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Immigration / Sponsor LicensingUnited Kingdom
Free Sponsor Licence Revocation JR Pre-Action Letter Template
A sponsor licence revocation by the United Kingdom Home Office (UK Visas and Immigration) is one of the most damaging decisions a sponsoring employer can face — the licence is essential to recruit Skilled Worker, Temporary Worker, Health and Care Worker, Senior or Specialist Worker and Scale-up route migrants. Revocation cancels every Certificate of Sponsorship and curtails every sponsored worker's leave. The judicial review route under the Senior Courts Act 1981 section 31 is the principal challenge; the Pre-Action Protocol for Judicial Review under Civil Procedure Rules 54 requires a pre-action letter to be sent and answered before a claim is filed. Our free UK template builds a structured Pre-Action letter to the Government Legal Department — sender identification, decision being challenged, brief factual rebuttal, statement of relief sought, JR claim form intent and response deadline — with four Expert clauses on the trust principle and proportionality, procedural fairness, Annex C2 ground-by-ground rebuttal, and interim relief.
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Sponsor Licence Revocation — Pre-Action Protocol Letter (Judicial Review)
Pre-action Protocol For Judicial Review · 10 June 2026
Greenfield Care Group Limited
14 Mariner Square, Manchester M3 4DX
0161 555 9210
compliance@greenfieldcare.co.uk
10 June 2026
Government Legal Department
On behalf of the Secretary of State for the Home Department
102 Petty France
London SW1H 9GL
102 Petty France
London SW1H 9GL
PRE-ACTION PROTOCOL LETTER — JUDICIAL REVIEW
Licence: SW1234567A | UKVI Ref: UKVI/2026/SLR/004482
Dear Sir or Madam,
We write on behalf of Greenfield Care Group Limited in accordance with the Pre-Action Protocol for Judicial Review annexed to the Civil Procedure Rules. Our client challenges the decision of the Secretary of State for the Home Department dated 29 May 2026 to revoke the Skilled Worker licence licence reference SW1234567A. This letter is sent to enable the Secretary of State to reconsider the decision and to avoid the need for proceedings in the Administrative Court. Unless a satisfactory response is received by 24 June 2026 our client will issue a claim for judicial review in the Administrative Court within the three months prescribed by Senior Courts Act 1981 section 31(6) and Civil Procedure Rules Part 54, which expires on 27 August 2026.
We write on behalf of Greenfield Care Group Limited in accordance with the Pre-Action Protocol for Judicial Review annexed to the Civil Procedure Rules. Our client challenges the decision of the Secretary of State for the Home Department dated 29 May 2026 to revoke the Skilled Worker licence licence reference SW1234567A. This letter is sent to enable the Secretary of State to reconsider the decision and to avoid the need for proceedings in the Administrative Court. Unless a satisfactory response is received by 24 June 2026 our client will issue a claim for judicial review in the Administrative Court within the three months prescribed by Senior Courts Act 1981 section 31(6) and Civil Procedure Rules Part 54, which expires on 27 August 2026.
1.
SENDER IDENTIFICATION (PROSPECTIVE CLAIMANT)
Prospective claimant: Greenfield Care Group Limited
Registered office: 14 Mariner Square, Manchester M3 4DX
Sponsor licence number: SW1234567A
Licence route: Skilled Worker licence
Authorising Officer: Margaret O Sullivan (Head of Workforce Compliance)
Legal representative: Mr Adeyemi Adebayo (Hartwell Immigration Solicitors LLP)
Registered office: 14 Mariner Square, Manchester M3 4DX
Sponsor licence number: SW1234567A
Licence route: Skilled Worker licence
Authorising Officer: Margaret O Sullivan (Head of Workforce Compliance)
Legal representative: Mr Adeyemi Adebayo (Hartwell Immigration Solicitors LLP)
2.
DECISION BEING CHALLENGED
Decision-maker: Secretary of State for the Home Department (UK Visas and Immigration)
Date of decision: 29 May 2026
UKVI reference: UKVI/2026/SLR/004482
Decision: Revocation of the sponsor licence held by the prospective claimant
Grounds cited in the revocation letter:
The revocation letter cites Annex C2 grounds: (i) record-keeping failures concerning Appendix D documents for two sponsored workers; (ii) reporting failures concerning unauthorised absence reporting in respect of one worker; (iii) genuine vacancy and salary concerns concerning a third worker; (iv) general concerns about the sponsor compliance culture following a compliance visit on 18 February 2026.
Date of decision: 29 May 2026
UKVI reference: UKVI/2026/SLR/004482
Decision: Revocation of the sponsor licence held by the prospective claimant
Grounds cited in the revocation letter:
The revocation letter cites Annex C2 grounds: (i) record-keeping failures concerning Appendix D documents for two sponsored workers; (ii) reporting failures concerning unauthorised absence reporting in respect of one worker; (iii) genuine vacancy and salary concerns concerning a third worker; (iv) general concerns about the sponsor compliance culture following a compliance visit on 18 February 2026.
3.
BRIEF FACTUAL REBUTTAL OF GROUNDS CITED
The Annex D record-keeping points are remediable and were remediated within seven days of the suspension letter; the SMS reporting in respect of the absent worker was made within ten working days of the sponsor learning of the absence; the genuine vacancy and salary point is based on a misreading of the worker contractual record and on a salary figure that does not reflect the worker actual salary post-promotion. The compliance culture finding is generic, is not supported by ground-specific evidence, and overlooks the prior compliance history of the sponsor.
4.
STATEMENT OF RELIEF SOUGHT
Withdrawal of the revocation decision dated 29 May 2026; reinstatement of licence SW1234567A on the Sponsorship Management System to A-rated status; closure of the compliance file without further action; and confirmation in writing that no curtailment notices will be issued to the sponsored workers pending substantive resolution.
If the matter is not resolved at the pre-action stage the prospective claimant will seek the following relief from the Administrative Court: (a) a quashing order in respect of the revocation decision dated 29 May 2026; (b) interim relief by way of a stay of the revocation and reinstatement of the licence to its pre-revocation status pending substantive hearing; (c) costs of the claim; and (d) such further or other relief as the Court considers appropriate.
If the matter is not resolved at the pre-action stage the prospective claimant will seek the following relief from the Administrative Court: (a) a quashing order in respect of the revocation decision dated 29 May 2026; (b) interim relief by way of a stay of the revocation and reinstatement of the licence to its pre-revocation status pending substantive hearing; (c) costs of the claim; and (d) such further or other relief as the Court considers appropriate.
5.
JUDICIAL REVIEW CLAIM FORM INTENT AND RESPONSE DEADLINE
In accordance with the Pre-Action Protocol for Judicial Review the prospective claimant invites the Secretary of State to:
(a) Provide a substantive response addressing each ground cited and the rebuttal set out in this letter;
(b) Confirm whether the revocation is withdrawn or upheld, with reasons; and
(c) Disclose the documents relied on by the decision-maker that were not previously shared with the sponsor.
Response deadline: 24 June 2026
Judicial review filing deadline (CPR 54.5 + SCA 1981 s.31(6)): 27 August 2026
In the absence of a satisfactory response within the deadline a claim form will be issued in the Administrative Court without further notice.
(a) Provide a substantive response addressing each ground cited and the rebuttal set out in this letter;
(b) Confirm whether the revocation is withdrawn or upheld, with reasons; and
(c) Disclose the documents relied on by the decision-maker that were not previously shared with the sponsor.
Response deadline: 24 June 2026
Judicial review filing deadline (CPR 54.5 + SCA 1981 s.31(6)): 27 August 2026
In the absence of a satisfactory response within the deadline a claim form will be issued in the Administrative Court without further notice.
6.
TRUST PRINCIPLE AND PROPORTIONALITY (RAJ AND KNOLL + PRESTWICK CARE)
(A) TRUST BASIS OF SPONSORSHIP. The Supreme Court in R (New London College Ltd) v Secretary of State for the Home Department [2013] UKSC 51 confirmed the sponsorship system as a lawful framework grounded in the privilege accorded to those who hold a licence. The Court of Appeal in R (Raj and Knoll Ltd) v Secretary of State for the Home Department [2016] EWCA Civ 770 confirmed the trust basis of the system: the Secretary of State may take action where the trust on which sponsorship rests has been undermined.
(B) PROPORTIONATE RESPONSE. The corollary of the trust framework is that any action taken must be a proportionate response to the conduct in question. Disproportionate action on a minor or remedied breach is amenable to judicial review on the ordinary public law grounds.
(C) TRUST BASIS POSITION. Greenfield Care Group has held a Skilled Worker licence since June 2018, has had no prior compliance action, and operated at A-rated status throughout. The compliance findings relied on relate to three of forty-two sponsored workers and were all addressed in the response to suspension. There is no substantive undermining of trust on the Raj and Knoll standard.
(D) PROPORTIONALITY ARGUMENT. The matters identified were remediable on the published Sponsor Guidance criteria. A graduated response of B-rating with an action plan would have been a proportionate response, as it was in published case decisions in the residential care sector during 2025. Revocation imposes a permanent commercial and reputational sanction that is disproportionate to the conduct relied on.
(E) PRESTWICK LIMITS. Per R (Prestwick Care Ltd) v Secretary of State for the Home Department [2023] EWHC 3193 (Admin) and [2025] EWCA Civ 184, UKVI is under no general duty to assess the impact of revocation on the sponsor business, on workers or on service users. The prospective claimant accepts the Prestwick limit that UKVI is under no general duty to assess impact on workers or service users. The prospective claimant case rests on procedural fairness under New Hope Care, on factual rebuttal of the Annex C2 grounds, and on proportionality under Raj and Knoll. The consequences for residents of the regulated care service are mentioned as context to interim-relief balance, not as a freestanding duty.
(B) PROPORTIONATE RESPONSE. The corollary of the trust framework is that any action taken must be a proportionate response to the conduct in question. Disproportionate action on a minor or remedied breach is amenable to judicial review on the ordinary public law grounds.
(C) TRUST BASIS POSITION. Greenfield Care Group has held a Skilled Worker licence since June 2018, has had no prior compliance action, and operated at A-rated status throughout. The compliance findings relied on relate to three of forty-two sponsored workers and were all addressed in the response to suspension. There is no substantive undermining of trust on the Raj and Knoll standard.
(D) PROPORTIONALITY ARGUMENT. The matters identified were remediable on the published Sponsor Guidance criteria. A graduated response of B-rating with an action plan would have been a proportionate response, as it was in published case decisions in the residential care sector during 2025. Revocation imposes a permanent commercial and reputational sanction that is disproportionate to the conduct relied on.
(E) PRESTWICK LIMITS. Per R (Prestwick Care Ltd) v Secretary of State for the Home Department [2023] EWHC 3193 (Admin) and [2025] EWCA Civ 184, UKVI is under no general duty to assess the impact of revocation on the sponsor business, on workers or on service users. The prospective claimant accepts the Prestwick limit that UKVI is under no general duty to assess impact on workers or service users. The prospective claimant case rests on procedural fairness under New Hope Care, on factual rebuttal of the Annex C2 grounds, and on proportionality under Raj and Knoll. The consequences for residents of the regulated care service are mentioned as context to interim-relief balance, not as a freestanding duty.
7.
MEANINGFUL OPPORTUNITY TO RESPOND (NEW HOPE CARE)
(A) PROCEDURAL FAIRNESS ANCHOR. Per R (New Hope Care Ltd) v Secretary of State for the Home Department [2024] EWHC 1270 (Admin), revoking a sponsor licence without giving the sponsor a meaningful opportunity to respond to the concerns relied on is unlawful — inconsistent with the published policy, contrary to legitimate expectation and procedurally unfair at common law.
(B) SUSPENSION LETTER HISTORY. The suspension letter is dated 11 March 2026 and identified the record-keeping and reporting concerns. The sponsor response was submitted by Hartwell Immigration Solicitors LLP on 5 April 2026 within the 20-working-day window, with sixty-eight pages of supporting evidence (Annexes 1 to 7). No further questions were put to the sponsor between 5 April 2026 and the revocation decision of 29 May 2026.
(C) RESPONSE WINDOW FACTS. The 20-working-day response window was accorded. However the revocation letter relies on the "compliance culture" finding and on the genuine vacancy and salary point which were not put to the sponsor in the suspension letter or in any subsequent correspondence. The decision-maker therefore relied on facts not put to the sponsor in the response window.
(D) APPLICATION OF NEW HOPE CARE. Applying New Hope Care: the compliance culture finding is a new fact not put to the sponsor in the suspension letter; the genuine vacancy and salary point relies on a salary figure from August 2025 superseded by a promotion-and-pay-rise letter of 11 January 2026 which was in the sponsor file but was not the subject of any question to the sponsor before revocation. These are material to the revocation decision and were not the subject of a meaningful opportunity to respond.
(B) SUSPENSION LETTER HISTORY. The suspension letter is dated 11 March 2026 and identified the record-keeping and reporting concerns. The sponsor response was submitted by Hartwell Immigration Solicitors LLP on 5 April 2026 within the 20-working-day window, with sixty-eight pages of supporting evidence (Annexes 1 to 7). No further questions were put to the sponsor between 5 April 2026 and the revocation decision of 29 May 2026.
(C) RESPONSE WINDOW FACTS. The 20-working-day response window was accorded. However the revocation letter relies on the "compliance culture" finding and on the genuine vacancy and salary point which were not put to the sponsor in the suspension letter or in any subsequent correspondence. The decision-maker therefore relied on facts not put to the sponsor in the response window.
(D) APPLICATION OF NEW HOPE CARE. Applying New Hope Care: the compliance culture finding is a new fact not put to the sponsor in the suspension letter; the genuine vacancy and salary point relies on a salary figure from August 2025 superseded by a promotion-and-pay-rise letter of 11 January 2026 which was in the sponsor file but was not the subject of any question to the sponsor before revocation. These are material to the revocation decision and were not the subject of a meaningful opportunity to respond.
8.
ANNEX C2 GROUND-BY-GROUND REBUTTAL
(A) THE ANNEX C2 FRAMEWORK. Annex C2 of the Worker and Temporary Worker Sponsor Guidance sets out the circumstances in which UKVI will normally or may revoke a licence as a matter of discretion. Each ground cited must be matched against the published wording and the underlying evidence; generic invocation of Annex C2 without ground-specific factual support is amenable to challenge.
(B) GROUND 1. Record-keeping under Annex D (Appendix D): the two missing documents are right-to-work check screenshots for two workers; replacements were obtained within seven days of the suspension letter and were exhibited to the sponsor response. The breach is remediable, remediated and historic. Annex C2 mandatory revocation requires a serious or repeated failure not made out on these facts.
(C) GROUND 2. Reporting under SMS: the unauthorised absence of worker AB123456 began on 24 February 2026; the worker contacted the sponsor on 7 March 2026; the SMS report was submitted on 11 March 2026, within ten working days of the sponsor learning of the absence and the ten-working-day window measured from the point of knowledge of the reportable event.
(D) GROUND 3. Genuine vacancy and salary for worker CD789012: the salary figure relied on in the revocation letter is GBP 31,500 from August 2025. The worker was promoted from Care Worker to Senior Care Worker on 11 January 2026 with effect from 1 February 2026 and the new salary is GBP 39,800 per annum, above the relevant going rate in force. The promotion documentation is at Annex 5 of the sponsor response.
(E) EVIDENCE INDEX. A bundle index is enclosed at Annex A listing: suspension letter dated 11 March 2026; sponsor response of 5 April 2026 with seven sub-annexes; replacement RTW screenshots for workers EF1 and EF2; SMS reporting screenshots for worker AB123456; promotion-and-pay-rise letter dated 11 January 2026 for worker CD789012; payroll records for January to May 2026; minute of the sponsor Compliance Committee meeting of 14 April 2026.
(B) GROUND 1. Record-keeping under Annex D (Appendix D): the two missing documents are right-to-work check screenshots for two workers; replacements were obtained within seven days of the suspension letter and were exhibited to the sponsor response. The breach is remediable, remediated and historic. Annex C2 mandatory revocation requires a serious or repeated failure not made out on these facts.
(C) GROUND 2. Reporting under SMS: the unauthorised absence of worker AB123456 began on 24 February 2026; the worker contacted the sponsor on 7 March 2026; the SMS report was submitted on 11 March 2026, within ten working days of the sponsor learning of the absence and the ten-working-day window measured from the point of knowledge of the reportable event.
(D) GROUND 3. Genuine vacancy and salary for worker CD789012: the salary figure relied on in the revocation letter is GBP 31,500 from August 2025. The worker was promoted from Care Worker to Senior Care Worker on 11 January 2026 with effect from 1 February 2026 and the new salary is GBP 39,800 per annum, above the relevant going rate in force. The promotion documentation is at Annex 5 of the sponsor response.
(E) EVIDENCE INDEX. A bundle index is enclosed at Annex A listing: suspension letter dated 11 March 2026; sponsor response of 5 April 2026 with seven sub-annexes; replacement RTW screenshots for workers EF1 and EF2; SMS reporting screenshots for worker AB123456; promotion-and-pay-rise letter dated 11 January 2026 for worker CD789012; payroll records for January to May 2026; minute of the sponsor Compliance Committee meeting of 14 April 2026.
9.
INTERIM RELIEF AND STAY APPLICATION (CPR 54.10)
(A) STAY APPLICATION ROUTE. Civil Procedure Rules 54.10 provides for interim relief in judicial review proceedings, including a stay of the impugned decision pending substantive hearing. A stay of a sponsor licence revocation is exceptional but available where the strength of the procedural fairness or proportionality challenge and the practical balance of harm favour the prospective claimant.
(B) INTERIM RELIEF BASIS. The procedural fairness challenge under New Hope Care is strong; on the facts the suspension letter did not put the compliance culture finding or the post-promotion salary to the sponsor. The balance-of-harm assessment, properly framed within Prestwick limits, favours interim relief: the prospective claimant operates regulated care services and 60-day curtailment of forty-two sponsored workers would have immediate operational consequences relevant to the proportionality limb. Comparator: a stay was ordered in care-sector sponsor revocation challenges in the period 2024 to 2025.
(C) WORKER CURTAILMENT. Revocation triggers curtailment of permission to a maximum of sixty days for each sponsored worker (Worker Guidance Annex C). Forty-two sponsored workers are employed in regulated CQC care services for vulnerable adults across three sites. The operational consequences for the regulated service are not advanced as a freestanding duty but are relevant to the interim-relief balance.
(D) JR PRE-ACTION TIMELINE. Letter date 10 June 2026; response deadline 24 June 2026; intended claim form filing 1 July 2026 if no satisfactory response; interim relief application together with the claim form; permission hearing anticipated within four weeks of issue. The three-month deadline under SCA 1981 section 31(6) and CPR 54.5 falls on 27 August 2026.
(B) INTERIM RELIEF BASIS. The procedural fairness challenge under New Hope Care is strong; on the facts the suspension letter did not put the compliance culture finding or the post-promotion salary to the sponsor. The balance-of-harm assessment, properly framed within Prestwick limits, favours interim relief: the prospective claimant operates regulated care services and 60-day curtailment of forty-two sponsored workers would have immediate operational consequences relevant to the proportionality limb. Comparator: a stay was ordered in care-sector sponsor revocation challenges in the period 2024 to 2025.
(C) WORKER CURTAILMENT. Revocation triggers curtailment of permission to a maximum of sixty days for each sponsored worker (Worker Guidance Annex C). Forty-two sponsored workers are employed in regulated CQC care services for vulnerable adults across three sites. The operational consequences for the regulated service are not advanced as a freestanding duty but are relevant to the interim-relief balance.
(D) JR PRE-ACTION TIMELINE. Letter date 10 June 2026; response deadline 24 June 2026; intended claim form filing 1 July 2026 if no satisfactory response; interim relief application together with the claim form; permission hearing anticipated within four weeks of issue. The three-month deadline under SCA 1981 section 31(6) and CPR 54.5 falls on 27 August 2026.
10.
CONCLUSION
The prospective claimant invites the Secretary of State to withdraw the revocation decision dated 29 May 2026, restore the licence to its pre-revocation status, and confirm reinstatement on the Sponsorship Management System within the response deadline set out above. In the absence of a substantive response or a satisfactory outcome the prospective claimant will issue a claim for judicial review.
YOURS FAITHFULLY,
Margaret O Sullivan
Head of Workforce Compliance and Authorising Officer
Date: ____________________
PROSPECTIVE CLAIMANT
Margaret O Sullivan
Head of Workforce Compliance and Authorising Officer
Greenfield Care Group Limited
Date: ____________________
Available as a print-ready PDF or an editable Microsoft Word (.docx) file.
What Is a Sponsor Licence Revocation JR?
A sponsor licence is the United Kingdom Home Office authorisation for an employer to issue Certificates of Sponsorship (CoS) to non-UK workers under the Skilled Worker, Temporary Worker, Health and Care Worker, Senior or Specialist Worker, Scale-up and other Points-Based System routes. The licence is administered by UK Visas and Immigration (UKVI) within the Home Office. UKVI can revoke a licence where it considers the sponsor has failed to comply with the Worker and Temporary Worker Sponsor Guidance, has assigned CoS in breach of the rules, has failed to report a reportable event, or has otherwise failed to maintain the trust required for sponsor status. The Worker and Temporary Worker Sponsor Guidance Annex C2 lists the discretionary revocation grounds.
Revocation cancels every Certificate of Sponsorship the licence has issued and curtails every sponsored worker's leave under Immigration Rules paragraph 323A. The commercial impact is severe — the sponsor cannot recruit Points-Based System migrants, existing sponsored employees lose their leave, and the sponsor is named on the public revocation list which makes future licence applications difficult. The judicial review route under section 31 of the Senior Courts Act 1981 is the principal challenge — a claim for JR must be filed promptly and in any event within three months of the decision being challenged (CPR 54.5). The Administrative Court of the High Court (or the Upper Tribunal where transferred) decides the claim.
The Pre-Action Protocol for Judicial Review under Civil Procedure Rules 54 requires a pre-action letter to be sent to the Government Legal Department before the claim is filed. Three frameworks dominate United Kingdom sponsor licence JR. First, R (Raj and Knoll Ltd) v Secretary of State for the Home Department [2016] EWCA Civ 770 on the trust principle and proportionality — UKVI must apply the published guidance proportionately. Second, R (New Hope Care Ltd) v Secretary of State for the Home Department [2024] EWHC 1270 (Admin) on procedural fairness — revoking a licence without giving the sponsor a meaningful opportunity to respond to the concerns relied on is unlawful. Third, R (Prestwick Care Ltd) v Secretary of State for the Home Department [2025] EWCA Civ on the scope of revocation and the curtailment of sponsored workers' leave.
What's Covered in This Template
Our United Kingdom Sponsor Licence Revocation JR Pre-Action template builds a structured Pre-Action Protocol letter to the Government Legal Department — sender identification, decision being challenged, brief factual rebuttal of the grounds cited, statement of relief sought, JR claim form intent and response deadline — with four Expert clauses on trust principle and proportionality, procedural fairness, Annex C2 ground-by-ground rebuttal, and interim relief.
Pre-Action Protocol for Judicial Review (CPR 54)
The template is structured as a Pre-Action Protocol letter under the Pre-Action Protocol for Judicial Review (CPR 54). The letter sets out the prospective claimant, the decision being challenged, the brief factual rebuttal, the relief sought and the JR claim form intent. The Government Legal Department is the addressee for Home Office decisions in the United Kingdom.
Skilled Worker / Temporary Worker / Health and Care Coverage
Covers all sponsor licence types — Skilled Worker, Temporary Worker (Creative, Religious, Charity, GAE, International Agreement, Seasonal Worker), Health and Care Worker, Senior or Specialist Worker (Global Business Mobility), Scale-up and other Points-Based System routes. The trust principle applies uniformly across categories.
Three-Month JR Deadline — Senior Courts Act 1981 s.31(6)
Captures the JR deadline. A claim for judicial review must be filed promptly and in any event within three months of the decision being challenged (Senior Courts Act 1981 section 31(6) and CPR 54.5). The Pre-Action letter is sent and answered within that window so the claim can be filed in time.
Sponsor Licence Number Capture
Records the sponsor licence number — typically a two-letter tier prefix followed by seven digits and a check letter (e.g. SW1234567A for a Skilled Worker licence). The number appears at the top of the Sponsorship Management System (SMS) profile and on the UKVI revocation letter.
Decision Date and Revocation Letter Reference
Captures the date of the revocation decision and the UKVI revocation letter reference. The three-month JR deadline runs from the decision date; the Pre-Action letter is sent typically 14-21 days after revocation to allow the Government Legal Department a 14-day response window before the claim is filed.
Trust Principle and Proportionality (Expert)
Expert clause structures the trust principle and proportionality argument. Per R (Raj and Knoll Ltd) v Secretary of State for the Home Department [2016] EWCA Civ 770 and R (Prestwick Care Ltd) v Secretary of State for the Home Department [2025] EWCA Civ, UKVI must apply the published Worker and Temporary Worker Sponsor Guidance proportionately. Revocation is a drastic step and must be proportionate to the breach.
Meaningful Opportunity to Respond — New Hope Care (Expert)
Expert clause covers the procedural fairness argument. Per R (New Hope Care Ltd) v Secretary of State for the Home Department [2024] EWHC 1270 (Admin), revoking a sponsor licence without giving the sponsor a meaningful opportunity to respond to the concerns relied on is unlawful — contrary to the published policy, contrary to legitimate expectation and procedurally unfair at common law in the United Kingdom.
Annex C2 Ground-by-Ground Rebuttal (Expert)
Expert clause covers the Annex C2 framework. Annex C2 of the Worker and Temporary Worker Sponsor Guidance sets out the discretionary revocation grounds. Each ground cited must be matched against the published wording and the underlying evidence. Generic invocation of Annex C2 without ground-specific factual support is amenable to challenge — ground-by-ground rebuttal with a numbered evidence index is decisive.
Interim Relief / Stay Application — CPR 54.10 (Expert)
Expert clause covers interim relief under CPR 54.10. A stay of a sponsor licence revocation is exceptional but available where the strength of the procedural fairness or proportionality challenge and the practical balance of harm favour the prospective claimant. Setting out the interim-relief basis at the Pre-Action stage signals seriousness and frames the United Kingdom Administrative Court timeline.
Statement of Relief Sought
Pre-drafts the relief sought — withdrawal of the revocation decision, restoration of the licence to its pre-revocation status, and confirmation of reinstatement on the Sponsorship Management System within the response deadline. The Administrative Court has full power to quash and remit; interim relief preserves the position pending the substantive hearing.
Sponsorship Management System (SMS) Linkage
Pre-frames the SMS context — the SMS profile is the operational system through which the sponsor manages CoS, reports reportable events and maintains compliance records. Revocation closes SMS access. The Pre-Action letter expressly invites reinstatement on SMS so existing CoS can be reactivated and sponsored workers' leave restored.
Government Legal Department as Addressee
The Pre-Action letter is addressed to the Government Legal Department — the Crown's lawyers for Home Office decisions in the United Kingdom. The GLD response is sent typically within 14 days under the Pre-Action Protocol for Judicial Review. Where the GLD does not concede, the prospective claimant files the JR claim form within the three-month CPR 54.5 deadline.
How to Build a Sponsor Licence Revocation JR Pre-Action Letter
Follow these steps to produce a structured United Kingdom Pre-Action Protocol letter to the Government Legal Department challenging a sponsor licence revocation by the Home Office.
- 1
Identify the Prospective Claimant Sponsor
Capture the prospective claimant sponsor's full registered name, company number, registered office address, sponsor licence number (e.g. SW1234567A) and the Authorising Officer's name. The Authorising Officer is the senior person responsible for the licence under the Worker and Temporary Worker Sponsor Guidance.
- 2
Capture the Decision Being Challenged
Record the date of the UKVI revocation decision, the revocation letter reference, the Sponsor licence number affected and the grounds cited in the revocation letter. The decision is by the Secretary of State for the Home Department, acting through UK Visas and Immigration. The three-month JR deadline runs from the decision date.
- 3
Brief Factual Rebuttal of the Grounds Cited
Set out a brief factual rebuttal of each ground cited in the revocation letter. The detailed ground-by-ground rebuttal goes in the Expert Annex C2 clause; the brief rebuttal in the body gives the Government Legal Department a roadmap on first read. Avoid generic denials — engage with the specific facts the revocation letter relies on in the United Kingdom.
- 4
Set Out the Relief Sought
State the relief sought — withdrawal of the revocation decision, restoration of the licence to its pre-revocation status, and confirmation of reinstatement on the Sponsorship Management System within the response deadline. Where interim relief is sought, signpost it in the body and develop it in the Expert clause.
- 5
Set the Response Deadline
The Pre-Action Protocol for Judicial Review (CPR 54) gives the respondent a 14-day window to respond. Set the deadline explicitly — typically 14 days from the date of the letter — and state that absent satisfactory response, the JR claim will be filed. The three-month CPR 54.5 deadline runs from the decision date.
- 6
Build the Trust Principle and Proportionality Argument (Expert)
Expert clause. Per R (Raj and Knoll Ltd) v Secretary of State for the Home Department [2016] EWCA Civ 770 and R (Prestwick Care Ltd) v Secretary of State for the Home Department [2025] EWCA Civ, UKVI must apply the published Worker and Temporary Worker Sponsor Guidance proportionately. Frame the proportionality argument — was revocation the proportionate response to the breach found? Could a less drastic step (warning letter, B-rated licence) have addressed the concerns?
- 7
Plead the Meaningful Opportunity to Respond Argument (Expert)
Expert clause. Per R (New Hope Care Ltd) v Secretary of State for the Home Department [2024] EWHC 1270 (Admin), revoking without giving the sponsor a meaningful opportunity to respond to the concerns is unlawful. Audit the suspension correspondence ground by ground; identify every fact relied on in the revocation decision that was not put to the sponsor in suspension correspondence. The procedural fairness argument is often the strongest.
- 8
Ground-by-Ground Rebuttal Against Annex C2 (Expert)
Expert clause. Annex C2 of the Worker and Temporary Worker Sponsor Guidance sets out the discretionary revocation grounds. Each ground cited must be matched against the published wording and the underlying evidence. Generic invocation of Annex C2 without ground-specific factual support is amenable to challenge. Use a numbered evidence index to force the decision-maker to engage with the sponsor case in the United Kingdom.
- 9
Frame Interim Relief / Stay Application (Expert)
Expert clause. CPR 54.10 provides for interim relief in JR proceedings, including a stay of the impugned decision pending substantive hearing. A stay of a sponsor licence revocation is exceptional but available where the strength of the procedural fairness or proportionality challenge and the practical balance of harm favour the prospective claimant. Setting out the interim-relief basis at Pre-Action stage signals seriousness.
- 10
Sign and Send to the Government Legal Department
Sign the Pre-Action letter and send to the Government Legal Department by post and email. The GLD response is sent typically within the 14-day window. Where the GLD does not concede, the prospective claimant files the JR claim form (Form N461) within the three-month CPR 54.5 deadline and the Administrative Court lists the permission hearing.
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Legal Considerations — Sponsor Licence Revocation JR
Sponsor licence revocations in the United Kingdom are challenged through the judicial review route. The substantive law is set by section 31 of the Senior Courts Act 1981, the Civil Procedure Rules Part 54, the Pre-Action Protocol for Judicial Review and the Worker and Temporary Worker Sponsor Guidance (especially Annex C2). The decision-maker is the Secretary of State for the Home Department acting through UK Visas and Immigration.
This template is for general information and does not constitute legal advice. Sponsor licence JR is technical and time-critical — the three-month CPR 54.5 deadline runs from the decision date and is rarely extended. Specialist advice from a solicitor of the Law Society Immigration Law Committee, an OISC adviser at Level 3, or a barrister of the Administrative Law Bar Association is strongly recommended. The Immigration Law Practitioners' Association (ILPA) and the Joint Council for the Welfare of Immigrants (JCWI) maintain resources on sponsor licence JR; Legal Aid is not normally available for sponsor licence JR (sponsors are typically commercial entities).
Reviewed for the United Kingdom (England and Wales)
Judicial Review Route — SCA 1981 s.31 + CPR 54
Judicial review of a sponsor licence revocation is brought under section 31 of the Senior Courts Act 1981 and Civil Procedure Rules Part 54. A claim must be filed promptly and in any event within three months of the decision being challenged (CPR 54.5). The Pre-Action Protocol for Judicial Review requires a pre-action letter to the Government Legal Department before the claim is filed. The Administrative Court of the High Court (or the Upper Tribunal where transferred under section 31A) decides the claim. The substantive grounds available are illegality, irrationality and procedural impropriety (Council of Civil Service Unions v Minister for the Civil Service [1985] AC 374) — supplemented by proportionality, legitimate expectation and (where ECHR rights are engaged) Convention-rights claims.
Trust Principle and Proportionality
The trust principle is the foundation of the United Kingdom sponsor licence regime — UKVI grants a licence on the basis that the sponsor will comply with the published guidance. Where compliance is in doubt, UKVI applies the discretionary revocation grounds in Annex C2 of the Worker and Temporary Worker Sponsor Guidance. The Court of Appeal in R (Raj and Knoll Ltd) v Secretary of State for the Home Department [2016] EWCA Civ 770 and R (Prestwick Care Ltd) v Secretary of State for the Home Department [2025] EWCA Civ confirm that UKVI must apply the guidance proportionately — revocation is a drastic step and must be proportionate to the breach. A less drastic step (warning letter, B-rated licence, action plan) may be the proportionate response.
Procedural Fairness — New Hope Care
Procedural fairness is often the strongest challenge to a sponsor licence revocation. Per R (New Hope Care Ltd) v Secretary of State for the Home Department [2024] EWHC 1270 (Admin), revoking a sponsor licence without giving the sponsor a meaningful opportunity to respond to the concerns relied on is unlawful — contrary to the published policy, contrary to legitimate expectation and procedurally unfair at common law. Auditing the suspension correspondence ground by ground, and identifying every fact relied on in the revocation decision that was not put to the sponsor in that correspondence, can be decisive without engaging the substantive merits.
Annex C2 Ground-by-Ground Rebuttal and Interim Relief
Annex C2 of the Worker and Temporary Worker Sponsor Guidance sets out the discretionary revocation grounds. Each ground cited must be matched against the published wording and the underlying evidence. Generic invocation of Annex C2 without ground-specific factual support is amenable to challenge. Interim relief is available under CPR 54.10 — a stay of a sponsor licence revocation is exceptional but available where the strength of the procedural fairness or proportionality challenge and the practical balance of harm favour the prospective claimant. Where granted, the stay preserves the licence pending substantive hearing and avoids curtailment of sponsored workers' leave under Immigration Rules paragraph 323A.
Frequently Asked Questions
Build Your Sponsor Licence Revocation JR Pre-Action Letter
Produce a structured United Kingdom Pre-Action Protocol for Judicial Review letter to the Government Legal Department challenging a sponsor licence revocation by the Home Office (UK Visas and Immigration) — sender identification with sponsor licence number and Authorising Officer, decision being challenged (revocation date and grounds), brief factual rebuttal of the grounds cited, statement of relief sought (withdrawal, restoration, SMS reinstatement), JR claim form intent and 14-day response deadline, and four Expert clauses on the trust principle and proportionality (R (Raj and Knoll Ltd) v Secretary of State for the Home Department [2016] EWCA Civ 770 + R (Prestwick Care Ltd) v Secretary of State for the Home Department [2025] EWCA Civ), the meaningful opportunity to respond requirement (R (New Hope Care Ltd) v Secretary of State for the Home Department [2024] EWHC 1270 (Admin)), Annex C2 ground-by-ground rebuttal, and interim relief under CPR 54.10. Sent within the three-month CPR 54.5 deadline running from the decision date.
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