Sponsor Licence Applications

Sponsor Licence Application

The UK immigration system is going through a significant transformation. After the post-Brexit adjustment phase, the current setup features higher standards, stricter compliance rules, and more automation in Home Office decision-making. Anyone looking to obtain a Sponsor Licence or hire skilled workers needs to grasp these changes to avoid costly mistakes.

Several major reforms are reshaping the sponsorship landscape. Routine sponsor licence renewals ended in April 2024, affecting how long-term compliance is tracked. In July 2025, the Skilled Worker skill threshold increased to RQF Level 6, which significantly limits the list of eligible occupations. A significant rise in the Immigration Skills Charge (ISC) is set for December 2025, impacting the financial plans of employers who depend on sponsored workers.

It is important for businesses to understand how these rules interact. The Skilled Worker, Global Business Mobility (GBM), and Scale-up routes each have different compliance duties, salary requirements, and sponsorship processes. Employers must pass the stricter "Genuine Vacancy" test that aims to stop system abuse. New 24-month cooling-off periods after licence revocation make compliance even more vital since a single mistake can disrupt business operations for years.

For employers dealing with sponsorship or professionals wanting to know their options, timely and clear information is essential. Bekenbey Solicitors, led by Dr. Ergul Celiksoy, offers straightforward guidance on each route, helping clients stay in line with the latest Home Office standards while developing a workforce strategy that fits the stricter immigration rules.

1. Strategic Context: The 2025 Immigration Landscape

To market legal services effectively in today's climate, it is crucial to understand the pressures UK employers face. The environment has changed from "hostile" to "compliance-first". The Home Office has moved resources from processing routine renewals to conducting focused, data-driven compliance audits. This change requires a complete rewrite of how sponsor licence services are presented.

1.1 From Administration to Enforcement

Historically, the sponsor licence system followed a predictable administrative cycle. Employers applied and renewed their licences every four years. They largely self-certified compliance in between. This cycle effectively ended on 6 April 2024. Most routes no longer require the renewal of a sponsor licence, and existing licences have been automatically extended by 10 years. While this removes a fee for clients, it also takes away the "renewal audit" trigger. This was a regular opportunity for businesses to review their compliance.

The removal of the renewal deadline hints at deregulation, but the reality is a shift towards continuous, unpredictable enforcement. The Home Office has redirected the resources previously used for renewal processing toward compliance activities. This change has resulted in more unannounced audits and digital checks.

The draft document currently has a section on "Sponsor Licence Renewal". This is a significant error. Keeping outdated information about renewals shows a lack of up-to-date knowledge, which can harm credibility. The new focus must be on continuous compliance instead of periodic renewal. Clients should be warned that without a renewal deadline, the risk of unintentional non-compliance may go unnoticed until a Home Office visit happens.

It's also important to note the exceptions to the automatic extension. The automatic 10-year extension mainly applies to the Skilled Worker, Health and Care Worker, and Global Business Mobility (Senior or Specialist Worker) routes. However, routes like the UK Expansion Worker and Scale-up Worker have different validity periods, usually four years, and cannot be renewed in the usual way. In these situations, the sponsor must switch to a standard route or stop sponsorship.

1.2 The Rising Cost of Sponsorship

Sponsorship has become much more expensive, affecting the cost-benefit analysis for UK employers. The Immigration Skills Charge (ISC), a fee meant to encourage domestic training, will increase by about 32% on 16 December 2025. This rise is a clear policy move to reduce dependence on foreign workers. Along with the increase in Certificate of Sponsorship (CoS) fees, which rose to £525 for worker routes in April 2025, and higher salary thresholds, the financial challenges of sponsorship now rival the skills challenges.

The timing of these increases is crucial. Employers who issue a CoS on or after 16 December 2025 will pay the higher ISC rates, no matter when they obtained their licence. The website must guide clients on accurate budgeting and the smart timing of CoS assignment. For large sponsors, the rise in ISC from £1,000 to £1,320 per year for each worker adds a significant operational cost.

1.3 The Digital Transformation: eVisas and Online Checks

Operational procedures are moving to a fully digital immigration status system. From late 2024 through 2025, physical Biometric Residence Permits (BRPs) will be replaced by eVisas. This shift changes the Right to Work (RTW) check process. Employers can no longer depend on physical cards for new checks and must use the Home Office's online "share code" system.

While retrospective checks for current employees with BRPs expiring on 31 December 2024 are not required if the initial check was compliant, employers need to update their onboarding systems to support digital verification. Failing to follow this process puts sponsors at risk of civil penalties, which have also increased.

2. Detailed Analysis of the Skilled Worker Route

The Skilled Worker route remains the primary vehicle for economic migration, yet the eligibility criteria have narrowed. Fewer roles now qualify, and those that do are more expensive to fill.

2.1 The "Graduate Standard" (RQF Level 6)

This indicates a return to the pre-2020 "Tier 2 (General)" standard. The message for clients is straightforward: "middle-skill" roles can no longer receive sponsorship unless they are on the Temporary Shortage List (TSL) or the applicant qualifies for transitional protection. The TSL is the only way for sub-degree level roles to access sponsorship, unlike the Immigration Salary List (ISL), which mainly deals with salary thresholds.

2.2 Salary Thresholds: The £41,700 Benchmark

The general salary threshold for Skilled Workers has undergone a rapid increase:

• Pre-April 2024: £26,200
• April 2024: £38,700
• July 2025: £41,700

Legal guidance needs to go beyond simply stating the general threshold. The requirement is always the higher amount between the general threshold (£41,700) and the "going rate" for the specific occupation code. In addition, the calculation of going rates has changed. Previously based on the 25th percentile of UK earnings, going rates are now set against the 50th percentile (median) of Annual Survey of Hours and Earnings (ASHE) data.

This approach means that for many professional roles, the effective minimum salary is higher than the stated figure. For example, a senior IT consultant could see a median going rate significantly above £60,000. Employers who budget based on the general threshold often find they cannot sponsor once the occupation-specific rate is applied. The website content should highlight this detail to avoid under-budgeting.

2.3 Transitional Arrangements

Employers sponsoring workers who were already in the route before these changes may still benefit from lower thresholds. The rules create a two-tier system:

• New Entrants: Subject to RQF Level 6 and £41,700/median rates.
• Transitional Cases: Workers already in the route before April 2024 may benefit from a lower general threshold (e.g. £31,300) and going rates based on the 25th percentile.

These transitional provisions apply when extending a visa or changing employers, provided the worker has maintained continuous permission. Guidance must distinguish between "New Entrants" and "Transitional" cases to ensure clients do not overpay or assume eligibility incorrectly.

2.4 The Immigration Salary List (ISL) vs Temporary Shortage List (TSL)

The Shortage Occupation List (SOL) has been replaced by the Immigration Salary List (ISL). The ISL provides a lower general salary threshold, usually £33,400 instead of £41,700; however, it does not lower the going rate. The 20% discount on the going rate that was available under the SOL has been removed.

Additionally, the government introduced the Temporary Shortage List (TSL). This allows sponsorship for certain RQF Level 3-5 roles that would otherwise be barred under the new RQF 6 rule.

• ISL: Reduces salary thresholds for eligible high-skill roles.
• TSL: Grants eligibility for lower-skilled roles deemed critical to the economy.

Inclusion on these lists does not mean "cheap labour". The salary must still meet the specified threshold of £33,400 and the full going rate. Additionally, workers sponsored in jobs on the TSL at RQF levels 3-5 are usually not allowed to bring dependants. This affects how appealing these roles are.

2.5 The Genuine Vacancy Test

3. Global Business Mobility (GBM) Routes

The GBM routes consolidate previous intra-company transfer categories. The draft document identifies them but lacks the specific 2025 financial details required for accurate guidance.

3.1 Senior or Specialist Worker

This route replaces the Intra-Company Transfer visa and is for established employees transferring to a UK branch.

• Salary Threshold: The general salary threshold increased from £48,500 to £52,500 per year as of July 2025.
• Tenure: To be eligible, applicants usually need 12 months of overseas service. However, if an applicant is a "high earner" making £73,900 or more, there is no minimum service requirement.
• Maximum Stay: Workers can stay for 5 years within any 6-year period if they earn under £73,900. Those earning over £73,900 can stay for 9 years within any 10-year period. This route does not lead to settlement.

3.2 UK Expansion Worker

This route replaces the Sole Representative visa and is for overseas businesses sending a senior team to establish a UK presence.

• Footprint vs Trading: The overseas business must not be trading in the UK yet, but it must have a "footprint," like registered premises or UK company registration. If the company has signed contracts or billed clients in the UK, it is not eligible and must apply for a standard Skilled Worker licence.
• Authorising Officer Flexibility: The Authorising Officer (AO) can initially be based outside the UK. This AO is often the Expansion Worker themselves, who assigns their own Certificate of Sponsorship. This is a rare exception to the rule against self-sponsorship.
• Licence Rating: The initial licence is rated "Provisional" and usually comes with one CoS for the AO. It can only be upgraded to an A-rating once the AO has entered the UK and updated the SMS.

3.3 Graduate Trainee

This route targets workers transferring as part of a structured graduate training programme.

• Salary: The general threshold increased to £27,300 (up from £25,410) or 70% of the going rate.
• Service Requirement: Only 3 months of overseas service is required.

4. The Scale-up Route: High Growth Definition

The Scale-up route offers flexible, unsponsored work after an initial 6-month sponsored period. However, the barrier to entry for the sponsor is strictly defined.

4.1 Defining "High Growth"

To obtain a Scale-up licence, a company must meet the "standard pathway" definition, verified automatically via HMRC data:

• Growth Metric: Annualised growth of 20% in either turnover or employment over a 3-year period.
• Baseline Requirement: A minimum of 10 employees at the start of the 3-year period. This prevents micro-businesses from qualifying purely on percentage growth.

HMRC Data Verification: The Home Office conducts automated checks on HMRC PAYE and VAT returns. If there are missing filings or late submissions in the company's record, the automated check will not pass, and the licence application will be denied.

4.2 Salary Thresholds (2025 Update)

For any Certificate of Sponsorship assigned on or after 22 July 2025, the minimum salary threshold is £39,100 (up from £36,300), or the going rate for the occupation code, whichever is higher. Bekenbey must advise clients to perform a rigorous pre-check of their employment history, as many startups fail the "10 employees at the start" criterion.

5. Compliance Framework: The New Enforcement Reality

The Home Office's compliance regime in 2025 is characterised by data-led enforcement and steeper penalties.

5.1 Sponsor Duties and the SMS

Sponsors must use the Sponsorship Management System (SMS) to maintain their licence.

• Reporting Deadlines: Changes such as worker absence, resignation, or a change in work location (including hybrid patterns) must be reported within 10 working days.
• Key Personnel: Sponsors must maintain an Authorising Officer, Key Contact, and Level 1 User. The Level 1 User must be a settled worker (British/Irish/ILR), with specific exceptions for the UK Expansion Worker route.
• Prohibited Actions: Guidance explicitly prohibits sponsoring workers in a "personal capacity" (e.g. for private household needs) and enforces that Key Personnel must be paid employees or office holders.

5.2 Digital Right to Work Checks

The transition to eVisas renders the physical BRP card obsolete for new checks.

• Online Checks: Employers must use the Home Office online checking service with a share code for all holders of eVisas or BRPs. Manual checks of physical cards are no longer compliant for new hires.
• Retrospective Action: HR systems must be updated to track the expiry of the online status rather than the physical document.

5.3 Revocation and Cooling-Off Periods

The consequences of non-compliance have escalated.

• Standard Cooling-Off: A revoked licence typically incurs a 12-month ban on re-applying.
• Extended Cooling-Off: Under new suitability rules, the cooling-off period increases to 24 months for sponsors with a history of non-compliance or severe breaches.
• Civil Penalties: Fines for employing illegal workers have risen significantly, reaching up to £60,000 per worker for repeat offenders.

6. Financial Breakdown: Fees and Charges (2025)

Accurate financial forecasting is essential for clients.

6.1 Sponsor Licence Application Fees

• Small/Charitable Sponsor: £574.
• Medium/Large Sponsor: £1,579.

(A company is "Small" if it meets two of the following: Turnover <£10.2m, Balance Sheet Total <£5.1m, <50 employees).

6.2 Certificate of Sponsorship (CoS) Fees

• Worker (Skilled/GBM): £525 per certificate.
• Temporary Worker: £55 per certificate.

6.3 Immigration Skills Charge (ISC) - Major Update

6.4 Priority Services

• Pre-Licence Priority: To get a licence decision in 10 working days, the fee is £500.
• Post-Licence Priority: For rapid allocation of CoS, the fee is £200.

7. The Application Process: Appendix A and Digital Submission

Applying for a licence requires a precise compilation of documents listed in Appendix A of the sponsor guidance.

7.1 Essential Documentation

The typical document package includes:

• Corporate Bank Statements: Proof of the account used for business activity.
• Employer's Liability Insurance: Certificate showing cover of at least £5 million.
• VAT/PAYE Registration: Proof of registration with HMRC.
• Premises Evidence: Lease or proof of ownership.

Specific sectors require additional documents, such as CQC registration for health providers or auditing body registration for financial firms.

7.2 The "Genuine" Assessment

The Home Office assesses the credibility of the application. This "Genuine Test" scrutinises:

• Trading Presence: Does the company actually operate in the UK?
• Key Personnel: Are the Authorising Officer and Level 1 User suitable and honest?
• Recruitment Systems: Does the company have HR processes capable of monitoring immigration status?

Failure here results in refusal and a potential cooling-off period.

8. Recommendations for Content Revision

We recommend the following specific revisions:

Recommendation 1: Rewrite "Renewal" Section

Current Text: Discusses applying for renewal every 4 years.

New Narrative: From April 2024, sponsor licences will no longer need a renewal application every four years. Instead, licences will automatically extend for ten years. However, this change eliminates the Home Office's 'check-in' point, which will lead to more unannounced compliance audits. Bekenbey Solicitors offers mock audits to help you stay 'audit-ready' at all times, taking the place of the old renewal preparation process.

Recommendation 2: Update Skilled Worker Eligibility

Current Text: Mentions RQF Level 3.

New Narrative: As of July 2025, the skill level for new Skilled Worker applications has increased to RQF Level 6 (Graduate level), unless the role is on the Temporary Shortage List or the worker is extending a current visa. The minimum salary requirement is now £41,700 or the median salary for the role, whichever is higher. We help verify your job against the new Standard Occupational Classification (SOC) 2020 codes.

Recommendation 3: Add Urgent Call-to-Action on Fees

New Section: Important Update: The Immigration Skills Charge will increase by about 32% on 16 December 2025. Employers should think about issuing Certificates of Sponsorship before this date to lock in the current lower rates. Contact us right away for workforce planning assistance.

Recommendation 4: Clarify Genuine Vacancy

Current Text: General description.

New Narrative: The Home Office's 'Genuine Vacancy' test was the main reason for refusals in 2025. It's not enough to just have a vacancy; the role must match your business model, growth path, and current structure. We assist you in writing job descriptions that meet Home Office standards.

Recommendation 5: Highlight TSL vs ISL

New Narrative: We help you navigate the details of the new lists. The Immigration Salary List (ISL) may lower the salary threshold. The Temporary Shortage List (TSL) allows sponsorship for certain roles below the degree level. Understanding the difference is essential for successful recruitment.

9. Why Choose Bekenbey Solicitors for Your Sponsor Licence Applications

The UK immigration landscape in 2025 is defined by higher barriers to entry and stricter policing. The elevation of the Skilled Worker route to a graduate-level system, combined with the significant hike in the Immigration Skills Charge and salary thresholds, fundamentally alters recruitment strategy. The abolition of licence renewals places the onus entirely on sponsors to maintain continuous compliance. Bekenbey Solicitors has a clear opportunity to provide the forensic expertise required to navigate these changes, certifying the "Genuine Vacancy" and protecting licences against the threat of revocation.

Contact Dr. Ergul Celiksoy and the team at Bekenbey Solicitors today for a consultation to discuss your sponsor licence applications. Let us manage the complexities of the law.

Disclaimer: The information in this article is for general guidance only and does not constitute legal advice. Immigration rules change frequently. Please contact Bekenbey Solicitors for advice specific to your circumstances.