorship

Sponsors can now apply for a Defined CoS if they have not yet identified a particular worker for a vacancy but they ‘reasonably anticipate’ that they may need to sponsor a worker from outside the UK to fill the role. This is different from the previous language which required sponsors to ‘think they may need to sponsor a worker from overseas’.

The sponsor guidance has also been updated to clarify that applicants being sponsored for a role in a regulated profession must be working towards a recognised UK qualification to qualify as New Entrants.

6. Compliance

Sponsor licences can now be refused and/or revoked where an owner, director, Key Personnel, person recorded as a person with significant control or a person involved in day-to-day running of the business have previously been named as Key Personnel at an organisation that has had a sponsor licence application refused within the last six months. This is in addition to the existing grounds for refusal or revocation which apply where such a person has held the position of Key Personnel at an organisation that has had its licence revoked in the past 12 months.

Action for sponsors

In light of these recent changes, sponsors are recommended to:

• Review the new sponsor guidance for a full understanding of changes.

• Update internal policies and procedures to ensure compliance with new rules and guidance.

• Check current policies on salary deductions are in keeping with the changes.

If you need further help navigating these changes, a member of our team is here to help.