Sponsor Licence B-Rating Recovery: The Action Plan Guide 2026

What you cannot do

• • Assign any new Certificates of Sponsorship
• • Recruit any new sponsored workers
• • Extend existing CoS for current workers
• • Hide the rating — it's published on the sponsor register

What still works

• • Existing CoS already assigned remain valid
• • Current sponsored workers keep their visa status
• • Day-to-day employment continues normally
• • You can recover to A-rating in 3 months

Mandatory refresher training for everyone running RTW checks, plus a full re-check programme for every sponsored worker on file with timestamped evidence.

A written reporting policy, named responsible person, and evidence that every absence over 10 working days, salary change, role change, and leaver is submitted within the strict deadline.

A complete document review against the published Appendix D requirements for each sponsored worker, with gaps closed and the full pack indexed for retrieval at audit.

The AO must be UK-based, demonstrably involved in day-to-day sponsor duties, and able to answer compliance questions cold. AO sign-off is required on the final evidence pack.

Spreadsheets and email folders don't pass. The Home Office expects a system that can produce timestamped audit packs for any worker within minutes.

Every sponsored worker checked against their CoS for salary (including uplifted going rate), SOC code accuracy, hours worked, and job duties actually performed.

An independent mock audit conducted before the evidence deadline, with all identified gaps closed and the remediation documented.

A named individual with sponsor compliance in their job description, plus a written sponsor compliance policy ratified by senior leadership.

Cross-reference everything to the plan

Submit your evidence with an explicit action-by-action map: every step in the original Action Plan listed alongside the specific evidence that addresses it. Assessors should never have to hunt for the proof.

Missing the deadline by even a day is usually fatal. Partial evidence reads as non-engagement.

Closing the named gaps but failing to evidence sustained process change is the most common failure mode.

Submitting a clean audit at month 3 is not enough — assessors expect evidence across the full plan period.

AO must personally attest to the evidence and be available to discuss it. Absent or unprepared AOs sink responses.

A 0–100% compliance score recorded every day across all 6 Home Office domains — provable sustained improvement over the full 3-month period.

Schedule, complete, and evidence Right to Work re-checks for every sponsored worker with timestamped audit logs.

Every reportable event logged with the SMS submission date — proving consistent compliance with the 10-day rule.

One-click downloadable Appendix D file per sponsored worker, version-controlled and audit-ready for inclusion in your month-3 submission.

Cross-reference each Action Plan item to the LuwaSuite evidence that addresses it — assessors see proof, not just claims.

Built-in Authorising Officer sign-off on the evidence pack with timestamped digital attestation, exactly as Home Office expects.

How long does a sponsor licence B-rating last?

The B-rating lasts as long as your Home Office Action Plan period — usually 3 months from the date the action plan is formally issued. If you complete the plan successfully and the reassessment passes, your A-rating is restored. If you fail, the licence is revoked. The B-rating itself cannot be 'served out' — you must actively recover.

Can I extend the Action Plan period?

No. The Action Plan period is non-extendable. The Home Office sets the deadline once and missing it almost always triggers revocation. The only legitimate flex is in exceptional circumstances (e.g. caseworker delay in issuing the plan itself) and you must request clarification in writing immediately, not at month 3.

Do I still pay normal sponsor fees during B-rating?

Yes. Normal sponsor licence fees, CoS fees on existing workers, and Immigration Skills Charge obligations continue. The £1,476 Action Plan fee is on top of those, not instead of them. Many employers also incur immigration solicitor fees of £3,000–£15,000 and compliance audit costs of £5,000–£25,000 during this period.

What if I disagree with the Action Plan?

There is no formal appeal against an Action Plan. Your options are: (a) request written clarification on any step you genuinely cannot evidence as worded — done early and politely; (b) comply with the plan as written while documenting any disputes for your records; or (c) apply for judicial review of the underlying B-rating decision, which is expensive, slow, and rarely succeeds. Most employers comply.

Can my existing Certificates of Sponsorship still be used?

CoS already assigned before the B-rating decision remain valid and can still be used by the named worker to apply for or extend their visa. But you cannot assign any new CoS while B-rated. Your CoS allocation is effectively frozen until the A-rating is restored.

Will my existing sponsored workers be affected by my B-rating?

Their current visas are not curtailed by a B-rating (unlike revocation, which curtails to 60 days). But they cannot extend with you until the A-rating is restored. If the B-rating becomes a revocation, all sponsored workers lose visa status and have 60 days to find a new sponsor, switch route, or leave.

Is the B-rating made public on the sponsor register?

Yes. The Home Office publishes the sponsor register at gov.uk and B-rated sponsors are marked accordingly. Candidates, recruitment agencies, regulators, and competitors can all see the rating. This is one of the most damaging reputational consequences and is often what motivates employers to move fast on recovery.

What evidence wins B-rating recovery responses?

Assessors want timestamped, continuous, retrievable evidence — not just one-off remediation. The strongest evidence packs include: daily compliance score snapshots showing sustained improvement (not just a clean audit at month 3), automated Right to Work re-check logs, complete 10-day SMS reporting records, indexed Appendix D files per worker, signed AO attestations, training completion certificates, and a written compliance policy mapped to the action plan items.

How much does it cost to recover from a B-rating?

Direct costs: £1,476 Home Office Action Plan fee. Indirect costs typically: immigration legal advice £3,000–£15,000; compliance audit and remediation £5,000–£25,000; ongoing compliance software £100–£500/month; staff time. Most employers spend £10,000–£50,000 in total, plus the lost revenue from frozen recruitment of sponsored roles during the 3-month plan period.

What happens if I fail the Action Plan?

Failure to meet the Action Plan typically leads to licence revocation. Once revoked, all sponsored workers' visas are curtailed to 60 days, you cannot apply for a new licence for 12 months minimum (the cooling-off period), and the revocation is published on the sponsor register. There is no formal appeal — only judicial review, which challenges the legality of the decision and is rarely successful.