A sponsor licence is Home Office authorisation allowing a UK organisation to employ workers who do not already have permission to work here, on routes such as the Skilled Worker visa. Before UK Visas and Immigration (UKVI), that runs the sponsorship system, grants a Sponsor License, it assesses the employer rather than the worker. It analyses whether your organisation is genuine, whether it operates or trades lawfully in the UK, whether the people you nominate are eligible, and whether anything in your history makes you unsuitable. If you are weighing up an application, have been told your business may not qualify, or want to know what UKVI actually checks before you commit a fee, this article answers that question directly.
This article covers who can hold a sponsor licence, what UKVI means by a genuine organisation, the Key Personnel you must nominate, the eligible role test, and the conduct that makes an organisation unsuitable. It does not cover assigning a Certificate of Sponsorship, the duties that begin once a licence is granted, or the worker’s own visa application and both of these are separate questions, each with their own detailed answer.
Key Takeaways
A sponsor licence authorises the employer, not the worker and so, the worker still has to win their own visa application.
UKVI must be satisfied that you are a genuine organisation operating or trading lawfully in the UK, that you are honest, dependable and reliable, and that you are capable of carrying out sponsor duties.
An employer sponsor does not have to be a commercial business. Charities, public bodies, local councils, schools and religious organisations can all hold licences.
An individual cannot sponsor unless they are a sole trader sponsoring into their own business; sponsorship in a personal or household capacity is not permitted.
No UK operating or trading presence means automatic refusal and revocation if UKVI discovers it after the licence has been granted.
At least one Level 1 User must be an employee, director or partner in your organisation and a settled worker, and an eligible Authorising Officer is required for the life of the licence.
An unspent conviction for a relevant offence, held by anyone connected with the organisation, is grounds for automatic refusal.
There is no right of appeal against a refusal, and a cooling-off period of at least 6 months applies before you can reapply.
Who Can Hold a Sponsor Licence?
The sponsor guidance does not restrict which type of organisation, company, charity, sole trader, partnership or public body, can apply. It only bars individuals from sponsoring in a personal capacity. Every other organisation is tested against the same eligibility and suitability criteria, whatever its legal form, and commercial trading is not required. The guidance asks whether you are “operating or trading lawfully in the UK”, and its glossary confirms that the phrase is not defined in law and carries its plain meaning, which is why a charity that operates without trading still satisfies it.
One rule is absolute. An individual cannot be a sponsor unless they are a sole trader sponsoring someone to work in their own business. Sponsorship in a personal or household capacity is not permitted. This includes engaging a nanny, carer or domestic staff privately, or sponsoring someone for the personal benefit of a member of your staff or their family, and using an existing licence that way is a normal ground for revocation. The narrow exception is a diplomatic mission, consular post or recognised international organisation sponsoring a private servant in a diplomatic household.
What Does UKVI Mean by a ‘Genuine Organisation’?
This is the requirement that fails more applications than any other, and it has three parts.
Genuineness comes first. You must show that you are a genuine organisation operating or trading lawfully in the UK, evidenced by the documents specified in Appendix A to the sponsor guidance, and you must hold any registration a regulator requires before you can operate legally at all, for example a care provider registered with the Care Quality Commission. Most organisations must send at least four documents, or four combinations of documents, and all of them, together with the signed submission sheet, must reach UKVI within 5 working days of the online application. Documents that arrive late or incomplete make the application invalid, and it is rejected without consideration rather than refused.
Trading presence is second, and it is absolute. If you have no operating or trading presence in the UK, the application will be refused, and if UKVI discovers this after the licence has been granted, the licence will be revoked. Only one route inverts the test: an applicant on the UK Expansion Worker route must not have an active UK trading presence but must instead show a UK “footprint”, and is then expected to establish a trading presence and add a further route within two years.
Where a business uses little or no physical office space, UKVI will look closely at what the sponsored worker will actually do and where, may ask to see contracts with third parties, and is highly likely to carry out a compliance visit before deciding rather than after.
Capability is third. You must be capable of carrying out sponsor duties and evidencing your compliance, judged on the human resources and recruitment practices you already have. That means systems that show sponsored employees have been given information about their employment rights, including National Minimum Wage, working time, pension auto-enrolment, statutory leave, health and safety, trade union rights and how to raise a grievance, with the evidence retained in line with the record-keeping duties in Appendix D.
Who Must You Nominate as Key Personnel?
Every applicant must nominate an Authorising Officer, a Key Contact and at least one Level 1 User. There can be only one Authorising Officer and one Key Contact, but several Level 1 Users. Everyone nominated must be based in the UK for the period they hold the role, hold a valid National Insurance number, come from within your organisation unless an exception applies, and must not be a contractor engaged for a specific purpose.
Two points catch applicants out. A UK-based representative can be your Key Contact, an additional Level 1 User or a Level 2 User, but never the Authorising Officer and never the primary Level 1 User. So, handing the whole licence to your adviser does not work. And everyone nominated is checked against Home Office records and the Police National Computer, with those checks capable of extending to people who are not named on the licence at all.
Is the Role You Want to Fill an Eligible Role?
Being a genuine organisation is not enough if the job itself does not stand up. You must be able and intend to offer work that meets the definition of an eligible role, which includes any salary and skill-level criteria for the route you are applying on.
The sponsor guidance gives three examples where this is unlikely to be met: an organisation that has never employed anyone in a qualifying role, such as a retail business staffed only by retail assistants; a role that appears unnecessary to the business, such as a fast-food outlet claiming to need a full-time business development manager; and a salary that is incommensurate with the organisation’s turnover, with no explanation of how it will be sustained. It connects to a wider power to refuse where UKVI has reasonable grounds to suspect the organisation exists mainly to facilitate the entry of someone who would not otherwise have permission to work. The example the guidance gives is a foreign national who registers a UK business from abroad without permission to enter or stay, appoints a UK-based worker as Level 1 User, and then assigns a Skilled Worker Certificate of Sponsorship to themselves.
Worked Example: Two Applications - One Outcome
Two London companies apply on the same day to sponsor one Skilled Worker each. Company A is an engineering consultancy with turnover of £9 million, 42 employees and three years of filed accounts; its finance director will be Authorising Officer and its in-house HR manager, a British citizen, will be Level 1 User. Company B was incorporated four months ago, has no trading history, uses a virtual office address, and proposes to sponsor its sole director, currently overseas, as a business development manager.
These figures are illustrative. UKVI’s actual decision on any specific case depends on the full compliance picture, not a single missed deadline viewed in isolation.
What Makes an Organisation Unsuitable?
Suitability is assessed separately from eligibility, and it decides not only whether a licence is granted but whether an existing one is downgraded or revoked, and how many Certificates of Sponsorship you are permitted to assign. UKVI looks at whether you understand and intend to comply with sponsor duties and have systems to do so, whether it can carry out compliance checks on an immediate and unannounced basis, any convictions or civil penalties, UK or United Nations sanctions, child safeguarding duties, evidence of previous non-compliance, and any evidence from another government department that you have not complied with its rules.
The hard line is an unspent criminal conviction for a relevant offence, which is grounds for automatic refusal. The people this covers is wider than most applicants expect: the organisation itself, any owner or director, all Key Personnel, anyone recorded at Companies House as a Person with Significant Control, and anyone involved in the day-to-day running of the business. A silent shareholder with significant control is therefore caught, despite holding no role on the licence.
One further ground is missed more often than any other. Anyone who was Key Personnel at an organisation refused a licence within the previous 6 months, or whose licence was revoked within the previous 12 months to 24 months where there have been multiple revocations, will normally cause your application to be refused. The same applies to an owner, director or Authorising Officer of a revoked sponsor with unpaid Home Office legal costs. A refusal attaches to individuals, not only to the company that suffered it.
What Does a Licence Cost, and What if You Are Refused?
The application fee depends on the size and status of your organisation. A Worker licence costs £611 for a small or charitable sponsor and £1,682 for a large sponsor; a Temporary Worker licence is £611 regardless of size. You qualify for the lower fee if you are applying on Temporary Worker routes only, if you have charitable status, if you are subject to the small companies regime under sections 381 and 382 of the Companies Act 2006, broadly meeting at least two of turnover under £15 million, a balance sheet total under £7.5 million, and no more than 50 employees, or if you are not a company within that regime and employ no more than 50 people. Each Certificate of Sponsorship then costs £525 on the Skilled Worker route, and the Immigration Skills Charge applies on top for most sponsored workers.
Three outcomes are possible, and they are not interchangeable. An application is rejected as invalid, without consideration, where mandatory documents are missing or the fee is short. It is refused where any eligibility or suitability requirement is unmet. And it is granted, in which case the licence is valid indefinitely unless revoked or surrendered, except that UK Expansion Worker and Scale-up licences remain valid for a maximum of four years.
There is no right of appeal against a refusal. A cooling-off period of at least 6 months applies before you can reapply, longer in some circumstances, and where a relevant civil penalty has been issued it runs from 12 months to 5 years from the date the penalty is paid in full.
Frequently Asked Questions
You must be a genuine organisation operating or trading lawfully in the UK, hold any regulatory registration needed to trade legally, be honest, dependable and reliable, be capable of carrying out sponsor duties and evidencing compliance, meet any requirements specific to your route, and offer work that meets the definition of an eligible role. You must also nominate eligible Key Personnel and satisfy the suitability criteria.
No. There is no list of permitted legal forms, and commercial trading is not required; the test is whether you are operating or trading lawfully in the UK. Charities, government departments, local councils, schools, religious organisations and diplomatic missions can all hold employer licences.
A sole trader can, but only to sponsor someone into that business. An individual otherwise cannot: sponsorship in a personal or household capacity is barred, and using an existing licence in that way is a normal ground for revocation.
There is no minimum trading period, and the guidance expressly contemplates start-ups trading for under 18 months. But you must still have an operating or trading presence in the UK and satisfy the eligible role test, which is where new companies most often fail. Expect a compliance visit before a decision if you use a virtual office.
An unspent conviction for a relevant offence, held by anyone connected with the organisation, means automatic refusal. A conviction outside that list may still lead to refusal if UKVI considers it relevant to your ability to carry out sponsor duties. You can apply once a conviction is spent, subject to any cooling-off period.
Indefinitely, unless it is revoked or you surrender it. Since April 2024 there is no four-year renewal requirement for most licence types. Licences to sponsor UK Expansion Workers or Scale-up Workers are the exception and remain valid for four years.
Glossary
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Sponsor Licence
Home Office authorisation allowing a UK organisation to employ migrant workers on routes such as the Skilled Worker visa.
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UK Visas and Immigration (UKVI)
The Home Office directorate responsible for licensing and monitoring sponsors.
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Certificate of Sponsorship (CoS)
The electronic reference a sponsor assigns to a worker, required for that worker’s visa application.
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Key Personnel
The Authorising Officer, Key Contact and Level 1 and Level 2 Users named on a sponsor licence.
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Settled worker
A person who is not subject to immigration control in the UK, or who has settled status, as defined in the sponsor guidance.
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Eligible role
A genuine vacancy meeting the skill, salary and other criteria of the route the sponsor is licensed on.
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Appendix A
The part of the sponsor guidance listing the supporting documents an applicant must submit.
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Appendix D
The part of the sponsor guidance setting out the records a sponsor must keep and for how long.
Conclusion
If anything above describes your organisation, a company incorporated only recently, a virtual office address, an intermediary supplying workers to clients, a director who was Key Personnel at a sponsor that lost its licence, or an Authorising Officer who is really your adviser then, the risk is not abstract. A refused application costs more than the fee. There is no appeal, at least 6 months must pass before you can try again, and the refusal attaches to the individuals you named rather than to the company alone, following them to any other organisation that nominates them. A recruitment plan built on a licence refused in month three does not simply restart in month four. Establishing before you apply that your organisation, your Key Personnel and the role itself will all withstand scrutiny is considerably cheaper than establishing it afterwards.
Sterling & Wells Business Immigration Services
Sterling & Wells’ Business Immigration Services advise employers on sponsor licence eligibility before an application is submitted: genuineness and trading-presence evidence, Key Personnel structuring and suitability checks, eligible role analysis, and preparation of the full Appendix A document pack.
This article is for general information only and does not constitute immigration advice. Your circumstances may alter the outcome. Speak to a qualified, regulated immigration adviser before acting.
