A domiciliary care provider in East Anglia sponsored 38 overseas care workers through the Health and Care Worker visa route in 2024. By early 2025, four had left without notice, two had changed address without informing the provider, and one had stopped attending shifts but was still technically employed. The provider had failed to report any of these changes to the Home Office within the required timeframe.
When the compliance visit came — unannounced, on a Tuesday morning — the provider could not produce current contact details for seven of its sponsored workers, had no evidence of ongoing right to work monitoring for twelve, and could not account for the whereabouts of the four who had left. The sponsor licence was suspended pending investigation. Within eight weeks, it was revoked.
The 38 sponsored workers who were still employed and working had their permission to work curtailed. The provider lost the ability to recruit from overseas. The workers lost their immigration status. Everyone paid the price for what amounted to an administrative failure.
This scenario is not hypothetical. It is playing out across the care sector at an alarming rate.
Why care is the hardest sector to sponsor in
The Health and Care Worker visa was designed to address a real crisis. The UK adult social care sector has approximately 152,000 vacancies at any given time, according to Skills for Care. Domestic recruitment has consistently failed to fill the gap. Overseas recruitment through the Health and Care Worker route became the primary solution — by 2024, care visas accounted for the single largest category of Skilled Worker visa grants.
But the visa route that was designed to solve the staffing crisis has created a compliance crisis. The Home Office migration transparency data tells the story: approximately one in three sponsor licence revocations in 2024-25 came from the care sector. The rate of revocation among care sponsors is more than double the cross-sector average.
The reasons are structural, not moral. Care providers are not less ethical than other employers. They are operating in conditions that make compliance exceptionally difficult.
The compliance obligations — identical to any sponsor
The Health and Care Worker visa is a variant of the Skilled Worker visa. It offers reduced fees, lower salary thresholds, and exemption from the Immigration Health Surcharge. What it does not offer is any relaxation of sponsorship compliance obligations.
Every care provider holding a sponsor licence must meet the same requirements as a technology company or a bank:
Record-keeping duties. Sponsors must maintain up-to-date records for every sponsored worker, including current home address, contact telephone number, a copy of the relevant right to work document or share code verification, the worker's job title and work location, and their normal working hours. These records must be producible within 24 hours of a compliance visit.
Reporting duties. Sponsors must report certain changes to the Home Office via the Sponsorship Management System (SMS) within 10 working days. These include: the worker failing to attend work for 10 or more consecutive working days without permission, the worker's contract ending (including resignation or dismissal), a significant change in the worker's duties, a change in work location, or a change in salary below the required threshold.
Monitoring duties. Sponsors must actively monitor that sponsored workers are complying with the conditions of their visa. This includes confirming that the worker is performing the role described in the Certificate of Sponsorship, working the required hours, and not engaging in prohibited activities.
Cooperation with enforcement. When the Home Office visits — and the visits are unannounced — the sponsor must provide access to records, premises, and workers. Inability to produce records, or records that contradict reality, is treated as a compliance failure.
What makes care different
The obligations listed above are identical for every sponsor. What makes care uniquely challenging is the operational context in which those obligations must be met.
High turnover. Adult social care turnover rates hover around 28% annually — and in some regions and roles, significantly higher. A care provider with 40 sponsored workers may process 10-12 departures and replacements per year. Each departure triggers a reporting obligation. Each new starter triggers a record-keeping obligation. The administrative volume is relentless.
Multiple work locations. Domiciliary care providers may have workers covering dozens of client addresses. Residential providers may operate across multiple sites. The Home Office expects to know where sponsored workers are working — and "they move between our six care homes depending on rota needs" is not an adequate answer. Each change of primary work location may require an update.
Shift patterns and irregular attendance. Care work runs 24/7. Night shifts, weekends, split shifts, and on-call arrangements make it difficult to monitor attendance through conventional means. A sponsored worker who does not attend for 10 working days triggers a reporting obligation — but tracking this across complex shift patterns, agency cover arrangements, and multiple sites requires systems that many care providers do not have.
Worker mobility. Sponsored care workers are, by definition, relatively new to the UK. They move house, change phone numbers, and — in some cases — leave without notice. Each of these events creates a compliance obligation for the sponsor. And the worker may not understand, or may not have been told, that they must inform their employer of these changes.
English language barriers. Many sponsored care workers have limited English proficiency, particularly in the early months. Communication about compliance obligations — "you must tell us if you move house within 10 days" — may not land clearly. This is not a criticism of the workers. It is a structural challenge that sponsors must address proactively.
CQC and the compliance crossover
Care providers face a unique dual regulatory burden. The Care Quality Commission regulates the quality and safety of care. The Home Office regulates immigration compliance. Both have inspection powers. Both can take enforcement action. And their requirements overlap in ways that create compounding risk.
CQC Regulation 19 requires providers to have "robust recruitment processes" and to satisfy themselves that workers are "of good character." This includes DBS checks, reference checks, proof of identity, and — for internationally recruited workers — verification of qualifications and professional registration.
A CQC inspection that uncovers safeguarding concerns related to unverified staff can trigger a referral to the Home Office. Conversely, a Home Office compliance visit that finds sponsored workers in roles or locations not matching their CoS can raise questions about CQC compliance.
The consequence is that a single failure can cascade across both regulatory regimes. A care provider that loses its sponsor licence due to record-keeping failures may simultaneously face CQC scrutiny over its recruitment processes. The combined impact — loss of staff, regulatory downgrades, reputational damage, and potential loss of contracts — can be existential for smaller providers.
The practical compliance framework for care sponsors
Meeting these obligations is not impossible. It requires treating sponsorship compliance as a dedicated operational function, not an add-on to existing HR processes.
1. Assign a compliance lead. The Authorising Officer named on the sponsor licence is ultimately responsible, but day-to-day compliance requires a designated individual with protected time. In small providers, this may be the registered manager. In larger organisations, it should be a dedicated compliance role. This person must understand both immigration obligations and the CQC regulatory framework.
2. Conduct structured onboarding for sponsored workers. Beyond the standard induction, sponsored workers need explicit, clear communication — in their first language where necessary — about their obligations: reporting changes of address, not working for anyone else, attending work as scheduled, and informing the employer before any travel outside the UK. Document that this communication happened.
3. Implement a 10-day reporting calendar. The 10-working-day reporting deadlines are not suggestions. Create a system — digital, not mental — that flags when a sponsored worker has been absent for five consecutive days, seven consecutive days, and ten consecutive days. The same system should flag when a worker's visa is approaching expiry, when a CoS needs updating, or when a change of work location needs reporting.
4. Maintain a central compliance file for each sponsored worker. Each file should contain: the CoS reference, visa expiry date, current address (updated in real time), contact details, right to work check evidence with dates, a record of every communication about compliance obligations, and evidence of any reports made to the Home Office via SMS.
5. Conduct quarterly self-audits. Before the Home Office visits you, visit yourself. Can you produce current contact details for every sponsored worker within one hour? Can you confirm that every worker is in the role and location described on their CoS? Can you show evidence of ongoing monitoring? If the answer to any of these is "no," you have identified a problem before enforcement does.
6. Prepare for the unannounced visit. Compliance officers will arrive without warning. They will ask to see records, to tour the premises, and potentially to speak with sponsored workers. If your compliance files are stored in a locked office and only one person has the key, and that person is on leave, you have a problem. Records must be accessible at all times, ideally in a digital system that can be accessed from any location.
The trajectory
The direction of travel is clear. Sponsor licence compliance in the care sector is going to get harder, not easier, for three reasons.
First, the Fair Work Agency now consolidates enforcement functions that were previously split across multiple bodies. This means more coordinated inspections, more data sharing between regulators, and less chance of falling through the cracks.
Second, the political environment around overseas care recruitment has shifted. The government has signalled an intention to reduce reliance on overseas care workers, which means increased scrutiny of existing sponsors and higher bars for new licence applications.
Third, the volume of sponsored workers in care means that even a stable revocation rate produces a large absolute number of failures. With over 20,000 care providers holding sponsor licences, the 33% revocation share represents thousands of individual compliance failures per year.
Certifyd's compliance portal gives care providers a single system for managing sponsored worker records, tracking visa expiry dates, scheduling follow-up checks, and maintaining the audit trails that Home Office compliance visits require. Built specifically for the operational realities of care — multiple sites, shift workers, high turnover — it replaces the spreadsheets and filing cabinets that most providers are still relying on. See how it works for care providers.