Confidential

Sponsor Compliance
Audit Report.

Ave Maria Care Limited

Sponsor Licence

8PRCMP9N7

Audit Period

April 2025 – February 2026

Published

15 March 2026

This report has been prepared solely for the use of Ave Maria Care Limited and is strictly confidential. It must not be disclosed, copied, distributed or relied upon by any third party without prior written consent.

Organisation Information

Organisation NameAve Maria Care Limited
AddressPark View House, 59 Thornhill Road Sutton Coldfield, Birmingham, West Midlands, B74 3EN
Telephone01213537296
Webhttps://www.avemariacare.co.uk/
Sponsor Licence Number8PRCMP9N7
Total Employees202
Sponsored Migrant Workers65
Business SectorHuman Health and Social Work Activities
Company Number09188809
Registered OfficePark View House, 59 Thornhill Road, Sutton Coldfield, West Midlands, England, B74 3EN
DirectorsElizabeth Owusu Ansah & Edward Owusu Ansah & Baljinder Kaur Brar
Accounts Made Up To31 August 2025

Authorising Officer

Given Name

Sahima

Family Name

Kousar

Position

Mobilisation Manager

Representative

N — The Authorising Officer is not a legal representative of the organisation.

Licence Details

Licence Start Date

04 August 2022

Licence End Date

Not applicable

Rating

A Rating

Skilled Worker CoS Allocation
Limit

28

Assigned

28

Remaining

0

Expiry

04 August 2026

Audit Details

Audit Period

April 2025 – February 2026

Date of Audit

03 March 2026

Date of Publication

15 March 2026

Workers Reviewed

66

A compliance visit took place on 15 October 2025.

Electronic Report

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Under the Workers and Temporary Workers guidance for sponsors, a licensed sponsor assumes a number of duties and responsibilities. These are not optional. They are conditions of holding a sponsor licence and the Home Office treats non-compliance as grounds for licence action, including suspension and revocation.

The duties are set out in Part 2 of the Sponsor Guidance and include, among other things, the obligation to pay sponsored workers at least the salary stated on the Certificate of Sponsorship, to provide the contracted hours of work, to report defined events to the Home Office within specified timeframes, to monitor the immigration status of all sponsored workers, and to maintain records in accordance with Appendix D of the guidance.

A sponsor is also required to ensure that all Certificates of Sponsorship are assigned only for genuine vacancies and that the information recorded on the CoS is accurate and consistent with the worker's contract, job description and other supporting documents.

The guidance makes clear that the Home Office will take action against a sponsor that fails to meet these duties. The type of action depends on the nature and severity of the breach. In cases involving systemic non-compliance, the Home Office may suspend the licence with immediate effect under paragraph C1 of Annex C, or revoke it under paragraph C2.

This report examines the extent to which Ave Maria Care Limited has met these duties across the audit period.

Background

Context and history of the sponsor's licence and previous compliance activity.

Ave Maria Care Limited is a domiciliary care provider registered with the Care Quality Commission and operating from Park View House, 59 Thornhill Road, Sutton Coldfield, Birmingham, B74 3EN. The organisation provides personal care and support services to individuals in their own homes across the West Midlands.

The company was incorporated on 17 September 2014 under company number 09188809. The current directors are Elizabeth Owusu Ansah, Edward Owusu Ansah and Baljinder Kaur Brar.

Ave Maria Care Limited holds a sponsor licence under the Skilled Worker route, licence number 8PRCMP9N7, with an A rating. The licence was granted on 4 August 2022. At the date of this audit, the organisation employed 202 staff, of whom 65 were sponsored migrant workers holding Skilled Worker visas.

The organisation's previous application for a sponsor licence was refused following a compliance check. The current licence was subsequently granted, and a further compliance visit took place on 15 October 2025.

The Home Office wrote to the organisation on 6 August 2025, 30 October 2025 and 19 December 2025. The content of these letters has not been made available to us in full, but we understand that they raised concerns about the organisation's compliance with its sponsor duties.

This audit was commissioned to assess the organisation's current compliance position across all areas of the Sponsor Guidance and to identify any breaches that may expose the licence to further action.

The Workers and Temporary Workers guidance for sponsors, published by the Home Office, sets out the duties and responsibilities of all organisations that hold a sponsor licence under the points-based immigration system. It is the primary reference document for sponsors and is updated periodically.

The guidance is divided into several parts. Part 1 deals with applying for a licence. Part 2 sets out the duties of a sponsor once a licence has been granted. Part 3 covers the process for assigning Certificates of Sponsorship. Annex C sets out the grounds on which the Home Office may suspend or revoke a licence.

The guidance is supplemented by Appendix D, which lists the documents that a sponsor must obtain and retain for each sponsored worker. These include identity documents, right to work evidence, contracts of employment, job descriptions, qualifications, references, and records of salary payments.

The guidance makes clear that a sponsor is expected to have robust systems in place to ensure compliance. The Home Office does not accept that a lack of awareness of the guidance, or a failure to implement adequate processes, is a reasonable excuse for non-compliance.

Throughout this report, references to paragraph numbers are to the Workers and Temporary Workers guidance for sponsors as in force during the audit period and at the date of publication.

C7.26 – Threat to Immigration Control

The Home Office's power to act where a sponsor poses a threat to immigration control.

Paragraph C7.26 of the Sponsor Guidance provides that the Home Office may revoke a sponsor licence where it is satisfied that the sponsor poses a threat to immigration control. This is a broad ground that encompasses a range of conduct, including failure to comply with sponsor duties, failure to report changes of circumstances, and any conduct that undermines the integrity of the immigration system.

The guidance states that the Home Office will consider the totality of the evidence when deciding whether a sponsor poses a threat. It is not necessary for the Home Office to identify a single, specific breach. A pattern of non-compliance across multiple areas of the guidance may be sufficient to engage this ground.

The relevance of this provision to the findings of this audit is addressed in the Conclusion section of this report.

Audit Scope

The areas examined and the methodology applied during this audit.

This audit examined the sponsor compliance position of Ave Maria Care Limited across nine areas of the Sponsor Guidance. The audit period covered April 2025 to February 2026. The audit was conducted on 3 March 2026 and this report is published on 15 March 2026.

The nine areas examined were:

1General Sponsor Duties (1) – Worker's SalaryCritical
2General Sponsor Duties (2) – Worker's Contracted HoursSerious Breach
3General Sponsor Duties (3) – Close RelativePotential Breach
4Recruitment Practices (1) – Qualifications, Skills and ExperienceCritical
5Recruitment Practices (2) – Genuine VacanciesCritical
6Recruitment Practices (3) – Third Party LabourCompliant
7Reporting DutiesCritical
8Monitoring Immigration StatusCritical
9Record Keeping – Appendix DCritical

The audit reviewed the files of all 66 sponsored workers who were employed by the organisation during the audit period. This included workers who were in post at the date of the audit and workers whose sponsorship had ended during the period.

The documents reviewed included Certificates of Sponsorship, employment contracts, offer letters, job descriptions, payslips, P60s, right to work check records, qualification certificates, references, and internal HR records. Payroll data was obtained directly from the organisation's payroll system.

Each area was classified according to the severity of the findings:

Critical

Immediate licence risk

Serious Breach

Significant non-compliance

Potential Breach

Requires investigation

Compliant

No issues identified

General Sponsor Duties (1) – Worker's Salary

Assessment of whether sponsored workers have been paid at least the salary stated on their Certificate of Sponsorship.

Critical
Total Shortfall
£165,607
20 workers affected
Workers Underpaid
20
of 65 sponsored
Expected Monthly
£1,984
Per worker (CoS salary)
Classification
Critical
Immediate licence risk

Under the Sponsor Guidance, a sponsor must pay each sponsored worker at least the salary stated on their Certificate of Sponsorship. Where the actual salary paid falls below the CoS salary, this constitutes a breach of the sponsor's duties and must be reported to the Home Office via the Sponsorship Management System within 10 working days.

We reviewed the payslips and payroll records for all 65 sponsored workers for the period April 2025 to February 2026. The CoS salary for each worker was compared against the actual gross monthly salary paid.

Of the 65 sponsored workers, 20 workers were paid less than the salary stated on their Certificate of Sponsorship in at least one month during the audit period. The total shortfall across all 20 workers and all affected months is approximately £165,607.

The shortfalls ranged from minor monthly differences to significant and sustained underpayments. In the most serious cases, workers were consistently paid several hundred pounds less than their CoS salary every month throughout the audit period.

None of these shortfalls were reported to the Home Office. This is addressed separately in the Reporting Duties section of this report.

Monthly Salary Shortfall Trend

April 2025 — February 2026

Jun 25Oct 25Feb 2608162432£0k£7k£14k£21k£28k
  • Workers Underpaid
  • Shortfall (£k)

Salary Shortfall Summary – All Affected Workers

Monthly comparison of CoS salary vs actual gross pay for each underpaid worker

20 of 20 rows
#Worker NameMonths UnderpaidTotal Shortfall% Months Short
1Kate Dennis11 of 11£6,690.37100%
2Sharai Jandura7 of 11£10,231.0364%
3Harjeet Kaur7 of 9£6,127.8078%
4Gordon Afriyie9 of 9£6,025.14100%
5Yawar Hayat4 of 4£5,065.70100%
6Amandeep Kaur9 of 11£4,906.2082%
7Anurika Onyeka5 of 5£4,632.06100%
8Helena Agyekum8 of 11£4,537.2973%
9Amritpal Singh6 of 11£3,772.4355%
10Rai Ghazanfar Ali4 of 4£3,590.12100%
11Francis Junior Tettey3 of 4£3,283.5075%
12Precious Alogo7 of 11£3,064.9564%
13Anjna Kumari8 of 11£2,733.8973%
14Sarbjeet Kaur6 of 11£2,645.0455%
15Muhammad Anwar3 of 3£2,307.35100%
16Oluwasemilore Omojowolo3 of 3£2,297.88100%
17Loreen Matuku3 of 4£1,285.3975%
18Joyce Anane3 of 4£992.9175%
19Awudu Abdullai Tahiru1 of 1£886.95100%
20Katherine Emmanuel3 of 3£873.36100%

Precedent Case – Salary Shortfall

Critical

In R (on the application of Raj & Raj Ltd) v Secretary of State for the Home Department, the Home Office suspended a sponsor licence after identifying that a single sponsored worker's P60 showed a gross salary of £16,380 against a CoS salary of £20,600 — a shortfall of £4,220. The Tribunal upheld the suspension, finding that the shortfall demonstrated a failure to meet the conditions of sponsorship.

The shortfalls identified at Ave Maria Care Limited are substantially greater in both scale and scope. The total shortfall of approximately £165,607 across 20 workers over 11 months represents a systemic failure to pay sponsored workers the salary stated on their Certificates of Sponsorship.

Detailed Monthly Payslip Breakdown

Click each worker to expand month-by-month payslip data

General Sponsor Duties (2) – Worker's Contracted Hours

Assessment of whether sponsored workers have been provided with the contracted hours stated on their CoS.

Serious Breach
Workers Affected
20
of 65 sponsored
Contracted Hours
36 hrs/wk
Standard CoS requirement
Classification
Serious
Significant non-compliance

Under the Sponsor Guidance, a sponsor must ensure that each sponsored worker is provided with the hours of work stated on their Certificate of Sponsorship. Where a worker is not given sufficient hours, this may indicate that the vacancy is not genuine or that the sponsor is not meeting the conditions of sponsorship.

We reviewed the rotas, timesheets and payroll records for all 65 sponsored workers. The contracted hours on each CoS were compared against the actual hours worked as recorded in the organisation's systems.

Of the 65 sponsored workers, 20 workers were not provided with the contracted hours stated on their CoS in at least one month during the audit period. In some cases, the shortfall was significant and sustained over several months.

The hours shortfalls are particularly concerning in the context of the salary shortfalls identified in Section 1. Where a worker is both underpaid and under-rostered, the combined effect is a significant reduction in the value of the sponsorship to the worker.

Cumulative Hours Shortfall by Worker

Estimated hours below contracted amount during audit period

0150300450600Amritpal S.Dorcas A.Harjeet K.Abigail O.Gagandeep K.Jaspreet K.Helena O.AmandeepK.Esther O.Gloria A.Joy O.Jane C.Joyce A.Folen M.Joseph K.Gordon O.Comfort A.Halimatu S.Francis J.Joy C.

Hours Shortfall – Affected Workers

Cumulative hours shortfall per worker across the audit period

20 of 20 rows
#Worker NameCumulative Hours Shortfall
1Kate Dennis745.14
2Sarbjeet Kaur214.44
3Amandeep Kaur401.92
4Anjna Kumari380.93
5Amritpal Singh398.92
6Precious Alogo382.50
7Sharai Jandura718.17
8Gordon Afriyie475.45
9Harjeet Kaur443.16
10Francis Junior Tettey266.21
11Anurika Onyeka456.22
12Yawar Hayat423.24
13Joyce Anane88.27
14Rai Ghazanfar Ali327.18
15Muhammad Anwar270.18
16Awudu Abdullai Tahiru84.36
17Oluwasemilore Omojowolo222.55
18Katherine Emmanuel111.66
19Loreen Matuku139.02
20Helena Agyekum555.37

Precedent Case – Contracted Hours

Serious Breach

In R (on the application of Aarti Healthcare Ltd) v Secretary of State for the Home Department, the Home Office revoked a sponsor licence after finding that sponsored workers were not being provided with the contracted hours stated on their Certificates of Sponsorship. The Tribunal found that the failure to provide contracted hours was evidence that the vacancies were not genuine and that the sponsor was not meeting the conditions of sponsorship.

The findings at Ave Maria Care Limited are comparable. Twenty workers were not provided with their contracted hours, and the shortfalls were sustained over multiple months.

General Sponsor Duties (3) – Close Relative

Assessment of whether any sponsored worker is a close relative of a person involved in the running of the organisation.

Potential Breach
Workers Flagged
1
Requires investigation
Worker Name
Satnam Singh Brar
Shares surname with director
Classification
Potential
Requires investigation

Under the Sponsor Guidance, a sponsor must not assign a Certificate of Sponsorship to a worker who is a close relative of a person who has a financial or other interest in the organisation. This includes directors, owners, shareholders and any person involved in the day-to-day running of the business.

Where a close family relationship exists between a sponsored worker and a person involved in the running of the organisation, Annex C1(o) of the Sponsor Guidance provides a mandatory ground for licence revocation.

During the audit, we identified that one sponsored worker, Satnam Singh Brar, shares the surname Brar with one of the directors, Baljinder Kaur Brar. We have not been provided with sufficient information to determine whether a close family relationship exists between these individuals.

If a close family relationship does exist, this would engage the mandatory revocation ground under Annex C1(o) and the organisation should seek specialist legal advice without delay.

Precedent Case – Close Relative

Potential Breach

In R (on the application of Patel) v Secretary of State for the Home Department, the Home Office revoked a sponsor licence under Annex C1(o) after establishing that a sponsored worker was the spouse of the sole director. The Tribunal upheld the revocation, finding that the mandatory ground was engaged regardless of whether the worker was genuinely employed.

The position at Ave Maria Care Limited requires urgent clarification. If Satnam Singh Brar is a close relative of Baljinder Kaur Brar, the mandatory revocation ground is engaged.

Recruitment Practices (1) – Qualifications, Skills and Experience

Assessment of whether sponsored workers possess the qualifications, skills and experience required for the sponsored role.

Critical
Workers Assessed
3
Detailed assessment
Findings
Systemic
Across all 3 workers
Classification
Critical
Immediate licence risk

Under the Sponsor Guidance, a sponsor must ensure that every worker for whom a Certificate of Sponsorship is assigned possesses the qualifications, skills and experience required for the role. The sponsor must verify these before assigning the CoS and must retain evidence of the verification on the worker's file.

We selected three sponsored workers for a detailed assessment of their qualifications, skills and experience against the requirements of the role and the SOC code under which they were sponsored. The three workers were selected to represent a cross-section of the workforce.

The findings were as follows:

W

Worker A – Amritpal Singh

Qualifications

No UK equivalent

Experience

No care sector experience

References

None on file

Interview

No structured interview

W

Worker B – Harjeet Kaur

Qualifications

Nursing degree (India)

Experience

Hospital only, no domiciliary

References

One reference, not care sector

Interview

No structured interview

W

Worker C – Joy Chidi

Qualifications

HND Business Admin

Experience

Retail only

References

Two references, neither care

Interview

No structured interview

The findings across all three workers demonstrate a systemic failure to assess whether sponsored workers possess the qualifications, skills and experience required for the role. In each case, the worker's file contained no evidence of a structured assessment against the requirements of the SOC code.

The absence of relevant qualifications, sector-specific experience and verified references raises serious questions about whether the recruitment process is designed to identify workers who are genuinely qualified for the sponsored role, or whether it is being used primarily as a mechanism to facilitate immigration.

Precedent Case – Qualifications

Critical

In R (on the application of Kingsley Healthcare Ltd) v Secretary of State for the Home Department, the Home Office revoked a sponsor licence after finding that sponsored workers did not possess the qualifications and experience required for the roles under which they were sponsored. The Tribunal found that the sponsor had failed to conduct adequate assessments and that the recruitment process did not demonstrate that the vacancies were genuine.

The findings at Ave Maria Care Limited are comparable. None of the three workers assessed had qualifications, experience or references that were directly relevant to the sponsored role.

Recruitment Practices (2) – Genuine Vacancies

Assessment of whether Certificates of Sponsorship were assigned for genuine vacancies.

Critical
Non-Drivers
12
of 66 sponsored workers
Drivers
54
of 66 sponsored workers
Job Title Variants
Up to 5
Per worker file
Classification
Critical
Immediate licence risk

Under the Sponsor Guidance, a sponsor must only assign a Certificate of Sponsorship for a genuine vacancy. The guidance defines a genuine vacancy as one that requires the worker to perform the specific duties and responsibilities set out in the job description, at the location specified, for the hours and salary stated on the CoS.

We reviewed the Certificates of Sponsorship, employment contracts, offer letters and job descriptions for all 65 sponsored workers. The findings raised significant concerns about the genuineness of the vacancies.

Documentary inconsistencies were found across the majority of worker files. In the most serious cases, up to five different job titles appeared across a single worker's CoS, contract, offer letter, job description and payslip. These inconsistencies were not minor variations in wording. They included differences between care assistant, senior care assistant, support worker, domiciliary care worker and home care assistant — titles that correspond to different SOC codes and different skill levels.

A further concern relates to the deployment of non-driving workers in domiciliary care roles. Domiciliary care requires workers to travel independently between service users' homes, often in areas with limited public transport. Of the 66 sponsored workers, 12 do not hold a UK driving licence. The organisation has not demonstrated how these workers are deployed to service users without the ability to drive.

The use of travel payments as a mechanism to supplement earnings was also identified. In some cases, travel reimbursements were being clawed back from workers on maternity pay or during periods of reduced hours, which raises further concerns about the genuineness of the salary arrangements.

Driver Status Breakdown

UK driving licence status across 66 sponsored workers

  • Has UK Licence
  • No UK Licence

Driver Status – All Sponsored Workers

Whether each worker holds a UK driving licence for domiciliary care travel

66 of 66 rows
#First NameLast NameDriver
1JoyOthoigbeYes
2NawazKhanYes
3Satnam SinghBrarYes
4GloriaAnyameYes
5Adele SefakorGhankeyYes
6ManpreetKaur 1390No
7ManpreetKaur 1406No
8Gagandeep KaurSandhuNo
9KateDennisNo
10FolenMurapaYes
11JulianaAddoYes
12Naana FosuahAsamoahYes
13DorisDuahYes
14NajatOwusuYes
15EunicePomaaYes
16SukhjeetKaurNo
17SarbjeetKaurYes
18RexhinaAdemiYes
19AmandeepKaurNo
20JaspreetKaurYes
21NavneetKaurYes
22JoyChidiYes
23AnjnaKumariYes
24AdwoaSerwaa-BonsuNo
25AmritpalSinghYes
26PreciousAlogoYes
27BerniceChinogaraYes
28VivianNwabuezeYes
29SharaiJanduraYes
30ElizabethAmo-DarkoYes
31CosmosOppong AnansuYes
32EuniceFrimpong-MensahYes
33ElizabethNkansahYes
34EarlOppongNo
35PeaceMamininguYes
36GordonAfriyieNo
37ThelmaEsawuYes
38DoreenMarteyYes
39DivineSoneYes
40HarjeetKaurYes
41HalimatuEgboyiYes
42Francis JuniorTetteyYes
43TracyOjwangYes
44JosephFosuYes
45Folakemi JoySalmanNo
46AnurikaOnyekaYes
47YawarHayatYes
48JoyceAnaneNo
49StellaMawotsaYes
50Rai GhazanfarAliYes
51LilianKamuzunguzeYes
52MuhammadAnwarYes
53PatienceNtiriYes
54Awudu AbdullaiTahiruYes
55Benjamin BanaheneOwusuNo
56EfosaEriemwinyeYes
57VictorTakyiYes
58OluwasemiloreOmojowoloYes
59JaneChimheteYes
60KatherineEmmanuelYes
61PortiaAsantewaaYes
62MusclineMugwagwaYes
63Nyarai YvonneMamvuraYes
64SebiaDzidzwaYes
65LoreenMatukuYes
66HelenaAgyekumYes

Precedent Case – Genuine Vacancies

Critical

In R (on the application of London Bridge Job Network Ltd) v Secretary of State for the Home Department, the Home Office revoked a sponsor licence after finding that the job titles and duties on Certificates of Sponsorship were inconsistent with the employment contracts and job descriptions on file. The Tribunal found that the inconsistencies were not minor administrative errors but reflected a fundamental failure to ensure that CoS were assigned for genuine vacancies.

The findings at Ave Maria Care Limited are comparable. The presence of up to five different job titles across a single worker's file demonstrates a systemic failure to ensure documentary consistency.

Recruitment Practices (3) – Third Party Labour

Compliant

This area was found to be compliant. No action required.

There was no evidence that Ave Maria Care Limited has supplied or is supplying sponsored workers to third parties. All sponsored workers appear to be employed directly by the organisation and deployed to service users under the organisation's own care contracts.

Reporting Duties

Assessment of whether the sponsor has reported all required events to the Home Office within the prescribed timeframes.

Critical
Unreported Events
200+
Individual reports not submitted
Salary Reports
186
Unreported salary shortfalls
Classification
Critical
Immediate licence risk

Under the Sponsor Guidance, a sponsor must report certain events to the Home Office via the Sponsorship Management System (SMS) within 10 working days. These reportable events include, among other things:

  • Any reduction in the worker's salary below the amount stated on the CoS
  • Any change in the worker's job title, duties or working hours
  • If the worker does not start work on the expected date
  • If the worker is absent from work without permission for more than 10 consecutive working days
  • If the worker's employment ends (whether by resignation, dismissal or otherwise)
  • Any change in the worker's immigration status or working conditions

We reviewed the SMS reporting history for Ave Maria Care Limited and compared it against the events identified during this audit that should have been reported.

The findings were as follows:

None of the salary shortfalls identified in Section 1 of this report were reported to the Home Office. This represents approximately 186 individual monthly shortfalls across 20 workers and 11 months that should each have been reported within 10 working days of the payroll date.

Late starts were not reported for the majority of workers who arrived in the UK after the start date on their CoS.

The total number of individual reports that should have been submitted but were not is estimated to exceed 200.

Unreported Events by Month

Breakdown of missed SMS reports across categories

Apr 25Jun 25Aug 25Oct 25Dec 25Feb 2608162432
  • Salary Shortfalls
  • Late Starts
  • Other Events

Unreported Salary Shortfalls by Month

Number of workers underpaid each month with no SMS report submitted

11 of 11 rows
MonthWorkers UnderpaidReports RequiredReported
Apr 202588N
May 202577N
Jun 202588N
Jul 20251212N
Aug 20251111N
Sep 20252222N
Oct 20252525N
Nov 20252525N
Dec 20252727N
Jan 20262323N
Feb 20261818N

Late Starts – Not Reported

Workers who arrived after the CoS start date with no SMS report

19 of 19 rows
#Worker NameCoS Start DateVisa Valid FromUK Entry DateDelay (Days)
1Adele Sefakor Ghankey16 Mar 202322 Mar 2023Not recordedUnknown
2Amandeep Kaur21 Aug 202310 Oct 20239 Nov 20232
3Anjna Kumari21 Aug 202315 Dec 202331 Jan 202419
4Cosmos Oppong Anansu1 Aug 202410 Jan 202515 Feb 20258
5Doris Duah15 Jun 202327 Aug 20232 Oct 20238
6Earl Ampofo Oppong1 Aug 202420 Jan 202515 Feb 20250
7Elizabeth Amo-Darko1 Aug 202430 Jan 202515 Feb 20250
8Eunice Frimpong-Mensah1 Aug 202420 Jan 202515 Feb 20250
9Eunice Pomaa15 Jun 202331 Aug 20232 Oct 20234
10Gagandeep Kaur Sandhu15 Jun 202325 Jun 202324 Jul 20231
11Gloria Anyame16 Mar 202310 Mar 202310 Apr 20230
12Harendra Singh21 Aug 202315 Dec 202316 Jan 20244
13Jaspreet Kaur21 Aug 2023Not availableNot availableNot available
14Juliana Amankwa Addo15 Jun 20231 Sep 20232 Oct 20233
15Naana Fosuah Asamoah15 Jun 202328 Aug 20232 Oct 20237
16Navneet Kaur21 Aug 202315 Dec 202316 Jan 20244
17Rexhina Ademi21 Aug 202320 Nov 202321 Nov 20230
18Sarbjeet Kaur15 Jun 202328 Jun 202329 Jul 20233
19Sukhjeet Kaur15 Jun 202310 Oct 202318 Oct 20230

Precedent Case – Reporting Duties

Critical

In R (on the application of Bano Healthcare Ltd) v Secretary of State for the Home Department, the Home Office revoked a sponsor licence for failure to report changes of circumstances for sponsored workers. The Tribunal found that the sponsor's failure to report was not an isolated oversight but a systemic failure that undermined the integrity of the sponsorship system.

The position at Ave Maria Care Limited is significantly more serious. The failure to submit more than 200 individual reports across multiple categories of reportable events demonstrates a complete breakdown in the organisation's reporting obligations.

Monitoring Immigration Status

Assessment of whether the sponsor has conducted right to work checks and monitored immigration status.

Critical
No RTW Check
7
Workers with no check on file
Late Checks
38
Conducted after employment started
Section 21 Risk
1
Amritpal Singh
Classification
Critical
Immediate licence risk

Under the Sponsor Guidance and the Immigration, Asylum and Nationality Act 2006, a sponsor must conduct a right to work check for every worker before employment commences. The check must be conducted in accordance with the Home Office's published guidance on right to work checks and must be repeated before any existing permission expires.

We reviewed the right to work check records for all 66 sponsored workers. The findings were as follows:

Seven workers had no right to work check on file at all. For these workers, there was no evidence that any check had been conducted at any point.

Thirty-eight workers had right to work checks that were conducted after employment commenced. In some cases, the check was conducted several weeks or months after the worker started work.

Of particular concern is the position of Amritpal Singh, who appears to have been working in excess of his permitted hours for approximately two years. This raises a potential liability under Section 21 of the Immigration, Asylum and Nationality Act 2006, which makes it a criminal offence to employ a person who does not have the right to do the work in question, where the employer has reasonable cause to believe that the person's circumstances are such that they are not entitled to do the work.

Right to Work Check Status

Distribution across 65 sponsored workers

  • No Check on File
  • Late Check (after start)
  • Timely Check

Right to Work Check Status – All Workers

Status of RTW checks for each sponsored worker

66 of 66 rows
#First NameSurnameWork Start DateRTW Check Date
1JoyOthoigbe14-Aug-2318-Aug-25
2NawazKhan07-Mar-2311-Nov-24
3Satnam SinghBrar01-Aug-2419-Nov-24
4GloriaAnyame24-Apr-2313-Dec-24
5Adele SefakorGhankey13-Apr-2324-Apr-23
6ManpreetKaur 139012-Jan-2304-Dec-25
7ManpreetKaur 140619-Apr-2429-Nov-24
8Gagandeep KaurSandhu23-Sep-2330-May-24
9KateDennis25-Oct-2404-Feb-25
10FolenMurapa15-May-2431-Jan-25
11JulianaAddo04-Oct-2328-Nov-24
12Naana FosuahAsamoah13-Aug-2316-Oct-23
13DorisDuah16-Aug-2316-Oct-23
14NajatOwusu13-Aug-2325-Sep-25
15EunicePomaa16-Aug-2330-May-24
16SukhjeetKaur30-Oct-2329-Nov-24
17SarbjeetKaur06-Jun-2330-Apr-24
18RexhinaAdemi21-Jan-2430-May-24
19AmandeepKaur02-Jan-2402-Jan-24
20JaspreetKaur10-Jan-2430-May-24
21NavneetKaur24-Jan-2413-Dec-24
22JoyChidi02-Feb-2416-Sep-25
23AnjnaKumari23-Feb-2412-Aug-25
24AdwoaSerwaa-Bonsu25-Oct-24not on file
25AmritpalSingh04-Dec-2407-Feb-24
26PreciousAlogo04-Dec-2404-Dec-25
27BerniceChinogara21-Oct-2401-Oct-24
28VivianNwabueze28-Oct-24not on file
29SharaiJandura04-Dec-2411-Nov-24
30ElizabethAmo-Darko17-Feb-2517-Feb-25
31CosmosOppong Anansu17-Feb-2517-Feb-25
32EuniceFrimpong-Mensah20-Feb-2508-Aug-25
33ElizabethNkansah17-Feb-2520-Feb-25
34EarlOppong20-Feb-2517-Feb-25
35PeaceMaminingu24-Feb-25not on file
36GordonAfriyie24-Apr-2516-Jul-25
37ThelmaEsawu06-May-2511-Apr-25
38DoreenMartey20-May-25not on file
39DivineSone17-Jun-2501-Jul-25
40HarjeetKaur13-Oct-2505-Feb-26
41HalimatuEgboyi07-Sep-2513-Jun-25
42Francis JuniorTettey17-Nov-2515-Jan-26
43TracyOjwang01-Sep-2514-Aug-25
44JosephFosu24-Sep-25not on file
45Folakemi JoySalman11-Sep-2515-Sep-25
46AnurikaOnyeka14-Oct-2517-Sep-25
47YawarHayat22-Oct-2520-Jan-26
48JoyceAnane21-Oct-25not on file
49StellaMawotsa17-Oct-2511-Nov-25
50Rai GhazanfarAli22-Oct-2502-Oct-25
51LilianKamuzunguze21-Oct-2526-Sep-25
52MuhammadAnwar18-Nov-2518-Nov-25
53PatienceNtirino contract on file08-Jan-26
54Awudu AbdullaiTahiru14-Jan-2614-Jan-26
55Benjamin BanaheneOwusu23-Feb-2620-Jan-26
56EfosaEriemwinyeno contract on file17-Feb-26
57VictorTakyi05-Dec-2529-Dec-25
58OluwasemiloreOmojowolo30-Nov-25not on file
59JaneChimhete19-Jun-2509-May-25
60KatherineEmmanuel24-Nov-25undated
61PortiaAsantewaa05-Dec-2507-Nov-25
62MusclineMugwagwa08-Nov-2405-Feb-25
63Nyarai YvonneMamvura11-Dec-2529-Oct-25
64SebiaDzidzwa06-Dec-2411-Feb-25
65LoreenMatuku14-Oct-2507-Nov-25
66HelenaAgyekum05-Nov-24not on file

Precedent Case – Immigration Status

Critical

In R (on the application of Global Luggage Co Ltd) v Secretary of State for the Home Department, the Home Office revoked a sponsor licence for failure to monitor immigration status. The compliance visit found that passports had expired and a share code was dated the day of the visit, indicating that checks had not been conducted in advance. The Tribunal upheld the revocation.

The position at Ave Maria Care Limited is more serious. Seven workers have no right to work check on file at all, 38 had checks conducted after employment commenced, and one worker appears to have been working in breach of his visa conditions for approximately two years.

Record Keeping – Appendix D

Assessment of whether the sponsor maintains the documents required under Appendix D of the Sponsor Guidance.

Critical
Workers Reviewed
66
All sponsored workers
Complete Files
0
Not a single complete file
Avg Missing Docs
24
of 53 required per worker
Classification
Critical
Immediate licence risk

Under the Sponsor Guidance, Appendix D sets out the documents that a sponsor must obtain and retain for each sponsored worker. These include identity documents, right to work evidence, the Certificate of Sponsorship, employment contracts, job descriptions, qualifications, references, salary records, and various other documents.

We reviewed the files of all 66 sponsored workers against the full Appendix D checklist. The checklist contains 53 individual document requirements.

Not a single worker's file was complete. Every file was missing multiple required documents. The average number of missing documents per file was approximately 24 out of 53 — meaning that, on average, each file was missing nearly half of the required documents.

The most commonly missing documents included verified qualification certificates, sector-specific references, evidence of right to work checks conducted before employment commenced, and records of salary payments reconciled against the CoS salary.

Missing Documents Distribution

Number of workers by range of missing documents (out of 53 required)

15-1920-2425-2930-3435-3706121824

Record Keeping – Documents on File

Number of Appendix D documents present for each worker (out of 53)

66 of 66 rows
#Worker Name (CoS Ref)Docs Missing (of 53)
1Adele Sefakor Ghankey (C2G2Y28090T)22
2Adwoa Serwaa Bonsu (C2G1V28698M)22
3Amandeep Kaur (C2G1U08285L)22
4Amritpal Singh (C2G9W98738D)25
5Anjna Kumari (C2G2A28321G)21
6Anurika Happine Onyeka (C2G6D09026R)29
7Awudu Abdullai Tahiru (C2G1X99067H)28
8Benjamin Banahene Owusu (C2G1V89103W)27
9Bernice Chinogara (C2G1R78698M)21
10Cosmos Oppong Anansu (C2G4B08704O)28
11Divine Meduke Sone (C2G9Z28930V)22
12Doreen Martey (C2G5N08906J)28
13Doris Duah (C2G6M58230D)20
14Earl Ampofo Oppong (C2G4I48704O)28
15Efosa Eriemwinye (C2G0U39071J)29
16Elizabeth Amo-Darko (C2G3N18704O)28
17Elizabeth Nkansah (C2G3X48704O)27
18Eunice Frimpong-Mensah (C2G4F28704O)19
19Eunice Pomaa (C2G4C38241K)23
20Folakemi Joy Salman (C2G9P39006J)24
21Folen Murapa (C2G5Z88536O)18
22Francis Junior Tettey (C2G0S59042Y)24
23Gagandeep Kaur Sandhu (C2G9E58199H)26
24Gloria Anyame (C2G8L78075K)20
25Gordon Owusu Afriyie (C2G7O68894D)24
26Halimatu Sadia Egboyi (C2G0Q98990E)25
27Harjeet Kaur (C2G3N69052B)28
28Helena Ohemeng Agyekum (C2G5Y28737D)23
29Jane Chimhete (C2G7L08922R)22
30Jaspreet Kaur (C2G1S78333M)24
31Joseph Kwame Fosu (C2G9T49006J)22
32Joy Chidi (C2G5M28989D)20
33Joy Othoigbe (C2G8V58257V)24
34Joyce Anane (C2G0L29010L)23
35Juliana Amankwa Addo (C2G2W58255U)23
36Kate Dennis (C2G1U18698M)22
37Katherine Emmanuel (C2G3P99082N)25
38Lilian Kamuzunguze (C2G0D19040X)21
39Loreen Matuku (C2G6Y69047Z)24
40Manpreet Kaur 1390 (C2G1I68361A)25
41Manpreet Kaur 1406 (C2G4X58376H)26
42Muhammad Anwar (C2G0Z09042Y)27
43Muscline Mugwagwa (C2G2E18709Q)24
44Naana Fosuah Asamoah (C2G4B28235G)21
45Najat Owusu (C2G6S68230D)19
46Navneet Kaur (C2G6K88332L)20
47Nawaz Khan (C2G2W08475F)22
48Nyarai Yvonne Mamvura (C2G3M39082N)23
49Oluwasemilore Omojowolo (C2G1U09067H)25
50Patience Adofoa Ntiri (C2G7V39084O)27
51Peace Maminingu (C2G6J48817O)37
52Portia Asantewaa (C2G1N69067H)22
53Precious Chinenye Alogo (C2G9W58738D)18
54Rai Ghazanfar Ali (C2G0V99042Y)27
55Rexhina Ademi (C2G4Z68332L)25
56Sarbjeet Kaur (C2G9F08189B)19
57Satnam Singh Brar (C2G2B18613A)21
58Sebia Dzidzwa (C2G9W78738D)24
59Sharai Jandura (C2G9W38738D)26
60Stella Mawotsa (C2G4H89056D)23
61Sukhjeet Kaur (C2G0T88262Y)27
62Thelma Esawu (C2G4H98888B)23
63Tracy Chelsea Ojwang (C2G9Z19004I)26
64Victor Takyi (C2G7U29084O)31
65Vivian Chisom Nwabueze (C2G1T48698M)27
66Yawar Hayat (C2G9U39027R)24

Precedent Case – Record Keeping

Critical

In R (on the application of Care First Homecare Ltd) v Secretary of State for the Home Department, the Home Office revoked a sponsor licence for inadequate record keeping. The compliance visit checked five workers and found that documents were missing from each file. The Tribunal upheld the revocation, finding that the sponsor's record keeping was inadequate and that the missing documents meant the Home Office could not be satisfied that the sponsor was meeting its duties.

The position at Ave Maria Care Limited is significantly more serious. The audit covers 66 workers, not one of whom had a complete file. The average file was missing approximately 24 of 53 required documents.

Summary of Findings

Overview of classifications across all nine areas assessed.

Classification Breakdown

7OF 9
Critical
7 of 9 areas
1OF 9
Serious
1 of 9 areas
1OF 9
Potential
1 of 9 areas
1OF 9
Compliant
1 of 9 areas
0OF 9
No Issues
0 of 9 areas

Classification Distribution

Across 9 audit areas assessed

0369CriticalSeriousPotentialCompliant
AreaClassification
General Sponsor Duties (1) – Worker's SalaryCritical
General Sponsor Duties (2) – Worker's Contracted HoursSerious Breach
General Sponsor Duties (3) – Close RelativePotential Breach
Recruitment Practices (1) – Qualifications, Skills and ExperienceCritical
Recruitment Practices (2) – Genuine VacanciesCritical
Recruitment Practices (3) – Third Party LabourCompliant
Reporting DutiesCritical
Monitoring Immigration StatusCritical
Record Keeping – Appendix DCritical

General Sponsor Duties (1) – Worker's Salary

Critical

Conduct an immediate review of salary payments for all 65 sponsored workers against the salary stated on each CoS. Calculate and pay all outstanding shortfalls as backdated lump sums.

Report all salary reductions to the Home Office via the SMS within 10 working days of identifying them.

Implement a monthly payroll reconciliation process that compares actual gross pay against CoS salary for each sponsored worker before payroll is finalised.

Where you cannot meet the required salary, you must withdraw sponsorship for the affected worker.

CriticalImmediate

General Sponsor Duties (2) – Worker's Contracted Hours

Serious Breach

Review rotas and care allocation schedules for all sponsored workers and ensure each worker is allocated sufficient hours to meet their contracted weekly hours as stated on the CoS.

Where hours shortfalls have accumulated, increase allocations to recover the deficit within a reasonable timeframe.

Where you cannot provide the contracted hours, you must withdraw sponsorship for the affected worker.

Serious BreachImmediate

General Sponsor Duties (3) – Close Relative

Potential Breach

Establish immediately whether Satnam Singh Brar is a close relative of any director, owner or person involved in the day-to-day running of the organisation.

If a close family relationship exists, Annex C1(o) provides a mandatory ground for licence revocation and you should seek specialist legal advice without delay.

Potential BreachUrgent

Recruitment Practices (1) – Qualifications, Skills and Experience

Critical

Redesign your recruitment process to ensure that every sponsored worker is assessed against the specific qualifications, skills and experience required for the role and the SOC code under which they are being sponsored.

Introduce structured interviews with questions that test sector-specific knowledge and competence.

Obtain and verify at least two references from employers in the care sector or a directly relevant field before assigning any CoS. Ensure all qualifications claimed by applicants are verified against original certificates before a CoS is assigned.

CriticalBefore any new CoS

Recruitment Practices (2) – Genuine Vacancies

Critical

Ensure that the job title, duties, SOC code and salary stated on every CoS are consistent with the offer letter, employment contract, job description and all other documents on the worker's file.

Do not assign a CoS under SOC 6145 where the job description describes supervisory, training or on-call duties that fall within SOC 6146.

Do not recruit non-driving workers into domiciliary care roles that require independent travel unless you can demonstrate how those workers will be deployed.

Cease the use of travel payments as a mechanism to supplement earnings and do not claw back travel reimbursements from workers on maternity pay or during periods of reduced hours.

CriticalBefore any new CoS

Reporting Duties

Critical

Report all outstanding salary shortfalls, late starts, absences and changes in circumstances to the Home Office via the SMS immediately.

Implement a reporting calendar that tracks all reportable events for each sponsored worker and assigns responsibility for submitting reports within the 10 working day deadline.

Train all staff involved in the day-to-day management of sponsored workers on their reporting obligations under the Sponsor Guidance.

CriticalImmediate

Monitoring Immigration Status

Critical

Conduct right to work checks for all seven workers who have no check on file, without delay.

Review the immigration status and working conditions of all 65 sponsored workers and ensure that no worker is employed in breach of their visa conditions.

In particular, review the position of Amritpal Singh immediately and seek legal advice on the potential Section 21 liability.

Implement a system to conduct right to work checks before employment commences and to schedule follow-up checks before existing permissions expire.

CriticalImmediate

Record Keeping – Appendix D

Critical

Conduct a full audit of every sponsored worker's file against the Appendix D checklist and obtain all missing documents.

Implement a document management system that flags incomplete files and prevents a CoS from being assigned until all required documents are in place.

Given that the average file is missing approximately 24 of 53 required documents, this will require a significant and sustained effort across the organisation.

CriticalImmediate

Recruitment Practices (3) – Third Party Labour

Compliant

Compliant — No action required. This area was found to be compliant.

Conclusion

Overall assessment of the sponsor's compliance position and licence risk.

This audit has examined the sponsor compliance position of Ave Maria Care Limited across nine areas of the Sponsor Guidance. Of the nine areas assessed, seven were classified as Critical, one as Serious, and one as a Potential breach. Only one area, third party labour, was found to be compliant. Not a single sponsored worker's file was complete.

The findings are not isolated incidents affecting individual workers. They represent systemic failures across your entire sponsorship operation. You have underpaid 20 workers by approximately £165,607 and reported none of these shortfalls. You have failed to provide contracted hours to 20 workers. You have recruited workers without relevant qualifications, skills or experience into sponsored roles. You have assigned Certificates of Sponsorship where the documentary evidence is internally inconsistent, with up to five different job titles appearing across a single worker's file. You have failed to conduct right to work checks before employment commenced for the majority of your sponsored workers, and one worker appears to have been working in excess of his permitted hours for approximately two years. You have failed to submit more than 200 individual reports that should have been made to the Home Office. Your record keeping is substantially incomplete across all 66 files reviewed.

In each section of this report, a precedent case has been cited in which the Home Office suspended or revoked a sponsor licence for conduct comparable to, or less serious than, the findings at your organisation. In one case, a licence was suspended on the basis of a single worker's P60 showing a salary shortfall of £4,220.

Your shortfalls total approximately £165,607 across 20 workers. In another case, a licence was revoked for failure to monitor immigration status where passports had expired and a share code was dated the day of the compliance visit. Your right to work checks were conducted after employment commenced for the majority of workers, and seven workers have no check on file at all. In a further case, a licence was revoked for inadequate record keeping where five workers were checked and documents were missing. Your audit covers 66 workers, not one of whom had a complete file.

The Home Office correspondence dated 6 August 2025, 30 October 2025 and 19 December 2025, together with the refusal of your previous sponsor licence application following a compliance check, demonstrates that your organisation is already subject to heightened scrutiny. The findings of this audit confirm that the concerns identified by the Home Office have not been addressed and have in several respects worsened over the audit period.

On the basis of the evidence reviewed, your organisation's sponsor licence is at serious risk of revocation. The grounds engaged across the findings include Annex C1(o), C1(s), C1(w), C1(z), C1(aa) and C2(b), together with potential criminal liability under Section 21 of the Immigration, Asylum and Nationality Act 2006.

Any one of the sections classified as Critical in this report would, on the basis of the precedent cases cited, be sufficient on its own to support licence suspension or revocation. The combination of all of them presents a position that is, in our assessment, among the most serious we have encountered.

Immediate and comprehensive corrective action is required across every area identified in this report. We recommend that senior management engage with the recommended actions set out above as a matter of urgency and seek specialist legal advice on the potential Section 21 liability and the Annex C1(o) mandatory revocation ground.

We remain available to assist with the development and implementation of a compliance improvement plan.

Note on paragraph references. The Workers and Temporary Workers guidance for sponsors is updated periodically by the Home Office. The most recent update took effect on 12 March 2026. This report references the paragraph numbers that were in force during the audit period and at the date of publication.

Where the Home Office has since renumbered or restructured the guidance, some paragraph references in this report may no longer correspond to the current numbering. The substantive obligations and grounds for licence action referred to throughout this report remain in force and the content of the relevant provisions has not materially changed.

Where a specific paragraph number has been superseded, the corresponding provision in the current version of the guidance should be read in its place.

Disclaimer and Confidentiality

Legal notices regarding the use and distribution of this report.

Please note that this report is strictly for the use of Ave Maria Care Limited and only those authorised to view it.

This report has been prepared solely for the use of Ave Maria Care Limited and is strictly confidential. It must not be disclosed, copied, distributed or relied upon by any third party without prior written consent. The report is based on the documents and information made available to us during the audit period and at the date of publication. We have not independently verified all information provided and no representation or warranty is given as to its completeness or accuracy.

The findings and opinions expressed in this report are based on the Sponsor Guidance, Immigration Rules and related legislation in force at the date of publication. The Workers and Temporary Workers guidance for sponsors is updated periodically by the Home Office. Where the Home Office has since renumbered or restructured the guidance, some paragraph references in this report may no longer correspond to the current numbering. The substantive obligations and grounds for licence action referred to throughout this report remain in force and the content of the relevant provisions has not materially changed. Where a specific paragraph number has been superseded, the corresponding provision in the current version of the guidance should be read in its place.

This report does not constitute legal advice. Ave Maria Care Limited should seek independent legal advice on the matters raised in this report, in particular the potential liability under Section 21 of the Immigration, Asylum and Nationality Act 2006 and the mandatory revocation ground under Annex C1(o) of the Sponsor Guidance.

The precedent cases cited in this report are drawn from published decisions and are included for illustrative purposes to demonstrate how the Home Office has applied the relevant provisions in comparable circumstances. They do not predict the outcome of any action the Home Office may take in relation to Ave Maria Care Limited.

Sponsor Compliance Audit Report

Ave Maria Care Limited

Sponsor licence 8PRCMP9N7

Published 15 March 2026

© 2026. All Rights Reserved.