On 3 June 2026, Conservative MP Blake Stephenson opened a Westminster Hall debate on improving the UK visa system, following his March 2026 report on the legal migration system. The report concluded that the system was “entirely unfit” for purpose and that legal migration was “out of control”. It made 30 recommendations, including restricting work visa sponsorship to companies with at least 6 employees, capping sponsored workers at 20% of an organisation’s workforce, and publishing more detailed compliance data.
None of those proposals are currently law. Westminster Hall debates do not produce binding votes, and there is no present rule requiring a sponsor to have 6 employees or limiting sponsored workers to 20% of the workforce. But the debate still matters. It reflects the political pressure now surrounding the sponsorship system, and that pressure sits alongside a clear rise in Home Office enforcement.
For employers with sponsor licences, the practical message is simple: review your compliance before the Home Office does.
The Numbers Behind the Enforcement Surge
The enforcement trend is already visible.
Between July 2024 and June 2025, the Home Office revoked 1,948 sponsor licences, more than double the 937 revocations in the previous 12 months. Official Home Office data identified adult social care, hospitality, retail and construction as among the sectors with the highest levels of abuse.
Published sponsorship transparency data and subsequent analysis also show that revocations continued to accelerate in late 2025, with more than 1,500 licences revoked between October and December 2025 alone. Across 2025, revocations reached around 3,100, the highest annual total since records began in 2012.
The point for sponsors is not that only high-risk sectors should be concerned. Social care has been a major focus, but enforcement has also touched hospitality, retail, construction, IT consultancy and other sectors. No sponsor should assume they are immune simply because they are outside the care sector.
The Home Office is also relying more heavily on data. HMRC, PAYE records, Companies House information and internal Home Office systems can now flag issues before a compliance officer visits your premises. A salary shortfall, dormant company concern, reporting inconsistency or mismatch between a Certificate of Sponsorship and payroll records can be identified remotely.
What the Stephenson Report Proposed
The Stephenson report made recommendations across Home Office compliance operations, visa criteria and data transparency.
One proposal was that work visa sponsorship should be restricted to businesses with at least 6 employees. The report argued that very small sponsor businesses present a higher risk of abuse, particularly where a company appears to exist mainly to facilitate immigration rather than trade as a genuine business.
Another proposal was a 20% cap on the proportion of an organisation’s workforce made up of people on work-related visas. This has not been adopted by the Government and would require a significant policy change before it could affect employers.
The report also argued for better data collection and publication across the visa system. This matters because improved data visibility usually means more targeted enforcement. If the Home Office is pushed to publish more information about sponsorship patterns, it is also likely to improve how it monitors sponsors internally.
For now, these proposals remain political recommendations, not legal duties. The current risk comes from the rules already in force.
What Sponsors Need to Act On Now
The debate is context. The sponsor guidance is what affects your licence today.
The eligible role test is now central. A sponsored role must be genuine, eligible under the relevant route, and reflect the duties, skill level, salary, location and working hours stated on the Certificate of Sponsorship. If the worker is not doing the job described, or if the role does not meet the route requirements, the licence is exposed. This is especially important for sponsors using the Skilled Worker route.
The pay period rules now need close attention. From 8 April 2026, Skilled Worker salary compliance is assessed through defined pay periods, not simply by looking at the annual salary in isolation. The worker must be paid at least the relevant going rate for every hour worked in each pay period, and wider salary requirements are assessed across the required 3-month, 12-week or 17-week periods depending on the pay structure. Our article on Skilled Worker pay period rules covers this in more detail.
Worker rights notification is now a real record-keeping issue. Sponsors are expected to inform sponsored workers about their employment rights in the UK and keep evidence that this has been done. This should cover matters such as pay, working time, holiday, sick pay, health and safety, pensions, grievance procedures and protection from discrimination. It is not enough to assume the information appears somewhere in a contract or handbook.
The operating and trading requirement is also under greater scrutiny. Sponsors must be able to show they are genuinely operating or trading in the UK. The May 2026 guidance made this especially important for businesses that appear to have limited activity, circular trading arrangements, related-party income, or structures that may have been created mainly to facilitate a worker’s entry or stay. Our article on the May 2026 sponsor guidance update explains the changes.
Right to work checks must also reflect the current guidance. The May 2026 update clarified that sponsors must check all workers they sponsor, whether employees or not, and all unsponsored employees. Earlier wording around unsponsored workers who were “directly engaged” but not employed has been removed and should be disregarded. Our article on eVisas and digital right to work checks covers the current process.
What the Debate Signals for Future Enforcement
The Stephenson debate does not change the law, but it does show where political attention is focused.
Smaller and newer sponsors should expect scrutiny. There is no legal minimum employee number, but UKVI already looks carefully at whether a business is genuine, active and able to meet its sponsor duties. If a business has very few employees and a high reliance on sponsored workers, its records need to be especially strong.
Sponsors with a high proportion of sponsored staff should also think ahead. The 20% cap is not law, but it reflects a wider policy concern about whether sponsorship is being used to fill genuine skill gaps or as a primary workforce model. A sponsor in construction, hospitality, retail, care or IT consultancy should be able to explain why each sponsored role is needed and how it fits the business.
Data-led compliance is increasing. Employers should assume that UKVI may compare CoS information, PAYE data, company records and sponsor reports. If your internal records do not match what has been reported to the Home Office, that inconsistency can become a compliance issue.
A Practical Scenario
Consider a construction firm with 80 workers, 22 of whom are sponsored under the Skilled Worker route. That is 27.5% of the workforce, above the proposed 20% cap. The company is not breaching that proposal because it is not law. But it may still be vulnerable if its SMS reports are late, pay records are unclear, or workers are carrying out duties that do not match their CoS.
The sensible approach is to run an internal audit now. Check whether all sponsored workers are being paid correctly in each relevant pay period. Confirm that worker rights notification evidence exists. Review right to work checks. Make sure role titles, duties, hours, work locations and salary records match the Certificates of Sponsorship. Check whether any changes should have been reported within the required deadline.
If everything is in order, the audit gives reassurance. If there are gaps, it is better to find them before UKVI does.
The Impact on Sponsored Workers When Things Go Wrong
When a sponsor licence is revoked, the consequences are not limited to the employer.
UKVI will normally cancel or shorten the permission of sponsored workers. If a worker was not complicit in the reason for revocation, they will usually be left with 60 calendar days’ permission. They must find a new sponsor, obtain a new Certificate of Sponsorship, and make a new immigration application, or leave the UK.
That is a short and stressful timeframe. It can disrupt employment, family life, settlement planning and future citizenship applications.
Our page on sponsor licence suspension and revocation explains what happens in each scenario. If enforcement action has already started, our article on sponsor licence reinstatement after suspension covers what recovery can involve.
A Self-Assessment Framework for Sponsors
A useful internal review should cover the following areas.
Are all Certificates of Sponsorship assigned for genuine roles that still match the worker’s actual duties, hours, salary and work location?
Can you produce pay records showing each sponsored worker meets the relevant salary and hourly rate requirements across the correct pay periods?
Have you completed right to work checks on all sponsored workers and all unsponsored employees?
Do you have evidence that each sponsored worker was told about their employment rights?
Have all required SMS reports been made on time, including changes to salary, role, location, working hours, absence and employment status?
Are your Authorising Officer and Level 1 Users still suitable, active and familiar with the current guidance?
Can you demonstrate that the business is genuinely operating or trading in the UK?
Our sponsor licence compliance page sets out how we approach compliance reviews and what they cover.
The Bigger Picture
The debate took place against a backdrop of falling but still politically sensitive migration figures. The latest ONS estimate put UK net migration at 171,000 for the year ending December 2025, down from 331,000 in the previous year and far below the peak seen in 2023. Even so, immigration remains a major political issue, and the sponsorship system is one of the main enforcement targets.
For good-faith sponsors, this should not be a reason to panic. The system is designed to prevent abuse, underpayment and exploitation. But a sponsor licence is not a passive asset. It requires active management.
Our overview of business changes that trigger sponsor reporting covers one of the most commonly missed duties, and our guide on key personnel on a sponsor licence explains the governance responsibilities behind the licence.
If you are a business owner or HR professional, the UK visa for skilled professionals page explains the route from the employer’s perspective, while our immigration solicitors team can advise on your specific situation.
FAQs
Are the Stephenson report recommendations now law?
No. The March 2026 report and the Westminster Hall debate of 3 June 2026 produced policy proposals, not binding law. There is no current rule requiring sponsors to have at least 6 employees or limiting sponsored workers to 20% of the workforce.
Does the 20% workforce cap apply to my business?
No. It is a proposal, not a legal requirement. However, a high proportion of sponsored workers may still attract scrutiny if UKVI questions whether roles are genuine or whether the business is relying on sponsorship in a way that raises compliance concerns.
What are the most common sponsor licence risks?
Common risks include underpaying sponsored workers, assigning CoS for roles that do not match the work actually performed, poor record-keeping, late SMS reporting, weak right to work processes and failure to keep key personnel up to date.
My business has fewer than 6 employees. Am I at risk?
There is no legal minimum employee number for sponsor licences. However, smaller businesses may face closer scrutiny, especially if the company has limited trading activity, few non-sponsored staff, or appears closely linked to the immigration position of one worker.
How quickly can UKVI identify pay issues?
UKVI can identify issues through compliance visits, HMRC checks, PAYE data and records requested from the sponsor. Pay issues are no longer something sponsors should expect to discover only during a site visit.
What should I do first if I think my compliance has gaps?
Start with a structured internal audit of CoS records, payroll, right to work checks, worker rights notification evidence, SMS reporting and key personnel. If you find gaps, take legal advice before UKVI contacts you.
Act Before You Are Asked To
The political pressure around the UK visa system is not going away. The Home Office is already enforcing sponsor duties more aggressively, and the 2026 guidance changes have added pressure around pay, role eligibility, worker rights, right to work checks and genuine trading activity.
A licence that felt safe under the old approach may not be safe under the current one.
At Garth Coates Solicitors, our team of immigration solicitors UK advises sponsor licence holders across all sectors on compliance reviews, enforcement responses and business immigration matters. Whether you are a well-established sponsor who wants to pressure-test your current position, or a business already facing a compliance concern, we can help you understand where you stand and what to do next.
Contact us today to arrange a consultation.
