Certificate of Sponsorship (CoS) Allocation and Assignment Process

Introduction

For HR information systems and process managers, mastering the Certificate of Sponsorship (CoS) allocation and assignment process is essential for managing UK Sponsor Licences and ensuring compliance with UK Visas and Immigration (UKVI) regulations. The CoS is a critical component for hiring non-UK nationals under routes like the Skilled Worker or Global Business Mobility (GBM) – Senior or Specialist Worker visas. With stricter enforcement in 2025, driven by the May 2025 Immigration White Paper, Restoring Control over the Immigration System, and the eVisa transition by 31 December 2026, streamlined processes are vital to avoid penalties. This guide details the CoS allocation and assignment process, compliance requirements, and best practices to optimize HR workflows in 2025.

What is a Certificate of Sponsorship (CoS)?

A CoS is an electronic record issued by a licensed sponsor through the Sponsor Management System (SMS) to a non-UK national, confirming their job role, salary, and visa eligibility. It is required for most work-related visa applications, such as Skilled Worker, GBM, and Innovator Founder visas. There are two types of CoS:

• Defined CoS: For Skilled Worker applicants applying from outside the UK, requiring Home Office approval.
• Undefined CoS: For in-country applications (e.g., visa extensions, GBM routes) or roles not requiring pre-approval.

HR Action: Understand the distinction between defined and undefined CoS to select the correct type for each worker’s visa application.

CoS Allocation Process

Allocation refers to the process of obtaining CoS quotas from UKVI to assign to workers. Sponsors must request sufficient CoS to cover hiring needs.

Steps for Allocation

1. Assess Hiring Needs:
   
   • Forecast the number of non-UK workers to be sponsored annually, based on recruitment plans and visa routes (e.g., Skilled Worker, GBM).
   • Consider visa durations (e.g., 3–5 years) and potential extensions.
2. Apply for CoS Allocation:
   
   • Log into the SMS and submit a request for defined or undefined CoS under “Request CoS allocation.”
   • For defined CoS (Skilled Worker, outside UK), apply via SMS with job details, salary, and role justification (RQF Level 6 or Temporary Shortage List).
   • For undefined CoS, request a yearly quota based on anticipated needs.
   • Processing time: 1–2 days for undefined CoS; up to 2 weeks for defined CoS.
3. Home Office Review:
   
   • UKVI assesses the sponsor’s compliance history and job role eligibility.
   • Defined CoS requires evidence of genuine vacancy and compliance with salary thresholds (e.g., £41,700 for Skilled Worker, £48,500 for GBM Senior/Specialist).
4. Allocation Approval:
   
   • Approved CoS are added to the sponsor’s SMS account for assignment.
   • Rejected requests (e.g., due to non-compliant roles) require resubmission with corrections.

Costs

• CoS Fee: £525 per CoS (increased April 2025).
• Immigration Skills Charge (ISC): For Skilled Worker Visas only, £364/year (small sponsors) or £1,000/year (large sponsors). Not applicable to GBM routes.

HR Action: Plan CoS requests 3–6 months in advance to align with recruitment timelines. Budget for CoS fees and ISC for Skilled Worker roles.

CoS Assignment Process

Assignment involves issuing a CoS to a specific worker for their visa application.

Steps for Assignment

1. Verify Worker Eligibility:
   
   • Confirm the worker meets visa requirements (e.g., prior employment for GBM, English proficiency for Skilled Worker).
   • Ensure the job role meets RQF Level 6 or Temporary Shortage List criteria and salary thresholds (e.g., £41,700 Skilled Worker, £48,500 GBM).
2. Assign CoS via SMS:
   
   • Log into SMS and select “Create CoS.”
   • Enter worker details: name, nationality, passport number, job title, salary, and work location.
   • Specify visa type (e.g., Skilled Worker, GBM Senior/Specialist) and duration (up to 5 years for Skilled Worker, 5–9 years for GBM).
   • Attach supporting documents (e.g., job description, contract).
3. Issue CoS Reference Number:
   
   • Once created, the CoS generates a unique reference number for the worker’s visa application.
   • Provide the reference number to the worker within 3 months (CoS expires after this period).
4. Support Visa Application:
   
   • Guide the worker to use the CoS reference in their online UKVI application, alongside documents like passports and TB test results (if applicable).
   • Monitor application progress, as the CoS is linked to the sponsor’s SMS account.

Processing Timelines

• CoS Creation: Instant for undefined CoS; 1–2 days for defined CoS approval.
• Visa Application: 3 weeks (outside UK) or 8 weeks (inside UK) standard; 5 days (priority, £500–£800) or next day (super priority, £800–£1,000).

HR Action: Assign CoS promptly after allocation and verify worker details to prevent errors. Use priority services for urgent hires, budgeting extra costs.

Compliance Requirements in 2025

Compliance with CoS processes is critical to avoid penalties, especially with stricter 2025 audits (1,948 licence revocations from July 2024 to June 2025).

• Accurate CoS Details:
  
  • Ensure job roles, salaries, and locations match SMS entries and comply with 2025 rules (e.g., RQF Level 6, £41,700/£48,500 salary thresholds).
• Reporting Duties:
  
  • Report worker changes (e.g., role, salary, location) within 10 working days via SMS.
  • Report organisational changes (e.g., address, ownership) within 20 working days.
• Right-to-Work Checks:
  
  • Conduct checks before employment and annually, using Biometric Residence Permits (BRPs) until 31 December 2026, then eVisa share codes.
• Record-Keeping:
  
  • Retain CoS records, payslips, contracts, and right-to-work documents for the sponsorship period plus 1 year.
• eVisa Transition:
  
  • By 31 December 2026, verify worker statuses via eVisa share codes in UKVI accounts.

Process Manager Action: Integrate CoS tracking into HR systems to automate reporting and ensure audit-ready records.

Penalties for Non-Compliance

Non-compliance with CoS processes risks severe consequences:

• Licence Downgrade: B-rating with a £1,476 action plan, halting new CoS issuance.
• Licence Suspension: Temporary halt of sponsorship, risking visa curtailments.
• Licence Revocation: Permanent loss, with a 12-month reapplication ban and £525/CoS losses.
• Civil Penalties: Up to £20,000 per illegal worker for failed right-to-work checks.
• Criminal Penalties: Up to 7 years’ imprisonment for knowingly employing illegal workers.

HR Action: Quantify penalty risks (£20,000–£100,000 for multiple violations) in process audits to justify compliance investments.

Best Practices for HR Information Systems

1. Automate CoS Management:
   
   • Use HR software (e.g., Workday, BambooHR) to track CoS allocations, assignments, and reporting deadlines.
   • Set automated alerts for 10- and 20-day SMS reporting requirements.
2. Conduct Internal Audits:
   
   • Perform quarterly reviews of CoS records, job compliance (RQF Level 6), and right-to-work checks.
   • Simulate Home Office audits to identify and fix gaps.
3. Train Staff:
   
   • Educate Level 1 Users and HR teams on SMS processes, 2025 rules, and eVisa verification.
   • Budget £500–£1,000 for training or £2,000–£5,000 for immigration advisors.
4. Streamline Allocation Requests:
   
   • Forecast CoS needs annually, aligning with recruitment and visa extension plans.
   • Request defined CoS early for out-of-country hires to avoid delays.
5. Support eVisa Transition:
   
   • Assist workers with UKVI account setup by Q1 2026 for eVisa verification.
   • Update right-to-work processes to use share codes post-2026.
6. Document Processes:
   
   • Create a CoS management manual with templates for SMS entries and audit preparation.

Process Manager Action: Develop a centralized CoS workflow in HR systems, integrating forecasting, allocation, and compliance tracking.

Challenges and Mitigation Strategies

• Non-Compliant Roles: Roles below RQF Level 6 or salary thresholds risk CoS rejection. Verify against Appendix Skilled Occupations before assignment.
• Missed Reporting Deadlines: Late SMS updates trigger audits. Use automated reminders to meet 10- and 20-day deadlines.
• eVisa Complexity: Technical issues with UKVI accounts may delay verification. Provide IT support and early setup guidance.
• Resource Constraints: Small sponsors may lack SMS expertise. Invest in cost-effective software or outsource to advisors (£2,000–£5,000).

HR Action: Incorporate these challenges into process workflows, prioritizing automation and training to reduce risks.

Conclusion

The CoS allocation and assignment process is a critical function for HR information systems and process managers in 2025. By forecasting needs, ensuring compliance with job and salary rules, and leveraging technology, HR teams can streamline workflows and avoid penalties. Preparing for stricter audits and the eVisa transition ensures seamless sponsorship and supports international hiring goals.

Disclaimer‍

Immigration laws and policies change frequently and may vary by country or nationality. While we strive to provide accurate and up-to-date information, we recommend doing your own due diligence or consulting official sources. You are also welcome to contact us directly for the latest guidance. Jobbatical is not responsible for decisions made based on the information provided.

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