UK sponsor licence compliance: Key updates employers must know for 2025

This guide breaks down the key changes, and the steps employers must take to stay compliant.

Ban on passing sponsorship costs to employees

Employers cannot recover sponsorship-related costs from workers, including:

• Sponsor licence fees (including fees for adding new visa routes)
• Certificate of Sponsorship (CoS) fees
• Immigration Skills Charge (ISC)
• Associated administrative costs, such as premium services, legal fees, or immigration advice

Broader accountability for key personnel

The definition of a sponsor now includes owners, directors, authorising officers, key contacts, and Persons with Significant Control (PSC). Key points:

• Individuals associated with refused or revoked licences within six months may affect new applications or trigger revocation of current licences.
• Recent key personnel at sponsors with refused or revoked licences face restrictions in acting on new applications.

Stricter key personnel rules

Key personnel (Authorising Officer, Key Contact, Level 1 User) must meet tighter eligibility criteria:

• Applications may be refused if personnel held a role at a sponsor whose licence was revoked in the past 12 months or were involved in a refused licence application in the past six months.
• Level 1 Users generally must be employees, partners, or directors settled in the UK.
• Individuals prohibited from acting as company directors (e.g., bankrupt persons) cannot be appointed without court permission.

Increased salary thresholds

The current general minimum salary threshold for the UK Skilled Worker visa, effective from 22 July 2025, is now the higher of £41,700 per year or the occupation-specific “going rate” for the job.

New applications must also meet a minimum hourly rate of £17.13 for most graduate-level roles, and the minimum skill level for sponsorship has been raised to Regulated Qualifications Framework (RQF) level 6.

Sector-specific compliance: Care worker recruitment (England)

From 9 April 2025, care providers sponsoring workers for Care Worker or Senior Care Worker roles must first demonstrate efforts to recruit existing UK-based workers before sponsoring overseas recruits.

Licence validity and cooling-off period

• Licence validity extended to 10 years for compliant sponsors, reducing renewal burden.
• Cooling-off periods:
• 12 months for first-time revocation
• 24 months for repeated revocations or if key personnel are linked to multiple revoked licences

Authorised absence: Employees on approved unpaid leave (including neonatal care leave) maintain visa compliance.

What should employers do now?

1. Review contracts and policies: Eliminate any recovery of sponsorship costs from workers.
2. Verify key personnel: Conduct thorough checks against new eligibility requirements.
3. Audit salaries and roles: Ensure roles meet updated salary thresholds and the RQF Level 6 skill requirement.
4. Calculate salary deductions: Ensure minimum thresholds are met after permitted deductions, loans, or investments.

Stay ahead of the 2025 sponsor licence changes. Our business immigration team will help you stay compliant and continue hiring the international talent your business needs to grow. Get in touch today for clear, practical guidance tailored to your organisation. Contact us at [email protected] or give us a call on +44 (0) 20 7759 5420.