UK Sponsor Licence Ongoing CoS Support

Certificate of Sponsorship & Sponsor Management Support

Receiving a UK Sponsor Licence is not the end of the sponsorship process.

Once licensed, an employer must correctly manage its Sponsor Management System (SMS), assign Certificates of Sponsorship, report relevant worker and organisational changes, maintain appropriate records and continue complying with Home Office sponsor duties.

At James Immigration Solutions Ltd, our Ongoing CoS Support service helps licensed employers manage their day-to-day sponsorship responsibilities and reduce avoidable compliance risks.

We can support employers with:

  • Defined Certificates of Sponsorship
  • Undefined Certificates of Sponsorship
  • CoS allocation requests
  • Certificate of Sponsorship assignment
  • Skilled Worker sponsorship checks
  • Sponsor Management System support
  • Sponsored worker changes
  • Sponsor reporting duties
  • Changes to business circumstances
  • Key personnel updates
  • Sponsor record keeping
  • Ongoing compliance support

What Is a Certificate of Sponsorship?

A Certificate of Sponsorship – CoS is an electronic sponsorship record assigned by a licensed employer to an eligible overseas worker.

It is not a physical certificate.

Each CoS contains a unique reference number which the worker uses when making their immigration application.

The Certificate of Sponsorship contains important information concerning matters such as:

  • Sponsor
  • Worker
  • Job title
  • Occupation
  • Salary
  • Working hours
  • Work location
  • Employment start date
  • Sponsorship route

The information entered on a CoS should accurately reflect the genuine employment being offered.

The Home Office confirms that a worker normally needs to use their assigned CoS for their visa application within 3 months.


Defined and Undefined Certificates of Sponsorship

For Skilled Worker sponsorship, there are two principal types of Certificate of Sponsorship:

Defined CoS

A Defined Certificate of Sponsorship is generally required where a Skilled Worker will apply for entry clearance from outside the UK.

Undefined CoS

An Undefined Certificate of Sponsorship is generally used for Skilled Workers applying from inside the UK and for workers in other applicable sponsorship categories.

Choosing the correct type of CoS is extremely important.

The Home Office specifically warns sponsors against assigning an Undefined CoS where a Defined CoS is required.


Defined Certificate of Sponsorship Support

A licensed employer wishing to sponsor a Skilled Worker applying from outside the UK normally needs to request a Defined CoS through the Sponsor Management System.

Our support can include reviewing:

  • Proposed job
  • Occupation code
  • Job description
  • Salary
  • Working hours
  • Work location
  • Start date
  • Sponsorship eligibility
  • Candidate circumstances
  • Information required for the Defined CoS request

A Level 1 User applies for the Defined CoS through the SMS.

According to current GOV.UK guidance, Defined CoS applications are usually decided within one working day, although additional checks can result in a longer processing period.


Undefined Certificate of Sponsorship Support

Undefined Certificates of Sponsorship can be used in qualifying circumstances, including certain Skilled Worker applications made from within the UK.

Licensed sponsors normally receive or request an allocation of Undefined CoS through the Sponsor Management System.

Before an Undefined CoS is assigned, we can help review whether:

  • The correct CoS type is being used
  • The job is eligible
  • Salary requirements are met
  • Working hours are accurately recorded
  • The occupation code is appropriate
  • The candidate can potentially qualify under the intended route
  • The employer has sufficient CoS allocation

Additional Undefined CoS Allocation

Employers may find that their available allocation is insufficient for future recruitment.

Additional Undefined Certificates of Sponsorship can be requested through the SMS.

The Home Office may ask the employer to explain:

  • Why additional CoS are required
  • Number of workers required
  • Job roles
  • Salary
  • Recruitment need
  • Business activity
  • Existing workforce
  • Proposed recruitment plans

Current GOV.UK guidance states that additional Undefined CoS allocation requests can normally take up to 12 weeks, although a faster service may be available for eligible requests.

We can help employers prepare a structured request supported by the genuine recruitment circumstances of the business.


CoS Assignment Review

Assigning a Certificate of Sponsorship creates an official Home Office sponsorship record.

The CoS should therefore be carefully reviewed before it is finally assigned.

Our review can include:

Worker Details

  • Full name
  • Date of birth
  • Nationality
  • Passport information
  • Current immigration status

Employment Details

  • Job title
  • Job description
  • Occupation code
  • Salary
  • Working hours
  • Start date
  • End date where applicable
  • Work address

Sponsorship Details

  • Correct immigration route
  • Correct CoS category
  • Sponsor certification questions
  • Maintenance certification where applicable
  • Relevant additional information

Errors should ideally be identified before assignment.


Choosing the Correct Occupation Code

An appropriate occupation code is an important part of Skilled Worker sponsorship.

The code should correspond with the actual duties of the job, rather than simply selecting an occupation because its title appears similar.

We review matters including:

  • Main duties
  • Level of responsibility
  • Skills required
  • Organisational position
  • Salary
  • Working arrangements
  • Applicable sponsorship requirements

The job description and occupation code should provide a consistent picture of the genuine role.


Skilled Worker Salary Review

Before assigning a Skilled Worker CoS, the employer should ensure that the proposed salary satisfies the immigration requirements applicable to that particular worker and occupation.

Different rules can apply depending on circumstances such as:

  • Occupation
  • Going rate
  • General salary threshold
  • Worker circumstances
  • New entrant provisions
  • Relevant qualifications
  • Immigration route
  • Other permitted salary provisions

The applicable salary rules should be checked at the time the CoS is assigned, as immigration thresholds can change.


Genuine Vacancy Review

A Sponsor Licence must only be used to sponsor genuine employment.

The proposed role should make sense within the employer’s business.

We may consider:

  • Why the position is required
  • Business activities
  • Existing workforce
  • Organisational structure
  • Job duties
  • Employee responsibilities
  • Salary
  • Working hours
  • Recruitment circumstances

A CoS should not be assigned for a role created primarily to facilitate an immigration application.


Sponsor Management System Support

The Sponsor Management System – SMS is the Home Office platform used by licensed sponsors to manage their licence.

It can be used to:

  • Assign Certificates of Sponsorship
  • Apply for Defined CoS
  • Request additional CoS
  • Report worker changes
  • Withdraw sponsorship
  • Update organisational information
  • Manage key personnel
  • Manage licence information

The Home Office confirms that the SMS is the system through which sponsors carry out these day-to-day sponsorship activities.


Reporting Sponsored Worker Changes

Sponsor Licence holders have continuing reporting duties.

Certain changes involving sponsored workers may need to be reported through the SMS.

Examples can include:

  • Worker does not start employment
  • Employment ends earlier than expected
  • Worker resigns
  • Worker is dismissed
  • Certain prolonged unauthorised absences
  • Significant changes to duties
  • Changes to salary
  • Changes to work location
  • Changes to working arrangements
  • Sponsorship is withdrawn

Whether a report is required and the applicable deadline depend on the circumstances.

Our ongoing support can help employers identify when an SMS report should be considered.


Worker Does Not Start Employment

If a sponsored worker does not begin employment as expected, the sponsor should determine why and whether the matter requires reporting.

Examples may include:

  • Visa delay
  • Worker changes their plans
  • Visa refusal
  • Recruitment withdrawn
  • Worker fails to attend
  • Employer withdraws the position

The circumstances should be recorded appropriately and any required Home Office action taken within the applicable timeframe.


Changes to Salary or Duties

A sponsored worker’s employment should continue to correspond with the role for which sponsorship was granted.

Employers should seek guidance before making significant changes involving:

  • Salary
  • Hours
  • Job duties
  • Occupation
  • Workplace
  • Employment conditions

Some changes can simply be reported, while others may require a new CoS and potentially a new immigration application.

Employers should therefore assess immigration implications before implementing major changes where possible.


Ending Sponsorship

Where a sponsored worker:

  • Resigns
  • Is dismissed
  • Is made redundant
  • Leaves employment early
  • Moves to another employer

the sponsor may have reporting obligations.

The Home Office can then take any appropriate action concerning the worker’s immigration permission.

The employer should maintain evidence showing:

  • Date employment ended
  • Reason for termination
  • Final salary
  • Relevant correspondence
  • SMS report where required

Reporting Business Changes

Sponsors must also consider whether changes affecting the organisation itself need to be reported.

These may include matters involving:

  • Business address
  • Trading address
  • Company name
  • Key personnel
  • Business structure
  • Ownership
  • Merger
  • Acquisition
  • De-merger
  • Insolvency
  • Business activity
  • Additional work locations

Some corporate changes can have significant consequences for an existing Sponsor Licence.

They should therefore be considered before the transaction takes place wherever possible.


Changes in Ownership

Sponsor Licences do not simply transfer automatically when ownership changes.

Corporate transactions involving:

  • Share sales
  • Business acquisitions
  • Mergers
  • Takeovers
  • De-mergers

can create important Sponsor Licence consequences.

The business should seek appropriate advice before completing significant ownership or corporate restructuring where sponsored workers are involved.


Key Personnel Changes

The Sponsor Licence must continue to have suitable individuals performing its required key personnel roles.

These include:

  • Authorising Officer
  • Key Contact
  • Level 1 User

Changes may be necessary when someone:

  • Leaves employment
  • Changes position
  • Becomes unavailable
  • Moves outside the UK
  • Is no longer suitable
  • No longer requires SMS access

Former staff should not retain inappropriate access to the Sponsor Management System.


Sponsor Record Keeping

Ongoing sponsorship support also involves maintaining appropriate records for sponsored workers.

Records can include evidence relating to:

  • Right to work
  • Passport and immigration status
  • Contact details
  • Employment
  • Salary
  • Job duties
  • Attendance
  • Absence
  • Recruitment
  • Qualifications where relevant
  • CoS details
  • SMS reports

Home Office compliance should form part of normal HR management rather than only being considered if a compliance visit occurs.


Sponsor Compliance Monitoring

An organisation can remain licensed only if it continues to comply with its sponsor duties.

We recommend periodic reviews of:

  • Sponsored worker files
  • Right to work records
  • Salary records
  • Employee duties
  • Work locations
  • Attendance
  • SMS users
  • CoS assignments
  • Reporting records
  • Company information

Regular reviews can identify problems while they are still capable of being corrected.


Sponsor Licence Renewal

The Home Office removed the general requirement for most sponsors to renew their licence every four years from 6 April 2024.

For most licensed sponsors, the licence now remains valid unless it is surrendered or revoked.

Certain routes, including UK Expansion Worker and Scale-up, remain subject to specific maximum licence periods.

This makes ongoing compliance even more important because maintaining the licence is now principally about continued adherence to sponsor duties rather than completing a routine four-year renewal application.


Home Office Compliance Action

Failure to comply with Sponsor Licence duties can result in Home Office action.

Depending on the circumstances, this can potentially include:

  • Additional enquiries
  • Compliance visit
  • Restrictions on sponsorship
  • Licence downgrade
  • Suspension
  • Revocation

The consequences can also affect workers sponsored by the organisation.

Employers should therefore address sponsorship problems promptly rather than waiting for Home Office intervention.


Our Ongoing CoS Support Service

At James Immigration Solutions Ltd, ongoing sponsorship support can be tailored to the needs of your organisation.

Our service may include:

Certificate of Sponsorship Review

Reviewing proposed sponsorship before a CoS is assigned.

Defined CoS Applications

Helping prepare information required for Defined CoS requests.

Undefined CoS Support

Reviewing allocation and proposed assignments.

CoS Allocation Requests

Helping employers explain genuine future sponsorship requirements.

SMS Reporting Support

Assisting with reportable sponsored worker or organisational changes.

Key Personnel Support

Helping maintain suitable Sponsor Licence key personnel arrangements.

Compliance Reviews

Periodic review of sponsorship and HR records.

Sponsor Guidance

Providing support when questions arise during the employment of sponsored workers.


Why Choose JISL for Ongoing Sponsor Support?

A Sponsor Licence creates responsibilities that continue for as long as the organisation employs sponsored workers.

James Immigration Solutions Ltd provides a structured approach to sponsor management focused on:

  • Accurate CoS assignment
  • Current immigration requirements
  • Sponsor Management System compliance
  • Appropriate record keeping
  • Timely reporting
  • Risk identification
  • Ongoing employer support

Our aim is to help businesses use their Sponsor Licence responsibly while maintaining effective sponsorship systems.


Complete Sponsor Licence Service

Our Sponsor Licence services cover the complete sponsorship journey:

  1. Business & Eligibility Assessment
  2. Supporting Document Review
  3. Key Personnel Selection
  4. Compliance Preparation
  5. Application Submission
  6. Ongoing CoS Support

This means support can continue after your Sponsor Licence has been approved.


Start Your Ongoing Sponsor Support

Already have a Sponsor Licence and need help with a Certificate of Sponsorship, SMS request or sponsored worker change?

Contact James Immigration Solutions Ltd for ongoing Sponsor Licence and CoS support.

We can help your organisation manage sponsorship activities, understand reporting obligations and maintain appropriate Home Office compliance.


Frequently Asked Questions

What is a Certificate of Sponsorship?

A CoS is an electronic record assigned by a licensed sponsor to a worker they intend to sponsor.

When do I need a Defined CoS?

A Defined CoS is normally required for a Skilled Worker making their visa application from outside the UK.

When is an Undefined CoS used?

For Skilled Worker sponsorship, an Undefined CoS is generally used where the worker is making the relevant application from inside the UK.

How long does a worker have to use a CoS?

The worker normally needs to use the CoS for their visa application within 3 months of assignment.

Can JISL help with additional CoS allocations?

Yes. We can help review the recruitment requirement and prepare the information supporting an additional allocation request.

Do Sponsor Licences still need renewing every four years?

For most sponsors, no. The general four-year renewal requirement was removed on 6 April 2024.