How to Assign a Certificate of Sponsorship (CoS) | Employer Guide

Assigning a Certificate of Sponsorship: At a Glance

 

Assigning a Certificate of Sponsorship (CoS) is the point at which a licensed sponsor formally confirms that it is sponsoring a worker for a specific role under an eligible immigration route.

The assignment process is completed electronically through the Sponsor Management System (SMS), but the key compliance decisions take place before the certificate is assigned. Employers need to confirm that the organisation can sponsor the worker, that the correct type of CoS is being used and that the information recorded accurately reflects the proposed employment.

A CoS creates the link between the sponsor, the sponsored worker and the role described on the certificate. Once assigned, it generates a unique reference number which the worker uses when making their immigration application.

Assignment does not give the worker immigration permission and does not confirm that their application will be successful. The worker remains responsible for making the relevant application and satisfying the requirements of the immigration route.

Employers should also keep the sponsorship process separate from right to work compliance. A CoS reference is not evidence of a right to work, and the employer needs to complete the appropriate right to work check before employment begins where required.

Errors at assignment stage can affect the worker’s immigration application, disrupt recruitment plans and create questions about the organisation’s sponsor licence controls. A robust CoS process therefore combines accurate SMS activity with effective internal checks and approval procedures.

This guide explains how employers prepare for and complete the CoS assignment process, the information they need to provide, the checks required before assignment, the applicable charges, common assignment errors and the compliance risks that arise where a certificate is assigned incorrectly.

 

Section A: How to Assign a Certificate of Sponsorship

 

A Certificate of Sponsorship is assigned by a licensed sponsor before a sponsored worker can use it in support of their UK immigration application. The process is completed electronically through the Sponsor Management System (SMS).

Before assignment, the employer should confirm that the sponsorship is permitted under the relevant immigration route, that the correct type of CoS is available and that the information recorded about the worker and proposed employment is accurate.

The information entered on the CoS forms part of the sponsor’s record with the Home Office. This includes details such as the worker, role, salary, occupation code, working arrangements and employment dates. The certificate should reflect the employment the organisation genuinely intends to provide.

Once the required information has been completed and the applicable charges have been paid, the SMS generates a unique CoS reference number. The worker can then use that reference when making their visa or permission application.

The assignment stage represents the employer’s formal sponsorship decision for the role described on the certificate. The worker still needs to make a valid immigration application and satisfy the requirements of the relevant route before they can work in the UK.

The employer’s responsibility also extends beyond the SMS transaction. Once the worker’s immigration permission has been granted, the organisation remains responsible for meeting its sponsor duties and ensuring that the worker’s employment continues to align with the sponsorship record.

 

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Section B: How Do You Assign a Certificate of Sponsorship?

To assign a Certificate of Sponsorship, an authorised SMS user must create or retrieve the relevant CoS in the Sponsor Management System, complete the required worker and employment information, review the details for accuracy, accept the relevant declaration, pay the applicable charges and confirm the assignment.

Once the assignment has been completed, the CoS is given a unique reference number and its status in the SMS changes to “ASSIGNED”. The worker can then use the CoS reference in support of their immigration application.

In practical terms, employers should approach the process in the following order:

1. Confirm that the organisation can sponsor the worker

Check that the organisation holds an active sponsor licence and is authorised to sponsor workers under the relevant immigration route. Any restrictions affecting the licence, including suspension or a B-rating, should be considered before proceeding.

 

2. Identify the correct type of CoS

Determine whether the worker requires a Defined or Undefined Certificate of Sponsorship. For Skilled Worker applications, this will depend primarily on whether the worker is applying for entry clearance from outside the UK or for permission to stay from within the UK.

The sponsor must have the appropriate Undefined CoS available within its allocation or, where a Defined CoS is required, have obtained approval for the Defined CoS before it can be assigned.

 

3. Check that the proposed role can be sponsored

Before creating the certificate, check that the proposed job is eligible for sponsorship under the relevant route.

This should include checking the job duties, occupation code, salary, working hours and any other route-specific requirements that affect whether the role can be sponsored.

 

4. Gather the worker and employment information

Collect the information needed to complete the CoS before beginning the final assignment process.

This will generally include the worker’s personal details and information about the job, occupation code, salary, working hours, work location, employment dates and any additional information required under the relevant immigration route.

 

5. Create or retrieve the CoS in the SMS

The authorised SMS user should access the appropriate Certificate of Sponsorship function and create a new certificate or retrieve a certificate that has already been prepared and saved.

Where the organisation is assigning an approved Defined CoS, the user should ensure that the correct approved certificate is being used for the worker.

 

6. Complete all mandatory CoS fields

Enter the required information about the worker and proposed employment.

Depending on the immigration route, this can include:

• worker identity and personal details;
• immigration route;
• job title;
• job description;
• occupation code;
• salary;
• weekly working hours;
• employment start and end dates;
• work location or locations;
• maintenance certification;
• ATAS information where relevant;
• recruitment or intermediary information where required; and
• other route-specific information or declarations.

The information entered should accurately describe the worker and the genuine employment arrangements.

 

7. Review the CoS before assignment

Before proceeding, review the complete CoS against the underlying worker and employment information.

This should not be treated merely as a spelling or data-entry check. The sponsor should confirm that the sponsorship decision itself is correct, including the immigration route, CoS type, occupation code, job description, salary, hours, work location and employment dates.

This is a particularly important control because an assigned CoS cannot simply be reopened and amended in the same way as a certificate that is still being prepared.

 

8. Accept the sponsor declaration

Once the sponsor is satisfied that the information is complete and accurate, the authorised SMS user can proceed to the relevant declaration.

The user should read the declaration carefully before confirming it, since assignment represents the sponsor’s formal sponsorship of the worker for the role recorded on the certificate.

 

9. Pay the applicable charges

The sponsor will be directed through the payment process for the relevant Certificate of Sponsorship assignment fee.

Where the Immigration Skills Charge applies, this will also need to be dealt with as part of the sponsorship process.

The employer should establish which charges apply before reaching this stage and should ensure that prohibited sponsorship costs are not passed to or recovered from the sponsored worker.

 

10. Assign the Certificate of Sponsorship

After the required declaration and payment process has been completed, the authorised user can confirm the assignment.

The CoS is then formally assigned to the worker and receives its unique Certificate of Sponsorship reference number.

A CoS for which all mandatory information has been completed but which has not yet been assigned may appear in the SMS with the status “READY TO GO”. Once the assignment has been successfully completed, its status changes to “ASSIGNED”.

 

11. Record the CoS reference and provide it to the worker

The employer should retain an appropriate record of the assigned certificate and provide the worker with the CoS reference and any other information they need to complete their immigration application.

The Certificate of Sponsorship is an electronic record. The worker does not need to be issued with a physical certificate.

 

12. Move the case into immigration and onboarding monitoring

Assignment should not be treated as the end of the employer’s immigration process.

The sponsor should monitor the worker’s immigration application, respond appropriately to any changes or issues and ensure that the required right to work check is completed before the individual starts work where required.

The practical SMS transaction is relatively straightforward. The greater compliance risk lies in the decisions that precede it. The sponsor remains responsible for ensuring that the worker, role, occupation code, remuneration, CoS type and other information support a compliant sponsorship decision before the final assignment is made.

 

 

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Section C: What Does Assigning a Certificate of Sponsorship Mean?

Assigning a Certificate of Sponsorship is the point at which a licensed sponsor formally links a specific CoS to a specific worker and the role they are being sponsored to perform.

A CoS is not a paper certificate or document issued to the worker. It is an electronic record held within the Sponsor Management System. Once assigned, the record contains a unique reference number that the worker uses when making their immigration application.

For employers, it is important to distinguish between CoS allocation, creation and assignment. These are related stages of the sponsorship process, but they do not mean the same thing.

Stage	What it means
CoS allocation or approval	The sponsor has the capacity or permission to use the relevant CoS. This may involve an Undefined CoS available within the sponsor’s allocation or an approved Defined CoS.
CoS creation	The sponsor enters the worker and employment details into the SMS and prepares the individual CoS record.
CoS assignment	The sponsor confirms the completed CoS for that worker, completes the relevant declaration and payment process and formally assigns the certificate.
Immigration application	The worker uses the assigned CoS reference when applying for the relevant visa or permission to stay.

This distinction matters because having an available CoS does not mean that a worker has been sponsored. Equally, creating a draft CoS in the SMS does not complete the sponsorship process.

The CoS has to be formally assigned before the worker can rely on it in support of the relevant sponsored work application.

 

1. What does the sponsor confirm by assigning a CoS?

Assignment is more than an administrative action within the Sponsor Management System.

By assigning the certificate, the sponsor is formally sponsoring the individual under the relevant immigration route and for the role described on the CoS. The sponsor is responsible for ensuring that the information provided is accurate and that the proposed sponsorship satisfies the relevant requirements.

The sponsor should therefore be satisfied before assignment that the information entered is accurate and that the proposed sponsorship meets the requirements applying to the worker and route.

This includes checking matters such as:

• the immigration route under which the worker will be sponsored;
• whether the correct type of CoS is being used;
• the worker’s identity and personal information;
• the job title and job description;
• the relevant occupation code;
• the worker’s salary and working hours;
• the proposed employment start and end dates;
• the worker’s normal work location or locations;
• any relevant third-party or client-site working arrangements; and
• any route-specific requirements that apply to the role or worker.

The information entered on the CoS should describe the genuine employment arrangements.

In particular, sponsors should not select an occupation code, alter a job description, manipulate working hours or state remuneration that does not reflect the genuine arrangements in an attempt to make a role appear eligible for sponsorship.

The job description and occupation code should reflect the work the sponsored worker will actually perform.

 

2. Does assigning a CoS grant the worker a visa?

No. Assignment of a Certificate of Sponsorship does not grant immigration permission and does not guarantee that the worker’s immigration application will be successful.

The CoS is part of the sponsorship information supporting the worker’s application.

After assignment, the worker will generally need to make their own application under the relevant immigration route and satisfy the applicable immigration requirements. UK Visas and Immigration will then determine whether permission should be granted.

This distinction is important for employers planning recruitment and employment start dates. A worker should not be treated as having permission to work simply because a CoS has been assigned.

The employer will still need to establish that the individual has the required permission to undertake the proposed work and complete the prescribed right to work check before employment begins where required.

An assigned CoS is therefore not evidence of a right to work.

 

3. Can an employer reserve a CoS for a worker without assigning it?

An available CoS and an assigned CoS are different things.

For an Undefined CoS, the sponsor may have certificates available within its allocation without those certificates yet being assigned to individual workers.

Similarly, where a Defined CoS is required, obtaining approval for the Defined CoS is not the same as completing the assignment process.

This distinction gives the sponsor an opportunity to carry out its final eligibility and compliance checks before formally assigning the certificate.

Employers should use this stage carefully. The existence of available Undefined CoS allocation or an approved Defined CoS should not be treated as a reason to assign automatically.

The sponsor should first be satisfied that the particular worker and role remain suitable for sponsorship and that the information to be recorded on the certificate is correct.

 

4. Why does the point of assignment matter?

Assignment creates an important dividing line in the sponsorship process.

Before assignment, the sponsor can review the proposed sponsorship and correct information while preparing the CoS. After assignment, the certificate has been formally assigned to the worker for use in their immigration application.

This makes the pre-assignment review particularly important.

Employers should avoid treating the SMS as a simple data-entry system where substantive mistakes can always be corrected later. Once assigned, a CoS cannot simply be reopened and freely amended as though it remained a draft.

Some post-assignment issues can be dealt with using the appropriate SMS functionality, including a sponsor note where permitted. Other errors can be sufficiently material that a different course of action, potentially including a replacement CoS, needs to be considered.

Additional care is required with an approved Defined CoS. A Defined CoS is approved on the basis of the information provided by the sponsor when requesting it. While certain limited information can be changed in accordance with the sponsor guidance, material changes can affect whether the approved Defined CoS can still be used. Changes to matters such as the occupation code, job description or other material details should therefore be assessed before assignment rather than assuming they can simply be corrected afterwards.

The safest approach is to identify substantive problems before the certificate is assigned.

The next stage is therefore to establish whether the sponsor is actually in a position to make the assignment and whether the proposed worker and role have passed the necessary pre-assignment checks.

 

 

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Section D: What Should Employers Check Before Assigning a CoS?

Before assigning a Certificate of Sponsorship, the employer should carry out a final check that both the organisation and the proposed sponsorship meet the requirements of the relevant immigration route.

This is one of the most important stages of the assignment process. The Sponsor Management System allows an authorised user to create and assign a CoS, but the sponsor remains responsible for determining whether it is permitted to sponsor the worker and whether the information recorded on the certificate is correct.

The checks required will depend on the immigration route and the worker’s circumstances, but employers should consider the following areas before proceeding with assignment.

 

1. Is the sponsor licence active?

The organisation must have the necessary sponsor licence in place and be authorised to sponsor workers under the relevant route.

A sponsor cannot assign a CoS while its licence is suspended, dormant or revoked.

Restrictions also apply where a sponsor has been downgraded to a B-rating. A B-rated sponsor is generally unable to assign a CoS to sponsor a new worker.

There is a limited exception where an existing sponsored worker is applying for permission to stay from within the UK on the same route, was sponsored by the same organisation for their previous grant of permission and will continue to be sponsored by that organisation.

Employers should therefore check their current licence status before beginning the assignment process, particularly where there has recently been Home Office compliance action, a downgrade, suspension or another change affecting the licence.

 

2. Is the organisation licensed for the correct immigration route?

A sponsor licence does not give an employer unrestricted authority to sponsor workers under every sponsored work route.

The organisation must hold the relevant route on its sponsor licence.

For example, an organisation intending to sponsor a worker under the Skilled Worker route must be authorised as a Skilled Worker sponsor. Different sponsorship arrangements apply to other Worker and Temporary Worker routes.

Employers should therefore identify the immigration route first and confirm that the organisation has the necessary authorisation before assigning the certificate.

 

3. Is the correct type of CoS available?

The sponsor must determine which type of Certificate of Sponsorship is required.

For Skilled Worker sponsorship, a Defined Certificate of Sponsorship is generally required where the worker will be making an application for entry clearance from outside the UK.

An Undefined Certificate of Sponsorship is generally required where a Skilled Worker will be applying for permission to stay from within the UK. Undefined CoS are also used for eligible workers under other sponsored work routes.

The sponsor must have the appropriate Undefined CoS available within its allocation or, where a Defined CoS is required, have obtained approval for the Defined CoS before it can be assigned.

Employers should not assume that Defined and Undefined CoS are interchangeable. Assigning the wrong type of certificate can create problems with the worker’s immigration application and may require corrective action before the application can proceed.

 

4. Is the job eligible for sponsorship?

Before assigning a CoS, the sponsor should confirm that the proposed role is eligible under the immigration route being used.

For Skilled Worker sponsorship, this includes identifying the appropriate occupation code and ensuring that the role meets the applicable skill and other route requirements.

The occupation code should be selected by reference to the work the individual will actually perform rather than simply choosing the code with the most convenient eligibility or salary requirements.

The job title alone will not necessarily determine the correct occupation code. Employers should consider the actual duties and responsibilities of the role and ensure that the description entered on the CoS accurately reflects them.

Where the Home Office considers that an inappropriate occupation code has been selected, or that a role has been structured or described primarily to obtain immigration permission, this can affect both the worker’s application and the sponsor’s compliance position.

 

5. Does the salary meet the applicable requirements?

The proposed salary should be checked before the CoS is assigned.

The applicable salary requirement will depend on the immigration route and, for routes such as Skilled Worker, potentially the occupation, the worker’s circumstances and whether any permitted alternative salary provisions apply.

Employers should check both the salary being stated on the CoS and the basis on which the relevant immigration salary requirement is being met.

This is particularly important where remuneration includes allowances, bonuses, overtime or other payments, since not every element of a worker’s remuneration will necessarily count towards the relevant immigration salary requirement.

The salary stated on the CoS should correspond with the genuine employment arrangements and the amount the sponsor actually intends to pay the worker.

 

6. Is the occupation code correct?

Selecting the correct occupation code is a separate exercise from deciding whether the salary is sufficient.

Sponsors should identify the code that most accurately corresponds to the job being offered.

The Home Office can consider the job description, duties, required skills, salary and other information when assessing whether the occupation code used by the sponsor is appropriate.

The sponsor should therefore be able to explain why the selected occupation code accurately reflects the role.

Using an incorrect code can have consequences beyond the individual immigration application. Where the Home Office considers that a sponsor has deliberately selected an inappropriate occupation code to make a worker or role eligible for sponsorship, this may raise wider sponsor compliance concerns.

 

7. Can the worker be sponsored under the proposed route?

The fact that a job is capable of sponsorship does not necessarily mean that every individual can be sponsored for it.

The employer should consider whether the worker’s circumstances are compatible with the immigration route being used.

For example, where the individual is already in the UK, their current immigration status may affect whether they can apply for permission to stay under the proposed route from within the UK or whether they would need to make an application for entry clearance from overseas.

The sponsor should also identify any worker-specific requirements that need to be addressed before the CoS is assigned.

The employer does not determine the worker’s immigration application — that remains a decision for UK Visas and Immigration — but the sponsor should not assign a CoS where it knows that the proposed sponsorship does not meet the relevant requirements.

 

8. Does the proposed employment relationship qualify for sponsorship?

The sponsor should be satisfied that it is genuinely responsible for the role for which the worker is being sponsored.

Sponsored workers cannot simply be supplied to another organisation to fill a routine position or undertake an ongoing role for a third party where the arrangement falls outside the sponsorship rules.

This issue can be particularly important for consultancy businesses, professional service firms, technology companies, contractors and organisations whose employees regularly work at client sites.

Working at a client’s premises does not automatically prevent sponsorship. The relevant issue is the nature of the arrangement and whether the sponsor retains responsibility for the worker and is sponsoring them to perform an eligible role for the sponsor, rather than effectively supplying labour to fill a position with another organisation.

Where third-party working arrangements are involved, the structure should be checked before the CoS is assigned.

 

9. Are the proposed employment dates realistic?

The employment start and end dates entered on the CoS should reflect the genuine proposed arrangements and take account of the immigration application timetable.

For Skilled Worker applications, an assigned CoS generally has to be used in support of an immigration application within three months of the date it is assigned. A Skilled Worker must also not apply more than three months before the employment start date recorded on the CoS.

Sponsors should therefore avoid assigning a CoS unnecessarily early.

Equally, where recruitment is time-sensitive, the employer should allow sufficient time for the worker to prepare and submit the immigration application, receive a decision and satisfy the employer’s right to work requirements before commencing employment.

 

10. Are there any route-specific requirements to address?

Depending on the route, worker and occupation, additional requirements may need to be considered before assignment.

These can include matters such as:

• Academic Technology Approval Scheme requirements where applicable;
• professional registration or regulatory requirements;
• specific requirements relating to the immigration route;
• additional information concerning the worker’s role or working arrangements;
• contractual arrangements where the worker will provide services to a third party;
• maintenance certification where relevant;
• recruitment or intermediary information where required; and
• any particular evidence the sponsor may need to retain.

Employers should identify these issues before assigning the certificate rather than discovering them after the worker has started the immigration application process.

The purpose of the pre-assignment review is ultimately straightforward: before the sponsor commits the CoS to the worker, it should be satisfied that the organisation can sponsor, the worker can properly be sponsored, the job qualifies and the information that will appear on the certificate is accurate.

Once those checks have been completed, the next issue is identifying who within the organisation is permitted to carry out the assignment in the Sponsor Management System.

 

 

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Section E: Who Can Assign a Certificate of Sponsorship?

A Certificate of Sponsorship can only be assigned through the Sponsor Management System by an SMS user who has the necessary permission to carry out the transaction.

Employers should therefore ensure that responsibility for CoS assignment is given to appropriately authorised personnel who understand both how to use the SMS and the immigration compliance implications of assigning a certificate.

The ability to access the SMS should not be confused with authority to make sponsorship decisions. An organisation should have internal controls governing who can approve a worker for sponsorship, who can prepare the CoS and who can complete the final assignment.

 

1. Level 1 Users

Level 1 Users have broad access to the Sponsor Management System and can carry out day-to-day sponsor licence management functions, including creating and assigning Certificates of Sponsorship where the relevant permissions apply.

For many sponsors, a Level 1 User will therefore be the person who completes the CoS assignment.

Employers should ensure that Level 1 Users are properly trained and understand the significance of the information they enter into the SMS. The Home Office can assess the sponsor’s systems and controls when considering whether the organisation is meeting its sponsorship duties.

Access to the SMS should therefore be treated as a compliance responsibility rather than simply an administrative function.

 

2. What is happening to Level 2 Users?

The Home Office introduced changes to the Level 2 User role in September 2026.

From 9 September 2026, sponsors can no longer appoint new Level 2 Users.

Existing Level 2 Users can continue to carry out their permitted functions during the transitional period. This can include creating and assigning Certificates of Sponsorship and reporting activity relating to certificates they personally created or assigned, or which have been transferred to them, subject to the permissions applying to their account.

Sponsors should review any existing Level 2 accounts and decide whether the individual should be converted to a Level 1 User, where eligible, or whether their SMS access should be deactivated.

The transition must be completed by 8 March 2027. Remaining Level 2 accounts are due to be deactivated by the Home Office after the transitional arrangements end.

Employers relying on Level 2 Users for CoS assignment should therefore review their SMS user arrangements now rather than waiting until the transition deadline.

 

3. Does the Authorising Officer have to assign the CoS?

No. The Authorising Officer does not have to assign each Certificate of Sponsorship personally.

The Authorising Officer is the senior person responsible for the sponsor licence and for ensuring that appropriate sponsorship systems and controls are maintained, but appointment as Authorising Officer does not automatically give that individual access to the Sponsor Management System.

If an Authorising Officer needs to use the SMS, they must also hold an appropriate SMS user role, such as being appointed as a Level 1 User.

This distinction is important for governance. The Authorising Officer can retain overall responsibility for sponsorship compliance while authorised Level 1 Users carry out operational tasks such as preparing and assigning individual CoS.

However, delegating the SMS transaction does not remove the sponsor’s responsibility for the accuracy and compliance of the sponsorship decision.

 

4. Can an SMS user assign a CoS to themselves?

As a general rule, an SMS user must not assign a Certificate of Sponsorship to themselves.

Restrictions also apply to assigning a CoS to the user’s partner or close relative.

This is designed to prevent conflicts of interest in the sponsorship process.

There is a specific exception affecting certain UK Expansion Worker sponsors with a Provisional rating, where the relevant Authorising Officer, who must also be the Level 1 User, may need to assign their own CoS in accordance with the requirements of that route.

Outside an applicable exception, employers should ensure that a different authorised SMS user carries out the assignment where the proposed sponsored worker is the SMS user, their partner or their close relative.

 

5. What if the worker is related to somebody else working for the sponsor?

A separate disclosure issue can arise where an SMS user assigns a CoS to the partner or close relative of another person working for the sponsor.

Where the SMS user knows, or could reasonably be expected to know, about that relationship, the sponsor should ensure that the required information is disclosed through the appropriate SMS functionality, including by adding a sponsor note where required under the sponsor guidance.

This is different from the prohibition on an SMS user assigning a CoS to their own partner or close relative.

Employers with family-owned businesses, closely held companies or organisations where several family members work within the business should pay particular attention to these requirements.

 

6. Can an external representative assign a CoS?

External representatives can be given certain SMS responsibilities where the sponsor guidance permits this and the individual has been appointed to an appropriate key personnel or SMS user role.

However, using an immigration adviser or other external representative does not transfer the sponsor’s legal and compliance responsibilities to the adviser.

The licensed organisation remains responsible for the sponsorship of its workers and for ensuring that information provided through its sponsor licence is accurate.

An employer should therefore have sufficient internal oversight to understand:

• which workers are being sponsored;
• why they qualify for sponsorship;
• which immigration route is being used;
• which CoS is being assigned;
• what information is being entered into the SMS;
• what declarations are being made on the sponsor’s behalf; and
• what records are being retained to support the sponsorship decision.

Outsourcing the administrative process should not result in the organisation losing control of its sponsor licence.

 

7. Should the person assigning the CoS also approve the sponsorship?

The Home Office sponsorship system does not require every organisation to operate the same internal approval structure, but sponsors should have controls appropriate to the size and complexity of their sponsorship activity.

For an organisation that sponsors workers regularly, it can be useful to separate the stages of the process.

For example:

1. Recruitment or HR confirms the proposed worker and employment terms.
2. Immigration or compliance personnel check the route, occupation code, salary and sponsorship requirements.
3. An authorised decision-maker approves the sponsorship.
4. The SMS user creates or completes the CoS.
5. A final check is carried out before assignment.
6. The authorised SMS user assigns the certificate.

For smaller sponsors, one individual may perform several of these functions. The important point is that the organisation should still have a reliable process for checking the sponsorship decision before the certificate is assigned.

 

8. SMS access and multi-factor authentication

Sponsors should also take account of the Home Office’s introduction of mandatory multi-factor authentication for Sponsor Management System users.

The Home Office began phasing in multi-factor authentication for existing SMS users from 3 September 2026, with implementation being extended across sponsor accounts. For organisations granted a sponsor licence on or after 9 September 2026, multi-factor authentication forms part of the current SMS access arrangements.

Where multi-factor authentication has been enabled, the SMS user will need to complete the additional authentication step, including use of the required one-time passcode, when accessing the system.

Employers should ensure that authorised SMS users can access the authentication method linked to their account and should not leave access arrangements until a CoS needs to be assigned urgently.

SMS credentials and authentication methods should remain under the control of the individual authorised user. Users should not share login credentials or allow another person to operate the SMS through their account.

 

9. Internal control over CoS assignment

Regardless of who performs the transaction, employers should be able to identify who authorised and who assigned each Certificate of Sponsorship.

A proportionate internal record could document:

• the worker being sponsored;
• the relevant immigration route;
• the type of CoS used;
• the occupation code;
• the approved salary and working hours;
• the proposed employment dates;
• who checked eligibility;
• who approved sponsorship;
• who entered the information into the SMS;
• who carried out the final review; and
• who assigned the CoS.

This provides an audit trail if the sponsorship decision is subsequently questioned and helps the organisation demonstrate that CoS assignment is subject to an appropriate compliance process.

Once the appropriate SMS user has been identified, the next question is whether the worker requires a Defined or Undefined Certificate of Sponsorship.

 

 

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Section F: Defined or Undefined CoS: Which Do You Assign?

Before assigning a Certificate of Sponsorship, the employer must determine whether the worker requires a Defined Certificate of Sponsorship or an Undefined Certificate of Sponsorship.

The distinction is important because the two types of CoS are obtained and managed differently within the Sponsor Management System. Using the wrong type can prevent the worker from relying on the certificate for the intended immigration application and may require corrective action.

For Skilled Worker sponsorship, the key distinction generally depends on the type of immigration application the worker will make.

 

1. When is a Defined CoS required?

A Defined Certificate of Sponsorship is generally required for a worker applying for entry clearance as a Skilled Worker from outside the UK.

The sponsor does not receive an annual allocation of Defined CoS in the same way as Undefined CoS. Instead, the sponsor applies through the Sponsor Management System for a Defined CoS when one is required.

The application requires information about the proposed role and sponsorship. Once the Defined CoS has been approved, it becomes available in the SMS for assignment to the relevant worker.

Approval of the Defined CoS and assignment of the Defined CoS are therefore separate stages:

1. The sponsor identifies the need to sponsor a Skilled Worker who will apply for entry clearance from outside the UK.
2. The sponsor applies for a Defined CoS through the SMS.
3. The Home Office considers the Defined CoS application.
4. If approved, the Defined CoS becomes available to the sponsor.
5. The sponsor completes the required worker details and final checks.
6. The approved Defined CoS is assigned to the worker.
7. The worker uses the assigned CoS reference when making their Skilled Worker application.

An approved Defined CoS should not be treated as interchangeable with another sponsorship case merely because the sponsor has received approval. The sponsor should ensure that the certificate being assigned corresponds with the genuine role and sponsorship arrangements for which approval was obtained.

 

2. When is an Undefined CoS required?

An Undefined Certificate of Sponsorship is generally used where a Skilled Worker is applying for permission to stay from within the UK.

Undefined CoS are also used for eligible workers under other sponsored work routes where a Defined CoS is not required.

For sponsors that regularly use Undefined CoS, the certificates will generally be assigned from the organisation’s available Undefined CoS allocation.

Before attempting assignment, the employer should therefore check that it has sufficient allocation available.

If the sponsor does not have an Undefined CoS available, it may need to request additional allocation through the Sponsor Management System before it can assign the certificate.

The process for obtaining additional allocation is separate from the process of assigning an individual CoS and should be dealt with before the employer reaches the final assignment stage.

 

3. Is the worker’s physical location enough to determine the CoS type?

No. Employers should avoid reducing the distinction to a simple rule that everyone outside the UK requires a Defined CoS and everyone inside the UK requires an Undefined CoS.

The important question for Skilled Worker sponsorship is the type of immigration application the worker will make.

A Defined CoS is used for a Skilled Worker making an application for entry clearance from outside the UK.

An Undefined CoS is used for a Skilled Worker making an application for permission to stay from within the UK.

Undefined CoS are also used under other relevant sponsored work routes, including in circumstances where the worker may be applying from overseas.

The sponsor should therefore identify the immigration route and application type before deciding which certificate to use.

 

4. Can a Defined CoS be used instead of an Undefined CoS?

No. Defined and Undefined Certificates of Sponsorship should not be treated as interchangeable.

If the worker requires an Undefined CoS, the sponsor should assign the appropriate Undefined certificate from its available allocation.

If the worker requires a Defined CoS, the sponsor should follow the Defined CoS process and obtain approval before completing the assignment.

The fact that one type of certificate happens to be available in the SMS does not make it suitable for a worker who requires the other type.

 

5. What if the sponsor has no Undefined CoS available?

If an Undefined CoS is required but the sponsor does not have sufficient allocation available, the employer cannot simply substitute a Defined CoS.

The sponsor will need to consider the appropriate process for obtaining additional Undefined CoS allocation through the Sponsor Management System.

Employers planning sponsored recruitment should monitor their available allocation rather than waiting until a worker is ready to make an immigration application.

A shortage of allocation can delay assignment and, in turn, delay the worker’s immigration application and proposed employment start date.

 

6. What if a Defined CoS has been approved but the job changes?

Additional care is required where a Defined CoS has already been approved but the proposed employment arrangements change before assignment.

The Defined CoS was approved on the basis of information supplied by the sponsor when making the request. Employers should not therefore assume that any change can simply be made when the certificate is assigned.

Current sponsor guidance permits certain limited changes in appropriate circumstances, but material changes can affect whether the approved Defined CoS can still be used.

Changes involving matters such as the occupation code, job description, salary, working hours or other material aspects of the proposed role should be checked against the applicable sponsor guidance before assignment.

Where a proposed change falls outside what is permitted, the sponsor may need to notify the Home Office and the Defined CoS may need to be cancelled rather than assigned on materially different terms.

The practical rule for employers is therefore to compare the approved Defined CoS with the final employment arrangements before assignment.

 

7. What should employers check before selecting the CoS?

Before proceeding, the sponsor should be able to answer the following questions:

• Which immigration route will the worker use?
• Will the worker make an application for entry clearance or permission to stay?
• Does the application require a Defined or Undefined CoS?
• If an Undefined CoS is required, does the sponsor have sufficient allocation available?
• If a Defined CoS is required, has the appropriate Defined CoS been approved?
• Does the approved Defined CoS still correspond with the role the worker will actually perform?
• Have there been any material changes since the Defined CoS was requested?
• Is the certificate being assigned to the correct worker and for the correct role?

Only once the correct type of CoS has been identified and is available for assignment should the employer move to preparing the detailed worker and employment information that will be entered into the Sponsor Management System.

 

 

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Section G: What Information Do You Need Before Assigning a CoS?

Before starting the final Certificate of Sponsorship assignment process, employers should gather the information needed to complete the CoS accurately.

Preparing the information in advance reduces the risk of inconsistent data being entered into the Sponsor Management System and allows the organisation to carry out its substantive immigration compliance checks before the certificate is assigned.

The exact information required will depend on the immigration route and the worker’s circumstances, but sponsors should generally have the following information available.

 

1. Worker details

The sponsor will need the worker’s personal information to create and assign the CoS.

This can include:

• full name;
• date of birth;
• nationality;
• country of residence;
• passport or travel document information where required;
• the worker’s current UK immigration status where relevant; and
• other personal information required by the SMS.

The information should be checked against reliable documentation rather than entered from memory or copied from an earlier recruitment record without verification.

Names, dates of birth and other identifying information should be entered accurately. Even apparently minor errors can create unnecessary complications when the worker subsequently makes their immigration application.

 

2. Immigration route

The employer should know which sponsored work route will be used before creating the certificate.

The immigration route affects:

• whether the sponsor is authorised to sponsor the worker;
• whether a Defined or Undefined CoS is required;
• the eligibility requirements applying to the role;
• the salary requirements;
• the information that must be entered on the CoS;
• whether the Immigration Skills Charge may apply; and
• any additional route-specific requirements.

The CoS should not be created first with the immigration route considered afterwards. Route selection is part of the underlying sponsorship decision.

 

3. Job title

The sponsor will need to provide the job title for the role being sponsored.

The title should accurately describe the position the worker will hold.

Employers should avoid changing or inflating job titles simply to make a role appear to fall within a particular occupation code. The Home Office can look beyond the title to the actual duties and responsibilities of the role.

 

4. Job description

The job description should explain what the sponsored worker will actually do.

This is particularly important because the job description provides context for the occupation code selected by the sponsor.

The description should be sufficiently specific to demonstrate the genuine nature of the role and its principal responsibilities without being artificially drafted around immigration terminology.

Where an employer uses a standard internal job description, it should check that the description remains accurate for the particular role being sponsored.

 

5. Occupation code

The sponsor must identify the appropriate occupation code for the role.

The code should be selected by considering the worker’s actual duties and responsibilities rather than relying solely on the job title.

The occupation code can affect whether the role qualifies for sponsorship and the salary requirements that apply. Selecting the wrong code can therefore affect the validity of the sponsorship decision.

The employer should retain an appropriate record of how the occupation code was selected where this forms part of its sponsorship compliance process.

 

6. Salary

The sponsor will need to enter the worker’s salary and should establish in advance whether the remuneration satisfies the requirements of the relevant immigration route.

The employer should consider:

• the worker’s basic gross salary;
• the relevant salary threshold;
• the applicable salary requirement for the occupation where relevant;
• whether any permitted alternative or discounted salary provisions apply;
• which elements of remuneration can be counted for immigration purposes; and
• whether the salary entered on the CoS corresponds with the employment contract and the amount the worker will actually receive.

Where salary is calculated by reference to hourly pay, weekly hours or another variable arrangement, the employer should ensure that the figures entered on the CoS are internally consistent.

 

7. Weekly working hours

The worker’s normal weekly working hours should be confirmed before the certificate is assigned.

Hours can be relevant to the assessment of salary and whether the proposed remuneration satisfies the applicable immigration requirements.

The figure entered on the CoS should reflect the genuine contractual working arrangements.

Employers should be particularly careful where workers have variable hours, shift patterns or contractual arrangements that do not fit a standard working week.

 

8. Employment start and end dates

The sponsor will need to provide the proposed employment dates.

The start date should be realistic and should take account of the expected immigration application process.

For Skilled Worker applications, the timing of assignment, the date of the worker’s immigration application and the employment start date are connected. An assigned CoS generally needs to be used for the immigration application within three months of assignment, and a Skilled Worker must not apply more than three months before the start date stated on the CoS.

Employers should therefore coordinate recruitment, sponsorship and onboarding rather than selecting an arbitrary start date.

The proposed end date should likewise reflect the genuine period for which the worker is being sponsored.

 

9. Work location

The sponsor should identify where the worker will normally carry out their sponsored employment.

Depending on the working arrangements, this may involve:

• the sponsor’s principal office;
• another branch or site operated by the sponsor;
• more than one regular work location;
• home working;
• hybrid working arrangements; or
• work at a client or third-party location.

The information entered should reflect the genuine working arrangements.

Where the worker will work at multiple locations or the arrangements are expected to change, the sponsor should also consider its ongoing SMS reporting obligations.

 

10. Third-party and client-site working

Where the worker will provide services at a client site or another third-party location, the sponsor should understand the commercial and contractual arrangement before assigning the CoS.

The sponsor should be satisfied that it remains responsible for the sponsored employment and that the arrangement does not amount to prohibited supply of the worker to fill an ongoing routine role for another organisation.

Depending on the circumstances, the employer may need information about:

• the end client;
• the nature of the project or services;
• where the work will be performed;
• the duration of the arrangement;
• who directs and manages the worker;
• the contractual relationship between the sponsor and the client; and
• the duties the sponsored worker will actually perform.

These issues should be resolved before assignment rather than after the worker has started work at the third-party location.

 

11. Maintenance certification

Depending on the immigration route and the worker’s circumstances, the sponsor may need to state whether it certifies maintenance for the worker.

The employer should decide whether it is willing and permitted to provide the relevant certification before completing the CoS.

The answer entered in the SMS should reflect the sponsor’s actual position rather than being selected automatically from a previous certificate.

 

12. ATAS information

Where the Academic Technology Approval Scheme is relevant to the role, the sponsor should establish whether the worker requires an ATAS certificate and ensure that the applicable sponsorship requirements are addressed.

This is particularly relevant to certain roles involving research or academic activity in specified subject areas.

Where ATAS applies, it should be treated as part of the pre-assignment compliance process rather than left for consideration after the CoS has been assigned.

 

13. Recruitment agencies and intermediaries

Where a recruitment agency, employment business or other intermediary has been involved in recruiting the worker, the sponsor should retain the relevant information and provide any details required by the SMS or sponsor guidance.

The involvement of a recruitment agency does not transfer responsibility for the sponsorship decision away from the licensed sponsor.

The employer remains responsible for ensuring that the worker and role qualify for sponsorship and that the information entered on the CoS is accurate.

 

14. Route-specific information

Different sponsored work routes can require additional information that is not relevant to every CoS.

Employers should therefore check the current route-specific sponsor guidance before completing the certificate.

Depending on the route and circumstances, additional information or confirmation may be required concerning matters such as:

• the basis on which the worker qualifies for the route;
• salary arrangements;
• professional or regulatory requirements;
• the nature of the role;
• the worker’s relationship with the sponsor;
• contractual or third-party working arrangements;
• maintenance;
• ATAS; or
• other information required by the Home Office for that sponsorship category.

 

15. Use a pre-assignment information pack

For employers that sponsor workers regularly, collecting this information through a standard pre-assignment process can reduce errors and improve consistency.

A practical internal CoS information pack could bring together:

• worker identity information;
• immigration status and proposed route;
• Defined or Undefined CoS requirement;
• job description;
• occupation code;
• salary and hours;
• employment dates;
• work locations;
• third-party working information;
• maintenance decision;
• ATAS information where relevant;
• route-specific checks;
• approval to sponsor; and
• the identity of the person responsible for final CoS review and assignment.

The objective is to reach the SMS assignment stage with the sponsorship decision already checked and the necessary information available.

The SMS should then be used to record and complete the sponsorship decision, rather than becoming the place where fundamental questions about the worker’s eligibility, occupation code, salary or sponsorship route are first considered.

 

 

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Section H: Step-by-Step: How to Assign a Certificate of Sponsorship in the SMS

Once the employer has confirmed that the worker can be sponsored, identified the correct type of CoS and gathered the required information, the authorised SMS user can proceed with the assignment through the Sponsor Management System.

The precise screens and fields presented in the SMS can depend on the sponsorship route and type of CoS being assigned. Employers should follow the current Home Office SMS instructions displayed within the system and the relevant sponsor guidance.

The following provides the general process for creating and assigning a Certificate of Sponsorship.

 

1. Sign in to the Sponsor Management System

The authorised user should sign in to the Sponsor Management System using their own SMS credentials.

SMS credentials should not be shared between users. Each person accessing the system should use the account assigned to them.

The Home Office began phasing in mandatory multi-factor authentication for existing SMS users from 3 September 2026. For organisations granted a sponsor licence on or after 9 September 2026, multi-factor authentication forms part of the current SMS access arrangements.

Where multi-factor authentication has been enabled for the account, the user will need to complete the additional authentication process, including entering the required one-time passcode.

Sponsors should ensure that authorised users have functioning access to the required authentication method before an urgent CoS assignment is needed.

 

2. Select the relevant Certificate of Sponsorship function

Once logged in, the user should navigate to the relevant Certificate of Sponsorship area within the SMS.

The appropriate process will depend on whether the sponsor is:

• creating and assigning an Undefined CoS;
• assigning an approved Defined CoS;
• retrieving a CoS that has already been created and saved; or
• using permitted batch functionality for multiple certificates.

The sponsor should confirm at this stage that it is working with the correct sponsorship route and CoS type.

 

3. Create a new CoS or retrieve the correct existing record

If a new certificate needs to be created, the user should select the appropriate function and begin entering the required information.

If the CoS has already been prepared, the user should retrieve the correct record rather than creating a duplicate certificate unnecessarily.

A certificate that has been started but is not yet complete may appear with the relevant work-in-progress status within the SMS.

Where all mandatory information has been completed and the certificate is ready for final assignment, the CoS may show as “READY TO GO”.

Employers should confirm that they have selected the correct worker and certificate before proceeding.

 

4. Enter and check the worker’s personal details

The sponsor should enter the worker information requested by the SMS.

This can include the individual’s:

• full name;
• date of birth;
• nationality;
• country of residence;
• passport or travel document details where required; and
• other identifying information required for the relevant route.

The information should be checked against the worker’s supporting documentation.

Employers should take particular care with names, dates of birth and nationality. Errors at this stage can create discrepancies between the CoS and the worker’s subsequent immigration application.

 

5. Enter the job details and occupation code

The sponsor should enter the job title, job description and relevant occupation code.

The occupation code should already have been checked as part of the employer’s pre-assignment process.

The job description should accurately reflect the duties the worker will perform and should be consistent with the occupation code selected.

The employer should not rely solely on the job title when determining the occupation code. The substantive duties and responsibilities of the role are the key consideration.

Where a Defined CoS has already been approved, the sponsor should also ensure that the role being entered or confirmed at assignment remains consistent with the basis on which the Defined CoS was approved.

 

6. Enter the salary and working hours

The sponsor should enter the worker’s salary and normal working hours as required by the SMS.

The figures should correspond with the genuine employment arrangements and should have been checked against the applicable immigration requirements before assignment.

Employers should ensure that:

• the salary is entered accurately;
• the stated working hours are correct;
• the figures are consistent with the employment contract;
• the salary satisfies the relevant immigration requirements; and
• only remuneration that can properly be taken into account for the relevant immigration requirement has been relied upon.

Salary errors can be particularly significant because they may affect whether the worker qualifies under the relevant immigration route.

 

7. Enter the employment start and end dates

The sponsor should enter the proposed dates of employment.

The dates should reflect the genuine intended sponsorship period and should be realistic in light of the worker’s immigration application timetable.

For Skilled Worker sponsorship, an assigned CoS generally needs to be used in support of the immigration application within three months of assignment. A Skilled Worker must also not apply more than three months before the employment start date recorded on the CoS.

The employer should therefore avoid entering an arbitrary start date simply to complete the SMS form.

The date should form part of the organisation’s wider recruitment, immigration and onboarding timetable.

 

8. Enter the worker’s work location

The sponsor should provide the required information about where the worker will carry out their sponsored employment.

The details should reflect the genuine working arrangements, including relevant office, branch, home-working or client-site arrangements.

Where the worker will regularly work at more than one location, the employer should provide the required information and consider whether subsequent changes will trigger an SMS reporting obligation.

Client-site working should also be checked to ensure that the underlying arrangement is compatible with the sponsorship rules.

 

9. Complete the sponsorship and route-specific information

The SMS may require additional information depending on the immigration route and the worker’s circumstances.

This can include information relating to:

• maintenance certification;
• ATAS requirements;
• recruitment agencies or intermediaries;
• third-party working arrangements;
• professional or regulatory requirements;
• the basis on which the worker meets route-specific requirements; and
• other declarations or information required by the Home Office.

The sponsor should answer each question by reference to the actual circumstances of the worker and role rather than copying answers from an earlier CoS.

 

10. Review the complete CoS

Before selecting the final assignment option, the user should review the entire certificate.

This is the point at which the sponsor should compare the information entered into the SMS against the approved sponsorship information and supporting records.

The final review should cover at least:

• worker identity;
• immigration route;
• Defined or Undefined CoS type;
• job title;
• job description;
• occupation code;
• salary;
• weekly working hours;
• employment start and end dates;
• work location;
• maintenance certification where relevant;
• ATAS information where relevant;
• third-party arrangements;
• route-specific information; and
• any additional information or explanation entered on the certificate.

This should be treated as a substantive compliance review, not simply a check for typographical errors.

Once a CoS has been assigned, it cannot simply be reopened and freely amended in the same way as a certificate that remains in preparation.

 

11. Complete the declaration

Once the user is satisfied that the CoS is correct, they can proceed to the sponsor declaration.

The declaration should be read carefully before it is accepted.

By completing the assignment, the sponsor is formally sponsoring the worker for the role described on the certificate and is providing information to the Home Office through the Sponsor Management System.

The person completing the transaction should therefore be satisfied that they have the necessary authority and that the organisation has completed the appropriate checks.

 

12. Pay the CoS assignment fee and any applicable charges

The SMS will direct the user through the applicable payment process.

For a Worker Certificate of Sponsorship, the current CoS assignment fee is £525.

Different charges can apply to other categories of CoS, and sponsors should check the current Home Office fee schedule at the point of assignment.

Where the Immigration Skills Charge applies, the sponsor will also need to pay the relevant amount as part of the sponsorship process.

The employer should not assume that the CoS assignment fee and Immigration Skills Charge are the same charge. They are separate sponsorship costs.

 

13. Confirm the assignment

Once the required declaration and payment process has been completed, the user can confirm the assignment.

The SMS will then assign the certificate to the worker.

The status of the CoS should change to “ASSIGNED”, and a unique Certificate of Sponsorship reference number will be generated.

The employer should check that the assignment has completed successfully rather than assuming that reaching the payment stage means the transaction is finished.

 

14. Record the CoS reference number

The sponsor should retain the CoS reference as part of its sponsorship records and provide the necessary reference information to the worker.

The worker will need the reference when making the relevant immigration application.

The CoS itself remains an electronic record. There is no physical Certificate of Sponsorship that needs to be issued to the worker.

 

15. Provide the worker with the information needed for their application

Employers should ensure that the worker receives the correct CoS reference and understands the key sponsorship information relevant to their application.

Where appropriate, the employer should also ensure that the worker’s immigration application is consistent with the information recorded on the CoS, particularly in relation to:

• the sponsoring employer;
• job title;
• occupation code;
• salary;
• working hours;
• employment dates; and
• work location.

Material inconsistencies between the CoS and the worker’s application can result in queries, delay or other immigration issues.

 

16. Retain an audit trail of the assignment

The sponsor should retain an appropriate internal record of the sponsorship decision and assignment process.

Depending on the organisation’s procedures, this could include:

• the final approved job description;
• occupation code assessment;
• salary assessment;
• evidence of the approved employment terms;
• route eligibility checks;
• Defined or Undefined CoS decision;
• relevant third-party working information;
• internal sponsorship approval;
• the identity of the SMS user who assigned the CoS;
• the assigned CoS reference; and
• the date of assignment.

This provides evidence of how the sponsorship decision was reached if the Home Office subsequently reviews the worker’s sponsorship or the organisation’s sponsor licence.

The technical act of assigning the certificate may only take a short time once the information is available. The more important control is the final review immediately before the authorised SMS user commits the sponsorship by clicking “Assign”.

 

 

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Section I: What Should You Check Before Clicking “Assign”?

The final review before clicking “Assign” is one of the most important controls in the Certificate of Sponsorship process.

At this point, the employer is no longer simply preparing a draft record. Assignment formally commits the CoS to the worker and enables the worker to use the unique CoS reference in support of their immigration application.

Employers should therefore use a structured pre-assignment check rather than relying on the SMS user to review individual fields informally.

The following checks provide a practical framework.

 

1. Worker eligibility checks

Confirm that the certificate is being assigned to the correct individual and that the proposed sponsorship remains appropriate for that worker.

Check:

• the worker’s full name and identifying information;
• nationality and country of residence where relevant;
• current immigration status where relevant;
• the immigration route being used;
• whether the worker will make an application for entry clearance or permission to stay;
• whether any restrictions affect the worker’s ability to make the proposed application;
• whether worker-specific route requirements have been considered; and
• whether there has been any material change in the worker’s circumstances since sponsorship was approved internally.

The employer should not assign the CoS simply because the recruitment process has been completed. Sponsorship eligibility should form a separate part of the decision.

 

2. Correct CoS checks

Confirm that the correct Certificate of Sponsorship is being assigned.

Check:

• whether a Defined or Undefined CoS is required;
• whether the correct sponsorship route has been selected;
• whether sufficient Undefined CoS allocation is available, where applicable;
• whether the correct Defined CoS has been approved, where applicable;
• whether the certificate relates to the intended worker;
• whether the approved Defined CoS still reflects the proposed role; and
• whether any material changes have occurred since a Defined CoS was approved.

Defined and Undefined CoS should not be treated as interchangeable.

Where an approved Defined CoS no longer reflects the proposed employment, the sponsor should check whether the change is permitted before proceeding. Material changes can mean that the existing Defined CoS should not be assigned.

 

3. Job and occupation code checks

Confirm that the role recorded on the CoS accurately describes the job the worker will actually perform.

Check:

• the job title;
• the substantive duties;
• the job description entered on the CoS;
• the occupation code;
• whether the occupation code corresponds with the actual duties;
• whether the role satisfies the requirements of the relevant immigration route; and
• whether the role is genuine and has not been structured primarily to obtain immigration permission.

The employer should be able to explain why the selected occupation code is appropriate if the Home Office subsequently examines the sponsorship decision.

 

4. Salary and working hours checks

Salary information should be checked independently before assignment.

Confirm:

• the worker’s basic gross salary;
• normal weekly working hours;
• the relevant immigration salary requirement;
• any occupation-specific salary requirement;
• whether any permitted alternative or discounted salary provision is being relied upon;
• whether the worker genuinely qualifies for that provision;
• which elements of remuneration can be counted for immigration purposes;
• whether the salary and hours entered into the SMS are mathematically consistent; and
• whether the CoS information corresponds with the worker’s employment contract or offer.

Employers should not assume that a figure is correct simply because it has been copied from payroll, recruitment documentation or a previous CoS.

The salary assessment should reflect the immigration rules applying at the date of sponsorship.

 

5. Work location and employment arrangement checks

Confirm that the work location information accurately reflects the intended arrangements.

Check:

• the worker’s principal work location;
• any regular additional locations;
• home or hybrid working arrangements where relevant;
• client-site working;
• third-party contractual arrangements; and
• whether the sponsor will remain responsible for the sponsored employment.

Where the worker will provide services to a client or work at a third-party location, the sponsor should be satisfied that the arrangement is compatible with the sponsorship rules and does not amount to prohibited labour supply.

 

6. Employment date checks

Confirm that the employment dates are accurate and realistic.

Check:

• the proposed employment start date;
• the proposed employment end date;
• the expected immigration application timetable;
• whether the worker will be able to use the CoS within the applicable period;
• whether the immigration application will be made at an appropriate time in relation to the proposed start date; and
• whether the recruitment team understands that the worker cannot simply begin sponsored employment because the CoS has been assigned.

For Skilled Worker applications, an assigned CoS generally needs to be used for the immigration application within three months of assignment. A Skilled Worker must not apply more than three months before the employment start date stated on the CoS.

 

7. Route-specific checks

Confirm that any additional requirements applying to the worker or immigration route have been addressed.

Depending on the circumstances, this can include:

• maintenance certification;
• ATAS requirements;
• professional registration;
• route-specific eligibility provisions;
• recruitment or intermediary information;
• third-party working arrangements; and
• any additional information required to explain the sponsorship.

The sponsor should not rely on the SMS to identify every substantive immigration issue. Some eligibility requirements have to be assessed by the employer before the information is entered into the system.

 

8. Sponsor licence checks

The employer should confirm that there is no sponsor licence issue preventing assignment.

Check:

• that the sponsor licence remains active;
• that the organisation is licensed for the relevant route;
• that the licence is not suspended, dormant or revoked;
• whether the sponsor is A-rated or B-rated;
• whether any B-rating restrictions affect the proposed assignment;
• that the SMS user has the appropriate permission to assign the CoS;
• that no conflict-of-interest restriction prevents that user from making the assignment; and
• that any necessary internal approval has been obtained.

A B-rated sponsor is generally unable to assign a CoS to sponsor a new worker. A limited exception can apply where an existing sponsored worker is applying for permission to stay from within the UK on the same route, was sponsored by the same organisation for their previous grant and will continue to be sponsored by that organisation.

 

9. SMS user and relationship checks

The sponsor should confirm that the person carrying out the transaction is permitted to assign the certificate.

An SMS user must not generally assign a CoS to themselves, their partner or their close relative, subject to the limited exceptions provided for in the sponsor guidance.

Where the SMS user knows, or could reasonably be expected to know, that the proposed worker is the partner or close relative of another person working for the sponsor, the organisation should also check whether the relationship needs to be disclosed through the appropriate SMS functionality, including by adding a sponsor note where required.

Any such relationship should be identified before the assignment is completed.

 

10. Charges and payment checks

Before proceeding, establish which sponsorship charges will become payable.

These can include:

• the Certificate of Sponsorship assignment fee; and
• the Immigration Skills Charge where applicable.

The employer should also check whether an exemption from the Immigration Skills Charge applies rather than assuming that the charge is payable in every sponsorship case.

Responsibility for these costs should be understood internally before the transaction is completed.

For Skilled Worker CoS assigned on or after 31 December 2024, sponsors must not recoup or attempt to recoup the CoS fee or associated administrative costs from the sponsored worker.

Equivalent restrictions apply to specified other sponsored work routes for CoS assigned on or after 9 April 2025.

The Immigration Skills Charge must also be paid by the sponsor and must not be passed on to the sponsored worker where the charge applies.

Breaching the Home Office restrictions on recovery of sponsorship costs can result in serious sponsor licence consequences.

 

11. Final SMS data check

The final stage should involve checking the information as it actually appears in the Sponsor Management System.

This is important because the underlying HR documentation can be correct while information has still been entered incorrectly into the SMS.

The reviewer should compare the final CoS record with the approved information and look specifically for:

• typing errors;
• incorrect dates;
• incorrect salary figures;
• incorrect weekly hours;
• the wrong occupation code;
• an inaccurate job description;
• incorrect work locations;
• the wrong worker;
• the wrong CoS type;
• incorrect route-specific answers; and
• information copied from another worker or previous CoS that does not apply to the current case.

A second-person review can be particularly valuable for sponsors that assign certificates frequently or operate a centralised immigration function.

 

12. The DavidsonMorris pre-assignment sequence

A practical way to structure the final review is to work through the sponsorship decision in the following order:

1. Eligibility – can this worker and role properly be sponsored?
2. Correct CoS – is this the right route and the right type of Certificate of Sponsorship?
3. Data – is the worker and employment information complete and accurate?
4. Validation – do the occupation code, salary, hours, dates, work location and route-specific requirements withstand review?
5. Charges – which fees and charges apply, and have prohibited cost-recovery arrangements been avoided?
6. Assignment – has the authorised SMS user completed the final review and assigned the correct certificate?
7. Worker application – does the worker have the correct CoS information to proceed with the immigration application?

This sequence separates the substantive sponsorship decision from the administrative SMS transaction.

Immediately before clicking “Assign”, the sponsor should be able to answer one final question:

Does this Certificate of Sponsorship accurately describe a genuine and eligible role that this organisation is entitled to sponsor this worker to perform?

If the answer is uncertain, the CoS should not be assigned until the issue has been resolved.

 

 

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Section J: How Much Does It Cost to Assign a Certificate of Sponsorship?

Employers should establish the full cost of sponsorship before assigning a Certificate of Sponsorship. Depending on the immigration route and the circumstances of the worker, the employer may need to pay both the Certificate of Sponsorship assignment fee and the Immigration Skills Charge.

These are separate charges. The CoS fee is payable for assigning the certificate, while the Immigration Skills Charge applies to certain sponsored workers and is calculated separately.

Sponsors should check the current Home Office fee schedule before assignment, since immigration and sponsorship fees can change.

 

1. Certificate of Sponsorship assignment fee

The current fee for assigning a Worker Certificate of Sponsorship is £525.

The fee is generally paid through the Sponsor Management System as part of the assignment process.

Different CoS fees can apply to certain other sponsorship categories, including Temporary Worker certificates and qualifying International Sportsperson assignments. Employers should therefore check the fee applying to the particular route rather than assuming that every CoS attracts the same charge.

The CoS assignment fee is separate from:

• the Immigration Skills Charge;
• the worker’s visa application fee;
• the Immigration Health Surcharge where applicable;
• sponsor licence application or renewal-related costs where relevant; and
• professional fees incurred for immigration advice or assistance.

 

2. What is the Immigration Skills Charge?

The Immigration Skills Charge is an additional charge payable by sponsors when sponsoring certain workers.

Whether the charge applies depends on factors including the immigration route, the worker’s circumstances and whether a specific exemption applies.

Where the charge applies, the amount payable is determined by:

• whether the sponsor qualifies as a small or charitable sponsor or is treated as a medium or large sponsor; and
• the length of the period for which the worker is being sponsored.

The charge is therefore not necessarily the same for every worker sponsored by an organisation.

 

3. What are the current Immigration Skills Charge rates?

For Certificates of Sponsorship assigned on or after 16 December 2025, the current Immigration Skills Charge rates are:

Sponsor	First 12 months	Each additional 6 months
Small or charitable sponsor	£480	£240
Medium or large sponsor	£1,320	£660

For example, where a medium or large sponsor assigns a CoS for a worker for a three-year period and the Immigration Skills Charge applies, the ISC would be £3,960.

This is calculated as:

• £1,320 for the first 12 months;
• £660 for months 13 to 18;
• £660 for months 19 to 24;
• £660 for months 25 to 30; and
• £660 for months 31 to 36.

These rates replaced the previous lower Immigration Skills Charge rates from 16 December 2025.

 

4. Does the Immigration Skills Charge apply every time a CoS is assigned?

No. The Immigration Skills Charge does not apply to every Certificate of Sponsorship.

Whether it is payable depends on the immigration route and the circumstances of the sponsorship. There are also exemptions that can apply to particular workers or situations.

Employers should therefore determine whether the charge applies to the individual case rather than treating it as an automatic cost attached to every CoS.

The assessment should be completed before assignment so that the organisation understands the financial commitment associated with sponsoring the worker.

 

5. When is the Immigration Skills Charge paid?

Where the Immigration Skills Charge applies, it is paid by the sponsor as part of the sponsorship process associated with assigning the Certificate of Sponsorship.

The amount is calculated by reference to the relevant sponsorship period and sponsor category.

The employer should therefore ensure that the appropriate payment method and internal approval are available before the authorised SMS user reaches the final assignment stage.

A failed or delayed payment can interrupt the assignment process and delay the worker’s immigration application.

 

6. Who must pay the CoS assignment fee?

The sponsor is responsible for the Certificate of Sponsorship assignment fee.

For a Skilled Worker CoS assigned on or after 31 December 2024, the sponsor must not recoup or attempt to recoup any part of the CoS fee or associated administrative costs from the sponsored worker.

Equivalent restrictions apply to specified other sponsored work routes for CoS assigned on or after 9 April 2025.

Employers should therefore review employment contracts, repayment agreements, clawback provisions and recruitment arrangements to ensure that prohibited sponsorship costs are not being passed to the worker directly or indirectly.

This is not simply a contractual issue between the employer and worker. Breaching the Home Office restrictions on recovery of sponsorship costs can result in sponsor licence compliance action and, in circumstances specified by the sponsor guidance, can lead to revocation action.

 

7. Who must pay the Immigration Skills Charge?

Where the Immigration Skills Charge applies, it is a cost for the sponsor.

The employer must not require the sponsored worker to pay the Immigration Skills Charge or seek to recover it from them.

Employers should be particularly careful where recruitment packages contain general repayment clauses covering immigration expenditure.

A broadly drafted clause requiring the worker to repay all immigration or sponsorship costs could create compliance problems if it captures charges that the sponsor is prohibited from recovering.

 

8. Can the worker pay their own visa costs?

The rules governing sponsor-paid charges should be distinguished from the worker’s own immigration application costs.

The worker may have separate personal immigration costs associated with their application, potentially including the visa application fee and Immigration Health Surcharge where applicable.

Employers may choose to pay some or all of these costs as part of a recruitment or relocation package, but this is a separate issue from sponsorship charges that the employer is required to bear.

Any repayment arrangement should therefore distinguish carefully between costs that can lawfully be recovered from a worker and costs that must remain with the sponsor.

 

9. Why should sponsorship costs be checked before assignment?

For employers sponsoring multiple workers, CoS and Immigration Skills Charge costs can become significant.

The organisation should understand the cost of sponsorship before committing to the assignment, particularly where the worker will be sponsored for several years.

A useful internal approval process should therefore consider:

• the applicable CoS assignment fee;
• whether the Immigration Skills Charge applies;
• the sponsor’s ISC category;
• the proposed sponsorship period;
• whether an ISC exemption applies;
• any worker immigration costs the employer has voluntarily agreed to meet;
• professional fees where advice is being obtained; and
• whether any proposed repayment arrangement complies with the sponsor rules.

Checking these issues before assignment helps prevent both unexpected costs and potentially serious compliance errors arising from unlawful cost recovery.

Once the applicable charges have been established, the employer should also ensure that the CoS is assigned at the correct point in the recruitment and immigration timetable.

 

 

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Section K: When Should a Certificate of Sponsorship Be Assigned?

A Certificate of Sponsorship should be assigned at a point when the employer has completed its sponsorship checks, the proposed employment arrangements are sufficiently settled and the worker is in a position to proceed with the relevant immigration application within the required timeframe.

Assigning a CoS too early can create problems if the certificate expires before it is used or if the job, salary, work location or other sponsorship information changes before the worker applies.

Assigning too late can delay the worker’s immigration application and potentially affect the intended employment start date.

Employers should therefore coordinate CoS assignment with the wider recruitment, immigration and onboarding timetable.

 

1. How long does a worker have to use an assigned CoS?

For Skilled Worker applications, an assigned Certificate of Sponsorship generally needs to be used in support of the worker’s immigration application within three months of the date of assignment.

This means employers should avoid assigning the certificate simply because the recruitment decision has been made if the worker will not be ready to submit their immigration application within the relevant period.

The assignment date should form part of the employer’s case timetable.

 

2. How early can a Skilled Worker apply?

A Skilled Worker must not apply more than three months before the employment start date stated on the Certificate of Sponsorship.

The employer therefore needs to consider two connected timing points:

• when the CoS is assigned; and
• the employment start date recorded on the CoS.

The dates should be planned so that the worker can make the immigration application within the permitted timeframe and there is sufficient time for the application to be processed before the intended employment arrangements begin.

 

3. Should a CoS be assigned as soon as recruitment is complete?

Not necessarily.

Completion of the recruitment process and assignment of the Certificate of Sponsorship are separate stages.

Before assignment, the employer should have sufficient certainty about:

• the identity of the worker;
• the immigration route;
• the type of CoS required;
• the job being offered;
• the occupation code;
• salary;
• weekly working hours;
• the work location;
• the proposed employment start date;
• the intended sponsorship period; and
• any route-specific sponsorship requirements.

If significant aspects of the employment remain under negotiation, it may be premature to assign the certificate.

This is particularly important where a change could affect whether the role qualifies for sponsorship.

 

4. What happens if the CoS is assigned too early?

Assigning the CoS significantly before the worker is ready to apply can create avoidable problems.

For example:

• the worker may not make the immigration application within the permitted period;
• the proposed start date may become unrealistic;
• the salary may change;
• the worker’s working hours may change;
• the work location may change;
• the job description or duties may change;
• the worker’s personal circumstances may change; or
• the recruitment itself may no longer proceed.

Some changes can be dealt with through the appropriate sponsorship procedures, but employers should not create unnecessary correction work by assigning a CoS before the sponsorship arrangements are sufficiently settled.

 

5. What happens if the CoS is assigned too late?

Waiting too long can create a different set of problems.

The worker will generally need the assigned CoS reference before they can complete the relevant sponsored work immigration application.

If assignment is delayed, this can affect:

• submission of the immigration application;
• the expected decision date;
• travel arrangements;
• notice periods;
• relocation arrangements;
• the proposed employment start date;
• project staffing; and
• business continuity.

Where the role is business-critical, employers should work backwards from the intended start date and allow sufficient time for sponsorship, the immigration application, the decision process and right to work onboarding.

 

6. What if the proposed start date changes before the worker applies?

A change to the anticipated start date does not necessarily mean that the entire sponsorship process has to begin again, but the employer should assess the position rather than allowing the worker to submit an application using information that is known to be inaccurate.

The appropriate action will depend on matters such as:

• whether the CoS has already been assigned;
• whether the worker has submitted their immigration application;
• the extent of the change;
• the immigration route;
• whether a sponsor note or other SMS action is appropriate; and
• whether the change affects the underlying eligibility of the sponsorship.

Where the change is material or there is uncertainty about the correct procedure, the sponsor should check the applicable Home Office guidance before the worker proceeds.

 

7. What if the worker cannot start on the date stated on the CoS?

Employers should distinguish between a change arising before the immigration application and a delayed start after immigration permission has been granted.

Different sponsorship and reporting considerations can apply depending on the stage reached and the reason for the delay.

The employer should therefore monitor the worker’s progress after assignment and should not assume that the start date entered on the CoS can simply be ignored if circumstances change.

Where the worker’s start is delayed, the sponsor should assess whether the delay is permitted and whether any SMS reporting obligation arises.

 

8. What if the worker decides not to proceed?

If the worker decides not to proceed after the CoS has been assigned, the sponsor should not simply leave the matter unattended.

The employer should establish:

• whether the worker has already submitted an immigration application;
• the current status of the assigned CoS;
• whether any action is required through the SMS;
• whether any sponsorship charges may be refundable in the circumstances;
• whether the recruitment process will continue with another candidate; and
• whether a new CoS will be required for any replacement worker.

An assigned CoS belongs to the sponsorship transaction for the individual to whom it was assigned. It should not simply be transferred informally to another candidate.

 

9. Coordinate assignment with the recruitment timetable

A useful approach is to treat CoS assignment as one stage within a controlled sequence:

1. Recruit – identify the preferred worker and agree the proposed employment terms.
2. Assess – confirm that the worker and role can be sponsored.
3. Prepare – obtain the required CoS and gather the necessary information.
4. Validate – check occupation code, salary, hours, dates, location and route-specific requirements.
5. Assign – complete the SMS transaction when the worker is ready to proceed.
6. Apply – the worker submits the immigration application within the relevant timeframe.
7. Monitor – track the immigration process and any changes affecting sponsorship.
8. Right to work – complete the required right to work process before employment begins.
9. Onboard – start employment in accordance with the worker’s immigration permission and sponsorship conditions.

This approach helps prevent the CoS from being treated as an isolated administrative task.

The appropriate time to assign is therefore when the sponsorship decision has been fully validated, the employment information is sufficiently settled and the worker is ready to move into the immigration application stage.

 

 

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Section L: What Happens After You Assign the CoS?

Assignment of the Certificate of Sponsorship is not the end of the employer’s sponsorship responsibilities.

Once the CoS has been successfully assigned, the sponsor should record the assignment, provide the relevant information to the worker and monitor the case through the immigration application and onboarding process.

The employer should also remain alert to any change in circumstances that could affect the information recorded on the CoS or the worker’s proposed employment.

 

1. The CoS receives a unique reference number

Once the Certificate of Sponsorship has been successfully assigned, the Sponsor Management System generates a unique CoS reference number.

The status of the certificate should show as “ASSIGNED”.

The employer should retain the reference as part of its sponsorship records and provide the worker with the information they need to make their immigration application.

The Certificate of Sponsorship remains an electronic record. There is no physical certificate that needs to be issued to the worker.

 

2. The worker uses the CoS for their immigration application

The worker uses the assigned CoS reference when making their application under the relevant sponsored work route.

The information in the worker’s immigration application should be consistent with the information recorded by the sponsor.

Particular attention should be given to matters such as:

• the sponsoring organisation;
• the immigration route;
• the job title;
• the occupation code;
• salary;
• weekly working hours;
• employment dates; and
• work location.

If the worker or employer identifies a discrepancy after assignment, it should be addressed before the case progresses further rather than being ignored.

 

3. Assignment does not guarantee that the visa will be granted

A Certificate of Sponsorship is an important part of a sponsored work application, but assignment does not mean that UK Visas and Immigration will automatically grant the worker permission.

The worker must still satisfy the requirements of the relevant immigration route.

The Home Office may consider matters including:

• whether the application is valid;
• whether the worker meets the requirements of the route;
• whether the sponsored role qualifies;
• whether the salary requirements are met;
• whether the occupation code is appropriate;
• whether the role is genuine;
• whether the information in the application is consistent with the CoS; and
• any other suitability or eligibility requirements applying to the application.

The fact that the SMS allowed the sponsor to assign the certificate should not therefore be interpreted as Home Office approval of the worker’s immigration application.

 

4. An assigned CoS is not evidence of a right to work

Employers should maintain a clear distinction between sponsorship and the prevention of illegal working.

An assigned Certificate of Sponsorship does not, by itself, establish that the individual has permission to work in the UK.

The employer must complete the appropriate right to work process and obtain the required evidence before allowing the individual to work where the prescribed check is required.

The relevant sequence is:

CoS assignment → immigration application → immigration permission → right to work check → employment.

Employers should ensure that recruitment managers and operational teams understand this distinction so that a CoS reference is not mistakenly treated as authority for the worker to begin employment.

 

5. Retain the sponsorship records

After assignment, the employer should retain the records required under its sponsor duties and its own compliance procedures.

Depending on the circumstances, the internal sponsorship file may include:

• worker identity information;
• the approved job description;
• the occupation code assessment;
• salary and working hours information;
• the employment contract or offer documentation;
• work location information;
• evidence supporting any route-specific requirement;
• Defined CoS approval information where applicable;
• the internal sponsorship approval;
• the identity of the SMS user who completed the assignment;
• the CoS reference number;
• the assignment date; and
• any subsequent sponsor notes, reports or changes relating to the sponsorship.

The employer should also retain the documents required by the applicable sponsor record-keeping rules.

These records can become important if the Home Office later reviews the sponsorship decision during a compliance visit, licence investigation or other sponsor compliance activity.

 

6. Monitor whether the worker submits the application

Employers should not assume that the worker will automatically make the immigration application immediately after receiving the CoS reference.

Where the recruitment is important to the organisation’s staffing plans, the sponsor should monitor whether the worker has submitted the application and whether any issue has arisen.

For Skilled Worker applications, the assigned CoS generally needs to be used in support of the immigration application within three months of assignment.

Failure to coordinate this stage can result in an assigned certificate becoming unusable and the recruitment timetable being disrupted.

 

7. What if the worker does not proceed?

A worker may decide not to proceed after the CoS has been assigned.

This can happen because:

• the worker accepts another job;
• their personal circumstances change;
• the proposed relocation no longer proceeds;
• the employer withdraws the job offer;
• the employment terms change;
• the immigration application is not made; or
• another issue makes the sponsorship unsuitable.

The sponsor should establish what stage has been reached and determine what action is required.

An assigned CoS should not simply be reused for another candidate. The certificate has been assigned to the individual worker and relates to that sponsorship transaction.

If the employer subsequently wishes to sponsor another worker, the appropriate CoS process will need to be followed for that individual.

 

8. What if the employment details change after assignment?

Changes can occur between CoS assignment and the worker starting employment.

For example:

• the start date may change;
• salary may change;
• working hours may change;
• the job duties may change;
• the work location may change;
• the worker may move to a different role; or
• the commercial arrangements surrounding the role may change.

The employer should assess whether the change affects the worker’s immigration eligibility, whether the assigned CoS remains appropriate and whether any action is required through the Sponsor Management System.

Employers should not assume that every post-assignment change can simply be explained informally or corrected later.

 

9. Monitor the immigration outcome

The employer should establish whether the worker’s immigration application has been granted, refused, rejected, withdrawn or otherwise affected.

If permission is granted, the employer should check that the permission allows the worker to undertake the proposed employment and should complete the appropriate right to work process.

If the application is refused or another problem arises, the employer should consider the implications before allowing the worker to start or continue work.

Where the issue relates to information on the CoS, the sponsor should establish whether a sponsorship error contributed to the problem and whether corrective action is required.

 

10. Complete the right to work process

Before the worker begins employment, the employer should complete the prescribed right to work check applicable to the individual’s circumstances.

The right to work process is separate from the sponsor licence process, although the two compliance regimes interact.

The employer should check that the individual’s immigration permission:

• is valid;
• permits the proposed employment;
• is consistent with the sponsored role where relevant;
• has any relevant work restrictions correctly understood; and
• has been checked using the appropriate prescribed right to work method.

The evidence of the check should be retained in accordance with the applicable right to work requirements.

 

11. Move the worker into ongoing sponsor monitoring

Once the worker starts sponsored employment, the organisation’s responsibility moves from recruitment and assignment into ongoing sponsor compliance.

The sponsor should have systems capable of monitoring matters such as:

• attendance and absences where relevant;
• changes in the worker’s contact information;
• changes to the sponsored role;
• changes to salary or working hours;
• changes to work location;
• changes to the worker’s employment status;
• delayed starts;
• termination of employment; and
• other circumstances that may trigger an SMS reporting obligation.

CoS assignment should therefore feed directly into the organisation’s wider sponsor licence management procedures.

 

12. The post-assignment sequence

A controlled post-assignment process can be summarised as follows:

1. Assign – complete the CoS transaction accurately.
2. Record – retain the CoS reference and supporting sponsorship records.
3. Worker – provide the worker with the information required for their immigration application.
4. Monitor – track whether the application is submitted and identify changes affecting the sponsorship.
5. Immigration outcome – establish whether the worker has been granted the required permission.
6. Right to work – complete the prescribed right to work check.
7. Onboard – ensure the worker starts employment in accordance with their permission and sponsored role.
8. Ongoing monitoring – manage reporting, record-keeping and sponsor duties throughout the period of sponsorship.

This approach helps ensure that the CoS is treated as part of a continuous sponsorship lifecycle rather than an isolated SMS transaction.

If an error is identified after assignment, the employer should determine promptly whether it can be dealt with through the appropriate SMS functionality or whether more substantial corrective action is required.

 

 

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Section M: Can You Change a CoS After It Has Been Assigned?

Once a Certificate of Sponsorship has been assigned, the sponsor cannot simply reopen the certificate and freely amend the information in the same way as a CoS that is still being prepared.

This is why the final review before assignment is so important.

If an error or change is identified after assignment, the employer should first establish exactly what is wrong, whether the worker has already submitted their immigration application and whether the issue can be dealt with through the available Sponsor Management System functionality.

Some issues can be clarified or corrected using a sponsor note or another permitted SMS process. More significant errors may require different action and, in some circumstances, a new Certificate of Sponsorship.

 

1. Can you edit an assigned CoS?

An assigned CoS cannot simply be returned to draft status and edited without restriction.

Once the assignment has taken place, the certificate has formally been assigned to the worker and may already be forming the basis of an immigration application.

The appropriate response to an error therefore depends on:

• what information is incorrect;
• how significant the error is;
• which immigration route is involved;
• whether the error affects the worker’s eligibility;
• whether the worker has already submitted their application;
• whether UKVI has already made a decision; and
• which SMS correction or reporting mechanism is available.

Employers should avoid assuming that every error can be resolved by adding an explanatory note.

 

2. What is a sponsor note?

The Sponsor Management System allows sponsors to add a sponsor note in certain circumstances.

A sponsor note can be used to provide information or clarify aspects of an assigned Certificate of Sponsorship where the relevant Home Office guidance permits this.

It should not be regarded as a mechanism for rewriting an assigned CoS or curing every type of sponsorship error.

Before using a sponsor note, the employer should establish whether the issue is one that can appropriately be dealt with in this way.

The note should clearly explain the relevant information and create an accurate audit trail of the correction or clarification.

 

3. What if the occupation code is wrong?

An incorrect occupation code can be a significant error because the occupation code can affect whether the role is eligible for sponsorship and which salary requirements apply.

The sponsor should not simply add a note and assume the issue has been resolved.

Instead, the employer should reassess:

• the worker’s actual duties;
• the job description;
• the correct occupation code;
• whether the role remains eligible for sponsorship;
• the salary requirements applying under the correct code;
• whether the worker still qualifies under the proposed immigration route; and
• whether a replacement CoS or other corrective action is required.

Where the error affects the underlying eligibility of the sponsorship, it should be treated as a substantive immigration issue rather than a simple administrative correction.

 

4. What if the salary is wrong?

A salary error should be assessed carefully because remuneration can be central to the worker’s eligibility.

The employer should establish whether the problem is:

• a simple typing error;
• an incorrect annual salary calculation;
• an error in the stated weekly hours;
• a discrepancy between the CoS and employment contract;
• an incorrect assessment of which remuneration can count;
• a change in salary after assignment; or
• a salary that does not satisfy the applicable immigration requirement.

The appropriate response will depend on the nature of the problem and the stage reached in the worker’s immigration application.

If the correct salary would mean that the worker no longer qualifies for sponsorship, the issue cannot safely be treated as a minor data-entry error.

 

5. What if the start date is wrong?

Start dates can change during recruitment and the immigration process.

The sponsor should establish whether the date was incorrect when the CoS was assigned or whether circumstances changed afterwards.

The employer should then consider:

• whether the worker has already applied;
• how significant the change is;
• whether the new date remains compatible with the immigration timetable;
• whether a sponsor note or other SMS action is appropriate; and
• whether any separate sponsor reporting requirement arises.

The employer should also ensure that the worker does not begin sponsored employment before they have the required immigration permission and the employer has completed the appropriate right to work process.

 

6. What if the wrong type of CoS was assigned?

Assigning the wrong type of Certificate of Sponsorship can be a material error.

For example, a Skilled Worker making an entry clearance application from outside the UK will generally require a Defined CoS, while a Skilled Worker applying for permission to stay from within the UK will generally require an Undefined CoS.

If the wrong type has been assigned, the employer should not assume that the worker can simply proceed with the immigration application.

The sponsor should identify the correct application route and CoS type and determine what action is required before the application is submitted or progressed.

 

7. What if the CoS was assigned to the wrong worker?

A Certificate of Sponsorship assigned to the wrong individual should be treated as a significant error.

The sponsor should not provide that CoS reference to the intended worker or attempt to treat the certificate as though it had been assigned to somebody else.

The employer should establish the correct SMS action and create a clear record explaining what occurred.

A separate, correctly prepared CoS may be required for the intended worker.

The organisation should also consider why the error occurred and whether its pre-assignment checking process needs to be strengthened.

 

8. What if the job changes after assignment?

A change to the proposed role can range from a minor adjustment to a fundamental change in the basis of sponsorship.

The sponsor should consider:

• whether the job title has changed;
• whether the substantive duties have changed;
• whether the occupation code remains correct;
• whether the salary has changed;
• whether the working hours have changed;
• whether the work location has changed;
• whether the role remains eligible for sponsorship; and
• whether the change requires a new immigration application or other sponsor action.

The employer should assess the substance of the change rather than relying solely on whether the internal job title remains the same.

 

9. Are there additional restrictions for an approved Defined CoS?

Yes. Particular care is required where the certificate is a Defined CoS.

A Defined CoS is approved by the Home Office on the basis of information supplied by the sponsor when requesting it. The sponsor should therefore not assume that material information can be changed freely between approval and assignment.

Current sponsor guidance permits certain limited changes in appropriate circumstances, but other changes can mean that the approved Defined CoS should not be used.

Changes involving matters such as the occupation code, job description, salary, working hours or other material aspects of the role should therefore be checked against the applicable sponsor guidance before assignment.

Where a proposed change falls outside the permitted parameters, the sponsor may need to notify the Home Office so that the Defined CoS can be cancelled rather than assigning it on materially different terms.

The same principle applies where an error is discovered after assignment: the employer should consider the specific Defined CoS rules rather than assuming that a sponsor note will resolve the issue.

 

10. Does it matter whether the worker has already applied?

Yes. The stage reached in the worker’s immigration application can materially affect the options available.

An issue identified immediately after assignment but before the worker has submitted their application may be easier to resolve than one identified after the application has been submitted or decided.

Employers should therefore establish immediately:

1. whether the CoS has been assigned;
2. whether the worker has received the CoS reference;
3. whether the worker has submitted the immigration application;
4. whether UKVI has contacted the worker or sponsor;
5. whether a decision has already been made; and
6. whether the worker has started employment.

This timeline should be established before deciding how to correct the problem.

 

11. When might a new CoS be required?

A new Certificate of Sponsorship may be required where the error or change is sufficiently significant that the original assigned certificate can no longer properly support the proposed immigration application.

Whether this is necessary will depend on the circumstances.

Potential examples can include cases involving:

• the wrong worker;
• the wrong type of CoS;
• a materially incorrect occupation code;
• a materially different role;
• salary information that changes the worker’s eligibility;
• significant changes to the proposed sponsorship arrangements; or
• another error that cannot appropriately be dealt with using the available SMS functionality.

The sponsor should check the relevant Home Office guidance before assigning a replacement certificate, particularly if an immigration application has already been made using the original CoS.

 

12. Keep an audit trail of corrections

Where an error is identified, the employer should retain a clear record of:

• what the original CoS stated;
• what was incorrect or subsequently changed;
• when the issue was identified;
• who identified it;
• whether the worker had already applied;
• what guidance was considered;
• what corrective action was taken;
• what was recorded in the SMS;
• whether a replacement CoS was assigned; and
• what procedural change, if any, was introduced to prevent recurrence.

This can be particularly important where the Home Office subsequently asks why information changed or reviews the sponsor’s systems during a compliance visit.

 

13. Correct errors promptly

Employers should not leave a known CoS error unresolved simply because the worker’s immigration application appears to be progressing.

The appropriate response depends on the nature of the mistake, but the safest approach is to identify the issue, establish the stage reached, determine the permitted correction mechanism and take the required action promptly.

Minor errors and material sponsorship errors should not be treated in the same way.

The central question is whether the assigned CoS still provides an accurate and compliant description of the worker, role and sponsorship on which the immigration application is based.

Where there is doubt, the sponsor should resolve the position before the worker proceeds further wherever possible.

 

 

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Section N: Common Certificate of Sponsorship Assignment Mistakes

Many Certificate of Sponsorship problems arise not because the employer is unable to use the Sponsor Management System, but because incorrect information or an incorrect sponsorship decision is entered into the system.

The SMS transaction itself can be relatively straightforward. The greater risk lies in assigning the wrong certificate, using inaccurate information or failing to identify an eligibility issue before the CoS is assigned.

Common CoS assignment mistakes include the following.

 

1. Assigning the wrong type of CoS

One of the most fundamental errors is assigning the wrong type of Certificate of Sponsorship.

For Skilled Worker sponsorship, a Defined CoS is generally required where the worker will make an application for entry clearance from outside the UK, while an Undefined CoS is generally used where the Skilled Worker will apply for permission to stay from within the UK.

Undefined CoS are also used for eligible workers under other sponsored work routes.

Employers should determine the immigration route and application type before selecting the certificate rather than simply using whichever type of CoS happens to be available.

 

2. Selecting the wrong occupation code

The occupation code should reflect the job the sponsored worker will actually perform.

A common mistake is to select the code by reference to the job title alone or to choose an occupation code because its eligibility or salary requirements appear more favourable.

The sponsor should consider the substantive duties and responsibilities of the role.

An incorrect occupation code can affect:

• whether the job is eligible for sponsorship;
• the applicable salary requirement;
• the worker’s immigration application; and
• the sponsor’s wider compliance position.

Where the Home Office considers that an occupation code has been deliberately selected to make an otherwise ineligible role qualify for sponsorship, the consequences can extend beyond the individual worker’s application.

 

3. Using an inaccurate or generic job description

The job description entered on the CoS should accurately describe the sponsored role.

Problems can arise where employers:

• copy a generic job description from another worker;
• use an internal job description that no longer reflects the role;
• provide insufficient information about the actual duties;
• use wording designed primarily to match an occupation code; or
• fail to update the description after the proposed role changes.

The job description should be consistent with the occupation code and the genuine work the employee will undertake.

 

4. Calculating the salary incorrectly

Salary errors can directly affect immigration eligibility.

Common problems include:

• entering the wrong annual salary;
• using the wrong number of weekly hours;
• incorrectly annualising hourly pay;
• relying on remuneration that cannot be counted for the relevant immigration requirement;
• applying the wrong salary threshold;
• using an incorrect occupation-specific salary requirement;
• incorrectly relying on a discounted or alternative salary provision; and
• entering a salary that does not correspond with the employment contract.

Salary should be checked as an immigration compliance issue before the certificate is assigned, not merely copied from recruitment or payroll information.

 

5. Entering the wrong working hours

Weekly working hours can affect the salary assessment and should accurately reflect the worker’s genuine employment arrangements.

Employers should take particular care where the worker:

• works shifts;
• has variable hours;
• works part time;
• has contractual overtime;
• has recently changed their working pattern; or
• has working arrangements that differ from the employer’s standard working week.

The salary and working-hours information recorded on the CoS should be internally consistent.

 

6. Recording the wrong work location

The work location recorded for the sponsored worker should reflect the genuine arrangements.

Errors can arise where an employer automatically enters its registered or head office address even though the worker will normally work elsewhere.

The sponsor should consider:

• the worker’s principal workplace;
• other regular work locations;
• home or hybrid working;
• branch locations;
• client sites; and
• other third-party locations.

Where the worker will operate at a client site, the employer should also ensure that the underlying arrangement is compatible with the sponsorship rules.

 

7. Using an unrealistic employment start date

The start date should be selected as part of the recruitment and immigration timetable rather than entered merely to complete the CoS.

An unrealistic date can result in:

• the worker being unable to complete the immigration process in time;
• the proposed start date passing before a decision is received;
• unnecessary post-assignment corrections;
• confusion within the recruiting business; or
• a delayed start that needs to be assessed under the sponsor rules.

For Skilled Worker applications, employers should remember both the three-month period generally available for using an assigned CoS and the restriction on applying more than three months before the start date stated on the certificate.

 

8. Missing a route-specific requirement

The SMS contains fields relevant to the sponsorship transaction, but employers should not assume that completing every mandatory field means that all immigration requirements have been satisfied.

Depending on the worker and route, the sponsor may need to consider additional matters such as:

• ATAS requirements;
• maintenance certification;
• professional registration;
• route-specific eligibility provisions;
• third-party working arrangements;
• recruitment or intermediary information; and
• other requirements identified in the relevant sponsor guidance.

These issues should be considered before assignment.

 

9. Completing the maintenance question incorrectly

Where the SMS asks whether the sponsor certifies maintenance, the answer should reflect the organisation’s actual decision and the requirements of the relevant route.

Employers should not automatically copy the answer used for another sponsored worker.

The sponsor should understand the effect of the declaration it is making and ensure that the relevant internal arrangements are in place where maintenance is being certified.

 

10. Assigning the CoS before checking eligibility

Another common procedural mistake is to treat CoS assignment as the first stage of the immigration assessment rather than the final stage of the sponsorship decision.

The preferred sequence is:

Assess eligibility → identify the correct CoS → validate the role and employment terms → prepare the information → review → assign.

If fundamental questions about the occupation code, salary, immigration route or worker’s eligibility are still unresolved, the certificate should not yet be assigned.

 

11. Copying an earlier CoS without reassessing the case

Using information from a previous Certificate of Sponsorship can save administrative time, but it can also introduce errors.

Information copied from an earlier worker or previous sponsorship period may no longer be accurate.

Employers should recheck:

• worker details;
• immigration route;
• CoS type;
• occupation code;
• job description;
• salary;
• weekly hours;
• work location;
• employment dates;
• maintenance;
• route-specific information; and
• the current immigration requirements.

Each CoS should be treated as a separate sponsorship decision even where the organisation has sponsored workers in similar roles previously.

 

12. Failing to carry out a final review

A certificate can contain accurate source information but still be assigned incorrectly because the wrong information was entered into the SMS.

A final review should therefore compare the completed CoS against the approved sponsorship information.

Where possible, sponsors with significant volumes of sponsored workers should consider a second-person check before assignment.

The review should focus not only on spelling and data entry but also on the substantive sponsorship decision.

 

13. Assuming an assigned CoS can always be corrected later

Employers should not use post-assignment correction mechanisms as a substitute for proper pre-assignment checking.

An assigned CoS cannot simply be reopened and freely amended.

While a sponsor note or another SMS function may be appropriate for certain issues, material errors can require more substantial corrective action and potentially a replacement certificate.

This is particularly important where the error concerns:

• the worker;
• CoS type;
• occupation code;
• job description;
• salary;
• working hours; or
• another matter affecting immigration eligibility.

 

14. Changing an approved Defined CoS without checking the restrictions

A Defined CoS is approved on the basis of information provided to the Home Office when the sponsor requests it.

Employers should therefore not assume that an approved Defined CoS can be materially changed when it is assigned.

While certain limited changes may be permitted, changes to matters such as the occupation code, job description, salary, working hours or other material elements of the role should be checked against the current sponsor guidance.

Where the proposed changes fall outside the permitted parameters, the Defined CoS may need to be cancelled rather than assigned on materially different terms.

 

15. Recovering prohibited sponsorship costs from the worker

Employers should also avoid treating sponsorship charges as costs that can automatically be passed to the employee.

For a Skilled Worker CoS assigned on or after 31 December 2024, the sponsor must not recoup or attempt to recoup the CoS fee or associated administrative costs from the sponsored worker.

Equivalent restrictions apply to specified other sponsored work routes for CoS assigned on or after 9 April 2025.

The Immigration Skills Charge is also a sponsor cost and must not be passed to the sponsored worker where it applies.

Employment contracts and immigration repayment agreements should therefore be checked carefully to ensure that prohibited costs are not captured by broad clawback provisions.

 

16. Treating the CoS as proof of a right to work

Assignment of a Certificate of Sponsorship does not establish a statutory excuse against illegal working and does not itself give the worker permission to work.

The worker must obtain the necessary immigration permission, and the employer must complete the appropriate prescribed right to work check before employment begins where required.

Recruitment managers should therefore understand that:

CoS assigned does not mean visa granted, and visa granted does not remove the need for the appropriate right to work check.

 

17. Failing to investigate repeated assignment errors

An isolated administrative mistake should be corrected appropriately, but repeated CoS errors can indicate a wider weakness in the sponsor’s systems and controls.

Where mistakes recur, the employer should consider whether there is a problem with:

• SMS user training;
• occupation code assessment;
• salary checking;
• HR-to-immigration handover;
• internal sponsorship approvals;
• record keeping;
• final review procedures; or
• oversight by the Authorising Officer.

The objective should not simply be to correct each individual certificate. The organisation should identify and address the underlying cause of the errors.

This is particularly important because repeated or material inaccuracies in Certificates of Sponsorship can become evidence of broader sponsor compliance failings if the Home Office reviews the organisation’s licence.

 

 

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Section O: What Are the Risks of Assigning a CoS Incorrectly?

Errors when assigning a Certificate of Sponsorship can have consequences for both the worker and the sponsoring organisation.

At worker level, an inaccurate CoS can delay an immigration application, contribute to a refusal or require the employer to take corrective action and potentially assign a replacement certificate.

At sponsor level, inaccurate or repeated CoS assignments can raise wider concerns about whether the organisation understands its sponsorship duties and has adequate systems for managing its licence.

The level of risk will depend on the nature of the error, whether it affects immigration eligibility, how the error occurred and how the sponsor responds when it is identified.

 

1. Delay to the worker’s immigration application

An incorrect CoS can prevent the worker from progressing their immigration application as planned.

If an error is identified before submission, the employer may need to determine whether it can be corrected through the appropriate SMS functionality or whether another CoS is required.

This can delay:

• submission of the immigration application;
• the immigration decision;
• the worker’s relocation;
• the proposed employment start date;
• project deployment;
• client commitments; and
• the employer’s wider recruitment plans.

Where the worker is filling a business-critical role, even a relatively short delay can have operational consequences.

 

2. Risk of the immigration application being refused

Where incorrect CoS information affects whether the worker satisfies the requirements of the immigration route, the problem can contribute to an unsuccessful immigration application.

Higher-risk errors can include issues involving:

• the wrong sponsorship route;
• the wrong type of CoS;
• an incorrect occupation code;
• an ineligible role;
• salary below the applicable requirement;
• incorrect working hours;
• materially inaccurate job information; or
• another requirement relevant to the worker’s eligibility.

Employers should therefore distinguish between minor administrative mistakes and errors that undermine the substantive basis on which the worker is being sponsored.

 

3. A replacement CoS may be required

Some mistakes cannot appropriately be dealt with simply by adding a sponsor note.

Where the original certificate no longer accurately represents the proposed sponsorship, the employer may need to consider whether a new CoS is required.

This can result in:

• additional administrative work;
• further internal approvals;
• additional sponsorship costs where applicable;
• delay to the immigration application;
• changes to the intended start date; and
• the need to explain the history of the case.

The correct response will depend on the nature of the error and the stage reached in the immigration process.

 

4. The Home Office may ask the sponsor for further information

Information on a Certificate of Sponsorship can be considered by the Home Office when assessing the worker’s immigration application and when monitoring the sponsor’s compliance with its licence duties.

Where information appears inconsistent, unusual or incomplete, the sponsor may be asked to provide further information or evidence.

For example, questions may arise about:

• why a particular occupation code was selected;
• how the salary was calculated;
• what duties the worker will actually perform;
• where the worker will work;
• the nature of any client-site arrangement;
• why information differs from previous sponsorship records;
• why information was changed after assignment; or
• how the organisation approved the sponsorship decision.

The sponsor should be able to explain the basis of the information recorded on the CoS and produce supporting documentation where required.

 

5. Repeated errors can indicate weak sponsor controls

A single error and a pattern of repeated inaccurate assignments do not necessarily present the same compliance risk.

Repeated mistakes can suggest weaknesses in the organisation’s sponsorship processes, including:

• inadequate SMS user training;
• poor internal communication;
• weak occupation code assessment;
• inadequate salary checking;
• insufficient management oversight;
• poor record keeping;
• failure to use a pre-assignment checklist; or
• lack of an effective final review process.

The Home Office can assess not only whether an individual CoS contains an error but also whether the sponsor has adequate systems and processes to comply with its duties.

 

6. Sponsor licence compliance action

Where CoS errors reveal wider or more serious compliance failures, the consequences can extend beyond the individual worker.

Depending on the circumstances and the nature of the breach, sponsor compliance action can include:

• requests for information or supporting documents;
• additional scrutiny of the sponsor’s records and systems;
• restrictions affecting sponsorship activity;
• downgrading of the sponsor licence where the applicable rules allow;
• suspension of the sponsor licence; or
• revocation of the sponsor licence in serious cases.

The appropriate consequence will depend on the relevant sponsor guidance and the particular circumstances. Not every CoS error will result in formal licence action.

The greater concern is where inaccurate assignments form part of a wider failure to comply with sponsor duties or demonstrate that the organisation does not have effective control over its sponsorship activity.

 

7. Deliberately inaccurate information creates greater risk

There is an important distinction between a genuine administrative mistake and deliberately providing inaccurate or misleading sponsorship information.

The risk is substantially greater where information has been manipulated or misrepresented to make a worker or role appear eligible for sponsorship.

Examples could include deliberately:

• selecting an inappropriate occupation code;
• inflating salary information;
• misstating working hours;
• providing a job description that does not reflect the genuine role;
• concealing the true work location;
• misrepresenting a third-party working arrangement; or
• providing other information intended to create an inaccurate impression of eligibility.

Such conduct can create serious immigration and sponsor licence consequences and should not be treated as an ordinary data-entry error.

 

8. Incorrect cost recovery can create separate compliance risk

CoS assignment can also create compliance risk where the sponsor pays the required charge but subsequently seeks to recover a prohibited sponsorship cost from the worker.

For Skilled Worker CoS assigned on or after 31 December 2024, sponsors must not recoup or attempt to recoup the CoS fee or associated administrative costs from the sponsored worker.

Equivalent restrictions apply to specified other sponsored work routes for CoS assigned on or after 9 April 2025.

The Immigration Skills Charge must also remain with the sponsor where it applies and cannot be passed to the sponsored worker.

Employers should therefore consider not only whether the correct charges were paid during assignment, but also how immigration costs are subsequently treated under employment contracts, repayment agreements and payroll arrangements.

 

9. Errors can affect the sponsor’s credibility

The Certificate of Sponsorship is an official sponsorship record containing information supplied by the licensed sponsor.

Consistently accurate CoS assignments support the organisation’s ability to demonstrate that it understands the sponsorship regime and exercises appropriate control over its sponsored workforce.

Conversely, repeated inconsistencies between CoS records, employment contracts, payroll information, HR records and the reality of the worker’s employment can raise questions about the reliability of the sponsor’s systems.

This becomes particularly important during a Home Office compliance visit or investigation.

 

10. CoS errors can expose wider governance weaknesses

Where a CoS has been assigned incorrectly, employers should consider whether the problem is isolated or evidence of a wider governance issue.

Questions to consider include:

• Who approved the sponsorship?
• Who selected the occupation code?
• Who checked the salary?
• Who confirmed the worker’s immigration route?
• Who entered the information into the SMS?
• Was there a second-person review?
• Were the relevant documents retained?
• Did the SMS user have sufficient training?
• Was the Authorising Officer appropriately overseeing sponsorship activity?
• Could the same mistake have affected other sponsored workers?

If the answer suggests a systemic weakness, the organisation should address the process rather than correcting only the individual CoS.

 

11. What should an employer do when an assignment error is identified?

The sponsor should act promptly and proportionately.

A practical response is to:

1. Identify the error – establish precisely what information is wrong.
2. Assess materiality – determine whether the error affects immigration eligibility or sponsorship compliance.
3. Establish the timeline – confirm whether the worker has already submitted an application or received a decision.
4. Check the permitted correction mechanism – determine whether a sponsor note or another SMS action can be used.
5. Consider whether a replacement CoS is required – particularly where the original certificate no longer accurately supports the proposed application.
6. Record the action taken – maintain a clear audit trail.
7. Review the underlying cause – establish why the mistake occurred.
8. Prevent recurrence – update procedures, training or approval controls where necessary.

The objective should be both to resolve the immediate worker issue and to protect the integrity of the sponsor’s wider compliance system.

 

12. Prevention is stronger than post-assignment correction

The most effective way to manage CoS assignment risk is to prevent material errors before the certificate is assigned.

A structured process should therefore require the sponsor to validate:

Worker → Route → CoS type → Role → Occupation code → Salary → Hours → Location → Dates → Route-specific requirements → Charges → Final SMS data.

Only after those elements have been checked should the authorised SMS user complete the assignment.

The key compliance question remains:

Does the assigned Certificate of Sponsorship accurately reflect a genuine and eligible sponsorship arrangement that the organisation can evidence if challenged by the Home Office?

If it does not, the issue should be resolved rather than allowing the worker to proceed on the basis of information known to be inaccurate.

 

 

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Section P: Assigning Certificates of Sponsorship in Bulk

Employers that sponsor significant numbers of workers may need to assign multiple Certificates of Sponsorship as part of a larger recruitment exercise.

The Sponsor Management System provides functionality that can assist sponsors with managing multiple CoS transactions. However, processing certificates in volume does not reduce the employer’s responsibility to ensure that every individual certificate is accurate and that every worker and role satisfies the relevant sponsorship requirements.

Bulk processing should therefore be treated as an administrative efficiency rather than a substitute for individual sponsorship assessment.

 

1. Can employers assign multiple Certificates of Sponsorship?

Yes. The Sponsor Management System includes functionality that can be used by sponsors managing multiple Certificates of Sponsorship.

This can be particularly relevant to organisations undertaking:

• large recruitment programmes;
• graduate recruitment;
• international recruitment campaigns;
• multiple hires into the same occupation;
• large-scale mobilisation projects;
• seasonal or project-based recruitment where the relevant sponsorship route permits it; or
• centralised sponsorship across different business units or locations.

The availability of batch or bulk functionality does not change the underlying sponsorship requirements.

Each certificate remains an individual sponsorship record relating to a specific worker and employment arrangement.

 

2. Each worker still requires an individual eligibility assessment

Employers should not assume that because several workers are being recruited into apparently identical positions, the same sponsorship assessment automatically applies to every individual.

For each worker, the sponsor should still confirm matters including:

• identity;
• immigration route;
• current immigration circumstances where relevant;
• the correct type of CoS;
• the role being sponsored;
• occupation code;
• salary;
• working hours;
• employment dates;
• work location;
• route-specific requirements; and
• any worker-specific circumstances affecting sponsorship.

A group recruitment exercise can therefore involve common employment information while still requiring individual validation for each sponsored worker.

 

3. Standardised information can create efficiency and risk

Where multiple workers are being recruited into genuinely identical roles, some information may legitimately be common across the certificates.

This could include:

• job title;
• job description;
• occupation code;
• standard working hours;
• work location;
• employment terms; and
• the employing entity.

Using standardised information can improve consistency and reduce administrative duplication.

It can also magnify an error.

If the underlying occupation code, salary assessment, job description or other standard information is wrong, the same error can potentially be reproduced across multiple Certificates of Sponsorship.

Employers should therefore validate the common data before it is used across a batch of workers.

 

4. Do not assume workers in the same role have identical sponsorship requirements

Even where the jobs are identical, individual workers may have different immigration circumstances.

For example, workers recruited for the same role may differ in relation to:

• whether they are applying from inside or outside the UK;
• the type of CoS required;
• their current immigration status;
• the basis on which they satisfy route requirements;
• the proposed sponsorship period;
• their intended start date;
• whether a particular exemption applies; or
• other worker-specific immigration considerations.

The employer should therefore separate role-level information from worker-level information when designing a bulk sponsorship process.

 

5. Validate the role before applying it across multiple certificates

Where the same role information will be used for multiple workers, the employer should complete the substantive role assessment before the certificates are prepared.

This should include checking:

• that the role is genuine;
• that the job description accurately reflects the work;
• that the occupation code is correct;
• that the role is eligible under the relevant sponsorship route;
• that the proposed salary satisfies the applicable requirements;
• that the working hours have been correctly assessed;
• that the work location information is accurate; and
• that any third-party or client-site arrangement is compatible with the sponsorship rules.

Resolving these issues at role level before certificates are processed can reduce the risk of replicating a substantive sponsorship error across an entire recruitment cohort.

 

6. Build exception checking into the process

A robust bulk assignment process should identify workers who fall outside the standard recruitment profile.

For example, an exception may arise where:

• a worker requires a different type of CoS;
• the worker will receive a different salary;
• the worker has different contractual hours;
• the proposed start date differs;
• the worker will be based at another location;
• the sponsorship period differs;
• a route-specific issue applies;
• an Immigration Skills Charge exemption may apply; or
• another aspect of the sponsorship differs from the standard case.

These cases should be removed from the standard workflow and reviewed individually before assignment.

The objective is to prevent efficiency measures from overriding relevant differences between workers.

 

7. Use the same pre-assignment controls for bulk sponsorship

Bulk assignment should remain subject to the same core controls as an individual Certificate of Sponsorship.

For every worker, the sponsor should be able to demonstrate that it has checked:

1. Eligibility – the worker and role can properly be sponsored.
2. Correct CoS – the correct route and type of certificate are being used.
3. Data – the worker and employment information is complete and accurate.
4. Validation – the occupation code, salary, hours, location, dates and route-specific requirements have been checked.
5. Charges – the applicable CoS fee and Immigration Skills Charge position have been established.
6. Assignment – the correct certificate is assigned to the correct worker.
7. Worker application – the correct CoS information is provided to the individual who will use it.

The volume of certificates being processed should not result in any of these stages being removed.

 

8. Consider a two-stage approval process

For higher-volume sponsorship, employers should consider separating preparation from final assignment.

For example:

1. HR or the recruitment team gathers the worker and employment information;
2. the immigration or compliance function validates the sponsorship requirements;
3. the CoS information is prepared in the SMS;
4. a second authorised reviewer checks the final information; and
5. the authorised SMS user completes the assignment.

This creates a clearer separation between data collection, immigration assessment and the final SMS transaction.

It can also reduce the risk of a single user inadvertently reproducing the same mistake across numerous certificates.

 

9. Maintain a worker-level audit trail

Even where certificates are processed together, the sponsor should be able to evidence the decision relating to each individual worker.

The sponsorship record should allow the organisation to establish:

• which worker was sponsored;
• which role they were sponsored to perform;
• which occupation code was used;
• what salary and hours were approved;
• which work location was recorded;
• which type of CoS was assigned;
• who approved the sponsorship;
• who assigned the CoS;
• when it was assigned;
• the CoS reference number;
• what charges were paid; and
• whether any exception or special issue was identified.

This is particularly important if the Home Office subsequently examines a sample of sponsored workers during a compliance visit or investigation.

 

10. Reconcile the batch after assignment

Once a group of Certificates of Sponsorship has been assigned, the sponsor should reconcile the completed transactions against its approved recruitment list.

The review should confirm:

• every intended worker received the correct CoS;
• no certificate was assigned to the wrong individual;
• the expected number of certificates was assigned;
• the relevant CoS references were recorded;
• the appropriate charges were paid;
• any failed or incomplete transactions were identified;
• any exceptions were dealt with separately; and
• the correct information was provided to each worker.

This post-assignment reconciliation can identify administrative errors before they progress into immigration applications.

 

11. Avoid copy-and-paste sponsorship

The principal risk in high-volume sponsorship is that the process becomes mechanical.

Information from one worker should not be copied into another worker’s certificate without verification.

Particular care should be taken with:

• names and personal details;
• passport or travel document information where required;
• salary;
• working hours;
• employment dates;
• work locations;
• maintenance information;
• worker-specific route information; and
• any explanatory information entered into the SMS.

A process that saves administrative time but produces inaccurate sponsorship records exposes the organisation to greater compliance risk.

 

12. Review patterns of errors across the batch

If an error is identified in one certificate within a larger recruitment exercise, the sponsor should consider whether the same issue could affect other certificates.

For example, discovering that the wrong occupation code was used for one worker should prompt a review of other workers sponsored into the same role.

The same approach should be taken where the problem concerns:

• salary calculations;
• working hours;
• job descriptions;
• work locations;
• start dates;
• Immigration Skills Charge treatment; or
• other standardised sponsorship information.

This allows the organisation to identify systemic problems before they affect a larger number of immigration applications or become a wider sponsor compliance issue.

 

13. Bulk assignment requires stronger governance, not weaker checking

The more Certificates of Sponsorship an organisation assigns, the greater the potential impact of a weakness in its sponsorship process.

High-volume sponsors should therefore consider formal controls covering:

• who can request sponsorship;
• who can approve sponsorship;
• who determines the occupation code;
• who validates salary;
• who prepares the SMS record;
• who performs the final review;
• who is authorised to assign the CoS;
• how exceptions are escalated;
• how assigned certificates are reconciled; and
• how records are retained for audit purposes.

The objective is to combine administrative efficiency with individual accountability.

Whether an employer assigns one Certificate of Sponsorship or hundreds, each assignment should ultimately withstand the same question:

Can the sponsor demonstrate that this particular worker, performing this particular role on these particular terms, was properly assessed and accurately sponsored?

 

 

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Section Q: Certificate of Sponsorship Assignment Checklist

Before assigning a Certificate of Sponsorship, employers should complete a final check covering the sponsor licence, the worker, the proposed role, the CoS itself and the information entered into the Sponsor Management System.

The purpose of the checklist is to identify problems before assignment, while the sponsor still has the opportunity to investigate and correct the information without having to deal with an already assigned certificate.

The following checklist can be adapted into an internal sponsorship approval procedure.

 

1. Sponsor licence checks

• Is the sponsor licence active?
• Is the organisation licensed under the correct sponsorship route?
• Is there any suspension, dormancy or other licence issue preventing assignment?
• Is the sponsor currently A-rated or, if B-rated, is the proposed assignment permitted under the applicable restrictions?
• Does the organisation have the appropriate CoS available for the worker?
• Has any necessary Defined CoS approval been obtained?
• Is sufficient Undefined CoS allocation available where required?

If the organisation is not currently entitled to assign the required CoS, the assignment should not proceed simply because the worker is ready to apply.

 

2. SMS user checks

• Is the person completing the assignment an authorised SMS user with the necessary permissions?
• Has the user completed the required SMS authentication process?
• Does any restriction prevent that user from assigning the CoS?
• Is the proposed worker the SMS user’s partner or close relative?
• Is there another relevant relationship that needs to be disclosed?
• Has the appropriate internal sponsorship approval been obtained?

The person physically completing the SMS transaction should not be treated as the sole decision-maker unless that reflects the organisation’s approved sponsorship governance structure.

 

3. Worker checks

• Has the worker’s identity been confirmed?
• Are the worker’s personal details accurate?
• Has the worker’s current immigration position been considered where relevant?
• Has the correct immigration route been identified?
• Is the worker expected to apply from inside or outside the UK?
• Does the worker satisfy the relevant worker-specific requirements?
• Have any restrictions affecting the proposed application been identified?
• Has anything material changed since the original sponsorship assessment?

 

4. CoS type checks

• Does the worker require a Defined or Undefined CoS?
• Is the correct sponsorship route selected?
• If using a Defined CoS, does the approved certificate still accurately reflect the proposed role?
• Have any changes occurred since the Defined CoS was approved?
• If using an Undefined CoS, is the necessary allocation available?
• Is the certificate being assigned to the correct individual?

The type of certificate should be determined from the worker’s immigration circumstances and route requirements rather than from whichever CoS is most readily available within the SMS.

 

5. Role eligibility checks

• Is there a genuine vacancy?
• Does the role qualify for sponsorship under the relevant route?
• Does the job title accurately describe the position?
• Does the job description accurately reflect the worker’s actual duties?
• Has the correct occupation code been selected?
• Can the sponsor explain why that occupation code is appropriate?
• Is the role consistent with the nature and activities of the sponsoring organisation?
• Are any client-site or third-party working arrangements compatible with the sponsorship rules?

The sponsor should assess the substance of the role rather than relying on the job title alone.

 

6. Salary and working hours checks

• Is the gross salary entered correctly?
• Are the weekly working hours accurate?
• Has the salary been assessed against the current requirements for the route?
• Has the applicable occupation-specific salary requirement been checked?
• If a discounted or alternative salary provision is being relied upon, does the worker qualify for it?
• Have only permitted elements of remuneration been included in the salary assessment?
• Does the salary recorded on the CoS correspond with the employment contract or offer?
• Are the salary and working hours mathematically consistent?

Where salary is central to eligibility, the calculation should be capable of being reproduced and explained if the Home Office later asks how the sponsor reached its conclusion.

 

7. Work location checks

• Is the principal work location correct?
• Have relevant additional work locations been identified?
• Have home or hybrid working arrangements been considered?
• Will the worker regularly work at a client or third-party site?
• Does the recorded location correspond with the actual employment arrangements?
• Does any third-party arrangement create additional sponsorship concerns?

 

8. Employment date checks

• Is the proposed start date realistic?
• Is the employment end date correct where applicable?
• Is the sponsorship period appropriate?
• Will the worker be able to use the CoS within the applicable timeframe?
• Is the proposed start date compatible with the anticipated immigration application timetable?
• Has sufficient time been allowed for the immigration process?

For Skilled Worker applications, remember that the assigned CoS generally needs to be used within three months and the worker must not apply more than three months before the employment start date stated on the certificate.

 

9. Route-specific checks

Depending on the route and circumstances, confirm whether additional matters have been addressed, including:

• maintenance certification;
• ATAS requirements;
• professional registration;
• route-specific eligibility provisions;
• recruitment information;
• agency or intermediary arrangements;
• third-party working arrangements; and
• any additional information required by the relevant sponsor guidance.

Completion of the mandatory SMS fields does not by itself confirm that every substantive immigration requirement has been met.

 

10. Charges and payment checks

• Has the applicable CoS assignment fee been confirmed?
• Does the Immigration Skills Charge apply?
• Has the sponsor’s correct ISC category been identified?
• Has the sponsorship period been used correctly to calculate the charge?
• Has any applicable ISC exemption been considered?
• Is the organisation’s payment method ready for the transaction?
• Have prohibited worker cost-recovery arrangements been identified and removed?

The sponsor should distinguish between the CoS assignment fee, the Immigration Skills Charge and the worker’s separate immigration application costs.

 

11. Final SMS data checks

Before clicking “Assign”, compare the completed SMS record against the approved worker and employment information.

Check specifically for:

• incorrect names or personal details;
• the wrong worker;
• the wrong sponsorship route;
• the wrong type of CoS;
• an incorrect occupation code;
• an inaccurate job description;
• an incorrect salary;
• incorrect working hours;
• incorrect employment dates;
• an incorrect work location;
• incorrect maintenance information;
• missing route-specific information;
• information accidentally copied from another worker; and
• any inconsistency between the CoS and the underlying employment documentation.

Where the organisation operates a second-person review procedure, this check should take place before the assignment is confirmed.

 

12. Post-assignment checks

The compliance process should continue immediately after assignment.

• Has the CoS status changed to “ASSIGNED”?
• Has the unique CoS reference number been recorded?
• Has the correct information been provided to the worker?
• Has the assignment date been recorded?
• Have the supporting sponsorship records been retained?
• Does the worker understand the timeframe for making the immigration application?
• Is there a process for monitoring whether the worker applies?
• Will the immigration outcome be recorded?
• Has the right to work check been built into the onboarding process?
• Will the worker move into the organisation’s ongoing sponsor monitoring procedures once employment begins?

 

13. Final CoS assignment control

A practical internal approval sequence is:

Eligibility → Correct CoS → Data → Validation → Charges → Assignment → Worker Application.

The final reviewer should be able to answer each of the following:

• Eligibility: Can this worker lawfully be sponsored for this role?
• Correct CoS: Are we using the correct route and certificate type?
• Data: Is the information complete and accurate?
• Validation: Have the role, occupation code, salary, hours, location, dates and route-specific requirements been checked?
• Charges: Have the correct sponsorship charges and any exemptions been identified?
• Assignment: Is the authorised SMS user assigning the correct certificate to the correct worker?
• Worker application: Is the worker ready to use the CoS correctly and within the relevant timeframe?

Immediately before assignment, the sponsor should ask:

Does this CoS accurately describe a genuine and eligible role that this organisation is entitled to sponsor this worker to perform?

If any material element remains uncertain, the employer should stop the assignment process and resolve the issue before clicking “Assign”.

 

 

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Section R: Frequently Asked Questions About Assigning a Certificate of Sponsorship

 

Can I assign a Certificate of Sponsorship before the worker has accepted the job?

Employers should generally avoid assigning a Certificate of Sponsorship until the proposed employment is sufficiently certain and the organisation is satisfied that the worker intends to proceed.

Before assignment, the sponsor should have confirmed the role, salary, working hours, work location, proposed employment dates and other information that will be recorded on the CoS.

Assigning a certificate prematurely increases the risk that the employment terms will change or the worker will decide not to proceed after the CoS has already been assigned.

 

Does assigning a CoS mean the worker has been granted a visa?

No. Assignment of a Certificate of Sponsorship does not grant immigration permission.

The CoS provides a unique reference number that the worker uses in support of their immigration application. The worker must still make the appropriate application and satisfy the requirements of the relevant immigration route.

UKVI will determine the immigration application separately.

 

Is a Certificate of Sponsorship a physical document?

No. A Certificate of Sponsorship is an electronic record created and assigned through the Sponsor Management System.

Once assigned, it has a unique reference number. The sponsor should provide the worker with the information they need to make their immigration application, but there is no physical certificate that has to be issued.

 

Can an employer assign more than one CoS to the same worker?

Employers should not assign multiple Certificates of Sponsorship unnecessarily.

If a CoS has already been assigned and a problem is identified, the sponsor should first establish whether the existing certificate can be dealt with through the appropriate SMS process or whether a replacement CoS is actually required.

Where more than one certificate exists, the employer and worker should be clear about which CoS relates to the immigration application.

 

Can an unused CoS be transferred to another worker?

The answer depends on what is meant by an unused CoS.

An available Undefined CoS within the sponsor’s allocation has not yet been assigned to a particular worker and can be used for an appropriate sponsorship case, subject to the applicable rules.

Once a CoS has been assigned to a worker, however, it should not simply be transferred to another candidate. The assigned certificate relates to that individual sponsorship transaction.

A Defined CoS is also approved on the basis of information supplied by the sponsor and should only be used in accordance with the applicable Defined CoS rules.

 

Can a sponsor assign a CoS while its licence is suspended?

No. A sponsor whose licence is suspended cannot assign new Certificates of Sponsorship while the suspension remains in place.

The organisation should follow the Home Office process relating to the suspension and should not attempt to continue normal sponsorship activity through the SMS.

 

Can a B-rated sponsor assign a Certificate of Sponsorship?

A B-rated sponsor is generally restricted from assigning a CoS to sponsor a new worker.

There is a limited exception where an existing sponsored worker is applying for permission to stay from within the UK on the same route, was sponsored by the same organisation for their previous grant of permission and will continue to be sponsored by that organisation.

Employers with a B-rating should check that the proposed assignment falls within the permitted circumstances before proceeding.

 

Can the employee pay the Certificate of Sponsorship fee?

For a Skilled Worker CoS assigned on or after 31 December 2024, the sponsor must not recoup or attempt to recoup any part of the CoS fee or associated administrative costs from the sponsored worker.

Equivalent restrictions apply to specified other sponsored work routes for Certificates of Sponsorship assigned on or after 9 April 2025.

Employers should review employment contracts and immigration repayment agreements to ensure that prohibited sponsorship costs are not being passed to sponsored workers.

 

Can the employee pay the Immigration Skills Charge?

No. Where the Immigration Skills Charge applies, it is a sponsor cost and must not be passed on to the sponsored worker.

The employer should distinguish the ISC from separate immigration costs that may be incurred personally by the worker, such as their visa application fee or Immigration Health Surcharge where applicable.

 

How much does it cost to assign a Certificate of Sponsorship?

The current fee for assigning a Worker Certificate of Sponsorship is £525.

Different CoS fees can apply to certain other sponsorship categories.

The Immigration Skills Charge may also be payable in addition to the CoS assignment fee, depending on the route and circumstances.

For Certificates of Sponsorship assigned on or after 16 December 2025, the ISC is £480 for the first 12 months and £240 for each additional six months for a small or charitable sponsor. For a medium or large sponsor, it is £1,320 for the first 12 months and £660 for each additional six months.

Employers should check whether an exemption applies before paying the charge.

 

How long does it take to assign a Certificate of Sponsorship?

Where the sponsor already has the appropriate CoS available and all necessary information has been prepared, the SMS transaction itself can be completed relatively quickly.

The more important timeframe is the work required before assignment.

This can include:

• checking the worker’s immigration circumstances;
• determining whether a Defined or Undefined CoS is required;
• obtaining a Defined CoS or additional Undefined CoS allocation where necessary;
• checking the role and occupation code;
• assessing salary;
• confirming the employment terms;
• checking route-specific requirements; and
• obtaining internal approval.

Employers should therefore distinguish between the time required to complete the SMS transaction and the time required to make a compliant sponsorship decision.

 

How long does a worker have to use an assigned CoS?

For Skilled Worker applications, an assigned Certificate of Sponsorship generally needs to be used in support of the immigration application within three months of assignment.

The worker must also not apply more than three months before the employment start date stated on the CoS.

Sponsors should therefore coordinate assignment with the worker’s intended application date and proposed employment start date.

 

Can you correct a CoS after it has been assigned?

Potentially, but an assigned Certificate of Sponsorship cannot simply be reopened and freely edited.

Depending on the nature of the issue, a sponsor note or another SMS process may be available to provide permitted corrections or clarification.

Material errors can require more substantial action and, in some circumstances, a new CoS.

The employer should consider the nature of the error and whether the worker has already submitted their immigration application before deciding how to proceed.

 

Can you change the occupation code after assigning a CoS?

An incorrect occupation code should be treated carefully because the code can affect both role eligibility and the applicable salary requirements.

The sponsor should reassess the actual job duties, determine the correct occupation code and establish whether the original certificate can still properly support the worker’s application.

A material occupation code error should not be treated as a routine correction without considering the wider immigration implications.

 

What happens if the salary is wrong on the CoS?

The employer should first determine whether the problem is a simple data-entry error or whether the correct salary affects the worker’s eligibility.

The sponsor should check the salary, weekly hours, applicable immigration threshold, occupation-specific requirement and any alternative salary provision being relied upon.

If the worker would not satisfy the relevant requirements using the correct information, the issue should be resolved before the worker proceeds wherever possible.

 

Does the Immigration Skills Charge apply every time a CoS is assigned?

No. The Immigration Skills Charge does not apply to every Certificate of Sponsorship.

Whether it is payable depends on the relevant immigration route and the circumstances of the worker and sponsorship. Specific exemptions can also apply.

The sponsor should assess the ISC position for each relevant assignment rather than automatically applying the charge to every sponsored worker.

 

Can an immigration adviser assign a CoS for the employer?

An external representative may be able to undertake permitted SMS activity where they have been appointed in accordance with the sponsor management rules and hold the appropriate SMS access.

Using an adviser does not transfer the sponsor’s compliance responsibilities to that adviser.

The licensed organisation remains responsible for its sponsor licence, the accuracy of the information supplied and compliance with its sponsor duties.

 

Does the Authorising Officer have to assign the CoS?

No. The Authorising Officer does not have to personally assign every Certificate of Sponsorship.

Assignment can be completed by an SMS user who has the appropriate permission to perform the relevant function.

The Authorising Officer role does not itself automatically provide access to the SMS. If the Authorising Officer is to use the system, they also need the appropriate SMS user role.

The organisation should nevertheless have appropriate governance and oversight of CoS assignment activity.

 

Can a Level 2 User assign a CoS?

Existing Level 2 Users can continue to perform the functions permitted for their role during the Home Office’s transition away from Level 2 access.

However, sponsors have not been able to appoint new Level 2 Users since 9 September 2026.

Existing Level 2 Users need to be converted to the appropriate Level 1 role or deactivated by 8 March 2027. Any remaining Level 2 access is due to be deactivated after the transition.

Sponsors should therefore ensure that their SMS user structure is updated and that sufficient appropriately authorised Level 1 Users are available to manage sponsorship activity.

 

What is the most important check before assigning a CoS?

No single SMS field should be considered in isolation. The most important control is whether the Certificate of Sponsorship accurately reflects a genuine sponsorship arrangement that satisfies the requirements of the relevant immigration route.

Immediately before assignment, the employer should be able to answer:

Does this CoS accurately describe a genuine and eligible role that this organisation is entitled to sponsor this worker to perform?

If the answer is uncertain, the employer should resolve the issue before assigning the certificate.

 

 

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Section S: Key Takeaways for Employers

Assigning a Certificate of Sponsorship is an important compliance step in the sponsorship process. Although the final transaction takes place through the Sponsor Management System, the employer’s responsibilities extend considerably beyond completing the required SMS fields and clicking “Assign”.

The sponsor is confirming that it is prepared to sponsor the named worker for the role described on the certificate and that the information provided is accurate.

Employers should therefore treat CoS assignment as the conclusion of a structured sponsorship assessment rather than as a standalone administrative task.

 

1. Confirm that the organisation is entitled to sponsor the worker

Before preparing the certificate, confirm that the sponsor licence is active and covers the relevant immigration route.

The organisation should also check whether there are any restrictions affecting its ability to assign the CoS, including licence suspension, dormancy or restrictions arising from a B-rating.

Where an Undefined CoS is required, sufficient allocation must be available. Where a Defined CoS is required, the appropriate Defined CoS must first have been approved and should remain suitable for the proposed sponsorship.

 

2. Identify the correct type of CoS

The sponsor should establish whether the worker requires a Defined or Undefined Certificate of Sponsorship before beginning the assignment process.

For Skilled Worker sponsorship:

• a Defined CoS is generally required for a worker applying for entry clearance from outside the UK; and
• an Undefined CoS is generally used for a Skilled Worker applying for permission to stay from within the UK.

Undefined CoS are also used for eligible sponsorship under other relevant routes.

The employer should determine the correct certificate from the immigration circumstances rather than simply using whichever type of CoS is available.

 

3. Validate the worker and the role before assignment

The employer should complete the substantive sponsorship assessment before the CoS is assigned.

This includes checking:

• the worker’s identity and relevant immigration circumstances;
• the sponsorship route;
• the genuineness and eligibility of the role;
• the job title and substantive duties;
• the occupation code;
• salary;
• working hours;
• work location;
• employment dates;
• any third-party working arrangements; and
• route-specific requirements.

The fact that the SMS permits information to be entered does not mean that the underlying sponsorship arrangement satisfies the Immigration Rules or sponsor guidance.

 

4. Check the information as it appears in the SMS

Even where the underlying employment information is correct, mistakes can occur when that information is entered into the Sponsor Management System.

Before assignment, the completed CoS should therefore be checked against the approved worker and employment information.

Particular attention should be given to:

• worker details;
• CoS type;
• sponsorship route;
• occupation code;
• job description;
• salary;
• working hours;
• start and end dates;
• work locations; and
• route-specific information.

For organisations assigning certificates regularly, a second-person review can provide an additional compliance control.

 

5. Understand the sponsorship charges before assigning

The employer should establish the financial consequences of assignment before completing the transaction.

This includes the applicable Certificate of Sponsorship assignment fee and whether the Immigration Skills Charge is payable.

The sponsor should also check whether an ISC exemption applies.

Where sponsorship costs are subject to Home Office restrictions on recovery from the worker, the employer should ensure that employment contracts, repayment agreements and internal charging arrangements do not pass prohibited costs to the sponsored employee.

 

6. Assign the CoS at the right time

Assignment should be coordinated with the worker’s immigration application and proposed employment start date.

Assigning too early can create problems if the employment arrangements subsequently change or the worker does not use the certificate within the required period.

Assigning too late can delay the immigration application, relocation and commencement of employment.

For Skilled Worker applications, the assigned CoS generally needs to be used within three months of assignment, and the worker must not apply more than three months before the employment start date recorded on the certificate.

 

7. Remember that assignment does not grant immigration permission

An assigned Certificate of Sponsorship does not constitute a visa and does not itself give the worker permission to work in the UK.

The worker must still make the appropriate immigration application and obtain the required permission.

The employer must also complete the prescribed right to work process before employment begins where required.

The operational sequence should therefore remain clear:

CoS assignment → immigration application → immigration decision → right to work check → employment.

 

8. Treat post-assignment changes and errors promptly

An assigned CoS cannot simply be reopened and freely amended.

If an error or change is identified, the sponsor should establish:

• what information is affected;
• whether the issue is material;
• whether the worker has already submitted their immigration application;
• whether a sponsor note or other SMS action is appropriate;
• whether the worker remains eligible for sponsorship; and
• whether a replacement CoS may be required.

The employer should retain an audit trail showing the issue identified and the corrective action taken.

 

9. Maintain records after assignment

CoS assignment should feed directly into the sponsor’s wider compliance system.

The employer should retain the relevant sponsorship records, monitor the worker’s immigration application and ensure that the individual moves into the organisation’s right to work and ongoing sponsor compliance procedures when employment begins.

Changes affecting the sponsored worker should then be monitored throughout the sponsorship period so that any required reporting or other compliance action can be taken.

 

10. Review repeated errors as a governance issue

If an organisation repeatedly identifies errors in Certificates of Sponsorship, correcting each certificate individually may not be sufficient.

The sponsor should consider whether the pattern indicates a weakness in:

• training;
• SMS access and user management;
• occupation code assessment;
• salary validation;
• HR and immigration workflows;
• internal approvals;
• record keeping;
• final review procedures; or
• Authorising Officer oversight.

Effective sponsor licence management requires the organisation to identify and correct systemic weaknesses as well as individual errors.

 

11. Use a controlled CoS assignment sequence

A practical employer process can be structured as follows:

1. Eligibility – confirm that the worker and role can properly be sponsored.
2. Correct CoS – identify the correct route and Certificate of Sponsorship type.
3. Data – gather complete and accurate worker and employment information.
4. Validation – check the occupation code, job duties, salary, hours, dates, location and route-specific requirements.
5. Charges – establish the applicable sponsorship costs and any exemptions.
6. Assignment – conduct the final SMS review and assign the certificate through an appropriately authorised user.
7. Worker application – provide the worker with the required CoS information and monitor progression to the immigration application.

This approach places the SMS transaction within a wider compliance process and reduces the risk of the organisation assigning a certificate before the underlying sponsorship decision has been properly validated.

 

12. The final compliance question

Before any Certificate of Sponsorship is assigned, the employer should be able to answer one central question:

Does this Certificate of Sponsorship accurately describe a genuine and eligible role that this organisation is entitled to sponsor this worker to perform?

If the organisation cannot answer that question confidently from the information and evidence available, the CoS should not yet be assigned.

The issue should be investigated and resolved before the sponsorship transaction is completed.

 

 

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Section T: Glossary

 

Term	Meaning
Authorising Officer	The Authorising Officer is the senior and competent person within the sponsoring organisation who has overall responsibility for the sponsor licence and the activities of the organisation’s SMS users. The Authorising Officer does not automatically have access to the Sponsor Management System simply by holding the role. If they need to use the SMS themselves, they must also have the appropriate SMS user access.
Certificate of Sponsorship (CoS)	A Certificate of Sponsorship, commonly referred to as a CoS, is an electronic sponsorship record created and assigned through the Sponsor Management System. It contains information about the sponsored worker, the proposed employment and the basis on which the organisation is sponsoring that individual. Once assigned, the CoS has a unique reference number that the worker uses when making the relevant sponsored work immigration application. A CoS is not a physical certificate, a visa or evidence by itself that the worker has a right to work in the UK.
CoS allocation	A CoS allocation generally refers to the number of Undefined Certificates of Sponsorship available to a sponsor to assign to eligible workers. Having allocation available is different from assigning a CoS. Allocation gives the sponsor the capacity to create and assign the relevant Undefined CoS. Assignment is the subsequent transaction that commits a specific certificate to a particular worker.
CoS assignment	CoS assignment is the process of formally assigning a Certificate of Sponsorship to a specific worker through the Sponsor Management System. Assignment creates the unique CoS reference that the worker can use for their immigration application. The act of assignment also confirms sponsorship information about the worker and proposed employment, which is why the employer should complete its eligibility and accuracy checks before the transaction is finalised.
Defined Certificate of Sponsorship	A Defined Certificate of Sponsorship is generally required to sponsor a Skilled Worker who will make an application for entry clearance from outside the UK. The sponsor requests a Defined CoS through the Sponsor Management System and provides information about the proposed role as part of that request. Once approved, the Defined CoS can be assigned to the relevant worker, provided the proposed sponsorship remains consistent with the applicable requirements and the basis on which the Defined CoS was approved.
Undefined Certificate of Sponsorship	An Undefined Certificate of Sponsorship is generally used for a Skilled Worker applying for permission to stay from within the UK and for eligible workers under other relevant sponsored work routes. Undefined CoS are generally managed through the sponsor’s available allocation. The sponsor must have sufficient allocation available before it can assign the required Undefined CoS.
Immigration Skills Charge (ISC)	The Immigration Skills Charge, or ISC, is a charge payable by sponsors in certain sponsored work cases. Whether the ISC applies depends on the relevant route and circumstances, including whether an exemption applies. Where payable, the amount is affected by the size or status of the sponsoring organisation and the length of the sponsorship period. The Immigration Skills Charge is separate from the Certificate of Sponsorship assignment fee.
Level 1 User	A Level 1 User is an individual with access to the Sponsor Management System who can carry out permitted sponsorship management functions according to their role and permissions. Level 1 Users can undertake key SMS activities, which can include creating and assigning Certificates of Sponsorship. Sponsors should control Level 1 access carefully and ensure users understand the immigration and compliance implications of the transactions they perform.
Level 2 User	A Level 2 User is a legacy SMS user role with more limited permissions than a Level 1 User. The Home Office is withdrawing the Level 2 User role. Sponsors have not been able to appoint new Level 2 Users since 9 September 2026. Existing Level 2 Users can continue to carry out the functions permitted for their role during the transitional period, but sponsors need to convert appropriate users to Level 1 access or deactivate them by 8 March 2027.
Occupation code	An occupation code is the occupational classification used to identify the type of work the sponsored worker will perform. The occupation code can affect whether the role is eligible for sponsorship and the salary requirements that apply. Sponsors should select the code by considering the worker’s genuine job duties rather than relying on the job title alone.
Sponsor Management System (SMS)	The Sponsor Management System, or SMS, is the Home Office online system used by licensed sponsors to manage their sponsor licence and carry out sponsorship activities. Depending on the sponsor, route and user’s permissions, SMS functions can include: managing sponsor licence information; managing SMS users; requesting or managing CoS allocation; requesting Defined Certificates of Sponsorship; creating Certificates of Sponsorship; assigning Certificates of Sponsorship; reporting relevant changes; and maintaining information relating to sponsored workers. Access to the SMS should be restricted to appropriately authorised users and managed as part of the organisation’s sponsor compliance controls.
Sponsor note	A sponsor note is functionality within the Sponsor Management System that can be used in permitted circumstances to add information or clarification relating to a Certificate of Sponsorship. A sponsor note can be useful where an employer identifies certain issues after assignment, but it should not be regarded as a mechanism for freely rewriting an assigned CoS. Where an error is material, the sponsor should establish whether a sponsor note is sufficient or whether different corrective action is required.
Sponsored worker	A sponsored worker is an individual whom a licensed sponsor supports under an eligible sponsored work immigration route. The sponsor assigns a Certificate of Sponsorship containing information about the worker and proposed employment, which the worker then uses as part of the relevant immigration application. Sponsorship creates ongoing duties for the employer in relation to the worker, including applicable record-keeping, monitoring and reporting requirements.
Sponsorship route	A sponsorship route is an immigration route under which an appropriately licensed organisation can sponsor an eligible worker. Different routes have different eligibility requirements, sponsorship procedures and conditions. The sponsor should identify the correct route before assigning the CoS because the route can affect: the type of CoS required; role eligibility; salary requirements; route-specific information entered on the CoS; sponsorship charges; and the worker’s subsequent immigration application.
UK Visas and Immigration (UKVI)	UK Visas and Immigration, commonly referred to as UKVI, is part of the Home Office and administers the UK’s visa and immigration system, including the sponsorship regime. UKVI oversees sponsor licensing and sponsored worker applications and can take compliance action where licensed sponsors fail to meet their duties. The Sponsor Management System is the principal online system through which sponsors manage many of their sponsorship functions and communicate relevant information to the Home Office.

 
 

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Section U: Useful Links

 

Resource	URL
Workers and Temporary Workers: Guidance for Sponsors Part 2 – Sponsor a Worker	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-2-sponsor-a-worker
Sponsor Management System: Manual 8 – Creating and Assigning a CoS	https://www.gov.uk/government/publications/creating-and-assigning-a-cos-sms-guide-8
Sponsor Management System: Manual 12 – Defined Certificates of Sponsorship	https://www.gov.uk/government/publications/restricted-certificate-of-sponsorship-sms-guide-12
Sponsor Management System user manuals	https://www.gov.uk/government/collections/sponsorship-management-system-sms-user-manuals
Certificates of Sponsorship – GOV.UK	https://www.gov.uk/uk-visa-sponsorship-employers/certificates-of-sponsorship
Immigration Skills Charge – GOV.UK	https://www.gov.uk/uk-visa-sponsorship-employers/immigration-skills-charge
Sponsor a Skilled Worker – GOV.UK	https://www.gov.uk/government/publications/sponsor-a-skilled-worker
Workers and Temporary Workers: Guidance for Sponsors Part 1 – Apply for a Licence	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-1-apply-for-a-licence
Workers and Temporary Workers: Guidance for Sponsors Part 3 – Sponsor Duties and Compliance	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
Immigration Rules – GOV.UK	https://www.gov.uk/guidance/immigration-rules

 

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