A cooling-off period is the time a UK employer must wait before it can make a successful new application for a sponsor licence. It applies after a refusal, a withdrawn application, a revoked or surrendered licence, certain civil penalties or an unspent conviction. An application made during the wait is automatically refused.
Key points
- After a refusal the usual wait is 6 months. After a first revocation or a surrender during compliance action it is 12 months, and after more than one revocation it is 24 months.
- Civil penalties for employing illegal workers bring a wait of 12 months from when the penalty is paid in full. Some penalties bring 5 years.
- If more than one cooling-off period applies, the longest one applies.
- An application made during the wait is automatically refused, even if the original reason no longer applies.
- When the wait ends the Home Office does not have to grant a licence. The employer must show it fully meets the current rules.
How the cooling-off period works
If an application for a sponsor licence is refused, the employer will not normally be able to make a successful new application until a set time has passed. The guidance calls this the cooling-off period.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version)
The period also normally applies when the employer withdrew an application during checks and the Home Office would likely have refused it, previously held a licence that was revoked, surrendered a licence while the Home Office was taking compliance action, has been issued with certain civil penalties or charges, or has an unspent conviction for a relevant offence.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version)
If the employer applies while a cooling-off period is running, the Home Office automatically refuses the application. This is so even if the reasons that led to the period no longer apply.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version)
How long it lasts
The guidance sets the length according to the circumstances.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version)
| Circumstance | Cooling-off period |
|---|---|
| Application refused for most reasons, or withdrawn when it would have been refused | 6 months from the refusal, or from the date the withdrawal was accepted |
| First revocation, or surrender during compliance action | 12 months from the date of the revocation notice, or from the date the surrender was accepted |
| Licence revoked on more than one occasion | 24 months from the date of the most recent notice |
| Civil penalty for employing an illegal worker, paid in full | 12 months from the date of full payment |
| Civil penalty for carrying clandestine entrants or passengers without proper documents, paid in full | 5 years from the date of full payment |
| Two or more illegal worker penalties, or three or more right to rent penalties on an owner, director or authorising officer | Up to 5 years after payment in full, depending on the facts |
| Unpaid civil penalty or charge still owed after objection and appeal rights end | Indefinite while it is unpaid |
| Unspent conviction for a relevant offence | Until the conviction is spent |
There is no cooling-off period where the application was sent by a representative, or where the employer did not provide requested documents by a deadline for reasons outside its control. There is also none where a licence was revoked solely because the sponsor had no active Level 1 user under the inactive accounts process.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version)
Where more than one period applies, the longest one applies. The guidance gives an example. A sponsor refused for not meeting the route requirements has a 6-month period. If it also paid an illegal working civil penalty in full 10 months ago, the 6-month period governs, because the 12-month penalty period ends in 2 months.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version) See illegal working civil penalty for how those penalties arise.
What happens when the period ends
The end of the wait does not mean a licence will be granted. Before reapplying, the employer must make sure the reasons for the earlier refusal or revocation no longer apply. It must still meet every requirement in the guidance.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version) It pays the correct fee and sends the documents for its route. If the earlier licence was revoked for deception or deliberate misconduct, the Home Office requires compelling evidence that the employer is now suitable.[2]Home Office, Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance (accessible version)
A compliance officer may check the employer again. If the officer is not satisfied, the application is refused and a further cooling-off period applies.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version)
Example
A sponsor’s licence is revoked, and it receives the notice. It cannot apply for a new licence for at least 12 months from the date of that notice.[3]Home Office, UK visa sponsorship for employers: Your licence rating Eleven months later it submits a new application anyway. The Home Office automatically refuses it, even if the sponsor has fixed every problem. The sponsor waits until the 12 months have passed, shows it has dealt with the reasons for revocation and applies again. This time the application is considered like any other.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version)[2]Home Office, Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance (accessible version)
What people get wrong
An early application is not held until the period ends. It is automatically refused, even if the reasons for the original refusal or revocation no longer apply.
The other point is that the period counts from a date in the notice, not from the day the sponsor decides it is ready. Revocation runs from the date of the notice, refusal from the date of the refusal, and a civil penalty from the day it was paid in full.[1]Home Office, Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version)
The bottom line
A cooling-off period is a fixed wait that protects the sponsorship system after a refusal, revocation or penalty. The lengths range from 6 months to 5 years, and the longest one applies. An early application is refused automatically. When the wait ends, the employer must still prove it meets the rules.
Common questions
At least 12 months from the date of the revocation notice. If the licence has been revoked on more than one occasion, it is 24 months from the date of the most recent notice.
Usually 6 months from the date of refusal. There is none if the application was sent by a representative or the sponsor missed a deadline for reasons outside its control, and a few other cases listed in the guidance.
There is no right of appeal against a refused licence application. If a caseworker has applied the period incorrectly, you can send an error correction request within 14 calendar days of the refusal letter.
Only if the Home Office was taking compliance action when you surrendered it. Then it is 12 months, or 24 months if you have been revoked more than once. A surrender at any other time carries no wait.
Sources
We cite the Immigration Rules, legislation and GOV.UK guidance directly. Rules change, so each source shows the date we last checked it.
- Home Office. Workers and Temporary Workers: guidance for sponsors part 1: apply for a licence (accessible version). Checked 11 November 2026. ↩
- Home Office. Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance (accessible version). Checked 11 November 2026. ↩
- Home Office. UK visa sponsorship for employers: Your licence rating. Checked 11 November 2026. ↩