With overseas recruitment routes tightening and compliance requirements increasing, Yash Dubal, Chief Executive and Director at A Y & J Solicitors, examines what the new immigration landscape means for social care providers and whether the sector can continue to rely on international recruitment
Until eighteen months ago, hiring an overseas care worker was a process. Now it is barely possible. Care visa applications collapsed from over 18,000 in 2023 to just 900 last December. Sponsor licence revocations doubled. And since April, live payroll data has flowed directly from HM Revenue and Customs to the Home Office. The workforce model the sector spent a decade building has been quietly rewritten.
Three changes did the damage. The previous government restricted care worker dependants in spring 2024. The current government ended overseas recruitment of care workers in July 2025. The Skilled Worker salary threshold rose from £38,700 to £41,700. Applications dropped 51 per cent year on year. The pipeline has not narrowed. It has stopped.
What overseas recruitment can still offer providers is retention, not recruitment. The focus has moved to sponsored workers already in the United Kingdom, and to staff displaced when their previous employer lost a licence. The Home Office actively encourages providers to recruit from this displaced pool. But the same compliance duties apply as for a fresh sponsorship. At A Y & J Solicitors, we see more of these transfers now than ever, often after a compliance problem has already surfaced at the new employer.
Compliance now runs in real time through your payroll. The annual-average defence has gone.
The new enforcement reality
Enforcement has changed in volume and in nature. Between July 2024 and June 2025, the Home Office revoked 1,948 sponsor licences. Across 2025, 3,100 licences were revoked. Adult social care accounted for roughly a third of those. Since 1 April 2026, UK Visas and Immigration has received a live payroll feed from HM Revenue and Customs for every sponsored worker. A single pay period where someone drops below the salary on their Certificate of Sponsorship is now visible without anyone flagging it. Civil penalties for illegal working stand at £45,000 for a first breach and £60,000 for repeat breaches.
In the casework I handle at A Y & J Solicitors, the same patterns repeat. A worker promoted without the Certificate of Sponsorship updated. A payroll run rounding down. A reporting deadline missed because no one knew it applied. None of this feels like wrongdoing to the provider. All of it can trigger a revocation.
Does this mean the sector has become too dependent on overseas recruitment? Yes for many homes, but the dependency has changed shape. Few providers can plan to bring in new overseas care workers. Many still rely heavily on the sponsored staff already on their books. If a licence is revoked, those workers have 60 days to find alternative sponsorship or leave the country. Dependency is now a retention risk, not a recruitment lever.
What providers can do now
Five disciplines protect a sponsor licence from the new enforcement regime:
- Check every sponsored worker’s pay against the rate on their Certificate of Sponsorship in every pay period, not just annually.
- Reconcile the Certificate of Sponsorship against actual hours, role and pay before each pay run.
- Report every change within ten working days. This includes pay, role, work location, absence and resignations.
- Keep right to work checks consistent across the workforce, including British and settled staff. The Home Office audits the whole register.
- Treat ethical recruitment as a compliance issue. Exploitation findings now sit alongside paperwork errors as grounds for revocation.
None of this fixes the staffing crisis on the floor. Vacancies cannot be filled through new overseas care worker visas. They must be filled through domestic recruitment, retention of the sponsored staff already here, and the Skilled Worker route for higher-banded clinical or managerial roles meeting the £41,700 threshold. Pay competitiveness with retail and hospitality is now a workforce issue, not a budget one.
Across the mock audit and revocation defence work we do at A Y & J Solicitors, three things consistently make the difference before the next audit cycle. A mock audit run by an outside team, focused on payroll, reporting and human resources file completeness, surfaces the gaps an inspector will find. Training line managers on what triggers a reporting duty closes the most common failure point. And a review of every Certificate of Sponsorship issued in the last twelve months against the role the worker is actually doing today catches role drift, still a leading reason for revocation.
The model that built the sector will not be the model that sustains it. A realistic future rests on stronger domestic recruitment, fair pay, careful retention of the sponsored workforce already here, and compliance treated as core operations. Providers who accept that the rules have changed permanently, and who invest in compliance as seriously as they invest in care, will protect both their licence and the people who depend on them.
