Further changes to UK Visa sponsorship rules

Major changes to the rules surrounding UK visa sponsorship took effect on 22 July 2025, introducing stricter measures for employers who sponsor workers.

In our previous article, we explored the key changes to the Skilled Worker visa route announced in the Home Office’s Statement of Changes on 1 July and highlighted the implications for UK employers.

On 22 July, the same day that the new changes came into effect, the Home Office also updated their sponsorship guidance. Although much of the update reflects the previously announced changes, it also introduces some discrete new additions that employers will now need to consider to ensure they remain compliant. These include an extended cooling-off period for revoked sponsorship licences, as well as updates to eVisas and record-keeping. In this article, we offer a reminder of the additional rules to help you stay informed and compliant.

Longer cooling-off periods if a sponsor licence is revoked

Before the changes came into force, employers whose licence had been revoked or their application refused were only required to wait 12 months before reapplying. This is still the case in most situations, except for employers who have had serious or repeated sponsorship breaches—they will now have to wait a mandatory 24 months before they are able to reapply. This increased waiting period for certain situations aims to prevent organisations from immediately reapplying without first addressing the underlying issues in the business.

The 24-month cooling-off period now affects:

• employers whose sponsor licence has been revoked more than once
• employers where senior staff or decision makers have held a Key Personnel role at more than one organisation that had its sponsor licence revoked OR at a single organisation whose licence was revoked more than once
• employers who want to add a branch to their sponsor licence, where the branch’s sponsor licence has been revoked more than once

The cooling-off period will start from the date of the last revocation or the date the licence would have been revoked, if it had not been surrendered by the employer.

Upon reapplying, the Home Office will be keen to see how employers have reflected on their previous application, made changes where appropriate and improved their suitability to manage sponsorship duties.

eVisa transformation

The Home Office is developing a new digital immigration system that will replace physical documents with a digital record of identity and immigration status, known as an eVisa. In their most recent guidance, they further clarified the situations where a sponsored worker should receive an eVisa following a successful application. These include:

• where they apply for entry clearance from outside the UK using the UK immigration ID check app and also have a biometric passport issued by an EU country, Iceland, Liechtenstein, Norway or Switzerland
• where they apply for entry clearance on or after 15 July 2025 on an eligible sponsored work route with a Home Office accepted passport or other approved identity document (this will not apply to certain sponsored routes such as the Scale-up route)
• where they apply from within the UK regardless of their route or nationality

Until further notice, sponsored workers will receive both an eVisa and an entry clearance vignette (a sticker placed in a passport or travel document, granting permission to enter the UK) if they do not fall into any of the three categories above.

Dependants of sponsored workers will also continue to receive both an eVisa and a vignette unless they’re eligible to use the immigration ID check app. Creative workers applying under their visa concession will receive either a wet ink stamp in their passport or an electronic remote clearance depending on whether they enter from outside or within the Common Travel Area.

Record-keeping duties and right to work checks

The updated Home Office guidance also places more rigorous record-keeping duties on the sponsors of care workers and senior care workers. Sponsors will now need to retain evidence that their care workers were legally working for them for three months prior to sponsorship (with permission on another immigration route). Evidence of work in the previous three-month period might include payslips or a contract of employment showing the start date.

Sponsors should also keep evidence of workers’ right to work documents during the period prior to their sponsorship. While this is already a requirement, it is something that will be specifically checked by the Home Office during any compliance visit following the new rule change.

The new guidance also confirms that sponsors who are sponsoring children under 16, for example, on a Creative Worker or Government Authorised Exchange visa, must keep evidence of their right to work. While those under 16 won’t be able to use the online right to work checking system, the sponsor should obtain other evidence such as contacting the worker or their parents to get a screenshot of their eVisa demonstrating their right to work.

How do the changes impact you?

Despite the short turnaround, sponsors and applicants will need to comply with these changes immediately or risk being non-compliant. If you’re considering a sponsor licence for your organisation, it is important to understand the implications of licence refusal and revocation and how this might impact your future applications.

As part of the Home Office’s strategy to tighten immigration routes and modernise the immigration system, there will be increased scrutiny on employers and the potential for severe consequences for getting it wrong.

How can we help?

There are several ways in which we can help you respond to these changes. We can provide training, host mock Home Office audits and provide bespoke advice to help you in your compliance. We can also support you in reviewing your current pool of skilled workers, including how they and your recruitment plans will be affected.

We discuss the changes to immigration rules in detail on our on demand session here. You can also sign up to our employment newsletter for the latest updates and advice.

We’re here to help you future-proof your business, so if you have any queries or need support in preparing for these changes, please don’t hesitate to get in touch.

Alex Christen

Partner

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