Certificate of Sponsorship Allocation: Employer Guide

Certificate of Sponsorship: At a Glance

Employers cannot sponsor a worker simply because they hold a sponsor licence. They also need the correct type of Certificate of Sponsorship (CoS), and where an Undefined CoS is required, sufficient allocation must be available.

A Certificate of Sponsorship allocation is the number of Undefined Certificates of Sponsorship available to the organisation during its CoS year. Each time an Undefined CoS is assigned, the available balance reduces.

Defined Certificates of Sponsorship work differently. They sit outside the annual allocation and are requested separately through the Sponsor Management System (SMS) when required for an eligible Skilled Worker applying for entry clearance from outside the UK.

In brief:

 

• Undefined CoS: assigned from the sponsor’s available annual allocation.
• Defined CoS: requested individually through the SMS and do not form part of the annual Undefined CoS allocation.

 

For employers with regular sponsored recruitment, allocation needs to be watched against actual and anticipated demand. A new contract, business growth, an additional location or an unexpected increase in vacancies can quickly change how many Undefined CoS are required.

UKVI does not automatically grant the number requested. It may approve fewer CoS, reduce an existing allocation in certain circumstances or set the allocation at zero. Employers seeking an allocation or increase need to be able to explain the recruitment requirement, how the number has been calculated and why the request reflects genuine anticipated sponsorship activity.

 

Section A: What Is a Certificate of Sponsorship Allocation?

 

1. Certificate of Sponsorship Allocation Meaning

A Certificate of Sponsorship allocation is the number of Undefined Certificates of Sponsorship a licensed sponsor has available to assign during its CoS year.

It gives the organisation capacity to issue Undefined CoS where this type of certificate is required. It does not mean the workers have already been sponsored, or that every available certificate can be assigned without further checks.

Each proposed sponsorship still needs to meet the requirements of the relevant immigration route and the Home Office sponsor guidance.

For example, an organisation with an allocation of 15 Undefined CoS may potentially assign up to 15 certificates during the relevant period, provided each proposed sponsorship is permitted and sufficient allocation remains available.

 

2. Allocation Is Different From Assignment

CoS allocation and CoS assignment are separate parts of the sponsorship process.

Allocation is the number of Undefined CoS available to the organisation.

Assignment is the use of an appropriate CoS for a particular worker.

If an employer starts with 10 Undefined CoS and assigns three, it would ordinarily have seven remaining.

Once the employer has confirmed that the required CoS is available, it still needs to complete the individual CoS assignment process and check that the worker, role and sponsorship arrangements meet the relevant requirements.

 

3. Allocation Applies to Undefined CoS

The annual CoS allocation system applies to Undefined Certificates of Sponsorship.

Undefined CoS are used for eligible Skilled Workers applying for permission to stay from within the UK and for workers under other eligible Worker and Temporary Worker routes where an Undefined CoS is required.

The sponsor needs enough allocation available before it can assign one. If the available allocation has been exhausted, the organisation may need to request additional Undefined CoS through the Sponsor Management System before sponsorship can proceed.

 

4. Defined CoS Do Not Form Part of the Annual Allocation

Defined Certificates of Sponsorship do not form part of the sponsor’s annual Undefined CoS allocation.

A Defined CoS is generally required for an eligible Skilled Worker applying for entry clearance from outside the UK. It is requested separately through the SMS when needed.

Employers therefore need to establish the correct CoS type before treating availability as an allocation problem. If the worker requires a Defined CoS, the organisation’s Undefined CoS balance is not the relevant issue.

Using the wrong type of CoS can have serious sponsor compliance consequences. Home Office sponsor guidance provides for licence action where an Undefined CoS is assigned when a Defined CoS was required, or where a Defined CoS is used for a job other than the one for which it was requested.

 

5. Allocation Does Not Guarantee That a Worker Can Be Sponsored

Having CoS allocation available does not mean that a particular worker can automatically be sponsored.

Before assigning a certificate, the employer still needs to check:

 

• whether the organisation is licensed for the relevant sponsorship route;
• whether the worker requires a Defined or Undefined CoS;
• whether the role is eligible for sponsorship;
• whether the applicable salary requirements are satisfied;
• whether the vacancy is genuine;
• whether any route-specific requirements are met; and
• whether the information entered on the CoS is accurate.

 

Allocation is therefore the organisation’s capacity to assign Undefined CoS. Whether a certificate can properly be used for a particular worker is a separate sponsorship decision.

 

6. How the Allocation Is Managed

Certificate of Sponsorship allocations are managed through the Sponsor Management System (SMS). Authorised users can view the organisation’s available allocation and submit requests for further CoS where the relevant process allows.

For employers that sponsor regularly, checking the balance only when a worker is ready to be sponsored is too late. Allocation should be monitored against the recruitment pipeline throughout the CoS year.

As part of routine sponsor licence management, the organisation should know:

 

• how many Undefined CoS are available;
• how many have already been assigned;
• how many workers in the recruitment pipeline are expected to require an Undefined CoS;
• when the current CoS year ends;
• whether additional allocation may be required; and
• whether the next annual allocation will be provided automatically or will require a manual request.

 

That gives the employer a practical view of whether current CoS capacity is likely to support planned recruitment, and enough time to act if a shortfall is developing.

 

7. Why CoS Allocation Matters to Employers

A CoS allocation shortage can stop sponsored recruitment at the point the employer expects to move forward.

The organisation may already have selected a candidate, agreed terms and planned a start date, only to find that no Undefined CoS remain. If additional allocation is needed, the recruitment timetable then depends on UKVI considering and approving that request before the relevant CoS can be assigned.

Employers with regular sponsored recruitment should therefore treat allocation as part of workforce planning, not something to check at the end of the recruitment process.

Employers should identify the immigration route and correct CoS type first, then check whether sufficient Undefined CoS allocation is available. If additional allocation is needed, that needs to be secured before the employer can complete the individual sponsorship assessment and assign the CoS.

Keeping those stages separate makes it easier to manage both the organisation’s sponsorship capacity and the individual decision about whether a worker can properly be sponsored.

 

 

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Section B: Which Certificates of Sponsorship Need an Allocation?

 

1. The Allocation System Applies to Undefined CoS

The annual Certificate of Sponsorship allocation system applies to Undefined Certificates of Sponsorship.

A licensed sponsor that needs to assign an Undefined CoS must have sufficient allocation available within its Sponsor Management System account.

Each time an Undefined CoS is assigned, the number remaining within the sponsor’s available allocation reduces accordingly.

Defined Certificates of Sponsorship operate outside this annual allocation system and are requested separately when required.

The fundamental distinction is therefore:

 

• Undefined CoS: issued from the sponsor’s available allocation.
• Defined CoS: requested individually through the SMS and do not come from the annual allocation.

 

2. Undefined CoS for Skilled Workers Applying From Within the UK

For the Skilled Worker route, an Undefined CoS is generally required where the worker is applying for permission to stay from within the UK.

This can include eligible workers who are:

 

• switching into the Skilled Worker route from another immigration category from within the UK;
• extending their permission as a Skilled Worker; or
• making another eligible in-country Skilled Worker application for which an Undefined CoS is required.

 

Before assigning the certificate, the employer should confirm that the worker is eligible to make the relevant application from within the UK and that an Undefined CoS is the correct type of certificate for the proposed sponsorship.

The fact that the organisation has Undefined CoS available does not itself establish that the worker is eligible to be sponsored or permitted to make the proposed immigration application.

 

3. Undefined CoS Under Other Worker and Temporary Worker Routes

Undefined CoS are also used under other eligible Worker and Temporary Worker sponsorship routes.

The precise requirements depend on the route under which the organisation is licensed and the circumstances of the proposed worker.

Employers operating across several sponsorship routes should therefore avoid treating their total anticipated number of sponsored workers as automatically equivalent to the number of Undefined CoS they require.

The allocation exercise should instead identify:

 

• which sponsorship routes the organisation expects to use;
• how many workers are expected to be sponsored under each relevant route;
• whether those workers will require Undefined CoS; and
• how many Undefined CoS the organisation consequently expects to assign during the CoS year.

 

This route-by-route analysis is particularly important when an employer is applying for its initial sponsor licence, since the organisation may need to estimate its expected Undefined CoS requirements for each relevant route for which it is seeking to be licensed.

 

4. Defined CoS for Skilled Workers Applying From Outside the UK

A Defined Certificate of Sponsorship is generally required for an eligible Skilled Worker applying for entry clearance from outside the UK.

Defined CoS do not form part of the sponsor’s annual Undefined CoS allocation.

Instead, the sponsor makes a separate request through the Sponsor Management System for the Defined CoS it requires.

This means an employer may have no Undefined CoS remaining within its annual allocation but still be able to request a Defined CoS for an eligible Skilled Worker who requires that type of certificate.

Conversely, having a large Undefined CoS allocation does not allow the employer to use one of those certificates where the worker is required to have a Defined CoS.

 

5. Why the Defined and Undefined CoS Distinction Matters

Determining the correct CoS type is a substantive sponsorship requirement, not merely an administrative choice.

A sponsor should not use an Undefined CoS simply because one is already available if the worker requires a Defined CoS.

Likewise, a Defined CoS should only be used for the job and sponsorship circumstances for which it was requested and granted.

Home Office sponsor guidance provides for serious compliance consequences where the CoS system is misused. In particular, the guidance provides that UKVI will normally revoke a sponsor licence where the sponsor assigns an Undefined CoS to a Skilled Worker who is required to have a Defined CoS, or assigns a Defined CoS for a job other than the one described in the application for that Defined CoS.

Employers should therefore establish the correct CoS type before considering whether they have sufficient allocation.

 

6. Allocation Is Not the Same as Permission to Sponsor

An available Undefined CoS within the organisation’s allocation is not, by itself, authority to sponsor a particular worker.

The allocation determines how many Undefined CoS the organisation has available. The employer must still consider whether the individual sponsorship meets the relevant requirements before assigning one of those certificates.

This distinction can be expressed as:

CoS type determines which certificate is required → allocation determines whether an Undefined CoS is available → assignment uses the appropriate certificate for the individual worker.

Keeping these stages separate is particularly important for organisations with multiple recruitment teams, business units or locations, where several people may be recruiting sponsored workers against the same central CoS allocation.

 

7. Checking the CoS Type Before Using Allocation

Before treating a proposed recruitment as an allocation requirement, the employer should establish:

 

• which immigration route will be used;
• whether the organisation is licensed to sponsor under that route;
• whether the worker will be applying from inside or outside the UK where this affects the type of CoS required;
• whether a Defined or Undefined CoS is required;
• where an Undefined CoS is required, whether sufficient allocation is available; and
• whether the proposed sponsorship otherwise satisfies the relevant route requirements.

 

This prevents an employer from requesting additional Undefined CoS unnecessarily where the proposed workers actually require Defined CoS, while also reducing the risk of assigning the wrong type of certificate.

For allocation planning purposes, the key rule remains:

Undefined CoS use the sponsor’s allocation. Defined CoS are requested separately.

 

 

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Section C: How the Annual CoS Allocation Works

 

1. What Is an Annual CoS Allocation?

An annual CoS allocation is the number of Undefined Certificates of Sponsorship that a sponsor has available to assign during its CoS year.

The allocation provides the sponsor with a pool of Undefined CoS that can be used for eligible workers during the relevant period.

For example, if a sponsor has an annual allocation of 20 Undefined CoS, it can potentially assign up to 20 of those certificates during the relevant CoS year, provided each individual sponsorship satisfies the applicable requirements.

The allocation is not a quota of workers that the organisation is required to sponsor. It represents the maximum number of Undefined CoS currently available for assignment.

If the organisation ultimately needs fewer certificates, it does not have to use its entire allocation.

If it needs more than the number available, it may need to request an additional allocation.

 

2. What Is a CoS Year?

The CoS year is the period during which the sponsor’s annual allocation of Undefined CoS is available for use.

Sponsors generally have up to 12 months in which to use an annual allocation, but the precise CoS year depends on the sponsor’s circumstances.

For many sponsors, the CoS year runs for 12 months from the date the sponsor licence was granted and, subsequently, for 12 months from the date an allocation renewal request is granted. Different arrangements can apply in certain cases, including some sponsors whose former Tier 2 licences were converted under the sponsorship system changes introduced in December 2020.

Employers should therefore not assume that their CoS year corresponds with:

 

• the calendar year;
• the tax year;
• the organisation’s financial year; or
• the immigration year of an individual sponsored worker.

 

The organisation should check its Sponsor Management System records to establish the period applying to its own allocation.

This date is important because it affects when the existing allocation ends and when the organisation may need its next annual allocation.

 

3. How an Annual Allocation Is Established

An organisation’s first allocation of Undefined CoS can be established as part of the sponsor licence application process.

When applying for a sponsor licence, an organisation that requires Undefined CoS must estimate how many it expects to assign during its first year under each relevant route for which it is applying to be licensed.

The organisation should be able to justify the number requested by reference to its genuine anticipated sponsorship requirements.

Once the organisation is licensed, its future annual allocation may then be determined through either:

 

• the automatic annual allocation process, where the sponsor and relevant route qualify; or
• a manual follow-on allocation request where automatic allocation does not apply.

 

The sponsor may also request additional Undefined CoS during the current CoS year where its existing allocation becomes insufficient.

 

4. What Happens When an Undefined CoS Is Assigned?

Each time the sponsor assigns an Undefined CoS, the number of certificates remaining within its available allocation reduces.

For example, if an organisation begins its CoS year with an allocation of 30 Undefined CoS and assigns 18 during the year, it would ordinarily have 12 remaining from that allocation.

This makes ongoing monitoring important.

An employer should not wait until the allocation reaches zero before considering whether more certificates may be required.

Instead, the remaining allocation should be reviewed against the organisation’s active and anticipated recruitment pipeline.

If 12 Undefined CoS remain but the organisation expects to sponsor 20 eligible workers requiring Undefined CoS over the coming months, the employer should identify the potential shortfall and consider an additional allocation request before the existing allocation is exhausted.

 

5. What Happens to Unused CoS at the End of the CoS Year?

Unused Undefined CoS do not carry over into the next CoS year.

At the end of the relevant CoS year, unused CoS from that allocation are removed from the Sponsor Management System and cannot simply be carried forward for future use.

This means an employer should not regard unused allocation as a permanent reserve of certificates.

For example, an organisation that receives an allocation of 25 Undefined CoS but assigns only 10 cannot assume that the remaining 15 will be added to its next annual allocation.

The next year’s allocation is determined under the applicable annual allocation process.

Where the sponsor qualifies for automatic annual allocation, the number automatically made available is generally based on the number of Undefined CoS actually assigned during the preceding CoS year rather than the size of the previous allocation.

This distinction is important for employers whose sponsorship requirements fluctuate substantially from year to year.

 

6. Why Actual CoS Usage Matters

The number of Undefined CoS actually assigned during the year can affect the sponsor’s next automatic annual allocation.

For eligible sponsors, automatic annual allocation is generally based on actual usage during the previous CoS year.

For example:

 

• the sponsor receives an allocation of 20 Undefined CoS;
• it assigns 12 during the CoS year;
• eight remain unused at the end of the year; and
• where the automatic allocation rules apply, the next automatic allocation would generally be based on the 12 certificates actually assigned rather than the previous allocation of 20.

 

This prevents sponsors from assuming that an historically large allocation will necessarily continue at the same level indefinitely.

It also means that an organisation expecting a significant increase in sponsored recruitment should not rely solely on its previous usage to determine whether the next automatic allocation will be sufficient.

 

7. Automatic and Manual Annual Allocations

Not every sponsor receives its next annual allocation in the same way.

Eligible sponsors can receive an automatic annual allocation of Undefined CoS.

Where automatic allocation does not apply, the sponsor may need to submit a manual or follow-on allocation request through the SMS.

Whether automatic allocation is available depends on factors including the sponsor’s licence rating, whether it has an active allocation and the sponsorship route concerned.

Certain routes are excluded from the automatic annual allocation process.

Employers should therefore establish how their next allocation will be obtained rather than assuming that certificates will automatically become available at the start of a new CoS year.

 

8. Annual Allocation and Additional Allocation Are Different

An annual allocation should also be distinguished from an additional CoS allocation.

The annual allocation concerns the number of Undefined CoS made available for the relevant CoS year.

An additional allocation request is used where the organisation is already within its current CoS year but needs more Undefined CoS than it presently has available.

For example, an employer may start the year with 15 Undefined CoS but subsequently expand its recruitment programme and identify a genuine requirement for another 10.

Rather than waiting for the next CoS year, the sponsor can consider requesting additional allocation through the SMS.

 

9. UKVI Can Reduce an Existing Allocation

A CoS allocation should not be regarded as permanently fixed merely because it has already been granted.

UKVI can reduce an existing allocation, including potentially reducing the allocation to zero, where the sponsor’s circumstances or compliance position justify doing so.

This can arise, for example, where the organisation’s circumstances change significantly, such as following downsizing, or where compliance action gives UKVI concerns about the sponsor and its use of the sponsorship system.

An allocation therefore remains connected to the organisation’s continuing sponsor licence status, circumstances and compliance with its sponsorship duties.

Employers should ensure that the number of CoS available within the SMS is treated as part of wider sponsor licence governance rather than as an unconditional entitlement.

 

10. Monitoring the Annual Allocation

Employers that sponsor workers regularly should monitor their annual allocation throughout the CoS year.

A useful internal review should consider:

 

• the total annual allocation;
• the number of Undefined CoS already assigned;
• the number remaining;
• workers currently progressing through recruitment;
• anticipated recruitment during the remainder of the CoS year;
• the date on which the current CoS year ends;
• whether the sponsor expects a significant change in recruitment demand;
• whether additional allocation may be required; and
• whether the next annual allocation will be automatic or require a manual request.

 

For organisations with regular sponsored recruitment, this should form part of routine sponsor licence management rather than being addressed only when the available allocation is almost exhausted.

The annual allocation cycle can therefore be viewed as:

Receive allocation → assign Undefined CoS as required → monitor remaining capacity → forecast future demand → request additional allocation if necessary → prepare for the next CoS year.

 

 

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Section D: Initial CoS Allocation When Applying for a Sponsor Licence

 

1. Requesting an Initial CoS Allocation

An organisation applying for a sponsor licence may need to request an initial allocation of Undefined Certificates of Sponsorship as part of the application process.

The purpose of the initial allocation is to provide the organisation with sufficient Undefined CoS to support its genuine anticipated sponsorship requirements during its first CoS year.

The employer should not simply select an arbitrary number of certificates. It should consider how many workers it reasonably expects to sponsor using Undefined CoS and be able to explain the basis of that estimate.

Where the organisation is applying to be licensed under more than one relevant sponsorship route, it should consider its anticipated Undefined CoS requirements for each route for which it is applying.

The initial allocation exercise should therefore form part of the organisation’s sponsor licence planning rather than being treated as an administrative estimate made without reference to its expected recruitment activity.

 

2. Estimating How Many Undefined CoS Will Be Required

When determining the initial allocation to request, the organisation should consider its anticipated sponsored recruitment during its first year as a licensed sponsor.

This requires more than estimating the total number of overseas workers the business expects to recruit.

The employer should distinguish between workers who are expected to require an Undefined CoS and those who may require a Defined CoS or who may not require sponsorship at all.

A practical assessment may therefore consider:

 

• the number of vacancies the organisation expects to fill;
• which vacancies may require sponsored workers;
• the immigration routes expected to be used;
• whether proposed workers are likely to require Defined or Undefined CoS;
• anticipated recruitment dates;
• planned business expansion;
• new contracts or projects creating additional workforce requirements;
• existing workers who may require continued sponsorship; and
• other reasonably foreseeable changes affecting sponsored recruitment.

 

The objective is to arrive at a reasonable and supportable estimate of the number of Undefined CoS the organisation expects to assign.

 

3. Initial Allocation Should Be Considered by Sponsorship Route

Where an organisation is applying for a sponsor licence under multiple relevant routes, its anticipated CoS requirements should be considered on a route-specific basis.

The employer should identify the number of Undefined CoS it expects to require in its first year under each relevant route for which it is seeking to be licensed.

This is particularly important where the organisation has different categories of sponsored workers or different recruitment programmes operating simultaneously.

For example, an organisation may anticipate sponsorship requirements across different business functions, projects or locations. The employer should be able to explain how its requested allocation corresponds with the sponsorship activity expected under the relevant route or routes.

A route-by-route assessment can also help prevent the organisation from overstating its Undefined CoS requirement by including workers who would actually require Defined CoS.

 

4. Justifying the Initial Allocation

The sponsor licence applicant should be prepared to justify the number of Undefined CoS requested.

The explanation should establish a logical connection between the organisation’s anticipated recruitment activity and the number of certificates required.

Depending on the circumstances, this may involve explaining:

 

• the nature of the organisation’s business;
• the size and structure of its workforce;
• the vacancies it expects to fill;
• the roles for which sponsorship may be required;
• the anticipated number of sponsored workers;
• the relevant sponsorship routes;
• the expected timing of recruitment;
• why the proposed workers are expected to require Undefined CoS; and
• any business developments driving the recruitment requirement.

 

The explanation should be specific enough to demonstrate that the requested number is based on a genuine anticipated requirement rather than a speculative desire to obtain as many certificates as possible.

 

5. Evidence Supporting the Requested Allocation

The evidence relevant to an initial CoS allocation request will depend on the organisation’s circumstances.

There is no single document that will establish the appropriate allocation in every case.

Depending on the nature of the business and the reason for the proposed recruitment, supporting information may relate to:

 

• existing and anticipated vacancies;
• current workforce structure;
• recruitment activity;
• business growth;
• new contracts or projects;
• new business locations or operational expansion;
• anticipated staffing requirements;
• the organisation’s trading activities; and
• other evidence demonstrating why the proposed level of sponsored recruitment is credible.

 

The purpose of the supporting material is not simply to demonstrate that the organisation is a genuine business. It should also help explain why the requested number of Undefined CoS is reasonable in the context of the organisation’s expected sponsorship activity.

 

6. UKVI Can Request Further Information

UKVI can request further information when considering the organisation’s proposed CoS allocation.

The employer should therefore ensure that the number requested can be explained consistently with the wider sponsor licence application and the organisation’s business circumstances.

Where further information is requested, the organisation should respond accurately and within the applicable deadline.

The response should address the questions raised directly rather than simply repeating the original allocation request.

Inconsistencies between the allocation request, the organisation’s recruitment plans and other information provided during the sponsor licence application can create additional scrutiny.

 

7. UKVI Does Not Have to Grant the Number Requested

Requesting a particular number of Undefined CoS does not create an entitlement to that allocation.

UKVI can decide to grant fewer certificates than the organisation requested or, depending on the circumstances, set the allocation at zero.

The decision can reflect UKVI’s assessment of the organisation, its proposed sponsorship activity and whether the requested number has been sufficiently justified.

A large allocation request should therefore be supported by a correspondingly clear explanation of the expected recruitment requirement.

Equally, employers should avoid artificially understating their expected requirements merely to make the sponsor licence application appear simpler. The objective should be to provide a realistic assessment supported by the organisation’s actual plans.

 

8. There Is No Universal ‘Correct’ Initial Allocation

There is no standard number of Undefined CoS that every new sponsor should request.

A small organisation expecting to sponsor one worker may have a very different requirement from a larger employer undertaking sustained recruitment across several business functions.

The appropriate number is therefore organisation-specific.

The key question is:

How many Undefined Certificates of Sponsorship does the organisation genuinely and reasonably expect to require during its first CoS year?

The employer should then be able to demonstrate how it arrived at that figure.

 

9. What If the Employer Underestimates Its Initial Requirement?

An initial allocation does not necessarily represent the maximum number of Undefined CoS the organisation can use for the entire year.

If genuine recruitment requirements subsequently exceed the original estimate, the sponsor can consider requesting an additional allocation through the Sponsor Management System.

This may arise where, for example:

 

• the organisation grows faster than anticipated;
• a new contract creates additional vacancies;
• a new project requires additional personnel;
• recruitment demand increases unexpectedly;
• the organisation opens another location;
• existing workers require sponsorship that had not previously been anticipated; or
• the original workforce forecast changes for another genuine business reason.

 

The employer should be prepared to explain why the additional certificates are now required and how the revised requirement has been calculated.

 

10. Avoiding an Excessive or Speculative Initial Request

Employers should also avoid requesting an unnecessarily large allocation simply to create a substantial reserve of unused CoS.

A request that is materially greater than the organisation’s apparent recruitment requirement may attract questions about why that number is needed.

The organisation should therefore base its request on reasonably foreseeable sponsorship activity.

This does not mean that every vacancy must already have a named candidate. The employer may legitimately have future recruitment requirements.

However, it should be able to explain why those requirements are credible and why the number of Undefined CoS requested is appropriate.

 

11. Initial Allocation as Part of Workforce Planning

The initial CoS allocation provides an opportunity for a new sponsor to establish a structured approach to sponsorship from the outset.

Before submitting the allocation request, the organisation should ideally have identified:

 

• who will oversee sponsored recruitment;
• who will monitor the CoS allocation;
• which teams can request sponsorship;
• how proposed sponsorship will be approved internally;
• how the organisation will distinguish Defined and Undefined CoS requirements;
• how recruitment forecasts will be communicated to the sponsor licence team; and
• how future allocation shortages will be identified.

 

This helps prevent the organisation from treating its initial allocation as a one-off sponsor licence application issue.

Instead, CoS allocation becomes part of the employer’s continuing sponsor management process:

Forecast sponsorship requirements → identify the relevant routes → determine expected Undefined CoS demand → request a justified initial allocation → monitor usage → adjust future allocation as recruitment requirements develop.

 

 

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Section E: How UKVI Decides a CoS Allocation

 

1. UKVI Does Not Apply a Single Allocation Formula

There is no single numerical formula that determines how many Undefined Certificates of Sponsorship an organisation will receive.

UKVI considers the allocation request in the context of the sponsor’s circumstances, its proposed use of the sponsorship system and the information available to the Home Office.

The central issue for the employer is whether the number requested represents a credible and properly explained sponsorship requirement.

An organisation should therefore be able to demonstrate both why it needs Undefined CoS and why it needs the particular number requested.

The assessment is not simply a question of organisation size. Two employers of a similar size may have substantially different sponsorship requirements depending on their workforce, recruitment model, business activities and previous use of the sponsorship system.

 

2. Factors UKVI Can Consider

Home Office sponsor guidance identifies a range of factors that UKVI may take into account when deciding the number of CoS to allocate.

Depending on the circumstances, these can include:

 

• the number of workers employed by the organisation;
• the nature of the organisation’s business;
• the extent of its business activities;
• how long the organisation has been trading;
• the sponsor’s previous dealings with the Home Office;
• any recruitment agents used by the organisation and whether those agents have been associated with immigration abuse; and
• other information relevant to the credibility and scale of the proposed sponsorship activity.

 

For the UK Expansion Worker route, the location of the proposed Authorising Officer can also be relevant to the Home Office assessment.

These factors should not be treated as a mechanical checklist under which satisfying a particular number of criteria guarantees a particular allocation.

They form part of UKVI’s wider assessment of whether the requested allocation is appropriate in the sponsor’s circumstances.

 

3. The Organisation’s Recruitment Requirement

A central consideration is the organisation’s anticipated requirement for sponsored workers.

The employer should be able to explain what recruitment is expected and why the workers concerned are likely to require Undefined CoS.

Depending on the circumstances, this may include information about:

 

• existing vacancies;
• anticipated vacancies;
• planned recruitment campaigns;
• specific roles or occupational groups;
• departments or business functions requiring additional workers;
• new contracts or projects;
• business expansion;
• new sites or locations;
• replacement recruitment;
• existing workers who may require continued sponsorship; and
• the expected timing of the recruitment.

 

The explanation should connect the organisation’s recruitment requirement with the number of Undefined CoS requested.

 

4. Previous Sponsorship and CoS Usage

For an existing sponsor, previous use of the sponsorship system can provide relevant context for a new allocation request.

UKVI may have information about the organisation’s previous dealings with the Home Office, while historic CoS usage can also help demonstrate how the organisation’s current request relates to its actual sponsorship activity.

For example, an employer that historically assigns around 10 Undefined CoS each year but suddenly requests 100 should be prepared to explain the change in circumstances supporting the substantially higher requirement.

The increase may be entirely legitimate. The organisation may have secured a major contract, opened additional locations, expanded a business function or implemented a new recruitment programme.

The important point is that the employer should be able to explain the change credibly and, where appropriate, support it with relevant information or evidence.

 

5. UKVI Can Grant Fewer CoS Than Requested

A sponsor does not have an automatic entitlement to the number of Undefined CoS it requests.

UKVI can grant fewer certificates than requested where it is not satisfied that the full number is appropriate.

Home Office guidance indicates that the allocation may be restricted where, for example:

 

• the sponsor has not sufficiently justified the number requested;
• the claimed sponsorship requirement is not considered credible;
• UKVI is not satisfied that the sponsor can offer eligible employment to the number of workers proposed;
• the organisation is uncertain whether, or when, it will actually recruit the proposed workers;
• there is relevant previous non-compliance or concern about the sponsor’s dealings with the Home Office; or
• the wider circumstances do not support the level of allocation requested.

 

Depending on the circumstances, UKVI can also set an allocation at zero.

This makes the quality of the allocation justification important, particularly where the number requested is substantial or materially exceeds the organisation’s historic sponsorship activity.

 

6. A CoS Allocation Is Not an Entitlement

Employers should avoid approaching the allocation process on the basis that a particular number of certificates is automatically due because the organisation holds a sponsor licence.

The sponsor licence gives the organisation permission to participate in the sponsorship system subject to the applicable requirements.

The number of Undefined CoS made available remains subject to the allocation rules and UKVI’s consideration of the sponsor’s circumstances.

This applies both when an organisation first requests an allocation and when an existing sponsor seeks further certificates.

A previous allocation of a particular size also does not guarantee that the same number will be available indefinitely.

 

7. UKVI Can Request Further Information

UKVI can request additional information before deciding an allocation request.

The employer should respond carefully and directly to the matters raised.

A request for further information may require the sponsor to provide more detail about matters such as:

 

• the roles it intends to fill;
• the number of workers required;
• why those workers are required;
• when recruitment is expected to take place;
• the organisation’s existing workforce;
• the nature and scale of the business;
• changes in recruitment demand;
• the reason for any significant increase in CoS requirements; or
• other matters relevant to the allocation request.

 

The response should be consistent with information already provided through the Sponsor Management System, previous sponsor applications and the organisation’s wider sponsorship records.

 

8. Business Size Is Relevant but Not Determinative

The number of workers employed by the organisation and the scale of its activities can be relevant to UKVI’s assessment, but business size should not be treated as a standalone allocation formula.

A relatively small organisation may have a genuine requirement for several sponsored workers, while a much larger organisation may have limited need to use the sponsorship system.

The employer should therefore explain the actual workforce requirement rather than relying simply on turnover, headcount or organisational size.

The allocation request should make sense when considered against the organisation’s business model, operations and anticipated recruitment activity.

 

9. Recruitment Agents and Immigration Abuse Concerns

UKVI may also consider information concerning recruitment agents used by the organisation, including whether an agent has been linked to immigration abuse.

This makes oversight of third-party recruitment particularly important for sponsors that rely on external recruiters, overseas recruitment partners or other intermediaries when identifying sponsored workers.

Using an external recruitment provider does not transfer the sponsor’s immigration responsibilities to that provider.

The licensed sponsor remains responsible for its participation in the sponsorship system and should understand how candidates are being sourced and how the proposed recruitment relates to its genuine workforce requirements.

 

10. Compliance History Can Affect Allocation Decisions

The sponsor’s previous dealings with the Home Office can also be relevant when UKVI considers an allocation request.

Where there is a history of sponsor non-compliance or other concerns about the organisation’s use of the sponsorship system, this can affect UKVI’s willingness to make the requested number of certificates available.

An allocation request can therefore have a wider compliance dimension.

If UKVI raises concerns that extend beyond the number of CoS requested, the organisation should consider whether there are underlying sponsor licence issues requiring attention rather than treating the matter solely as an allocation administration problem.

 

11. UKVI Can Reduce an Existing Allocation

UKVI’s ability to control allocation is not limited to deciding new requests.

An existing allocation can also be reduced where circumstances justify this.

Depending on the circumstances, UKVI can reduce an allocation to a lower number or potentially to zero.

This may be relevant where, for example, the organisation has downsized and no longer appears to require the same number of certificates, or where compliance action gives UKVI concerns about the sponsor and the potential risk to immigration control.

Employers should therefore not treat an existing allocation as an unconditional asset that will necessarily remain available regardless of subsequent changes to the organisation or its compliance position.

 

12. Building a Credible Allocation Case

A strong allocation request should enable UKVI to understand the connection between the organisation, its recruitment plans and the number of Undefined CoS requested.

The employer should be able to answer five basic questions:

 

1. What does the organisation need?
2. Why does it need those workers?
3. How many sponsored workers are involved?
4. Why are Undefined CoS required?
5. When are the certificates expected to be used?

 

Where the requested number represents a significant increase from previous sponsorship activity, the organisation should also be able to explain:

What has changed?

This creates a clear evidential chain:

Business requirement → workforce requirement → anticipated sponsored recruitment → correct CoS type → number of Undefined CoS required → timing of expected use.

The objective is not to produce the longest possible explanation. It is to provide a coherent, credible and supportable basis for the allocation requested.

 

 

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Section F: Automatic Annual CoS Allocation

 

1. What Is an Automatic Annual CoS Allocation?

An automatic annual CoS allocation allows certain eligible sponsors to receive their next allocation of Undefined Certificates of Sponsorship without having to submit a manual annual allocation request.

Where the automatic allocation rules apply, the new allocation becomes available for the sponsor’s next CoS year in accordance with the Home Office allocation process.

This can reduce the administrative burden on sponsors that continue to meet the relevant requirements and have an established pattern of using Undefined CoS.

Automatic allocation does not, however, mean that the sponsor automatically receives the same number of certificates that it held during the previous CoS year.

The number is generally determined by reference to the sponsor’s actual use of Undefined CoS during the preceding CoS year.

 

2. Who Can Receive an Automatic Annual Allocation?

Automatic annual allocation is available only where the sponsor and the relevant sponsorship route meet the applicable Home Office requirements.

In general, the automatic process requires the sponsor to:

 

• hold an A-rated sponsor licence;
• have an active annual allocation of Undefined CoS; and
• be licensed under a route that is eligible for automatic annual allocation.

 

Employers should not assume that holding a sponsor licence alone means the next annual allocation will automatically be provided.

The organisation should establish whether the automatic process applies to its own licence and relevant route before relying on certificates becoming available for the next CoS year.

 

3. Which Routes Are Excluded From Automatic Annual Allocation?

Under the current sponsor guidance, automatic annual allocation does not apply to certain routes.

These include:

 

• Seasonal Worker;
• Secondment Worker;
• Service Supplier; and
• UK Expansion Worker.

 

Sponsors operating under an excluded route should therefore not rely on the automatic annual allocation process and should consider the applicable manual allocation requirements.

Organisations licensed across several routes should assess the allocation arrangements applying to each relevant route rather than assuming that the same annual process applies across the entire sponsor licence.

 

4. How Is the Automatic Allocation Calculated?

Where the automatic annual allocation process applies, the number of Undefined CoS provided is generally based on the number the sponsor actually assigned during the preceding CoS year.

This is different from simply repeating the total allocation that the sponsor previously held.

For example:

 

• the sponsor receives 25 Undefined CoS for the current CoS year;
• it assigns 14 of those certificates;
• 11 remain unused at the end of the CoS year; and
• the next automatic annual allocation would generally be based on the 14 Undefined CoS actually assigned.

 

The unused 11 certificates do not carry forward into the next CoS year.

This means that an historically large allocation does not necessarily preserve the same level of CoS availability for future years.

 

5. Why Previous CoS Usage Matters

Actual CoS usage can have a direct effect on the size of a sponsor’s next automatic allocation.

This is particularly important for organisations where sponsored recruitment fluctuates.

For example, an employer may have had relatively low sponsorship requirements during one year but expect substantial recruitment during the following year because of:

 

• business expansion;
• a new contract;
• a new project;
• the opening of additional locations;
• a change in workforce strategy;
• increased recruitment into hard-to-fill roles; or
• another genuine change in operational requirements.

 

If the next automatic allocation is based on the lower level of previous usage, it may not be sufficient to support the organisation’s new recruitment plans.

The employer should therefore compare its expected future demand with the number likely to become available rather than assuming automatic allocation will meet its requirements.

 

6. What If the Automatic Allocation Is Too Low?

An automatic annual allocation does not prevent the sponsor from requesting additional Undefined CoS where it has a genuine requirement for more certificates.

If the number automatically provided is insufficient, the employer can consider submitting an additional allocation request through the Sponsor Management System.

The sponsor should be prepared to explain:

 

• why the automatic allocation is insufficient;
• how many additional Undefined CoS are required;
• the recruitment activity creating the additional requirement;
• the roles or workforce requirements involved;
• when the additional certificates are expected to be used; and
• why the workers concerned are expected to require Undefined CoS.

 

This is particularly important where the organisation’s anticipated requirement is materially higher than its previous CoS usage.

 

7. Automatic Allocation Is Not a Guarantee of Future Capacity

Employers should avoid treating automatic annual allocation as a guarantee that sufficient CoS will always be available.

The automatic process is based substantially on previous usage, whereas workforce requirements can change quickly.

An organisation that recruited 10 sponsored workers during one CoS year may need 25 during the next.

If its automatic allocation reflects the previous lower level of usage, the employer will need to identify the shortfall and take appropriate action.

For this reason, automatic allocation should be regarded as a starting point for the next CoS year rather than a substitute for workforce forecasting.

 

8. What If the Sponsor Is No Longer Eligible for Automatic Allocation?

The automatic allocation process depends on the sponsor continuing to satisfy the relevant requirements.

A change in the organisation’s licence status, allocation position or sponsorship route can affect whether automatic allocation applies.

For example, the requirement for the sponsor to be A-rated means an organisation should not assume that automatic arrangements will continue regardless of changes to its sponsor licence position.

Similarly, an organisation using a route excluded from automatic allocation will need to follow the applicable manual process.

Employers should therefore check their position before the end of the current CoS year rather than discovering after the event that the expected allocation has not become available.

 

9. Automatic Allocation and Unused CoS

Unused Undefined CoS from the previous allocation do not simply transfer into the next CoS year.

They are removed at the end of the relevant CoS year and cannot be carried over.

This creates an important distinction between:

 

• the number of CoS originally allocated;
• the number actually assigned;
• the number remaining unused at the end of the year; and
• the number made available for the next CoS year.

 

Employers should maintain visibility over all four figures when reviewing their sponsorship requirements.

 

10. Planning Ahead for the Next Automatic Allocation

Even where the sponsor expects its next allocation to be provided automatically, it should review its anticipated requirements before the current CoS year ends.

The organisation should consider:

 

• how many Undefined CoS it has assigned during the current year;
• how many remain unused;
• the likely level of the next automatic allocation;
• anticipated recruitment during the next CoS year;
• whether recruitment demand is increasing or decreasing;
• whether a material shortfall is foreseeable; and
• whether an additional allocation request may subsequently be required.

 

This allows the employer to identify a potential mismatch between historic CoS usage and future recruitment requirements before that mismatch disrupts recruitment.

The practical planning sequence is:

Review current-year assignments → estimate the next automatic allocation → forecast next-year recruitment → identify any likely shortfall → plan any additional allocation requirement.

Automatic allocation can simplify sponsor administration, but it does not remove the need for active CoS management.

 

 

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Section G: Manual or Follow-On CoS Allocation

 

1. What Is a Manual or Follow-On CoS Allocation?

A manual or follow-on CoS allocation is an allocation of Undefined Certificates of Sponsorship requested by the sponsor for its next CoS year where the allocation will not be provided automatically.

This should be distinguished from an additional allocation request.

A follow-on allocation concerns the sponsor’s requirements for the next CoS year, while an additional allocation request concerns extra Undefined CoS required during the current CoS year.

The distinction is important because the employer should use the allocation process that corresponds with the period in which the certificates will be required.

 

2. When Is a Follow-On Allocation Required?

A sponsor may need to make a manual follow-on allocation request where it does not qualify for automatic annual allocation.

This can arise because of the sponsorship route concerned or because the sponsor does not satisfy the requirements for the automatic process.

Employers should therefore establish how their next annual allocation will be obtained before the current CoS year expires.

They should not assume that a new allocation will automatically appear in the Sponsor Management System simply because the organisation previously held an allocation.

 

3. When Can a Follow-On Allocation Request Be Made?

Where a sponsor needs to make a manual request for its next annual allocation, the request can generally be submitted up to three months before the end of the current CoS year.

This provides an opportunity for the employer to assess its anticipated sponsorship requirements before the existing allocation period ends.

The organisation should use this period to consider:

 

• how many Undefined CoS it has assigned during the current CoS year;
• its expected recruitment requirements for the next CoS year;
• whether sponsorship demand is expected to increase or decrease;
• which sponsorship routes will be used;
• how many anticipated workers are likely to require Undefined CoS; and
• the number of certificates that can reasonably be justified.

 

Waiting until the current allocation has ended can create unnecessary operational risk where the organisation expects to continue sponsoring workers.

 

4. How Is a Follow-On Allocation Requested?

The request is made through the Sponsor Management System (SMS) by an authorised user with the appropriate access.

The employer should request the number of Undefined CoS it genuinely expects to require for the next allocation period.

As with other allocation requests, the organisation should be prepared to explain the basis of the number requested.

The fact that the sponsor received a particular allocation previously does not automatically entitle it to the same number again.

 

5. Calculating the Next Year’s Requirement

The employer should calculate its follow-on allocation by looking forward at anticipated sponsorship requirements rather than simply copying the previous year’s allocation.

A useful assessment should consider:

 

• historic CoS usage;
• current workforce requirements;
• anticipated vacancies;
• known recruitment campaigns;
• business expansion or contraction;
• new contracts or projects;
• expected staff turnover;
• existing sponsored workers who may require further sponsorship;
• the likely timing of recruitment; and
• the type of CoS expected to be required.

 

Historic usage can provide useful evidence, but it should not be treated as the sole measure of future demand.

If the organisation’s circumstances have changed, the employer should explain why the next allocation needs to be higher or lower than previous usage.

 

6. Justifying a Higher Follow-On Allocation

An employer may legitimately require substantially more Undefined CoS in the next CoS year than it used during the current year.

For example, the organisation may:

 

• have secured a major new contract;
• be opening additional sites;
• be expanding an existing business function;
• be launching a new service;
• expect significantly higher recruitment volumes;
• have identified new skills shortages;
• be restructuring its workforce; or
• have another genuine business reason for increased sponsored recruitment.

 

Where the requested allocation represents a substantial increase, the organisation should explain what has changed and how the revised number has been calculated.

The allocation case should demonstrate a credible connection between the business development and the resulting sponsorship requirement.

 

7. UKVI Can Request Further Information

UKVI may request further information before deciding a manual or follow-on allocation request.

The sponsor should be prepared to provide additional detail about the proposed recruitment and the basis of the number requested.

Depending on the circumstances, UKVI may seek information concerning:

 

• the organisation’s business activities;
• the roles to be filled;
• the anticipated number of workers;
• the expected recruitment timetable;
• previous sponsorship activity;
• changes in workforce requirements; and
• the reason for any material increase in the requested allocation.

 

The organisation should respond accurately and within any deadline specified by UKVI.

 

8. UKVI Can Grant Fewer CoS Than Requested

A manual allocation request does not guarantee that the sponsor will receive the full number of Undefined CoS requested.

UKVI can make fewer certificates available where it is not satisfied that the full requested allocation is justified.

Depending on the circumstances, an allocation can also be set at zero.

The employer should therefore ensure that the requested number is realistic and capable of being supported by its anticipated sponsorship requirements.

Where fewer certificates are granted than requested, the organisation should assess the impact on planned recruitment and consider the reasons for the decision before deciding what further action may be appropriate.

 

9. What Happens to the Previous Year’s Unused Allocation?

Unused Undefined CoS from the previous CoS year do not carry over into the new allocation period.

They are removed from the SMS at the end of the relevant CoS year.

For example, if an employer had an allocation of 20 Undefined CoS and used only 12, the remaining eight cannot simply be added to the follow-on allocation for the next year.

The employer should instead calculate the number genuinely required for the new CoS year and request the appropriate allocation.

 

10. Avoiding a Gap Between Annual Allocations

Employers with continuing sponsored recruitment should plan carefully for the transition between CoS years.

A gap in available Undefined CoS can prevent the organisation from assigning a certificate to a worker who requires one, even where the underlying role and worker would otherwise qualify for sponsorship.

This can create difficulties where:

 

• a worker’s immigration deadline is approaching;
• a recruitment start date has already been agreed;
• a project depends on the worker starting by a particular date;
• several sponsored workers are being recruited simultaneously; or
• the employer has incorrectly assumed that the next allocation will be automatic.

 

The organisation should therefore identify whether a manual request will be required well before the current CoS year ends.

 

11. Follow-On Allocation as Part of Annual Sponsor Management

For sponsors that require a manual annual allocation, the follow-on request should form part of the organisation’s regular sponsor licence management cycle.

A practical process is:

Check the CoS year end date → determine whether automatic allocation applies → review current CoS usage → forecast next-year recruitment → calculate the Undefined CoS requirement → submit the follow-on request within the permitted period → monitor the request and respond to UKVI enquiries.

This approach reduces the risk of the organisation reaching a new CoS year without sufficient certificates to support planned recruitment.

 

 

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Section H: Requesting an Additional CoS Allocation

 

1. What Is an Additional CoS Allocation?

An additional CoS allocation is an increase in the number of Undefined Certificates of Sponsorship available to a sponsor during its current CoS year.

An employer may need additional allocation where the number of Undefined CoS currently available is insufficient to support its genuine anticipated sponsorship requirements.

This should be distinguished from a follow-on allocation request.

 

• Additional allocation: further Undefined CoS required during the current CoS year.
• Follow-on allocation: Undefined CoS required for the sponsor’s next CoS year where a manual annual allocation request is necessary.

 

The employer should therefore establish when the certificates will be required before deciding which type of allocation request to make.

 

2. When Might an Employer Need Additional CoS?

A sponsor may need additional Undefined CoS for a wide range of legitimate reasons.

For example, the organisation may:

 

• have used more of its existing allocation than originally anticipated;
• experience an unexpected increase in recruitment;
• secure a new contract requiring additional personnel;
• open a new site or business location;
• expand a department or business function;
• launch a new project or service;
• identify additional hard-to-fill vacancies;
• need to sponsor existing workers whose requirements were not previously anticipated; or
• experience another genuine change in workforce requirements.

 

The fact that recruitment demand has changed since the original allocation was granted does not, by itself, prevent the employer from obtaining further CoS.

The important issue is whether the organisation can demonstrate a genuine and credible requirement for the additional Undefined CoS requested.

 

3. Check the Existing Allocation Before Making a Request

Before requesting additional allocation, the employer should establish its current position through the Sponsor Management System.

This should include checking:

 

• the total current allocation;
• the number of Undefined CoS already assigned;
• the number remaining available;
• the end date of the current CoS year;
• anticipated sponsored recruitment before that date; and
• whether the proposed workers actually require Undefined CoS.

 

This last point is particularly important.

If proposed workers require Defined CoS, increasing the organisation’s Undefined CoS allocation will not address the requirement because Defined CoS are requested separately.

The employer should therefore establish the correct CoS type before calculating any allocation shortfall.

 

4. Calculate the Additional Number Required

The sponsor should calculate how many additional Undefined CoS it genuinely expects to require during the remainder of the current CoS year.

A practical calculation can compare:

Existing available allocation against anticipated Undefined CoS demand.

For example, if the organisation has four Undefined CoS remaining but reasonably expects to sponsor 12 workers requiring Undefined CoS before the end of its CoS year, the potential shortfall is eight certificates.

The employer should then consider whether those anticipated sponsorship requirements are sufficiently developed and credible to support a request for the additional eight CoS.

Where the organisation expects further recruitment beyond the immediately identified vacancies, it should ensure that any additional number requested remains capable of reasonable explanation.

 

5. How to Request Additional CoS Allocation

An additional allocation request is made through the Sponsor Management System (SMS).

The request should be submitted by an authorised SMS user with the appropriate permissions.

The employer should provide the information required through the system and explain why further Undefined CoS are needed.

The explanation should be consistent with the organisation’s actual recruitment plans and wider sponsorship records.

Submitting the request does not itself increase the allocation. The employer must wait for UKVI to determine the request and make any approved additional certificates available.

 

6. Explain Why the Existing Allocation Is Insufficient

A strong additional allocation request should explain why the sponsor’s current allocation no longer meets its requirements.

The explanation may be straightforward where the employer has simply used its allocation faster than expected, but the organisation should still explain the underlying recruitment activity.

Where demand has materially increased, the employer should identify what has changed.

For example:

 

• a new client contract has created additional vacancies;
• business growth has increased staffing requirements;
• a new site requires additional workers;
• recruitment volumes have increased beyond the original forecast;
• additional roles have become vacant; or
• the organisation has identified further workers who require sponsorship.

 

The explanation should allow UKVI to understand why the sponsor now requires more Undefined CoS than were previously available.

 

7. Linking the Number Requested to Recruitment

The number of additional CoS requested should be connected to identifiable recruitment requirements.

For larger requests, it can be helpful to break down the requirement by factors such as:

 

• role or occupation;
• department;
• business function;
• location;
• project;
• number of anticipated workers;
• expected recruitment period; and
• relevant sponsorship route.

 

This can make it easier to demonstrate how the organisation arrived at the requested number.

For example, a request for 30 additional Undefined CoS is more readily understood where the employer can explain that the requirement comprises specified numbers of anticipated sponsored workers across particular roles, locations or projects than where the request merely states that additional recruitment is expected.

 

8. Evidence for an Additional Allocation Request

The information or evidence relevant to an additional allocation request will depend on the organisation’s circumstances and the reason for the increase.

Depending on the case, relevant material may relate to:

 

• vacancies;
• recruitment campaigns;
• workforce planning;
• new contracts;
• new projects;
• business expansion;
• additional sites or locations;
• changes to staffing requirements;
• historic CoS usage; and
• other information demonstrating the genuine requirement for additional sponsored workers.

 

The objective is to support the connection between the organisation’s business requirement and the number of additional Undefined CoS requested.

 

9. UKVI May Request Further Information

UKVI can request further information before deciding whether to grant an additional allocation.

The employer should respond accurately, consistently and within any deadline specified.

Where further information is requested, the sponsor should address the particular questions raised rather than simply restating that additional CoS are needed.

The request may require the organisation to explain the proposed roles, recruitment volumes, timing, business circumstances or other matters relevant to the additional allocation.

A delayed or incomplete response can affect the progress of the request and, in turn, the organisation’s recruitment timetable.

 

10. UKVI Can Grant Fewer CoS Than Requested

An additional allocation request does not create an entitlement to the full number requested.

UKVI may grant the requested number, make fewer certificates available or, depending on the circumstances, decline to increase the allocation.

The employer should therefore ensure that the number requested can be credibly justified.

Where UKVI grants fewer CoS than requested, the organisation should assess which anticipated sponsorships are affected and consider the reasons for the reduced allocation before deciding whether further action is appropriate.

 

11. Do Not Wait Until the Allocation Reaches Zero

Where possible, employers should identify a likely allocation shortage before all available Undefined CoS have been used.

Waiting until the allocation reaches zero can expose the organisation to avoidable recruitment delays.

Until additional allocation is made available, the sponsor cannot assign another Undefined CoS to a worker who requires one.

This can become particularly problematic where:

 

• a worker has an approaching immigration deadline;
• a planned start date depends on sponsorship;
• several workers need to be sponsored at approximately the same time;
• a project depends on rapid recruitment; or
• the employer has made commercial commitments based on anticipated staffing levels.

 

Allocation monitoring should therefore be forward-looking rather than simply recording how many certificates remain.

 

12. Additional Allocation and Processing Times

Employers should allow sufficient time for UKVI to consider an additional allocation request.

Home Office guidance currently states that requests for additional Undefined CoS are usually decided within 12 weeks, although processing can take longer where further checks are required.

Eligible sponsors may be able to use the Home Office priority change of circumstances service to seek faster consideration of an eligible additional Undefined CoS allocation request, subject to the current requirements, availability and payment of the applicable fee.

Employers with time-sensitive recruitment should therefore factor allocation processing into their sponsorship timetable rather than considering only the processing time for the worker’s subsequent immigration application.

 

13. Additional Allocation as a Workforce Planning Process

The need for additional CoS should ideally be identified through regular comparison of available allocation against anticipated recruitment.

A practical process is:

Check available Undefined CoS → review the recruitment pipeline → determine which workers require Undefined CoS → calculate the expected shortfall → prepare the justification → submit the additional allocation request → monitor the decision → update the recruitment plan.

This allows the employer to manage CoS availability proactively and reduces the risk of discovering an allocation shortage only when an individual worker is ready to be sponsored.

 

 

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Section I: How to Justify a CoS Allocation Request

 

1. Why the Allocation Justification Matters

When requesting an allocation of Undefined Certificates of Sponsorship, the employer should be able to explain why the certificates are required and how the number requested has been calculated.

This applies whether the organisation is seeking an initial allocation, a follow-on annual allocation or additional CoS during its current CoS year.

The allocation request should demonstrate a credible relationship between the organisation’s business circumstances, its workforce requirements and the number of workers it reasonably expects to sponsor using Undefined CoS.

The objective is not simply to state that the organisation intends to recruit overseas workers.

UKVI should be able to understand:

 

• why recruitment is required;
• what roles or workforce requirements are involved;
• how many sponsored workers are anticipated;
• why those workers are expected to require Undefined CoS; and
• when the certificates are expected to be used.

 

2. Start With the Business Requirement

A clear allocation justification should begin with the underlying business or workforce requirement.

The employer should explain what is creating the need for recruitment.

Depending on the circumstances, this may include:

 

• normal ongoing recruitment;
• business growth;
• a new client contract;
• a new project;
• the opening of a new site;
• expansion of an existing department;
• increased customer demand;
• replacement recruitment;
• skills shortages;
• changes to the existing workforce; or
• another genuine operational requirement.

 

This provides the commercial and operational context for the number of certificates requested.

Where the organisation’s sponsorship requirement has increased significantly, the explanation should identify what has changed since the previous allocation or period of CoS usage.

 

3. Identify the Proposed Roles

The employer should then explain the types of roles for which sponsored recruitment is anticipated.

The level of detail required will depend on the circumstances and the nature of the allocation request.

For a relatively small request, the organisation may be able to identify the proposed vacancies individually.

For larger or recurring recruitment programmes, it may be more appropriate to group the requirement by:

 

• job role;
• occupation;
• department;
• business function;
• location;
• project; or
• recruitment campaign.

 

The important point is that the number requested should correspond with an identifiable workforce requirement rather than an unexplained estimate.

 

4. Explain the Anticipated Recruitment Volume

The employer should explain how many workers it expects to recruit and how this translates into the number of Undefined CoS requested.

For example, if the organisation expects to recruit 20 sponsored workers, this does not necessarily mean that it requires 20 additional Undefined CoS.

The employer should first consider:

 

• how many of the workers will require sponsorship;
• which sponsorship routes will be used;
• which workers are expected to require Undefined CoS;
• whether any workers will instead require Defined CoS; and
• how many Undefined CoS the sponsor already has available.

 

This allows the organisation to calculate the actual allocation requirement rather than simply using its total anticipated overseas recruitment figure.

 

5. Explain Why Undefined CoS Are Required

The justification should be based specifically on the organisation’s requirement for Undefined Certificates of Sponsorship.

This is important because Defined CoS are requested separately and do not come from the annual Undefined CoS allocation.

An employer requesting additional allocation should therefore avoid including workers who are expected to require Defined CoS within its calculation of the additional Undefined CoS needed.

Where the proposed recruitment involves Skilled Workers applying from within the UK, for example, the organisation may be able to explain that the anticipated workers are expected to require Undefined CoS because of the circumstances in which their Skilled Worker applications will be made.

The employer should still verify the correct CoS type for each worker before assignment.

 

6. Explain When the CoS Are Expected to Be Used

Timing can help demonstrate that an allocation request reflects genuine anticipated recruitment rather than a speculative attempt to build up a reserve of certificates.

The organisation should consider when the proposed workers are expected to be recruited and sponsored.

This may involve identifying:

 

• immediate vacancies;
• recruitment expected during the next few months;
• scheduled recruitment campaigns;
• project start dates;
• contract mobilisation dates;
• planned business expansion; or
• other relevant workforce deadlines.

 

Where recruitment will take place in stages, explaining the anticipated timetable can help demonstrate how the requested number has been calculated.

 

7. Use Historic CoS Usage Where Relevant

Historic sponsorship activity can provide useful context for an allocation request.

If an organisation regularly assigns a similar number of Undefined CoS each year, previous usage may help demonstrate an established sponsorship requirement.

Where the new request is materially higher than previous usage, however, the employer should explain the reason for the increase.

For example:

Previous CoS usage → changed business circumstances → increased recruitment requirement → increased Undefined CoS requirement.

A significant increase is not necessarily problematic where it reflects genuine business circumstances, but the organisation should be prepared to explain the change.

 

8. Supporting Evidence for the Allocation Request

The evidence relevant to an allocation request will depend on the facts of the case.

There is no single standard evidence package suitable for every employer.

Depending on the reason for the request, supporting material may relate to:

 

• vacancies and job descriptions;
• recruitment activity;
• current workforce information;
• organisational structure;
• business expansion;
• new contracts;
• project requirements;
• new sites or locations;
• workforce forecasts;
• historic CoS usage; or
• other information demonstrating the underlying recruitment requirement.

 

The evidence should support the explanation being provided rather than being submitted without a clear connection to the allocation requested.

 

9. Large Allocation Requests

Where an employer is requesting a substantial number of additional Undefined CoS, a more detailed breakdown of the requirement may be appropriate.

For example, instead of stating simply that the organisation requires 50 additional CoS, the employer may be able to explain the requirement by reference to:

 

• the number of workers required in each role;
• the departments requiring additional staff;
• the locations where workers will be based;
• the projects or contracts generating the vacancies;
• the expected recruitment timetable; and
• the number of existing Undefined CoS still available.

 

This can make the calculation easier to understand and demonstrate that the requested number has been derived from actual workforce planning.

 

10. Avoid Speculative Allocation Requests

An employer should avoid requesting an unnecessarily large number of Undefined CoS simply because it would prefer to have a substantial reserve available.

UKVI may grant fewer CoS than requested or set an allocation at zero where the requirement has not been sufficiently justified or is not considered credible.

Home Office guidance also indicates that uncertainty over whether or when proposed workers will actually be recruited can be relevant to the allocation decision.

The sponsor should therefore distinguish between reasonably anticipated recruitment and purely speculative future possibilities.

This does not mean that every proposed worker must already have been identified. Employers can have genuine future recruitment requirements without having selected every candidate.

The important issue is whether the anticipated requirement is credible and capable of explanation.

 

11. Ensure the Request Is Consistent With the Organisation’s Circumstances

The allocation request should be consistent with the organisation’s wider circumstances and the information available to UKVI.

This can include factors such as:

 

• the number of workers employed;
• the nature and extent of the business;
• how long the organisation has been trading;
• previous dealings with the Home Office;
• historic sponsorship activity;
• the organisation’s recruitment model; and
• the scale of the proposed sponsored recruitment.

 

Where an allocation request appears unusual when compared with the organisation’s existing activities, the employer should explain the circumstances creating the requirement rather than leaving UKVI to infer why the number has changed.

 

12. Recruitment Agents and Third-Party Recruitment

Where the organisation uses recruitment agents or other intermediaries, sponsors should remain aware that UKVI may consider information about recruitment agents, including whether they have been linked to immigration abuse.

The sponsor should retain appropriate oversight of how sponsored workers are being recruited.

Using an external recruiter does not transfer the sponsor’s responsibilities under the sponsorship system.

The employer should be able to understand and explain its own workforce requirement, the proposed roles and the basis on which the number of sponsored workers has been calculated.

 

13. A Practical CoS Allocation Justification Framework

A useful structure for preparing an allocation request is:

Business need → proposed roles → anticipated recruitment volume → timing → immigration route → number of Undefined CoS required.

In practical terms, the employer should be able to answer:

 

1. Why does the organisation need additional workers?
2. What roles are expected to be filled?
3. How many workers are anticipated?
4. When will recruitment take place?
5. Which sponsorship route will be used?
6. Why are Undefined CoS required?
7. How many Undefined CoS are already available?
8. How many additional certificates are therefore required?

 

This provides a logical basis for the allocation request and helps ensure that the number requested can be traced back to the organisation’s genuine recruitment requirements.

 

14. Example CoS Allocation Justification

A concise allocation justification might follow this structure:

“We require [number] Undefined Certificates of Sponsorship because we expect to recruit [number/type of workers] into [roles/functions] during [period]. This requirement arises because of [business/recruitment reason], and these workers are expected to require Undefined CoS because [relevant sponsorship circumstances]. We currently have [number] Undefined CoS available and therefore require an additional [number] certificates to meet the anticipated requirement.”

The wording should be adapted to the organisation’s actual circumstances and supported with further detail or evidence where appropriate.

The employer should not use generic wording where it does not accurately describe the underlying recruitment requirement.

 

15. Responding to UKVI Questions About the Justification

UKVI may request further information before deciding the allocation request.

Where this happens, the employer should address the questions raised directly and ensure that the response remains consistent with the original request and the organisation’s wider sponsor records.

If UKVI questions a significant increase in the number requested, the sponsor should explain what has changed and provide relevant supporting information where appropriate.

If UKVI questions whether the roles or recruitment requirement are credible, the organisation should address those concerns specifically rather than merely repeating the requested number.

A clear allocation case should ultimately demonstrate:

Why the workers are needed → why sponsorship is expected → why Undefined CoS are required → why the requested number is reasonable → when the certificates are expected to be used.

 

 

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Section J: CoS Allocation Processing Times

 

1. How Long Does a CoS Allocation Request Take?

Employers should factor Home Office processing times into their Certificate of Sponsorship allocation planning.

Under current Home Office guidance, requests for additional Undefined Certificates of Sponsorship are usually decided within 12 weeks.

This should be treated as a planning timeframe rather than a guarantee that every allocation request will be decided within exactly 12 weeks.

Processing can take longer where UKVI needs to carry out further checks or requires additional information before determining the request.

For employers with time-sensitive recruitment, the allocation stage can therefore become an important part of the overall sponsorship timetable.

 

2. Why CoS Allocation Processing Time Matters

An employer cannot assign an Undefined CoS that it does not have available within its allocation.

If the organisation discovers that its allocation is insufficient only when a worker is ready to be sponsored, it may first have to obtain additional allocation before it can proceed with the relevant CoS.

This can create an additional stage in the recruitment and immigration process.

The practical sequence may become:

Identify allocation shortage → submit additional allocation request → wait for UKVI decision → receive additional allocation → consider individual sponsorship requirements → assign CoS → worker makes immigration application.

The time taken to obtain additional allocation therefore arises before the worker’s subsequent immigration application can proceed using that Undefined CoS.

 

3. Processing Can Take Longer Where Further Checks Are Required

The usual processing period should not be treated as an absolute deadline.

Home Office guidance makes clear that an additional allocation request can take longer where further checks are required.

UKVI may need to examine the organisation’s circumstances, previous sponsorship activity, proposed recruitment or other information relevant to the allocation request.

Where questions arise, UKVI may seek further information before deciding how many additional certificates should be made available.

Employers should therefore avoid building recruitment plans around an assumption that an allocation request will necessarily be approved by a particular date.

 

4. Requests for Further Information Can Affect Timing

Where UKVI requests further information, the employer should respond promptly and accurately within any deadline specified.

The information requested may concern matters such as:

 

• the reason additional CoS are required;
• the number of workers the organisation expects to sponsor;
• the proposed roles;
• the anticipated recruitment timetable;
• the organisation’s existing workforce;
• historic CoS usage;
• a significant increase in the number of certificates requested;
• the nature and scale of the organisation’s business; or
• other matters relevant to the credibility of the request.

 

A request for further information should be treated as a substantive part of the allocation process.

The employer should answer the questions raised directly and ensure that its response is consistent with the original request and its wider sponsor records.

 

5. Allocation Processing Time and Immigration Deadlines

Allocation delays can become particularly significant where a proposed worker has an approaching immigration deadline.

For example, a worker may need to make an in-country application before their existing immigration permission expires.

If an Undefined CoS is required for that application and the employer has no allocation remaining, the organisation may first need UKVI to approve additional allocation before the relevant certificate can be assigned.

Employers should therefore identify immigration deadlines as early as possible and consider whether sufficient CoS capacity is already available.

Waiting until shortly before a worker’s existing permission expires can leave limited time to resolve an allocation shortage.

 

6. Allocation Processing Time and Recruitment Start Dates

CoS allocation can also affect planned employment start dates.

An organisation may have completed its recruitment process and selected a candidate but still be unable to proceed immediately with sponsorship if the required Undefined CoS is not available.

This can have operational consequences where:

 

• a project depends on the worker starting by a particular date;
• a vacancy is business-critical;
• several sponsored workers are being recruited simultaneously;
• a new contract requires rapid mobilisation;
• the employer has committed to a recruitment timetable; or
• the worker has contractual or immigration deadlines of their own.

 

Allocation availability should therefore be checked before the recruitment process reaches its final stages wherever sponsored recruitment is anticipated.

 

7. Do Not Confuse Allocation Processing With Visa Processing

The processing time for a CoS allocation request is separate from the processing time for the worker’s immigration application.

This distinction is important when planning the overall recruitment timetable.

If additional allocation is required, the employer may first need to wait for UKVI to determine the allocation request.

Once sufficient allocation is available and the individual sponsorship requirements have been satisfied, the appropriate CoS can then be assigned.

The worker can subsequently use the CoS reference in the relevant immigration application.

Employers should therefore consider the full sequence rather than looking only at the published processing time for the worker’s visa application.

 

8. Can a CoS Allocation Request Be Prioritised?

Eligible sponsors may be able to use the Home Office Worker and Temporary Worker priority change of circumstances service for certain CoS allocation requests.

The service can include eligible requests relating to additional and annual CoS allocations.

For additional CoS allocation requests, the priority service applies to eligible requests for Undefined CoS.

Use of the priority service is subject to the current Home Office eligibility requirements, service capacity, application procedure and payment of the applicable fee.

Priority processing should therefore not be assumed to be automatically available whenever an employer has an urgent recruitment requirement.

 

9. Current Priority Processing Times

Under the current priority change of circumstances service, eligible requests accepted into the service are generally considered within five working days following payment, subject to the detailed Home Office service rules and the need for any further checks or information.

The current Home Office fee is £350 per priority request.

The service is capacity-controlled and acceptance is not guaranteed.

The Home Office currently provides for a minimum number of priority requests to be accepted each working day, but employers should check the current service arrangements before relying on priority processing.

Fees, capacity and procedural requirements can change, so sponsors should verify the current position at the point the service is required.

 

10. Priority Processing Does Not Guarantee Approval

Priority processing affects the speed at which an eligible request is considered. It does not change the substantive requirements governing the allocation request.

Paying for priority processing does not guarantee that:

 

• the allocation request will be approved;
• the full number of CoS requested will be granted;
• UKVI will not request further information;
• UKVI will not undertake additional checks; or
• there are no wider sponsor compliance issues requiring consideration.

 

The allocation request should therefore be properly prepared regardless of whether the standard or priority process is used.

 

11. Build Allocation Time Into Workforce Planning

The most effective way to reduce the operational impact of CoS allocation processing times is to identify future requirements before the available allocation is exhausted.

Employers should periodically compare:

 

• the number of Undefined CoS currently available;
• the number of workers already progressing through recruitment;
• anticipated recruitment during the remainder of the CoS year;
• known immigration deadlines;
• planned employment start dates; and
• the time potentially required to obtain additional allocation.

 

This allows the organisation to identify a likely shortage while there is still time to submit an allocation request through the normal process.

The planning principle is:

Do not wait for the allocation to reach zero before deciding whether more Undefined CoS will be required.

Where a shortfall can be anticipated, early action can reduce reliance on urgent processing and lower the risk of CoS availability disrupting planned recruitment.

 

 

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Section K: Priority CoS Allocation Requests

 

1. Can a CoS Allocation Request Be Prioritised?

Eligible sponsors may be able to use the Home Office Worker and Temporary Worker priority change of circumstances service to obtain faster consideration of certain Certificate of Sponsorship allocation requests.

The priority service can cover eligible requests relating to:

 

• additional Undefined CoS allocations; and
• annual CoS allocations.

 

For an additional CoS allocation request, the priority service applies to eligible requests for Undefined Certificates of Sponsorship.

The service does not remove the requirement for the underlying allocation request to satisfy the applicable Home Office requirements.

 

2. Eligibility for the Priority Service

Use of the priority service is subject to the current Home Office eligibility requirements.

Under the current arrangements, the sponsor must generally:

 

• hold an A-rated sponsor licence;
• have a sponsor licence that is fully active;
• have already submitted the relevant request through the Sponsor Management System;
• make a priority request that falls within the categories accepted by the service; and
• satisfy the current procedural requirements for requesting priority consideration.

 

A request will not necessarily be eligible for priority consideration if the underlying request is already in progress or has been allocated to a caseworker.

Sponsors should check the current Home Office priority service requirements before attempting to use the service, as eligibility and procedural arrangements can change.

 

3. Submit the SMS Request First

The priority service should not be confused with the underlying CoS allocation request.

The sponsor must first submit the relevant allocation request through the Sponsor Management System.

The priority process is then used, where eligible, to seek expedited consideration of that existing request.

The practical sequence is therefore:

Identify the allocation requirement → prepare the justification → submit the relevant request through the SMS → apply for priority consideration in accordance with the current Home Office procedure → pay the priority fee if the request is accepted → await the expedited decision.

Employers should ensure that the underlying SMS request is complete and properly justified before seeking priority processing.

 

4. How Quickly Is a Priority CoS Allocation Request Decided?

Under the current priority service, the Home Office aims to consider an accepted priority request within five working days following payment, subject to the detailed rules governing when the processing period begins and whether further information or checks are required.

This can provide a significantly faster route than relying on the standard processing timeframe for an additional Undefined CoS allocation request.

Employers should nevertheless avoid treating five working days as an unconditional guarantee of a final approval.

The circumstances of the request, further checks and any requirement for additional information can affect how the matter progresses.

 

5. How Much Does Priority CoS Allocation Processing Cost?

The current Home Office fee for the Worker and Temporary Worker priority change of circumstances service is £350 per priority request.

This fee is payable for priority consideration of the request and is separate from any other sponsorship or immigration costs that may arise.

Home Office fees can change. Employers should therefore check the current published fee before making a priority request rather than relying on historic figures.

 

6. Priority Service Capacity Is Limited

Access to the priority service is capacity-controlled.

The Home Office currently provides for a minimum number of priority requests to be accepted each working day, but this does not mean that every sponsor seeking priority consideration will necessarily obtain a place when required.

Availability should therefore not be assumed.

An employer should not deliberately postpone an allocation request on the basis that it expects to use the priority service later.

Where a future allocation shortage can reasonably be identified in advance, the more reliable approach is to submit the appropriate request in sufficient time through the normal allocation process.

 

7. Priority Processing Does Not Guarantee Approval

Priority processing changes the speed at which an eligible request is considered. It does not lower the substantive requirements applying to the allocation request.

Payment of the priority fee does not guarantee that:

 

• the allocation request will be approved;
• the sponsor will receive the full number of Undefined CoS requested;
• UKVI will not ask for further information;
• UKVI will not carry out additional checks; or
• the request will avoid consideration of wider sponsor compliance issues where these arise.

 

The sponsor should therefore prepare the allocation request to the same standard whether it intends to use standard or priority processing.

 

8. Prepare the Allocation Case Before Seeking Priority

An urgent request still needs a credible allocation justification.

Before seeking priority processing, the employer should have established:

 

• how many Undefined CoS are currently available;
• how many additional certificates are required;
• why the existing allocation is insufficient;
• which anticipated workers or recruitment requirements create the shortfall;
• why Undefined CoS are required;
• when the certificates are expected to be used; and
• what evidence or information supports the request.

 

Using priority processing for a poorly prepared allocation request can result in faster consideration without necessarily producing the outcome the employer needs.

Speed should therefore not replace substantive preparation.

 

9. When Might Priority Processing Be Appropriate?

Priority consideration may be particularly relevant where there is a genuine time-sensitive requirement and waiting for standard processing could materially affect recruitment or immigration timing.

Examples may include circumstances where:

 

• a worker has an approaching immigration deadline;
• a critical vacancy needs to be filled urgently;
• a project or contract has a fixed mobilisation date;
• the employer has unexpectedly exhausted its allocation;
• an unforeseen recruitment requirement has arisen; or
• a delay in obtaining allocation could materially affect planned sponsored recruitment.

 

The existence of an urgent commercial requirement does not itself guarantee acceptance into the priority service or approval of the allocation request.

 

10. Priority Processing Should Not Replace Allocation Planning

The priority service can be valuable where an urgent CoS allocation requirement arises, but it should not become the organisation’s routine method of managing its annual sponsorship capacity.

Regular reliance on urgent allocation requests may indicate that the employer’s recruitment forecasting or sponsor management processes need improvement.

Employers that sponsor workers regularly should monitor:

 

• available Undefined CoS;
• current recruitment activity;
• anticipated sponsorship demand;
• immigration deadlines;
• the end of the CoS year; and
• the likely requirement for further allocation.

 

The objective should be to identify foreseeable shortages early enough to use the standard process wherever practicable.

 

11. Check the Current Priority Service Before Applying

Priority service requirements, fees, capacity and procedures can change.

Before relying on priority processing, the sponsor should check the current Home Office guidance to confirm:

 

• whether the allocation request is eligible;
• whether the sponsor satisfies the eligibility requirements;
• the current priority fee;
• the current application procedure;
• service availability;
• the current processing target; and
• any restrictions affecting the request.

 

The practical rule is:

Use priority processing to accelerate an eligible and properly prepared allocation request where necessary, not as a substitute for forecasting and managing CoS demand.

 

 

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Section L: What Happens If You Run Out of CoS?

 

1. Running Out of Undefined CoS

If a sponsor has no Undefined Certificates of Sponsorship remaining within its allocation, it cannot assign another Undefined CoS until sufficient allocation becomes available.

This can prevent the organisation from progressing a proposed sponsorship even where it has already identified a suitable worker and the underlying role appears capable of meeting the relevant immigration requirements.

The immediate issue is not necessarily whether the organisation continues to hold a valid sponsor licence. It is whether the sponsor has sufficient Undefined CoS allocation available to issue the type of certificate required by the worker.

An employer that has exhausted its allocation should therefore identify the nature of the requirement before deciding what action to take.

 

2. First Check Whether the Worker Requires an Undefined CoS

Before requesting additional allocation, the employer should confirm that the proposed worker actually requires an Undefined CoS.

This is important because Defined CoS operate through a separate request process and do not come from the sponsor’s annual Undefined CoS allocation.

For Skilled Worker sponsorship:

 

• an eligible worker applying for permission to stay from within the UK will generally require an Undefined CoS; while
• an eligible Skilled Worker applying for entry clearance from outside the UK will generally require a Defined CoS.

 

If the worker requires a Defined CoS, the fact that the sponsor’s Undefined CoS allocation has reached zero does not mean that the organisation needs additional Undefined CoS for that worker.

The sponsor should instead follow the applicable Defined CoS request process.

 

3. Do Not Use the Wrong Type of CoS

A sponsor should not attempt to solve an allocation shortage by assigning the wrong type of Certificate of Sponsorship.

An available CoS can only be used where it is the correct type for the proposed sponsorship.

Home Office sponsor guidance provides for serious compliance consequences where the CoS system is misused. In particular, UKVI will normally revoke a sponsor licence where a sponsor assigns an Undefined CoS to a Skilled Worker who is required to have a Defined CoS, or assigns a Defined CoS for a job other than the one specified in the application for that Defined CoS.

The correct sequence is therefore:

Identify the worker’s circumstances → establish the correct CoS type → check whether the relevant CoS is available → take the appropriate action if it is not.

 

4. Request Additional Undefined CoS

Where the worker requires an Undefined CoS and the organisation does not have sufficient allocation available, the sponsor can consider making an additional allocation request through the Sponsor Management System.

The employer should calculate how many further Undefined CoS it genuinely requires rather than limiting the assessment to the immediate worker if further sponsored recruitment is already anticipated.

For example, if the organisation has reached zero allocation but has six workers progressing through recruitment who are expected to require Undefined CoS, it may be more appropriate to assess the requirement for all six workers rather than repeatedly requesting certificates one at a time.

The number requested should remain credible and capable of justification.

 

5. Explain Why the Allocation Has Been Exhausted

Where additional CoS are required, the sponsor should be prepared to explain why its existing allocation is no longer sufficient.

Possible reasons may include:

 

• higher recruitment volumes than originally anticipated;
• business expansion;
• a new contract or project;
• additional vacancies;
• unexpected staff turnover;
• a change in workforce requirements;
• increased demand for sponsored workers; or
• another genuine change in the organisation’s circumstances.

 

The fact that the organisation has exhausted its allocation is not, by itself, the complete justification for additional CoS.

The employer should explain the underlying recruitment requirement that creates the need for further certificates.

 

6. Running Out of CoS Can Delay Sponsorship

An allocation shortage can delay the sponsorship process because the employer may need to obtain additional allocation before an Undefined CoS can be assigned.

The sequence can become:

Worker identified → allocation shortage discovered → additional allocation request submitted → UKVI considers request → additional CoS become available if approved → individual sponsorship checked → CoS assigned → worker proceeds with the relevant immigration application.

This additional stage can be particularly significant where the employer had assumed that sponsorship could proceed immediately.

The organisation should therefore check CoS availability early in the recruitment process where sponsorship is likely to be required.

 

7. Consider the Worker’s Immigration Deadline

An allocation shortage can become particularly urgent where the worker has an approaching immigration deadline.

For example, an existing worker may need to make an eligible in-country application before their current immigration permission expires.

If an Undefined CoS is required and the employer has no available allocation, additional CoS may need to be obtained before the certificate can be assigned and the worker can use it for the relevant application.

Employers should therefore avoid leaving allocation checks until shortly before a worker’s existing permission expires.

Where an immigration deadline is approaching, the organisation should identify the available options promptly and ensure that any advice about the worker’s immigration position takes account of the actual circumstances and applicable rules.

 

8. Consider Planned Employment Start Dates

Running out of CoS can also affect anticipated employment start dates.

An employer may have completed recruitment, made an offer and planned for a worker to start on a particular date, but sponsorship cannot simply proceed if the required Undefined CoS is unavailable.

The resulting delay may affect:

 

• workforce planning;
• project mobilisation;
• client commitments;
• departmental staffing;
• recruitment costs; and
• the worker’s own arrangements.

 

Employers should therefore avoid making sponsorship-dependent recruitment timetables without checking that the necessary sponsorship capacity is available.

 

9. Can Priority Processing Help?

Where the employer has an urgent requirement for additional Undefined CoS, it may be possible to seek priority consideration through the Home Office Worker and Temporary Worker priority change of circumstances service.

The sponsor must satisfy the current eligibility requirements, and the underlying allocation request must first be submitted through the Sponsor Management System.

The current priority service is subject to capacity and an additional Home Office fee.

Priority processing can accelerate consideration of an eligible request, but it does not guarantee that the additional allocation will be approved or that the sponsor will receive the full number of CoS requested.

An urgent request therefore still requires an appropriate justification.

 

10. Avoid Making Premature Commitments

Employers should be careful about making commitments that depend on sponsorship before confirming that the necessary CoS can be made available.

This is particularly relevant where the organisation has little or no remaining Undefined CoS allocation.

Before committing to a sponsorship-dependent timetable, the employer should consider:

 

• whether the worker requires sponsorship;
• which immigration route applies;
• whether a Defined or Undefined CoS is required;
• whether sufficient allocation is currently available;
• whether additional allocation will be necessary;
• the likely allocation processing period; and
• the subsequent immigration application process.

 

This does not mean that recruitment has to stop whenever additional allocation is required. It means the organisation should plan on the basis of the actual sponsorship steps that need to be completed.

 

11. Preventing Future CoS Shortages

Repeatedly reaching zero allocation can indicate that the organisation needs a more structured approach to CoS forecasting.

Employers should monitor not only the certificates already assigned but also anticipated future demand.

A useful internal review can compare:

 

• current Undefined CoS allocation;
• CoS already assigned;
• remaining available allocation;
• workers currently progressing through recruitment;
• anticipated recruitment over the following months;
• known immigration deadlines;
• planned business expansion or projects; and
• the end date of the current CoS year.

 

This allows the organisation to identify a potential shortage while certificates are still available.

 

12. Practical Steps When the Allocation Reaches Zero

If an employer discovers that it has no Undefined CoS remaining, the practical response should be structured rather than reactive.

The organisation should:

 

1. Confirm the current allocation position in the SMS.
2. Identify which proposed workers require sponsorship.
3. Confirm whether each worker requires a Defined or Undefined CoS.
4. Identify how many Undefined CoS are genuinely required.
5. Review relevant immigration and recruitment deadlines.
6. Prepare the justification for additional allocation.
7. Submit the appropriate request through the SMS.
8. Consider priority processing where the request is eligible and genuinely urgent.
9. Monitor the request and respond promptly to any UKVI enquiries.
10. Review internal allocation forecasting to reduce the risk of recurrence.

 

The central rule is straightforward:

If an Undefined CoS is required and none are available, the sponsor must obtain sufficient allocation before that Undefined CoS can be assigned.

 

 

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Section M: CoS Allocation Request Refused or Reduced

 

1. UKVI Does Not Have to Grant the Allocation Requested

A sponsor does not have an automatic entitlement to the number of Undefined Certificates of Sponsorship it requests.

UKVI can decide to:

 

• grant the requested allocation in full;
• grant fewer CoS than requested;
• set the allocation at zero; or
• seek further information before making a decision.

 

The allocation decision is therefore separate from the organisation’s general ability to hold a sponsor licence.

Holding a sponsor licence allows an organisation to participate in the sponsorship system, but it does not give the employer an unrestricted supply of Certificates of Sponsorship.

The sponsor must be able to demonstrate a credible requirement for the allocation it requests.

 

2. Why Might UKVI Reduce or Refuse a CoS Allocation?

UKVI can consider a range of factors when determining how many Undefined CoS should be made available.

A request may be reduced or set at zero where, for example, UKVI is not satisfied that the number requested has been adequately justified or that the proposed sponsorship requirement is credible.

Potential issues can include:

 

• insufficient explanation of why the CoS are required;
• a large increase in the requested allocation without a corresponding explanation;
• uncertainty about whether or when the proposed workers will actually be recruited;
• the number requested appearing inconsistent with the nature or scale of the organisation;
• insufficient information about the proposed roles or recruitment requirement;
• concerns about whether the organisation can offer eligible work to the proposed sponsored workers;
• inconsistencies between the allocation request and other information available to UKVI;
• previous sponsor compliance concerns; or
• wider concerns arising from the organisation’s dealings with the Home Office.

 

The precise reason will depend on the circumstances of the individual sponsor and allocation request.

 

3. UKVI Can Consider the Organisation’s Wider Circumstances

An allocation request is not necessarily considered in isolation from the organisation’s wider sponsorship history and business circumstances.

Home Office guidance identifies a range of factors that UKVI may take into account when considering an allocation, including:

 

• the number of workers employed by the organisation;
• the nature of the business;
• the extent of the business;
• how long the organisation has been trading;
• the sponsor’s previous dealings with the Home Office;
• the use of recruitment agents and whether an agent has been linked to immigration abuse; and
• other matters relevant to the particular sponsorship route or allocation request.

 

The employer should therefore ensure that the number requested is capable of being understood in the context of the organisation’s actual operations.

Where the requirement appears unusual compared with previous sponsorship activity, the sponsor should explain what has changed.

 

4. A Reduced Allocation Does Not Necessarily Mean There Is No Genuine Need

UKVI may accept that an organisation has a genuine requirement for sponsored workers while still deciding that the full number of CoS requested has not been justified.

For example, an employer may request 30 additional Undefined CoS but receive an increase of only 15.

The practical issue is then to understand why UKVI considered a lower number appropriate and how the reduced allocation affects the organisation’s recruitment plans.

The employer should not assume that a partial grant necessarily represents a finding that its entire recruitment requirement is illegitimate.

Equally, the organisation should not assume that it can simply submit the same request again without addressing the reason the full allocation was not granted.

 

5. Responding to a Request for Further Information

Before deciding an allocation request, UKVI may ask the sponsor to provide further information.

This can provide the employer with an opportunity to clarify the requirement and address specific questions about the number of CoS requested.

The organisation should respond directly to the issues raised.

Depending on the request, this may involve providing further information about:

 

• the proposed roles;
• the number of vacancies;
• anticipated recruitment dates;
• the reason for an increase in sponsorship demand;
• the organisation’s workforce;
• new contracts or projects;
• business expansion;
• historic CoS usage; or
• other circumstances relevant to the allocation requirement.

 

The response should be consistent with the original allocation request and with information already provided to UKVI through the sponsorship system.

 

6. What Should an Employer Do If Fewer CoS Are Granted?

Where UKVI grants fewer Undefined CoS than requested, the employer should first establish the practical effect of the decision.

This should include reviewing:

 

• the number of CoS granted;
• the number already available;
• workers currently awaiting sponsorship;
• anticipated recruitment during the remainder of the CoS year;
• immigration deadlines;
• business-critical vacancies; and
• the reasons for the original allocation request.

 

The employer can then determine whether the available allocation is sufficient for its immediate requirements and whether any further action may be necessary.

Where certificates are limited, internal recruitment priorities should not result in the sponsor bypassing the immigration or sponsorship requirements applying to individual workers.

 

7. Can the Employer Make a Further Allocation Request?

Where a genuine requirement for further Undefined CoS remains, it may be possible for the sponsor to make a further allocation request.

Whether this is appropriate will depend on the circumstances.

The employer should first understand why the previous request was reduced or unsuccessful.

If the problem was insufficient explanation or evidence, a further request should address that deficiency.

If the organisation’s circumstances have subsequently changed, the new request should explain the change.

If UKVI questioned the credibility of the recruitment requirement, simply resubmitting substantially the same explanation may not resolve the issue.

A further request should therefore be based on a genuine continuing requirement and should respond to any identifiable concerns arising from the previous decision.

 

8. Allocation Decisions and Sponsor Compliance

An unsuccessful or reduced allocation request does not automatically mean that the sponsor has breached its sponsor duties.

However, an allocation request can bring wider sponsorship issues to UKVI’s attention, and UKVI may consider the sponsor’s compliance history and previous dealings with the Home Office when determining allocation.

Where an allocation decision raises wider concerns about the sponsor’s records, recruitment practices, sponsored roles or compliance systems, the organisation should consider those issues separately rather than treating the matter purely as a question of CoS numbers.

This is particularly important where the allocation decision is accompanied by requests for information or other Home Office action suggesting broader concerns.

 

9. UKVI Can Reduce an Existing CoS Allocation

UKVI’s powers are not limited to deciding new allocation requests.

The Home Office can also reduce an organisation’s existing CoS allocation where circumstances justify doing so.

Depending on the circumstances, the allocation can potentially be reduced to zero.

This may arise where the organisation’s circumstances have materially changed, for example where the business has downsized and no longer appears to require the number of certificates previously made available.

UKVI may also reduce an allocation where compliance action or other information creates concerns about the sponsor or a potential threat to immigration control.

Employers should therefore view an allocation as sponsorship capacity that remains subject to Home Office oversight rather than as an unconditional entitlement that cannot subsequently be changed.

 

10. Business Changes Can Affect the Required Allocation

A sponsor’s workforce requirements can change during the CoS year.

For example, an organisation may:

 

• downsize;
• lose a major contract;
• close a site;
• reduce recruitment;
• restructure part of the business; or
• otherwise experience a material reduction in its anticipated sponsorship requirements.

 

Such changes can affect the factual basis on which the organisation’s previous CoS requirement was calculated.

Sponsors should ensure that their use of CoS remains connected to genuine vacancies and actual sponsorship requirements throughout the allocation period.

 

11. Compliance Concerns and Allocation Reduction

Where UKVI identifies sponsor compliance concerns, the organisation’s CoS allocation may become part of the wider regulatory response.

The employer should take any such concerns seriously because they may extend beyond the immediate availability of Certificates of Sponsorship.

Depending on the circumstances, the organisation may need to review:

 

• sponsor record keeping;
• reporting compliance;
• the genuineness of sponsored vacancies;
• recruitment practices;
• SMS administration;
• key personnel arrangements;
• right to work processes; and
• wider compliance with sponsor duties.

 

Where UKVI action indicates broader sponsor compliance concerns, the employer should assess the underlying issue rather than focusing solely on restoring its CoS allocation.

 

12. Avoid Repeating the Same Allocation Request

If an allocation request has been reduced or unsuccessful, the employer should avoid responding automatically by submitting the same request again with substantially identical information.

Instead, the organisation should consider:

 

1. What number was requested?
2. What number was granted?
3. What explanation was originally provided?
4. Did UKVI request further information?
5. Were any concerns identified?
6. Does the original business requirement still exist?
7. Has the organisation’s position changed?
8. What additional information can substantiate the continuing requirement?

 

The next step should then be determined by the facts rather than by an assumption that repeated submission will produce a different outcome.

 

13. Practical Response to a Refused or Reduced Allocation

Where a CoS allocation request is refused, set at zero or granted for fewer certificates than requested, the employer should take a structured approach.

A practical framework is:

Review the decision → identify the reason or likely issue → assess the remaining CoS capacity → identify affected recruitment → check immigration deadlines → determine whether further evidence or changed circumstances support another request → address any wider compliance concerns → plan the next allocation step.

The immediate commercial objective may be to obtain enough CoS to continue recruitment, but the sponsor should also ensure that the underlying allocation case and wider sponsor compliance position are sound.

 

 

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Section N: Managing CoS Allocations Through the Sponsor Management System

 

1. Using the SMS to Manage CoS Allocations

The Sponsor Management System (SMS) is the Home Office online system through which licensed sponsors carry out many of the administrative functions associated with their sponsor licence.

For Certificate of Sponsorship allocation purposes, the SMS allows the organisation to manage and monitor its available Undefined CoS and submit relevant allocation requests.

Effective allocation management requires more than checking the SMS immediately before a worker needs to be sponsored.

Employers should use the information available through the system as part of an ongoing process for monitoring sponsorship capacity against anticipated recruitment.

 

2. Check the Current CoS Allocation

Sponsors should regularly check their current allocation position within the SMS.

This should include understanding:

 

• the organisation’s current Undefined CoS allocation;
• the number of CoS already assigned;
• the number remaining available;
• the relevant CoS year; and
• whether further allocation is likely to be required.

 

The number of certificates currently available should then be considered alongside the organisation’s recruitment pipeline.

An allocation that appears sufficient when viewed in isolation may be inadequate once planned recruitment and upcoming sponsorship requirements are taken into account.

 

3. Monitor the CoS Year

The employer should know when its current CoS year begins and ends.

For most sponsors, the CoS year runs for 12 months from the date the sponsor licence was granted and, subsequently, for 12 months from the date a follow-on allocation request is granted.

Different arrangements can apply to certain legacy sponsors whose former Tier 2 licences were converted under the sponsorship system changes introduced in December 2020.

The organisation should therefore check its own position in the SMS rather than assuming that its CoS year corresponds with the calendar year, financial year or another internal reporting period.

This is particularly important because unused Undefined CoS do not carry forward into the next CoS year.

 

4. Level 1 Users and CoS Allocation Management

Level 1 Users have access to the principal day-to-day sponsor management functions available through the SMS, subject to the permissions and restrictions applying to the particular user and sponsor licence.

Organisations should ensure that appropriate personnel are available to manage CoS requirements and that access is not dependent on a single individual without contingency arrangements.

Internal responsibility should be clear for activities such as:

 

• checking available allocation;
• monitoring CoS usage;
• submitting allocation requests;
• responding to Home Office enquiries;
• coordinating sponsorship with recruitment teams; and
• maintaining appropriate internal records.

 

Access to the SMS should only be provided and used in accordance with the applicable sponsor management requirements.

 

5. Changes to Level 2 Users

Sponsors should be aware of changes to the Home Office’s arrangements for Level 2 Users.

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

Existing Level 2 Users are subject to transitional arrangements and must be upgraded to Level 1 User status, where eligible, or deactivated by 8 March 2027.

Employers that historically relied on Level 2 Users for restricted SMS functions should therefore review their user arrangements and ensure that appropriate Level 1 User coverage is maintained.

The organisation should not assume that the historic Level 1 User and Level 2 User structure will continue indefinitely in its previous form.

 

6. Multi-Factor Authentication for SMS Users

Mandatory multi-factor authentication has also been introduced for SMS users.

From 3 September 2026, SMS access is subject to the Home Office’s multi-factor authentication requirements.

Employers should ensure that authorised users can access the system when required and that internal sponsor management arrangements take account of the updated authentication process.

This is particularly important where an urgent allocation request, Home Office information request or time-sensitive sponsorship action needs to be completed.

Access problems should not be allowed to become a preventable cause of delay in the organisation’s sponsorship process.

 

7. SMS Access Does Not Replace Internal Authority

Technical ability to perform an action through the SMS should not be treated as a substitute for appropriate internal governance.

An organisation may have several authorised users, but it should still determine who has authority internally to request additional allocation, approve sponsored recruitment and commit the organisation to particular sponsorship actions.

Depending on the size and structure of the employer, internal approval may involve:

 

• HR;
• global mobility;
• recruitment;
• legal or compliance teams;
• finance;
• business unit leaders; or
• the Authorising Officer.

 

The precise process will differ between organisations, but responsibility should be sufficiently clear to prevent duplicate, inconsistent or unauthorised sponsorship activity.

 

8. Maintain an Internal CoS Allocation Tracker

Employers that sponsor workers regularly may benefit from maintaining an internal CoS allocation tracker alongside the SMS.

The SMS remains the relevant Home Office system, but an internal tracker can help the organisation connect its available allocation with future recruitment requirements.

The tracker may record:

 

• current Undefined CoS allocation;
• CoS already assigned;
• remaining allocation;
• anticipated sponsored workers;
• expected CoS type;
• proposed assignment dates;
• immigration deadlines;
• recruitment start dates;
• pending allocation requests;
• the CoS year end date; and
• responsibility for the next action.

 

This can be particularly useful for organisations with several recruitment teams, business units or locations.

 

9. Managing Allocations Across Multiple Teams

Allocation problems can arise where different parts of an organisation recruit sponsored workers independently but draw on the same available Undefined CoS allocation.

For example, one department may plan recruitment on the assumption that six CoS remain available while another department is simultaneously preparing to use four of them.

Without central oversight, the organisation can unintentionally overcommit its remaining sponsorship capacity.

Employers with decentralised recruitment should therefore establish a process for communicating planned CoS requirements before certificates are assigned.

A central allocation record can help ensure that all relevant teams are working from the same information.

 

10. Monitor Future Demand, Not Just the Current Balance

The number shown as currently available in the SMS provides only part of the information required for effective allocation management.

The employer should also consider certificates that are likely to be required in the near future.

For example, an organisation may have ten Undefined CoS available and therefore appear to have sufficient capacity.

However, if 16 workers are already progressing through recruitment and are expected to require Undefined CoS during the next two months, the organisation may have a foreseeable shortfall of six certificates.

The relevant management question is therefore not simply:

“How many CoS do we have left?”

It is:

“How many Undefined CoS do we have available compared with how many we reasonably expect to need?”

 

11. Reconcile CoS Usage With Recruitment Activity

Sponsors should periodically reconcile CoS usage against actual recruitment and sponsorship activity.

This can help identify:

 

• unexpectedly high CoS usage;
• departments using more sponsorship capacity than forecast;
• unused recruitment forecasts;
• upcoming allocation shortages;
• incorrect assumptions about Defined and Undefined CoS;
• changes in recruitment demand; and
• the likely requirement for additional allocation.

 

Regular reconciliation also provides better information when the organisation needs to justify a future allocation request.

Rather than estimating requirements at the point of application, the sponsor can draw on its actual sponsorship and recruitment data.

 

12. Control the Allocation Request Process

Requests for additional or follow-on allocation should form part of a controlled internal process.

Before a request is submitted through the SMS, the organisation should establish:

 

1. How many Undefined CoS are currently available?
2. How many are expected to be required?
3. When will they be required?
4. Why are the additional certificates needed?
5. How has the requested number been calculated?
6. What information supports the request?
7. Who has approved the request internally?

 

This reduces the risk of speculative requests or allocation applications that cannot be adequately explained if UKVI seeks further information.

 

13. Monitor Pending Allocation Requests

Submitting an allocation request should not be treated as the end of the process.

The organisation should monitor the request and ensure that relevant personnel are able to respond if UKVI seeks further information.

Internal recruitment teams should also understand that an allocation request is not the same as an approved allocation.

Until UKVI makes the relevant CoS available, the employer should not assume that the requested number can be used for planned sponsorship.

Once a decision is received, the organisation should update its internal allocation records and reassess its recruitment capacity accordingly.

 

14. Keep Allocation Management Separate From Individual CoS Assignment

Managing the organisation’s CoS allocation should be distinguished from deciding whether a Certificate of Sponsorship can be assigned to a particular worker.

An available Undefined CoS means that the organisation has allocation capacity. It does not, by itself, establish that a particular worker or role satisfies the relevant sponsorship requirements.

Before an individual CoS is assigned, the sponsor must separately consider the requirements applying to the proposed sponsorship.

This distinction can be expressed as:

Allocation = how many Undefined CoS the organisation has available.

Assignment = using an available CoS for a particular worker.

Keeping these functions conceptually separate helps prevent the organisation from treating available allocation as automatic authority to sponsor any proposed worker.

 

15. A Practical SMS Allocation Management Cycle

For employers that sponsor workers regularly, CoS allocation management should operate as a continuous cycle rather than an annual administrative exercise.

A practical process is:

Check allocation → review assignments → assess recruitment pipeline → forecast demand → identify shortfall → request additional allocation where required → monitor outcome → reconcile actual usage → plan for the next CoS year.

This approach connects the Sponsor Management System with the organisation’s wider workforce planning and reduces the risk of an avoidable allocation shortage disrupting sponsored recruitment.

 

 

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Section O: CoS Allocation Planning for Employers

 

1. Treat CoS Allocation as Workforce Planning

Certificate of Sponsorship allocation should be treated as part of the organisation’s workforce planning rather than as an administrative issue addressed only when a worker is ready to be sponsored.

For employers that recruit sponsored workers regularly, the number of Undefined CoS available can directly affect whether planned recruitment can proceed on schedule.

A sponsor should therefore connect its CoS allocation management with:

 

• workforce forecasts;
• recruitment pipelines;
• business growth plans;
• new projects and contracts;
• anticipated vacancies;
• existing sponsored workers;
• immigration deadlines; and
• the organisation’s CoS year.

 

The objective is to identify future CoS requirements early enough for the organisation to take appropriate action before an allocation shortage affects recruitment.

 

2. Forecast Sponsored Recruitment

The starting point for allocation planning is an assessment of anticipated sponsored recruitment.

The employer should consider the workers it reasonably expects to sponsor during the relevant period rather than looking only at vacancies that have already reached the offer stage.

This can include:

 

• workers currently progressing through recruitment;
• known vacancies likely to require sponsorship;
• planned recruitment campaigns;
• new roles expected to be created;
• anticipated replacement recruitment;
• business expansion;
• new sites;
• new projects or contracts; and
• other reasonably foreseeable workforce requirements.

 

The forecast does not have to assume that every potential vacancy will result in sponsorship. It should provide a realistic assessment of the organisation’s expected requirement.

 

3. Determine Which Workers Are Likely to Require Undefined CoS

Total overseas recruitment should not automatically be treated as the organisation’s CoS allocation requirement.

The employer should determine which anticipated workers are likely to require sponsorship and then identify the appropriate CoS type.

Defined CoS are requested separately and do not use the organisation’s annual Undefined CoS allocation.

The allocation forecast should therefore focus specifically on anticipated workers who are expected to require Undefined CoS.

A useful planning sequence is:

Anticipated recruitment → workers likely to require sponsorship → relevant sponsorship route → expected CoS type → Undefined CoS demand.

This produces a more accurate allocation forecast than simply counting all international recruits.

 

4. Compare Forecast Demand With the Current Allocation

Once anticipated demand has been identified, the organisation should compare it with its current available allocation.

For example, an employer may have 15 Undefined CoS remaining but expect 22 workers to require Undefined CoS before the end of the current CoS year.

On those assumptions, the organisation has a potential shortfall of seven certificates.

The employer can then assess whether the underlying recruitment plans are sufficiently developed to justify an additional allocation request.

This comparison should be repeated periodically because both recruitment demand and available allocation can change throughout the year.

 

5. Monitor the Recruitment Pipeline

Employers should not wait until a worker reaches the final sponsorship stage before including the potential requirement in allocation planning.

The recruitment pipeline can provide an early indication of future CoS demand.

Depending on the organisation, it may be useful to track workers or vacancies through stages such as:

Vacancy identified → recruitment approved → recruitment underway → candidate identified → sponsorship assessment → CoS required → CoS assigned.

This allows the sponsor to distinguish between speculative recruitment and requirements that are increasingly likely to result in a CoS assignment.

The organisation can then update its allocation forecast as recruitment progresses.

 

6. Plan for Large Recruitment Campaigns

Large or concentrated recruitment campaigns can place particular pressure on an organisation’s CoS allocation.

An employer may have sufficient certificates for its normal monthly recruitment but experience a significant shortfall when several sponsored workers need to be recruited within a relatively short period.

Examples can include:

 

• opening a new site;
• mobilising a new contract;
• launching a major project;
• expanding a business function;
• responding to a sudden increase in demand; or
• conducting a large international recruitment campaign.

 

Where these activities are foreseeable, CoS requirements should be considered during the planning stage rather than after candidates have been selected.

 

7. Allow for CoS Allocation Processing Times

Allocation planning should take account of the time potentially required for UKVI to determine an additional allocation request.

Requests for additional Undefined CoS are usually decided within 12 weeks under current Home Office guidance, although cases can take longer where further checks are required.

An employer that identifies a likely shortfall several months in advance may therefore have sufficient time to use the standard allocation process.

By contrast, an organisation that discovers the same shortfall only when its remaining allocation reaches zero may face an urgent recruitment problem.

The allocation forecast should therefore consider both:

How many CoS will be required?

and

When will they be required?

 

8. Plan Around Immigration Deadlines

Some sponsorship requirements are more time-sensitive than others.

Where an existing worker is expected to make an in-country immigration application requiring an Undefined CoS, the employer should identify the relevant immigration timetable in advance.

The organisation should avoid assuming that additional allocation can be obtained immediately if the requirement is discovered shortly before the worker needs to make an application.

Allocation planning should therefore identify known or reasonably foreseeable immigration deadlines alongside the recruitment pipeline.

This is particularly important where several sponsored workers may require action within the same period.

 

9. Plan for the End of the CoS Year

The end of the sponsor’s CoS year is an important allocation planning point.

Unused Undefined CoS do not carry forward into the next CoS year.

The organisation should therefore review:

 

• when the current CoS year ends;
• how many certificates remain unused;
• anticipated sponsorship before the year end;
• expected requirements for the next CoS year;
• whether automatic annual allocation applies; and
• whether a manual follow-on allocation request will be required.

 

Where a manual follow-on request is required, the employer can generally submit the request up to three months before the end of the current CoS year.

Planning ahead reduces the risk of entering the next CoS year without sufficient sponsorship capacity.

 

10. Coordinate HR, Recruitment and Immigration Functions

Allocation shortages can occur because the people responsible for the sponsor licence do not have sufficient visibility of future recruitment.

For example, an HR or recruitment team may be planning a substantial overseas recruitment exercise without informing the personnel responsible for managing the SMS until candidates have already been selected.

Employers should therefore establish communication between relevant functions, which may include:

 

• HR;
• recruitment;
• global mobility;
• immigration;
• legal and compliance;
• business unit leaders;
• project managers; and
• sponsor licence key personnel.

 

The appropriate structure will depend on the organisation, but the sponsor management function should receive sufficient notice of anticipated sponsored recruitment to assess CoS availability.

 

11. Planning Across Multiple Business Units or Locations

Allocation planning can be more complex where different teams, sites or business units recruit independently.

Each part of the organisation may have its own recruitment forecast while drawing on the sponsor’s available CoS capacity.

A central planning process can help the organisation understand aggregate demand.

For example:

 

• Business Unit A expects to require six Undefined CoS;
• Business Unit B expects to require eight;
• Business Unit C expects to require five; and
• the sponsor currently has 12 available.

 

Viewed separately, each team may assume that sufficient allocation exists. Viewed across the organisation, the expected requirement is 19 certificates against an available allocation of 12.

Central oversight allows the seven-certificate potential shortfall to be identified before it affects recruitment.

 

12. Should Employers Keep a CoS Buffer?

Employers with regular sponsored recruitment may wish to avoid operating with an allocation that exactly matches only the workers currently ready for sponsorship.

A reasonable allowance for genuinely anticipated recruitment can provide greater operational flexibility where recruitment timing changes or additional vacancies arise.

However, this should not be confused with requesting a large speculative reserve of CoS without an identifiable business requirement.

The number requested should remain proportionate to the organisation’s genuine and reasonably foreseeable sponsorship needs.

The appropriate approach is therefore:

Reasonable forward planning, not unrestricted stockpiling.

 

13. Review Forecasts Against Actual CoS Usage

Allocation forecasting should be tested against actual sponsorship activity.

Employers should periodically compare:

 

• forecast CoS demand;
• actual CoS assignments;
• remaining allocation;
• recruitment that did not proceed;
• unexpected additional recruitment; and
• future requirements.

 

This allows the organisation to improve future forecasts and identify whether its assumptions about sponsored recruitment are consistently too high or too low.

Historic usage can also provide useful context when the sponsor later needs to justify an annual or additional allocation request.

 

14. Build CoS Allocation Into Recruitment Approval

Organisations with significant sponsored recruitment may benefit from including sponsorship capacity within their internal recruitment approval process.

Before recruitment proceeds, relevant teams can consider:

 

1. Could the vacancy require sponsorship?
2. Which sponsorship route is likely to apply?
3. Which type of CoS is likely to be required?
4. Is sufficient allocation currently available?
5. If not, when will additional allocation need to be requested?

 

This does not require every recruitment decision to become an immigration exercise.

It ensures that foreseeable sponsorship requirements are identified early enough to be incorporated into workforce planning.

 

15. A Practical CoS Allocation Planning Cycle

For regular sponsors, a structured allocation planning cycle can be expressed as:

Forecast → Check → Request → Monitor → Reconcile → Renew.

Forecast: estimate anticipated sponsored recruitment and the likely requirement for Undefined CoS.

Check: compare expected demand with the allocation currently available through the SMS.

Request: seek additional or follow-on allocation where a genuine shortfall is identified.

Monitor: track the allocation request, recruitment pipeline, CoS assignments and changing business requirements.

Reconcile: compare forecast demand against actual usage and update the allocation plan.

Renew: prepare for the next CoS year and establish whether the next allocation will be automatic or require a manual follow-on request.

The aim is not to obtain the largest possible CoS allocation.

It is to maintain sufficient, properly justified sponsorship capacity to support the organisation’s genuine recruitment requirements without avoidable disruption.

 

 

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Section P: Common CoS Allocation Problems

 

1. Insufficient CoS Allocation

One of the most common allocation problems is discovering that the organisation does not have enough Undefined Certificates of Sponsorship available to support its planned recruitment.

This can arise because:

 

• recruitment volumes have increased;
• the original allocation was lower than anticipated;
• the organisation has used CoS faster than forecast;
• new vacancies have arisen during the CoS year;
• business expansion has increased staffing requirements; or
• the employer did not adequately forecast future sponsorship demand.

 

Where a genuine shortfall exists, the employer should calculate the number of additional Undefined CoS required and consider making an additional allocation request through the Sponsor Management System.

The request should explain the underlying recruitment requirement rather than merely stating that the existing allocation has been exhausted.

 

2. Requesting Additional Allocation Too Late

An employer may have a genuine requirement for further Undefined CoS but identify the shortage only when its remaining allocation is close to zero.

This can create an avoidable timing problem because additional allocation is not necessarily available immediately after a request is submitted.

Under current Home Office guidance, additional Undefined CoS allocation requests are usually decided within 12 weeks, although processing can take longer where further checks are required.

Employers should therefore compare available allocation with anticipated recruitment throughout the CoS year rather than waiting until the last certificate has been assigned.

A foreseeable shortfall should be addressed sufficiently early to allow time for the relevant allocation process.

 

3. Receiving a Lower Allocation Than Expected

UKVI can grant fewer Undefined CoS than the sponsor requests.

This can affect recruitment where the organisation has planned on the assumption that the entire requested allocation will be approved.

If a reduced allocation is granted, the employer should review:

 

• the number requested;
• the number granted;
• the justification originally provided;
• any questions or concerns raised by UKVI;
• the number of workers awaiting sponsorship;
• relevant immigration deadlines; and
• whether a genuine requirement for further CoS remains.

 

The sponsor should avoid automatically resubmitting the same request without considering why the original allocation was reduced.

 

4. Recruitment Demand Exceeds the Original Forecast

Even where the organisation prepared a reasonable allocation forecast, circumstances can change during the CoS year.

For example, the employer may secure a new contract, open another site, expand a department or experience unexpectedly high recruitment demand.

A higher requirement than originally forecast does not necessarily indicate poor sponsor management.

The employer should, however, be able to explain what changed and how those circumstances translate into a requirement for additional Undefined CoS.

A useful structure is:

Original forecast → changed business circumstances → additional recruitment → additional sponsored workers → further Undefined CoS requirement.

 

5. Confusing Defined and Undefined CoS

A significant allocation problem can arise where the employer assumes that every Certificate of Sponsorship must come from its annual allocation.

The annual allocation relates to Undefined CoS.

Defined CoS are requested separately as required for eligible Skilled Workers applying for entry clearance from outside the UK.

If a proposed worker requires a Defined CoS, obtaining additional Undefined CoS allocation will not solve the problem.

Equally, an employer should not attempt to use an Undefined CoS merely because one is available where the worker is required to have a Defined CoS.

Home Office guidance provides for serious sponsor compliance consequences where the wrong CoS type is deliberately or incorrectly used in circumstances covered by the revocation provisions.

The employer should therefore establish the correct CoS type before taking allocation action.

 

6. Unused CoS Disappear at the End of the CoS Year

Unused Undefined CoS do not carry forward into the next CoS year.

This can cause confusion where an employer has a significant number of certificates remaining shortly before the end of its current allocation period and assumes that they will remain available afterwards.

At the end of the relevant CoS year, unused allocation is removed from the SMS.

The employer should therefore distinguish between:

 

• certificates available for use during the current CoS year; and
• the allocation required for the next CoS year.

 

The organisation should not assign CoS merely to avoid losing unused allocation. A CoS should only be assigned where there is a genuine sponsorship requirement and the relevant requirements for the proposed worker and role have been satisfied.

 

7. Assuming the Annual Allocation Will Automatically Renew

Another potential problem is assuming that the sponsor will automatically receive a new allocation at the end of every CoS year.

Automatic annual allocation is available only where the applicable Home Office requirements are satisfied.

Where the automatic process does not apply, the sponsor may need to make a manual follow-on allocation request.

Employers should therefore establish before the end of the current CoS year:

 

• whether the organisation is eligible for automatic allocation;
• whether the relevant sponsorship route is eligible;
• what the likely automatic allocation will be; and
• whether a manual follow-on request will instead be required.

 

Where a manual request is required, this can generally be made up to three months before the end of the current CoS year.

 

8. Automatic Allocation Is Lower Than Future Recruitment Demand

Even where the sponsor qualifies for automatic annual allocation, the resulting number may not be sufficient for the organisation’s future recruitment plans.

For eligible sponsors, automatic allocation is generally based on the number of Undefined CoS actually assigned during the preceding CoS year rather than simply reproducing the previous total allocation.

For example, if the organisation had 25 Undefined CoS available but assigned only 14, the next automatic allocation would generally be based on those 14 assignments.

If the employer expects to require substantially more certificates during the new CoS year, it should identify the likely shortfall and consider an additional allocation request where appropriate.

Automatic allocation should therefore not replace workforce forecasting.

 

9. The Employer Cannot Explain the Number Requested

An allocation request can become difficult where the organisation has selected a number without being able to explain how it was calculated.

A request for a large reserve of certificates without an identifiable recruitment basis may attract questions from UKVI and may result in fewer CoS being granted than requested.

The employer should be able to connect the number requested to matters such as:

 

• anticipated vacancies;
• specific roles or occupational groups;
• recruitment campaigns;
• business expansion;
• projects or contracts;
• historic sponsorship activity;
• expected recruitment dates; and
• the number of Undefined CoS already available.

 

The allocation calculation should be capable of being explained in practical workforce terms.

 

10. A Large Increase From Previous CoS Usage

A significant increase in the number of CoS requested may require a more detailed explanation.

This does not mean that an employer cannot substantially increase its sponsored recruitment.

The organisation may have genuine reasons for doing so, such as rapid growth, a major new contract, additional locations or a new recruitment programme.

The allocation request should explain the change.

For example:

Previous year: 10 Undefined CoS assigned.

Current requirement: 35 additional Undefined CoS requested.

The sponsor should be prepared to explain the business developments and recruitment requirements that account for the difference rather than relying solely on the assertion that more workers are now required.

 

11. Allocation Planning Is Disconnected From Recruitment

In larger organisations, sponsor licence administration and recruitment can be handled by different teams.

This can result in the personnel responsible for the SMS being unaware that substantial sponsored recruitment is being planned elsewhere in the organisation.

By the time the sponsorship team becomes involved, candidates may already have been selected and start dates proposed.

Employers can reduce this risk by establishing an internal process under which anticipated sponsored recruitment is communicated to the team responsible for CoS allocation management.

Allocation planning should therefore be connected with recruitment forecasting rather than operating as a separate administrative function.

 

12. Multiple Teams Assume the Same CoS Are Available

Where several departments, business units or locations recruit independently, different teams may each assume that the same remaining allocation is available for their workers.

For example, the SMS may show eight Undefined CoS remaining, while three separate departments are each planning to sponsor four workers.

The organisation’s actual anticipated requirement is therefore 12 certificates against an available allocation of eight.

A central CoS tracker or approval process can help prevent the same allocation capacity from effectively being committed more than once.

 

13. SMS Access or User Problems Delay the Request

An employer may identify an allocation shortage but then encounter difficulties because the appropriate personnel cannot access or use the SMS when required.

This risk has become particularly important following changes to SMS user arrangements and authentication requirements.

From 9 September 2026, sponsors can no longer appoint new Level 2 Users, while existing Level 2 Users must be upgraded to Level 1 status where eligible or deactivated by 8 March 2027.

Mandatory multi-factor authentication for SMS users was introduced from 3 September 2026.

Employers should therefore ensure that:

 

• appropriate Level 1 User coverage is maintained;
• authorised users can access the SMS;
• user details are kept current;
• internal responsibility for allocation requests is clear; and
• the organisation is not dependent on a single unavailable individual for essential sponsor management activity.

 

14. An Allocation Request Is Submitted but Not Monitored

Submitting an allocation request does not complete the process.

UKVI may request additional information before making a decision.

If the request is not actively monitored, the organisation may lose valuable time responding to Home Office enquiries or fail to appreciate that the requested allocation has not yet been approved.

The employer should monitor pending requests, ensure that relevant communications are acted upon and update recruitment teams when a decision is received.

Until the allocation is actually made available, the sponsor should not treat the requested certificates as available for assignment.

 

15. Assuming Available Allocation Means the Worker Can Be Sponsored

An available Undefined CoS is not confirmation that a particular worker can be sponsored.

Allocation and assignment are separate issues.

Allocation determines how many Undefined CoS the organisation has available.

Assignment involves using an appropriate CoS for an individual worker after the relevant sponsorship requirements have been considered.

The employer must therefore assess the proposed role, worker and relevant immigration route before assigning a certificate.

A large available allocation does not permit the sponsor to bypass the substantive sponsorship requirements.

 

16. The Organisation’s Circumstances Change

An employer’s business and workforce requirements may change after an allocation has been granted.

For example, the organisation may downsize, lose a contract, close a location or materially reduce its recruitment plans.

UKVI can reduce an existing CoS allocation, potentially to zero, where circumstances justify doing so.

An allocation can also be affected where compliance action creates concerns about the sponsor or a potential threat to immigration control.

Employers should therefore treat CoS allocation as subject to continuing Home Office oversight rather than as a fixed entitlement for the entire allocation period regardless of subsequent developments.

 

17. A Practical Troubleshooting Framework

When a CoS allocation problem arises, the employer should avoid immediately assuming that the answer is simply to request more certificates.

Start with four questions:

 

1. What type of CoS is required?
2. How many relevant CoS are currently available?
3. How many are genuinely needed and by when?
4. What action is required through the SMS to make the necessary CoS available?

 

The answers will help distinguish between problems involving:

 

• insufficient Undefined CoS allocation;
• the need for a Defined CoS;
• a pending allocation request;
• a follow-on annual allocation;
• an additional allocation requirement;
• SMS access or administration;
• allocation justification; or
• a wider sponsor compliance issue.

 

The appropriate response can then be directed at the actual problem rather than simply increasing the number of CoS requested.

 

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Section Q: Certificate of Sponsorship Allocation Checklist

 

1. Employer CoS Allocation Checklist

Before requesting, increasing or relying on a Certificate of Sponsorship allocation, employers should work through the following checks.

The objective is to establish the correct sponsorship requirement, confirm the organisation’s existing capacity and identify any allocation shortfall before it affects recruitment.

 

2. Confirm the Relevant Sponsorship Route

Start by identifying the immigration route under which the proposed worker or workers are expected to be sponsored.

This is important because the applicable sponsorship route affects the type of Certificate of Sponsorship required and whether the organisation’s annual Undefined CoS allocation is relevant.

Do not begin with the assumption that every sponsored worker requires a certificate from the organisation’s annual allocation.

 

3. Determine Whether a Defined or Undefined CoS Is Required

Establish which type of Certificate of Sponsorship will be required.

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

Undefined CoS are also used for workers on other eligible Worker and Temporary Worker routes.

Defined CoS are requested separately and do not form part of the sponsor’s annual Undefined CoS allocation.

Getting this distinction right is fundamental before calculating any allocation requirement.

 

4. Check the Current Undefined CoS Allocation

Check the Sponsor Management System to establish the organisation’s current allocation position.

Confirm:

 

• the total current Undefined CoS allocation;
• the number already assigned;
• the number remaining available;
• any allocation requests currently pending; and
• the end date of the current CoS year.

 

Do not rely solely on an internal spreadsheet or an allocation figure recorded earlier in the year. The current position should be reconciled with the SMS.

 

5. Review Anticipated Sponsored Recruitment

Look beyond workers who are immediately ready for sponsorship.

Review the organisation’s recruitment pipeline to identify workers and vacancies that are reasonably expected to require sponsorship during the relevant period.

This may include:

 

• candidates already selected;
• recruitment currently underway;
• approved vacancies;
• planned recruitment campaigns;
• new projects or contracts;
• business expansion;
• replacement recruitment; and
• existing workers with foreseeable sponsorship requirements.

 

The purpose is to identify future demand before the existing allocation is exhausted.

 

6. Calculate the Additional Allocation Requirement

Compare the anticipated requirement for Undefined CoS with the number currently available.

A simple planning calculation is:

Anticipated Undefined CoS requirement − available Undefined CoS = potential allocation shortfall.

The employer should then test whether the anticipated requirement is sufficiently genuine and developed to support the number of additional certificates it intends to request.

The calculation should exclude workers who are expected to require Defined CoS.

 

7. Prepare the Allocation Justification

Before submitting the request, prepare a clear explanation of why the allocation is required.

A useful framework is:

Business need → proposed roles → anticipated recruitment volume → timing → immigration route → number of Undefined CoS required.

The justification should explain how the requested number has been calculated and why it reflects a genuine recruitment requirement.

Where the request represents a significant increase over previous CoS usage, explain what has changed.

 

8. Submit the Appropriate Allocation Request

Determine which allocation process applies.

Depending on the circumstances, this may involve:

 

• an initial Undefined CoS allocation requested as part of the sponsor licence application;
• an additional allocation request during the current CoS year; or
• a manual follow-on allocation request for the next CoS year.

 

Where automatic annual allocation applies, the employer should still assess whether the resulting number is likely to be sufficient for anticipated recruitment.

The relevant request should be made through the Sponsor Management System in accordance with the applicable Home Office process.

 

9. Respond Promptly to UKVI

Monitor the allocation request after submission.

UKVI may seek further information before deciding the request.

If further information is requested, respond accurately and within any deadline specified.

The response should address the particular issues raised and remain consistent with:

 

• the original allocation request;
• the organisation’s sponsor records;
• its actual recruitment activity; and
• its wider business circumstances.

 

Do not assume that submission of an allocation request means that the requested certificates have been approved.

 

10. Allow Sufficient Processing Time

Build allocation processing into the recruitment timetable.

Additional Undefined CoS requests are usually decided within 12 weeks under current Home Office guidance, although processing can take longer where further checks are required.

Where an eligible request is genuinely urgent, the sponsor may consider whether the Home Office priority change of circumstances service is available and appropriate.

Priority processing is subject to eligibility, availability, current procedural requirements and payment of the applicable fee. It does not guarantee approval of the allocation request or the full number of CoS requested.

 

11. Monitor the Allocation After Approval

Once an allocation is granted, continue to monitor its use.

The organisation should track:

 

• CoS assigned;
• remaining Undefined CoS;
• workers progressing through recruitment;
• future anticipated demand;
• pending sponsorship cases;
• relevant immigration deadlines; and
• the end of the CoS year.

 

Allocation management should be continuous. The organisation should not wait until the available number reaches zero before reviewing whether further certificates will be required.

 

12. Check the Individual Sponsorship Before Assigning a CoS

Having sufficient CoS allocation does not mean that a Certificate of Sponsorship can automatically be assigned to a particular worker.

Before assignment, the employer must separately consider whether the proposed sponsorship satisfies the applicable requirements.

This includes confirming the correct route and CoS type and assessing the relevant requirements for the proposed worker and role.

The distinction remains:

Allocation = the number of Undefined CoS available to the organisation.

Assignment = using an appropriate available CoS for a particular worker.

The allocation stage should not be used as a substitute for the individual sponsorship assessment.

 

13. Review the Position Before the End of the CoS Year

Employers should carry out a specific allocation review before the end of each CoS year.

The review should confirm:

 

• the CoS year end date;
• the number of Undefined CoS remaining;
• anticipated sponsorship before year end;
• expected recruitment during the next CoS year;
• whether automatic annual allocation applies;
• the likely level of any automatic allocation; and
• whether a manual follow-on request is required.

 

Unused Undefined CoS do not carry forward into the next CoS year.

Where a manual follow-on allocation request is required, this can generally be made up to three months before the current CoS year ends.

 

14. CoS Allocation Checklist: The Complete Process

For employers, the overall allocation process can be summarised as:

Identify route → determine CoS type → check allocation → forecast demand → identify any shortfall → calculate the number required → prepare the justification → submit the appropriate allocation request → monitor the decision → verify individual sponsorship requirements → assign the CoS → continue monitoring allocation.

For regular sponsors, this should operate as an ongoing management cycle rather than an exercise carried out only when the organisation runs out of certificates.

 

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Section R: How DavidsonMorris Can Help

 

Certificate of Sponsorship allocation problems can directly affect an employer’s ability to recruit and retain sponsored workers.

DavidsonMorris advises sponsor licence holders on CoS allocation strategy, annual and additional allocation requests, Sponsor Management System issues and the wider sponsor compliance considerations that can arise where UKVI questions an organisation’s sponsorship requirements.

We work with employers to ensure that CoS requirements are properly assessed, allocation requests are supported by a credible business and recruitment rationale, and potential shortages are identified before they disrupt planned sponsorship.

 

1. CoS Allocation Strategy

 

We can help employers assess how many Undefined Certificates of Sponsorship they are likely to require and develop an allocation strategy that reflects their actual recruitment plans.

This can include reviewing:

 

• current CoS allocation and usage;
• historic sponsorship activity;
• anticipated recruitment;
• existing sponsored workers;
• planned business growth;
• new contracts or projects;
• recruitment across different departments or locations;
• the organisation’s CoS year; and
• the likely requirement for additional or future allocation.

 

The objective is to align the organisation’s available sponsorship capacity with its genuine workforce requirements.

 

2. Annual CoS Allocation Planning

 

For employers that sponsor workers regularly, annual allocation planning can reduce the risk of entering a new CoS year without sufficient Undefined CoS.

We can advise on whether the organisation is likely to receive an automatic annual allocation or whether a manual follow-on request is required.

Where automatic allocation applies, we can also assess whether the anticipated allocation is likely to be sufficient in light of the organisation’s future recruitment plans.

If the expected allocation is lower than projected demand, the employer can consider the appropriate steps to address the anticipated shortfall.

 

3. Additional CoS Allocation Requests

 

Where an employer does not have enough Undefined CoS available during its current CoS year, we can assist with preparing and submitting an additional allocation request.

This includes assessing:

 

• the current allocation position;
• the number of additional CoS required;
• the workers and roles creating the requirement;
• the recruitment timetable;
• the reason the existing allocation is insufficient;
• the supporting business circumstances; and
• the information required to justify the requested increase.

 

This can be particularly important where the employer is requesting a substantial increase over previous CoS usage or where the requirement has arisen because of a significant change in business activity.

 

4. Preparing the CoS Allocation Justification

 

The quality of the allocation justification can be important where UKVI needs to understand why the organisation requires the number of certificates requested.

We can help employers present the requirement in a clear and structured way, connecting:

Business need → proposed roles → recruitment volume → timing → sponsorship route → Undefined CoS requirement.

Where appropriate, we can also advise on the information and supporting evidence that may help substantiate the request.

This is particularly relevant where the organisation’s future sponsorship requirement is materially higher than its historic usage.

 

5. Responding to UKVI Requests for Information

 

UKVI may request further information before determining a CoS allocation request.

We can assist employers in reviewing the questions raised, identifying the information required and preparing a response that addresses UKVI’s concerns directly.

This may involve issues relating to:

 

• the number of CoS requested;
• proposed vacancies;
• the organisation’s recruitment plans;
• business growth;
• new contracts or projects;
• historic sponsorship activity;
• the size and nature of the organisation;
• the use of recruitment agents; or
• wider sponsor compliance matters.

 

Responses should be accurate, consistent with the original allocation request and aligned with the organisation’s wider sponsor records.

 

6. Urgent CoS Requirements

 

Where an allocation shortage creates an urgent recruitment or immigration issue, we can advise on the available options and whether the request may be eligible for the Home Office Worker and Temporary Worker priority change of circumstances service.

This can be relevant where, for example:

 

• a worker has an approaching immigration deadline;
• the employer has unexpectedly exhausted its Undefined CoS allocation;
• a critical vacancy needs to be filled;
• a project or contract has a fixed mobilisation date; or
• a delay in obtaining additional allocation could materially affect planned recruitment.

 

Priority processing remains subject to the current Home Office eligibility requirements, service capacity, procedure and fee. It expedites consideration of an eligible request but does not guarantee approval or the full number of CoS requested.

 

7. Sponsor Licence and SMS Management

 

CoS allocation should form part of the organisation’s wider sponsor licence management framework.

We advise employers on the processes and controls needed to manage sponsorship activity effectively, including:

 

• SMS administration;
• Level 1 User arrangements;
• CoS allocation monitoring;
• internal approval processes;
• allocation forecasting;
• CoS assignment controls;
• sponsor reporting;
• record keeping; and
• ongoing sponsor compliance.

 

For organisations with significant or decentralised sponsored recruitment, we can also help develop governance processes to coordinate CoS requirements across HR, recruitment, global mobility and operational teams.

 

8. Support With CoS Allocation Problems

 

We can advise where an employer encounters problems with its CoS allocation, including where:

 

• the available allocation has been exhausted;
• an additional allocation request is delayed;
• UKVI grants fewer CoS than requested;
• an allocation request is unsuccessful;
• UKVI requests further information;
• the organisation expects a significant increase in sponsored recruitment;
• there is uncertainty over the correct allocation process;
• an existing allocation has been reduced; or
• the allocation issue forms part of a wider sponsor compliance concern.

 

Where UKVI action indicates broader compliance concerns, we can assess the underlying sponsor licence position and advise on the steps required to respond.

 

9. Speak to DavidsonMorris About CoS Allocation

 

If your organisation has run out of Undefined CoS, needs a larger allocation, is preparing an annual or additional allocation request, or is experiencing delays or difficulties with UKVI, DavidsonMorris can provide specialist advice on the appropriate next steps.

We can also assist employers that need to review their wider CoS planning and sponsor management processes to reduce the risk of future allocation shortages.

For advice on Certificate of Sponsorship allocation and sponsor licence management, contact DavidsonMorris.

 

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Section S: Certificate of Sponsorship Allocation FAQs

 

What is a Certificate of Sponsorship allocation?

A Certificate of Sponsorship allocation is the number of Undefined Certificates of Sponsorship that a licensed sponsor has available to assign during its CoS year.

The allocation does not represent a supply of physical or downloadable certificates. A CoS is an electronic record created through the Sponsor Management System.

Having an allocation means the organisation has capacity to assign up to the available number of Undefined CoS, subject to the relevant sponsorship requirements being satisfied for each individual worker.

 

How many Certificates of Sponsorship can an employer have?

There is no single standard CoS allocation that applies to every sponsor.

The appropriate number depends on the organisation’s circumstances and its genuine anticipated sponsorship requirements.

UKVI can consider factors including the size and nature of the business, its previous sponsorship activity, the number of workers employed, the extent of its operations, its previous dealings with the Home Office and the justification provided for the number requested.

The sponsor may receive the number requested, a lower number or, depending on the circumstances, an allocation of zero.

 

How do I check my CoS allocation?

A sponsor can check its Certificate of Sponsorship allocation through the Sponsor Management System (SMS).

The organisation should monitor the number of Undefined CoS available, the number already assigned and the relevant CoS year.

For effective allocation management, this information should also be compared with anticipated sponsored recruitment rather than considered in isolation.

 

How do I increase my CoS allocation?

If an organisation requires more Undefined CoS during its current CoS year, it can make an additional allocation request through the Sponsor Management System.

The employer should explain why the additional certificates are required and how the number requested has been calculated.

A strong request will generally connect the additional requirement to genuine recruitment needs, such as identified vacancies, business expansion, a new project, increased recruitment or another credible workforce requirement.

UKVI does not have to grant the full number requested.

 

How long does a CoS allocation request take?

Under current Home Office guidance, requests for additional Undefined CoS are usually decided within 12 weeks.

Processing can take longer where further checks are required or UKVI needs additional information before making a decision.

Employers should therefore incorporate allocation processing into their recruitment and immigration planning rather than assuming that additional CoS can be obtained immediately.

 

Can I get an urgent CoS allocation decision?

Eligible sponsors may be able to use the Home Office Worker and Temporary Worker priority change of circumstances service for certain additional and annual CoS allocation requests.

Under the current arrangements, the sponsor must satisfy the applicable eligibility requirements, including holding an A-rated, fully active sponsor licence, and the relevant SMS request must already have been submitted.

The current priority fee is £350 per request, and accepted requests are generally considered within five working days following payment, subject to the detailed service rules, further checks and any request for additional information.

Priority capacity is limited and availability is not guaranteed. Employers should check the current Home Office procedure, eligibility requirements, fee and availability before relying on the service.

 

What happens if I run out of CoS?

If the organisation has no Undefined CoS remaining, it cannot assign another Undefined CoS until sufficient allocation becomes available.

The employer should first confirm that the proposed worker actually requires an Undefined CoS.

If an Undefined CoS is required, the sponsor can consider requesting additional allocation through the SMS.

Where the worker instead requires a Defined CoS, increasing the Undefined CoS allocation is not the appropriate process because Defined CoS are requested separately.

 

Do Defined CoS come from the annual CoS allocation?

No. Defined Certificates of Sponsorship do not form part of the sponsor’s annual Undefined CoS allocation.

Defined CoS are requested separately when required for eligible Skilled Workers applying for entry clearance from outside the UK.

The sponsor should obtain the correct type of CoS for the worker’s circumstances rather than attempting to use whichever type appears to be available.

 

Do Undefined CoS come from the annual allocation?

Yes. Undefined CoS are assigned from the sponsor’s available annual allocation.

They are generally used for eligible Skilled Workers applying for permission to stay from within the UK and for workers on other eligible Worker and Temporary Worker routes.

The sponsor must have sufficient Undefined CoS available before it can assign one to a worker who requires this type of certificate.

 

What happens to unused CoS at the end of the year?

Unused Undefined CoS do not carry forward into the sponsor’s next CoS year.

Unused allocation is removed from the SMS at the end of the relevant allocation period.

The employer should therefore calculate its requirements for the new CoS year separately rather than assuming that unused certificates will be added to its next allocation.

A sponsor should not assign unnecessary CoS simply to use an allocation before it expires.

 

Does a CoS allocation renew automatically?

Some eligible sponsors can receive an automatic annual allocation of Undefined CoS.

Automatic allocation is subject to the applicable Home Office requirements and does not apply to every sponsor or sponsorship route.

Eligible sponsors will generally need an A-rated, fully active licence and an active allocation in the current CoS year. Certain routes are excluded from automatic allocation, including the Seasonal Worker, Secondment Worker, Service Supplier and UK Expansion Worker routes.

Where automatic allocation does not apply, the sponsor may need to make a manual follow-on allocation request.

 

How does UKVI decide how many CoS to allocate?

UKVI can consider the sponsor’s circumstances and the justification for the requested allocation.

Relevant factors identified in Home Office guidance can include:

 

• the number of workers employed;
• the nature of the organisation’s business;
• the extent of its business activities;
• how long it has been trading;
• its previous dealings with the Home Office;
• the use of recruitment agents and whether they have been linked to immigration abuse; and
• other matters relevant to the particular allocation request.

 

The employer should be able to explain how the number requested relates to genuine anticipated sponsored recruitment.

 

Can UKVI give me fewer CoS than I request?

Yes. The number requested is not guaranteed.

UKVI can grant fewer Undefined CoS than requested or, depending on the circumstances, set an allocation at zero.

This may arise where the full number has not been sufficiently justified, the claimed recruitment requirement is not considered credible, there are concerns about whether eligible work can be offered, or wider sponsor compliance issues are relevant.

UKVI can also reduce an existing allocation where circumstances change or compliance concerns arise.

 

What evidence is needed for a CoS allocation request?

The relevant evidence will depend on why the organisation requires the allocation.

Depending on the circumstances, supporting information may relate to:

 

• vacancies;
• job roles;
• recruitment campaigns;
• workforce forecasts;
• new contracts or projects;
• business expansion;
• new sites or locations;
• historic CoS usage;
• current workforce requirements; and
• other information demonstrating the genuine need for sponsored recruitment.

 

The evidence should support the explanation of why the requested number of Undefined CoS is required.

 

When can I request my next annual CoS allocation?

Where the sponsor needs to make a manual follow-on allocation request, this can generally be submitted up to three months before the end of the current CoS year.

The employer should use this period to review its anticipated recruitment requirements and calculate how many Undefined CoS it expects to need during the next allocation period.

The organisation should also confirm its own CoS year through the SMS rather than assuming that it follows the calendar or financial year.

 

How is an automatic annual CoS allocation calculated?

For eligible sponsors, the automatic annual allocation is generally based on the number of Undefined CoS the organisation actually assigned during the preceding CoS year rather than the total number it previously had available.

For example, if the sponsor had an allocation of 25 Undefined CoS but assigned only 14, its next automatic allocation would generally be based on the 14 certificates actually assigned.

If the organisation expects to require more CoS in the new year, it should assess the likely shortfall and consider requesting additional allocation where appropriate.

 

Is a CoS allocation the same as assigning a CoS?

No. Allocation and assignment are separate parts of the sponsorship process.

CoS allocation concerns how many Undefined Certificates of Sponsorship the organisation has available.

CoS assignment involves using an appropriate available certificate for a particular worker.

Having allocation available does not mean that the employer can automatically sponsor an individual. The relevant sponsorship requirements must still be considered before a CoS is assigned.

 

Can UKVI reduce an allocation after it has been granted?

Yes. UKVI can reduce an existing CoS allocation where circumstances justify doing so, potentially reducing it to zero.

This can arise where the sponsor’s circumstances change, such as significant downsizing, or where compliance action gives rise to concerns about the sponsor or a potential threat to immigration control.

An allocation should therefore not be treated as an unconditional entitlement that is guaranteed to remain unchanged throughout the CoS year.

 

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Section T: Conclusion

 

A sponsor licence does not provide an employer with an unlimited number of Certificates of Sponsorship.

For workers who require an Undefined Certificate of Sponsorship, the organisation must have sufficient CoS allocation available before the relevant certificate can be assigned.

Defined CoS operate differently. They do not form part of the sponsor’s annual Undefined CoS allocation and are requested separately where required for eligible Skilled Workers applying for entry clearance from outside the UK.

Understanding this distinction is fundamental to effective CoS management.

 

1. Monitor CoS Availability Throughout the Year

 

Employers should not wait until their Undefined CoS allocation reaches zero before reviewing future requirements.

Effective allocation management requires regular monitoring of:

 

• the number of Undefined CoS currently available;
• the number already assigned;
• workers progressing through recruitment;
• anticipated sponsored recruitment;
• relevant immigration deadlines;
• planned projects, contracts or business expansion;
• the organisation’s CoS year; and
• whether further allocation is likely to be required.

 

This allows the employer to identify a potential shortage while there is still time to make the appropriate allocation request.

 

2. Understand How the Next Allocation Will Be Obtained

 

Sponsors should also understand what will happen when their current CoS year ends.

Eligible sponsors may receive an automatic annual allocation, generally based on the number of Undefined CoS actually assigned during the preceding CoS year.

Where the automatic process does not apply, the organisation may need to submit a manual follow-on allocation request.

Unused Undefined CoS do not carry forward into the next CoS year.

The employer should therefore establish in advance:

 

• when its current CoS year ends;
• whether automatic annual allocation applies;
• what its likely next allocation will be;
• whether that number will meet anticipated recruitment demand; and
• whether a manual or additional allocation request will be required.

 

3. Request the Number the Organisation Can Justify

 

The purpose of allocation planning is not to obtain the largest possible number of Certificates of Sponsorship.

The organisation should request the number of Undefined CoS that reflects its genuine and reasonably foreseeable sponsorship requirements.

A well-prepared allocation request should connect:

Business need → proposed roles → recruitment volume → timing → sponsorship route → Undefined CoS requirement.

Where the number requested represents a significant increase over previous usage, the sponsor should be prepared to explain what has changed and how the revised requirement has been calculated.

UKVI can grant fewer certificates than requested, set an allocation at zero or seek further information before determining the request.

 

4. Build Allocation Into Recruitment Planning

 

CoS allocation should be considered before sponsored recruitment reaches its final stages.

An employer that identifies a suitable worker but has no relevant CoS available may first need to obtain additional allocation before sponsorship can proceed.

This can affect recruitment timetables, employment start dates, project mobilisation and immigration deadlines.

For organisations that sponsor workers regularly, allocation management should therefore form part of the wider workforce planning process rather than being treated solely as an SMS administration task.

 

5. Keep Allocation and Assignment Separate

 

Employers should maintain a clear distinction between having CoS allocation available and assigning a CoS to an individual worker.

Allocation determines how many Undefined CoS the organisation has available.

Assignment involves using an appropriate CoS for a particular worker.

An available certificate does not, by itself, establish that a worker can be sponsored.

The employer must still confirm that the proposed sponsorship satisfies the applicable requirements before assigning the CoS.

 

6. The Employer CoS Allocation Framework

 

For practical purposes, employers can manage Certificate of Sponsorship allocation using the following framework:

Forecast recruitment → identify the correct CoS type → check available allocation → calculate any shortfall → request additional or follow-on allocation where required → monitor the UKVI decision → verify the individual sponsorship requirements → assign the appropriate CoS → monitor remaining allocation → plan for the next CoS year.

For regular sponsors, this should operate as a continuous cycle.

The objective is to maintain sufficient, properly justified CoS availability to support genuine sponsored recruitment while maintaining effective control of the organisation’s sponsor licence responsibilities.

 

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Section U: Glossary

 

Term	Meaning
Certificate of Sponsorship (CoS)	A Certificate of Sponsorship (CoS) is an electronic record assigned by a licensed sponsor to a worker who is being sponsored under an eligible UK immigration route. It is not a physical certificate or paper document. Each CoS has a unique reference number that the worker can use as part of the relevant immigration application. Assignment of a CoS does not itself grant immigration permission. The worker must make the appropriate immigration application and satisfy the requirements of the relevant route.
CoS Allocation	A CoS allocation is the number of Undefined Certificates of Sponsorship that a licensed sponsor has available to assign during its relevant CoS year. Allocation should be distinguished from assignment. Allocation concerns the organisation’s available sponsorship capacity, while assignment involves using an appropriate CoS for a particular worker.
Annual CoS Allocation	An annual CoS allocation is the allocation of Undefined CoS available to the sponsor for the relevant CoS year. Depending on the sponsor’s circumstances and the routes for which it is licensed, the next annual allocation may be provided automatically or may require a manual follow-on allocation request.
Additional CoS Allocation	An additional CoS allocation is a request for further Undefined CoS during the sponsor’s current CoS year where the existing allocation is insufficient for its genuine sponsorship requirements. The sponsor should be able to explain why the additional certificates are required and how the number requested has been calculated.
Follow-On CoS Allocation	A follow-on allocation is an allocation of Undefined CoS requested for the sponsor’s next CoS year where the automatic annual allocation process does not apply. A manual follow-on request can generally be made up to three months before the end of the current CoS year.
CoS Year	The CoS year is the period during which the sponsor’s annual allocation of Undefined CoS is available. For most sponsors, the CoS year runs for 12 months from the date the sponsor licence is granted and, subsequently, for 12 months from the date a follow-on allocation request is granted. Different arrangements can apply to certain legacy sponsors whose former Tier 2 licences were converted under the sponsorship system changes in December 2020. Sponsors should check the SMS to confirm their own CoS year rather than assuming that it follows the calendar year, financial year or another standard annual period.
Defined Certificate of Sponsorship	A Defined Certificate of Sponsorship is generally required for an eligible Skilled Worker who is applying for entry clearance from outside the UK. Defined CoS do not form part of the sponsor’s annual Undefined CoS allocation. They are requested separately through the Sponsor Management System when required.
Undefined Certificate of Sponsorship	An Undefined Certificate of Sponsorship is assigned from the sponsor’s available annual CoS allocation. Undefined CoS are generally used for eligible Skilled Workers applying for permission to stay from within the UK and for workers being sponsored under other eligible Worker and Temporary Worker routes. The sponsor must have sufficient Undefined CoS allocation available before an Undefined CoS can be assigned.
Sponsor Management System (SMS)	The Sponsor Management System (SMS) is the Home Office online system used by licensed sponsors to manage their sponsor licence and carry out sponsorship functions. In relation to CoS allocation, the SMS is used to view available allocation, submit relevant allocation requests and manage Certificates of Sponsorship.
UK Visas and Immigration (UKVI)	UK Visas and Immigration (UKVI) is part of the Home Office and administers the UK’s visa and immigration system, including the sponsorship system for employers. UKVI determines sponsor licence applications and CoS allocation requests and can take compliance action where sponsors fail to meet their sponsorship duties.
Level 1 User	A Level 1 User is an individual authorised to carry out principal day-to-day sponsor management functions through the SMS. This can include functions relating to Certificates of Sponsorship and CoS allocation. SMS access should form part of a wider internal governance process so that technical authority to use the system is supported by appropriate organisational controls and approvals.
Authorising Officer	The Authorising Officer is the senior and competent person appointed by the sponsor with overall responsibility for the organisation’s sponsor licence and the activities of the personnel who use the Sponsor Management System. The Authorising Officer does not necessarily carry out day-to-day SMS activity but has an important role in the organisation’s wider sponsor licence governance.
A-Rated Sponsor	An A-rated sponsor is a sponsor licence holder that holds an A-rating on the Home Office sponsor register. An A-rating is relevant to a number of sponsor management processes, including eligibility for automatic annual CoS allocation and the priority change of circumstances service, where the other applicable requirements are satisfied.
CoS Assignment	CoS assignment is the process of assigning an appropriate Certificate of Sponsorship to a particular worker through the Sponsor Management System. Assignment should not be confused with allocation. Allocation = how many Undefined CoS the organisation has available. Assignment = using an appropriate CoS for an individual worker. Before assigning a CoS, the sponsor should separately confirm that the proposed worker, role and sponsorship satisfy the applicable requirements.
Automatic Annual Allocation	Automatic annual allocation is the process under which eligible sponsors can receive their next allocation of Undefined CoS without having to make a manual follow-on allocation request. Where the process applies, the allocation is generally based on the number of Undefined CoS actually assigned during the preceding CoS year. Automatic allocation does not apply to every sponsor or every sponsorship route.
Priority Change of Circumstances Service	The Worker and Temporary Worker priority change of circumstances service is a Home Office service that can provide expedited consideration of certain eligible sponsor management requests. Eligible additional and annual CoS allocation requests can fall within the service, subject to the current eligibility criteria, capacity, procedure and applicable fee. Priority treatment accelerates consideration of an eligible request. It does not guarantee that the allocation will be approved or that the sponsor will receive the full number of CoS requested.
Sponsor Licence	A sponsor licence is the Home Office authorisation that allows an eligible organisation to sponsor qualifying workers under the immigration routes covered by its licence. Holding a sponsor licence does not provide an unlimited entitlement to issue Certificates of Sponsorship. Where Undefined CoS are required, the sponsor must have sufficient allocation available.
Sponsor Compliance	Sponsor compliance refers to the duties and requirements that apply to organisations holding a sponsor licence. These include obligations relating to record keeping, reporting, sponsored workers, immigration status, recruitment and the proper use and management of the sponsorship system. CoS allocation and assignment should therefore be managed within the organisation’s wider sponsor compliance framework.

 

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Section V: Useful Links & Resources

 

Resource	URL
Workers and Temporary Workers: Sponsor Guidance Part 2 — Sponsor a Worker Home Office sponsor guidance covering the sponsorship of workers, including the rules and procedures relating to Certificates of Sponsorship, Defined and Undefined CoS, annual allocations and requests for additional allocation.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-2-sponsor-a-worker
Sponsor a Skilled Worker Home Office guidance for organisations sponsoring workers under the Skilled Worker route, including the sponsorship requirements that apply to the worker and the role. This guidance should be considered separately from the allocation question when an employer is assessing whether an individual worker can be sponsored.	https://www.gov.uk/government/publications/skilled-worker-visa-sponsor-a-skilled-worker
Sponsor Management System Guidance The Home Office publishes a series of Sponsor Management System manuals explaining how licensed sponsors carry out functions through the SMS. These manuals should be used when completing sponsor management actions, including relevant Certificate of Sponsorship and allocation processes.	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Worker and Temporary Worker Priority Change of Circumstances Service Home Office guidance on the priority service available for certain eligible sponsor management requests, including qualifying annual and additional CoS allocation requests. Employers considering priority processing should check the current eligibility requirements, application procedure, fee, capacity and service standard before relying on the service.	https://www.gov.uk/government/publications/priority-change-of-circumstance-service-for-sponsors
Register of Licensed Sponsors The Home Office register lists organisations licensed to sponsor workers under the Worker and Temporary Worker immigration routes.	https://www.gov.uk/government/publications/register-of-licensed-sponsors-workers

 

 

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