‘Subject to Action Plan’: the register column most applicants never see
The register of licensed student sponsors has a column called “Immigration Compliance”. For almost every sponsor it is empty. For a few it reads “Subject to Action Plan”. On 27 October 2026 that was true of 12 institutions, holding 14 licences between them. Our own sponsor list left the column out until now. It is the nearest thing the public register has to a warning light, so this is what it means.
What an action plan is
An action plan is a formal step the Home Office takes with a sponsor that has fallen short but is being given the chance to put it right. Its compliance guidance describes two routes to one.
After a failed annual assessment. Every sponsor must apply for a Basic Compliance Assessment every 12 months (2.1). It is measured on three numbers: how many of its applicants are refused visas, how many who get visas actually enrol, and how many complete their course. The result is a red, amber or green rating. A sponsor rated red for the first time “will be placed on an action plan with a minimum duration of 12 months” (paragraph 2.44). Its allocation of CAS for the following year is also cut, by at least 10% of what it used the year before (2.45).
After a breach of sponsor duties. Where a breach is “an isolated issue”, the sponsor is willing and able to correct it and poses no continuing threat to immigration control, the Home Office “will in most cases support the sponsor in making the relevant improvements by issuing an action plan, which sets out the steps that the sponsor must take in order to retain its Student sponsor licence” (3.6). A shorter plan can also be imposed on an amber-rated sponsor with significant recruitment problems (2.70).
The bar was raised in June 2026
For assessments applied for before 1 June 2026, a sponsor had to keep its visa refusal rate under 10%, its enrolment rate at 90% or more and its course completion rate at 85% or more. For assessments applied for from 1 June 2026 the thresholds are a refusal rate under 5% and an enrolment rate of at least 95%, with completion at 85%; from 1 June 2027 completion rises to 90% (2.14). More sponsors will find themselves near the line than before.
Who is on one
| Sponsor type | Institutions subject to an action plan |
|---|---|
| Universities and other higher education institutions | 7 |
| Independent schools | 3 |
| Publicly funded colleges | 2 |
We publish the current list, and the date each flag first appeared in our archive, on the register changes page, where it is updated daily. We do not repeat the names here because an article stays as written while the register moves on: since 30 November 2024 we have seen the flag placed 19 times and lifted 14 times. On the first day of our archive, 4 institutions carried it.
What it means for an applicant
- The sponsor is still licensed. It is on the register and it can issue a CAS. The Rules ask that the CAS comes from a sponsor whose licence is valid when the application is decided; an action plan does not change that.
- It may have fewer CAS to give out. Where the plan follows a red rating, the allocation is reduced. That is a reason not to leave accepting an offer and paying a deposit to the last moment.
- It tells you nothing about teaching. The assessment measures visa refusals, enrolment and completion among sponsored students. A university can be excellent academically and be here because of how one recruitment channel performed.
- It is not permanent, in either direction. Plans are lifted, as the figures above show. But a sponsor rated red is also given a “Final Warning” (2.46), and the plan sets out what it must do to keep its licence.
The sensible response is not to avoid these institutions but to ask a direct question before you commit: is the action plan affecting CAS allocation for my intake, and what are your refund terms if a CAS cannot be issued? A sponsor that answers plainly is giving you useful information.
Sources
- Home Office, Student sponsor guidance: Student sponsor compliance
- Home Office, Register of licensed sponsors: students
- Immigration Rules, Appendix Student
- UK Student Sponsors register archive and change log
This article explains published rules and data. It is not immigration advice, and it cannot tell you how an individual application will be decided. Found an error? Tell us; corrections are recorded in the corrections log.
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