Streamlining Certificate of Sponsorship (CoS) Allocation: Best Practices for UK HR Teams

Overview of the CoS Process

A Certificate of Sponsorship is an electronic record issued by licensed sponsors via the Sponsor Management System (SMS). There are two types:

• Defined CoS: For skilled workers applying from outside the UK, with each allocation requiring Home Office approval.
  
• Undefined CoS: For in-country applications (e.g., visa extensions) or roles not requiring prior approval.
  

The allocation process involves forecasting annual hiring needs, requesting the correct type and amount of CoS, and assigning them accurately through the SMS.

Step-by-Step Allocation and Assignment

• Assess annual hiring needs based on recruitment forecasts, visa routes, expected start dates, and workforce turnover.
  
• Request sufficient CoS allocations from UK Visas & Immigration (UKVI) via SMS, specifying defined or undefined CoS as relevant.
  
• For defined CoS, provide detailed job information and justification; processing may take up to two weeks.
  
• Assign the CoS by accurately entering employment details into SMS and confirming information before final submission.
  
• Share the assigned CoS with the prospective employee for their visa application; monitor and report any changes to UKVI on an ongoing basis.
  

Common HR Challenges

HR teams regularly face issues such as:

• Delays in CoS allocation, particularly during peak periods or when relying on last-minute requests.
  
• Stringent scrutiny from UKVI, requiring precise, genuine justifications of hiring needs and job eligibility.
  
• Insufficient forecasting, leading to urgent requests or shortfalls in allocated CoS during the year.
  
• Inability to respond swiftly to urgent or unforeseen hiring needs due to rigid annual allocation windows.
  

Compliance and Record-Keeping Requirements

Employers must strictly comply with Home Office rules to retain their sponsor licence and avoid penalties:

• Ensure all roles are genuine, meet skill and salary requirements, and are assigned to eligible candidates.
  
• Keep detailed records supporting the allocation, including advertisements, interview notes, salary justifications, and right-to-work checks as required by Appendix D.
  
• Monitor visa expiry dates and maintain up-to-date information, reporting any changes in employment or circumstances to UKVI without delay.
  

Misuse or errors in CoS assignments can lead to severe consequences, including visa refusals, compliance audits, licence downgrades, or suspension.

Best Practices for Streamlining CoS Allocation

• Proactively forecast recruitment demand and build a reserve (buffer) of undefined CoS for unexpected needs.
  
• Coordinate hiring and visa planning between HR, recruitment, and compliance teams to avoid duplicated efforts or missed allocations.
  
• Regularly review usage and audit assigned and unused CoS to optimise allocation and prevent wastage.
  
• Take advantage of priority allocation services when truly necessary but aim to minimise last-minute requests.
  

Conclusion

• Respond swiftly to UKVI requests for information to avoid delays.
  
• When assigning a defined CoS, ensure contractually accurate details (including weekly hours) are entered at the application stage.
  
• Carefully monitor renewal and extension needs for current sponsors to avoid costly gaps in sponsorship.
  

By following these best practices, HR teams can streamline the CoS process, minimize business risk, and help ensure timely onboarding of international talent.Invest in ongoing compliance training for HR users responsible for allocation and assignment, and stay updated with the latest UKVI guidance and policy changes.

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