Apply for CoS: Do it Yourself? Common Mistakes 2026

Section A: How to apply for a Certificate of Sponsorship

Applying for a Certificate of Sponsorship is often described as an administrative step carried out through the Sponsor Management System (SMS). In effect, it is a formal compliance event under the Immigration Rules. When a sponsor assigns or requests a CoS, it confirms that the role meets the required skill level, that the salary satisfies the applicable thresholds and going rate, that the vacancy is genuine and that the sponsor’s systems are capable of supporting ongoing compliance.

The procedural route depends on whether the worker requires a Defined or Undefined CoS.

A Defined CoS is required for most Skilled Worker applications made from outside the United Kingdom. The sponsor submits the request through the SMS and wait for UKVI approval before the certificate can be assigned.

An Undefined CoS is drawn from the sponsor’s annual allocation and can be assigned directly, provided sufficient allocation remains available.

Although the system interface is straightforward, the substantive checks sit outside the visible form fields. Before applying for a CoS, the sponsor needs to verify that the selected SOC 2020 occupation code accurately reflects the role as it operates in practice. The skill level requirement and salary rules must be satisfied in full, including any relevant general threshold and going rate. The vacancy must represent a genuine operational requirement within the organisation and not a role constructed primarily for immigration purposes.

Timing also forms part of the application process. A Defined CoS is not granted automatically and may be subject to review. Once assigned, a CoS is valid for three months, during which the worker must submit their visa application. Where the worker is already in the United Kingdom, the expiry date of existing leave becomes critical, particularly in relation to section 3C protection. These factors mean that applying for a CoS is not simply about issuing a document. It is about ensuring that immigration timing, role design and compliance systems are aligned before submission.

Where those elements are not aligned, risk does not remain confined to a single visa outcome. A flawed CoS application can draw attention to wider sponsor practices and expose weaknesses in record keeping, reporting or oversight. For that reason, the application stage requires preparation and internal verification rather than reactive submission.

Section B: The genuine vacancy requirement

Before applying for a Certificate of Sponsorship, the sponsor needs to consider whether the role satisfies the genuine vacancy requirement under Appendix Skilled Worker. This requirement is frequently underestimated because it does not sit neatly within a single field on the Sponsor Management System. It is assessed by reference to the substance of the role and the credibility of the business.

A genuine vacancy is one that exists in reality and reflects a true operational need. The role must correspond to the selected SOC 2020 occupation code not only in title but in day-to-day duties. The position cannot be created primarily to enable sponsorship, nor can it operate as a token appointment without genuine commercial purpose. The salary must be credible in the context of the organisation’s size, structure and sector. Meeting the numerical threshold alone is not sufficient if the overall profile of the role appears inconsistent with the business.

UKVI caseworkers assess the vacancy in context. They consider the trading history of the sponsor, the scale of its workforce and the nature of its commercial activity. They examine whether similar roles already exist within the organisation and whether the duties described align with the business model. Where a sponsor is newly licensed or recently incorporated, scrutiny may be closer. Where a role carries senior or specialist responsibilities in a very small operation, questions may arise about proportionality and credibility.

Defined CoS requests bring this assessment to the forefront because approval is required before assignment. In those cases, UKVI may request clarification or refuse the application where concerns arise. With Undefined CoS, the same issues may surface later at visa decision stage or during a compliance visit. The timing differs, but the underlying assessment remains the same.

Recent refusal patterns show that UKVI is increasingly willing to challenge roles that appear engineered to meet minimum criteria. Generic duty descriptions lifted from occupation code guidance, salaries that sit precisely at threshold level without explanation and positions that do not align with the sponsor’s operational footprint are all capable of triggering refusal. In many cases, the reason given is not a simple coding or salary error but a failure to demonstrate that the vacancy is genuine.

For sponsors, this means that the genuine vacancy test is not an abstract rule. It is a substantive requirement that should be addressed before a CoS request is submitted. Where the role cannot be clearly evidenced as commercially credible and properly aligned with the Immigration Rules, the risk extends beyond the individual application and into the wider sponsor compliance framework.

Section C: Common mistakes when applying for a CoS

Once the role has been identified and the recruitment decision made, sponsors often move quickly to the Sponsor Management System. At that stage, the focus tends to be on completing the required fields accurately. The more difficult task is ensuring that what is entered reflects a coherent compliance position.

A common mistake is drafting duties so that they resemble the summary wording of the chosen SOC 2020 occupation code rather than describing the role as it genuinely operates within the organisation. This approach can create an appearance of alignment on paper while masking inconsistencies in practice. If the duties are later examined at visa stage or during audit, discrepancies between the CoS and the actual job can become apparent.

Salary errors also arise in more nuanced ways than sponsors expect. A figure may meet the general threshold but fail to align with the going rate for the occupation code when calculated properly. In other cases, the salary may sit exactly at the minimum level without any commercial context to support it. Where a business of limited size is offering a role at a threshold salary with senior responsibilities, the overall profile may invite closer review.

Inconsistency across sponsor records is another frequent source of difficulty. Details entered on a CoS can conflict with earlier sponsor licence applications, previous CoS assignments or internal workforce data. UKVI has access to historic records and routinely cross-references information. Differences in job descriptions, salary structures or working patterns across similar sponsored workers can suggest weak internal controls rather than isolated oversight.

Timing mistakes compound these issues. Sponsors sometimes assign a CoS before fully verifying eligibility, assuming that corrections can be made later. Where a Defined CoS is refused or returned for clarification, the time available to respond may be limited. Where an Undefined CoS has already been assigned and the visa application is submitted, weaknesses in the original assessment can surface at decision stage, when the sponsor has far less opportunity to intervene.

Most of these errors do not arise from deliberate non-compliance. They arise from treating the CoS as an administrative step rather than as part of a wider sponsorship framework. The cumulative effect, however, can be significant. A single flawed application can draw attention to record keeping, reporting practices and internal oversight across the sponsor’s wider workforce.

Section D: Timing risks when applying for a CoS

Timing risk is one of the most common and least understood aspects of applying for a Certificate of Sponsorship. Recruitment decisions are often driven by commercial urgency, and the immigration step is left until close to the worker’s proposed start date or the expiry of existing leave. In practice, the CoS stage is governed by fixed statutory and administrative timelines that cannot be adjusted once the process is underway.

A Defined CoS request is not granted automatically. It requires UKVI approval before assignment. Where the role raises questions around salary level, skill classification or credibility, UKVI may request further information or refuse the request outright. The review period is outside the sponsor’s control. If the request is submitted shortly before the worker’s leave expires, there may be insufficient time to address queries or submit a revised application.

Once a CoS has been assigned, it remains valid for three months. The worker must submit their visa application within that period. If the deadline passes, the certificate cannot be used and a fresh CoS is required. Where allocation limits apply or where previous refusals have triggered closer scrutiny, obtaining a further certificate may not be straightforward. Sponsors who treat the CoS as an open-ended document frequently discover this rule only after the validity period has expired.

Where the worker is already in the United Kingdom, the expiry date of current leave introduces an additional layer of risk. To benefit from section 3C protection, a new application must be submitted before existing leave expires. Delay at CoS stage can prevent an in-time application, resulting in loss of lawful status and potential right to work exposure. In some cases, a new application may need to be made from outside the United Kingdom, disrupting continuity of employment and, in certain circumstances, continuity towards settlement.

Timing pressures also arise from annual allocation limits for Undefined CoS, internal authorisation processes within the sponsor organisation and the practicalities of gathering supporting information. Once a CoS request has been submitted, the sponsor cannot accelerate the decision beyond the parameters set by UKVI.
Applying for a CoS therefore requires forward planning. Where the process is left until immigration deadlines are imminent, even minor weaknesses can become decisive because there is no margin to correct them. The immigration timetable does not pause while a sponsor revisits role design, salary calculations or supporting evidence.

Section E: What happens if a CoS application goes wrong

A refused or challenged Certificate of Sponsorship rarely remains confined to a single worker. While the immediate consequence is that the visa application cannot proceed as planned, the wider impact can extend into recruitment strategy and sponsor compliance.

Defined CoS requests may be granted, refused or returned for further information. Where a request is refused, the recruitment process pauses immediately. Where clarification is sought, response time is limited and the sponsor is required to justify the role in greater detail. In both situations, the worker may face delay or uncertainty, and alternative employment options may become more attractive.

With Undefined CoS, problems often emerge later. A visa application may be refused on the basis that the role does not satisfy the Immigration Rules, or concerns may surface during a compliance visit. By that stage, the certificate has already been assigned and the sponsor has formally confirmed that the vacancy met all requirements.

Rectifying weaknesses becomes more difficult once a decision has been issued.
Repeated issues can attract closer scrutiny. UKVI may review patterns across previous assignments, examine salary consistency across the sponsored workforce and assess whether similar roles have been justified in the same manner. A single refusal does not automatically lead to licence action, but it can form part of a broader compliance assessment.

The commercial consequences can be significant. Recruitment costs may be lost, project timelines may be disrupted and senior management may need to become involved. Where the worker is already employed, operational continuity may be affected. In some cases, a refusal may also affect the worker’s longer-term immigration plans.
For these reasons, a CoS refusal is rarely a discrete event. It can act as a trigger for wider review, particularly where similar issues appear across multiple applications. The reputational and operational impact on the sponsor may extend beyond the immediate visa outcome.

Section F: Sponsor licence exposure and wider compliance risk

Errors at Certificate of Sponsorship stage are not assessed in isolation. UKVI treats the accuracy of CoS assignments as an indicator of how well a sponsor understands and applies its duties under the Immigration Rules and sponsor guidance.

Where concerns arise around role classification, salary calculation or the genuine vacancy requirement, UKVI may consider whether the issue reflects a broader weakness in internal systems. Record keeping, reporting accuracy and oversight of sponsored workers can all come under review. A pattern of inconsistent job descriptions, marginal salary calculations or late reporting can suggest that sponsor controls are not operating as required.

Increased scrutiny can take several forms. UKVI may restrict future CoS allocations, decline requests for additional certificates or subject the sponsor to closer monitoring. In more serious cases, the sponsor licence may be downgraded, suspended or revoked. These outcomes are not automatic, but they become more likely where errors recur or where explanations lack supporting evidence.

The impact of licence action extends beyond immigration teams. Recruitment planning may be constrained, existing sponsored workers may face uncertainty and commercial projects that depend on overseas talent may be disrupted. Where a licence is suspended, no new CoS can be assigned until the suspension is lifted. Where a licence is revoked, sponsored workers may have limited time to secure alternative sponsorship or leave the United Kingdom.

Applying for a CoS therefore carries consequences beyond the individual application. Each assignment forms part of the sponsor’s compliance record. Weaknesses identified at CoS stage can shape UKVI’s assessment of the organisation’s overall approach to sponsorship.

For sponsors operating in competitive or time-sensitive sectors, maintaining confidence in the robustness of CoS decisions is not simply an immigration concern. It is a matter of operational stability and governance.

Section G: Applying for a CoS as a governance decision

Applying for a Certificate of Sponsorship should be approached as a governance decision rather than a routine administrative step. Each CoS confirms that the sponsor has assessed the role against the Immigration Rules, verified salary compliance and satisfied itself that the vacancy is genuine and commercially credible.
Where roles sit comfortably above skill and salary thresholds and where internal compliance systems are mature, the process may proceed without difficulty. Greater care is required where the role is close to minimum criteria, where the sponsor is newly licensed or where there has been previous Home Office scrutiny. In those circumstances, the margin for error is narrower and the consequences of refusal more significant.

Early review allows the sponsor to test occupation code selection, salary calculations and the consistency of role descriptions against existing workforce records. It also allows immigration timing to be aligned with recruitment plans and visa deadlines. Addressing these points before submission is materially different from attempting to correct weaknesses once a Defined CoS has been refused or a visa application has been challenged.

Once a CoS request has been submitted, the sponsor’s explanation is assessed against the information already held by UKVI. Opportunities to revisit role design or adjust salary structure may be limited. Preventative review therefore serves to protect not only the individual application but also the integrity of the sponsor’s licence.
For organisations that depend on sponsored workers, the question is not simply how to apply for a CoS. It is how to apply in a way that withstands scrutiny and supports long-term compliance. Early, structured assessment of risk at CoS stage is often the most effective means of avoiding disruption to recruitment and licence exposure later.

Section I: Need assistance?

Applying for a Certificate of Sponsorship at short notice or without full internal verification can create risk that extends beyond a single recruitment decision. Where a role is close to minimum thresholds, where the sponsor has recently obtained its licence or where previous applications have attracted scrutiny, early review can prevent avoidable disruption.

Legal input at CoS stage is not limited to completing the Sponsor Management System entry. It involves assessing occupation code selection, salary structure, role credibility and immigration timing against the current Immigration Rules and sponsor guidance. Addressing these points before submission reduces the likelihood of refusal and minimises exposure to wider licence review.

If your organisation is preparing to apply for a CoS and requires a second opinion on role eligibility, compliance alignment or timing strategy, book a fixed-fee telephone consultation with one of our UK sponsorship advisers.

Section J: FAQs

What does it mean to apply for a CoS?

Applying for a Certificate of Sponsorship means assigning or requesting a certificate through the Sponsor Management System to support a worker’s visa application. It is a formal confirmation that the role meets the skill, salary and genuine vacancy requirements under the Immigration Rules and that the sponsor is satisfied its compliance duties are being met.

Do Defined CoS requests require Home Office approval?

Defined CoS requests, which are typically required for Skilled Worker applications made from outside the United Kingdom, must be submitted for UKVI approval before they can be assigned. Approval is not automatic and may involve review of the role and supporting information.

How long is a Certificate of Sponsorship valid for?

Once assigned, a CoS is valid for three months. The worker must submit their visa application within that period. If the deadline passes, the certificate cannot be used and a new CoS will be required.

What happens if a CoS is refused?

If a Defined CoS request is refused, the role cannot proceed to visa application stage unless a fresh request is approved. A refusal may prompt further scrutiny of future requests and, depending on the circumstances, could contribute to wider review of the sponsor’s compliance record.

Can mistakes on a CoS affect a sponsor licence?

UKVI treats CoS accuracy as an indicator of sponsor competence. Repeated inconsistencies, incorrect occupation code selection or salary miscalculations can raise concerns about internal controls. In more serious cases, this may lead to allocation restrictions, downgrading, suspension or revocation of the licence.

Is it safe to apply for a CoS close to a worker’s visa expiry date?

Applying close to expiry increases risk. Defined CoS requests may be reviewed before approval and, once assigned, the worker must submit their visa application within three months. Where the worker is already in the United Kingdom, failure to submit an in-time application may affect lawful status and right to work compliance.

Does meeting the salary threshold guarantee approval?

The salary must meet the relevant thresholds and going rate, but UKVI also assesses whether the role satisfies the genuine vacancy requirement and aligns with the sponsor’s business operations. Meeting the numerical threshold alone does not remove the need for the role to be credible and properly classified.

When should a sponsor seek legal advice?

Advice is often helpful where the role is close to minimum criteria, where the sponsor is newly licensed, where previous applications have attracted scrutiny or where immigration timing is tight. Early assessment can reduce the likelihood of refusal and wider compliance exposure.

Section K: Glossary

Section L: Useful Links