Sponsor Licence

From Sponsor Licence to Sponsored Employee

22 min readAbdul Basit Jabbar
In brief

The sponsor licence has been granted. For an employer that has spent several weeks preparing the application, gathering documents and waiting for a decision, approval can feel like the end…

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The sponsor licence has been granted.

For an employer that has spent several weeks preparing the application, gathering documents and waiting for a decision, approval can feel like the end of the process.

In reality, it is the point at which sponsorship becomes possible.

The licence gives the organisation permission to participate in the sponsorship system. It does not give a particular worker permission to work for the business, and it does not mean that every vacancy can now be sponsored.

If the business wants to employ someone under the Skilled Worker route, there are still several decisions to make.

Is the job eligible?

Has the correct occupation code been selected?

Does the salary work under the current rules?

Does the worker meet the relevant requirements?

Does the business need a Defined or Undefined Certificate of Sponsorship?

What information should go onto the certificate?

When should it be assigned?

And once the worker’s application has been approved, when can they actually start work?

Those questions should be answered before the Certificate of Sponsorship is assigned, not afterwards.

A sponsor licence is permission to sponsor, not permission for a worker to start

The distinction sounds obvious, but it is important.

A sponsor licence belongs to the organisation.

A Certificate of Sponsorship connects a particular worker to a particular job.

The worker then makes their own immigration application using that sponsorship.

These are three separate stages.

A business can therefore hold a perfectly valid sponsor licence and still make a poor sponsorship decision.

It might choose the wrong occupation code.

It might offer a salary that does not meet the applicable requirements.

It might assign the wrong type of Certificate of Sponsorship.

It might sponsor someone who cannot switch into the Skilled Worker route from their present immigration category.

Or it might describe a job on the CoS differently from the job the employee will actually perform.

Licence approval does not remove the need to check the individual sponsorship carefully.

Start with the job, not the Certificate of Sponsorship

The temptation after a licence is granted is to log into the Sponsorship Management System and begin assigning certificates.

There should be another step first.

Review the job.

For Skilled Worker sponsorship, the employer needs to establish that the role is eligible, genuine and paid at the appropriate level.

The occupation code matters because it connects the job to the skill and salary requirements within the Immigration Rules.

It should be chosen by looking at the actual duties of the position.

Not simply the job title.

A company may call somebody a Project Manager, Operations Manager or Business Development Manager, but those titles can describe very different jobs in different organisations.

The Home Office is concerned with what the worker will actually do.

That means looking at the day-to-day responsibilities, level of responsibility, skills required and where the role sits within the business.

The occupation code should follow the job.

The job should not be rewritten to fit a convenient occupation code.

Is the job at the right skill level?

The Skilled Worker skill rules changed significantly in July 2025.

For Certificates of Sponsorship assigned from 22 July 2025, a role must now normally be skilled to at least RQF level 6, broadly graduate level.

That does not mean the employee must hold a university degree.

It means the work itself must be considered to be at that level.

There remain routes into Skilled Worker sponsorship for certain jobs below RQF level 6, principally where the occupation appears on the Immigration Salary List or Temporary Shortage List, or where a transitional provision applies to an existing Skilled Worker.

Those exceptions should be checked carefully rather than assumed.

The fact that an occupation was sponsorable several years ago does not necessarily mean a new worker can still be sponsored in that occupation today.

This is an area where employers relying on previous experience can easily work from an outdated position.

Then look at the salary

Salary is rarely as simple as asking whether the employee will earn more than one headline figure.

For a standard Skilled Worker application under the main salary option, the salary will normally need to meet both the applicable general salary threshold and the going rate for the relevant occupation.

As at September 2026, the standard general threshold is £41,700 per year.

But that does not mean £41,700 makes every Skilled Worker job eligible.

If the applicable going rate for the occupation is higher, the worker will normally need to be paid at least that higher figure.

Different salary options can apply in specified circumstances, including certain new entrants, workers with relevant PhDs, jobs on the Immigration Salary List and particular health and education occupations.

There are also transitional arrangements for some existing Skilled Workers.

Hours matter too.

The rules for testing the general salary threshold and occupation going rate are not identical, particularly where somebody works part-time or unusually long hours.

This is why salary should be calculated against the relevant Skilled Worker option rather than checked against a single number found online.

The offer letter should ideally follow that analysis.

Not the other way around.

Do not assume the worker qualifies because the job qualifies

An eligible job does not automatically produce an eligible worker.

Before assigning a Certificate of Sponsorship, the employer should satisfy itself that the proposed worker can meet the relevant immigration requirements.

For a Skilled Worker, these include requirements concerning sponsorship, the skill level of the job, salary and English language ability.

For new Skilled Worker applicants, the English language requirement is now normally B2 in reading, writing, speaking and listening.

A transitional B1 requirement can continue to apply to certain people who were already granted Skilled Worker permission under the rules in force before 8 January 2026 and whose most recent permission was also as a Skilled Worker.

Other requirements may also need to be considered.

Depending on the worker and the role, there may be questions concerning finances, criminal record certificates, ATAS clearance, previous government-sponsored study or whether the applicant is permitted to switch into the Skilled Worker route from inside the UK.

The sponsor is not deciding the visa application.

That remains a Home Office decision.

But assigning a CoS is not supposed to be speculative. The sponsor guidance expects the employer to satisfy itself that the worker can meet the relevant immigration requirements before sponsorship is assigned.

“A Certificate of Sponsorship should be the result of the assessment, not the start of it. By the time we are ready to assign the CoS, I would want the occupation code, salary, immigration position and relevant worker requirements to have been considered. Correcting an avoidable mistake after assignment is rarely the better way to manage a sponsorship.”

Abdul Jabbar, Principal Immigration Adviser

Defined or Undefined Certificate of Sponsorship?

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

The distinction depends primarily on where the worker is applying from.

Defined Certificate of Sponsorship

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

The employer does not receive an annual allocation of Defined Certificates.

Instead, it applies through the Sponsorship Management System when one is required.

The application provides details of the job to be sponsored.

If the Defined CoS request is approved, it becomes available within the SMS and can then be assigned to the individual worker.

Straightforward Defined CoS applications are often decided quickly. GOV.UK currently states that applications are usually approved within one working day, although they can take longer where UKVI wants to carry out further checks.

That distinction matters when an employer is planning a start date.

“Usually within one working day” is not the same as a guaranteed one-working-day service.

Undefined Certificate of Sponsorship

An Undefined CoS is used for Skilled Workers applying for permission to stay from within the UK.

Undefined Certificates are also used for workers on other sponsored routes, including many Global Business Mobility and Temporary Worker applications.

These certificates come from the sponsor’s annual CoS allocation.

When a sponsor licence is first granted, the Home Office will confirm the Undefined CoS allocation approved for the organisation.

If the business has an available certificate within that allocation, it can potentially assign it once the sponsorship assessment is complete.

If there is no allocation available, the sponsor may need to request additional Undefined Certificates through the SMS.

That can affect timing considerably. GOV.UK currently states that an additional Undefined CoS request will usually be decided within 12 weeks, although an eligible sponsor may be able to use the paid priority service for an expedited decision.

This is why employers should look at their CoS position before promising an immigration timetable to a candidate.

Using the wrong type of CoS is not a minor technical error

Defined and Undefined Certificates should not be treated as interchangeable.

The sponsor guidance makes clear that a Skilled Worker applying from outside the UK needs a Defined CoS.

A Skilled Worker applying for permission to stay inside the UK normally needs an Undefined CoS.

The Home Office treats misuse seriously.

A sponsor should therefore establish where the worker will make the immigration application before the certificate is assigned.

That also means understanding the worker’s current immigration status.

Someone physically present in the UK may not necessarily be able to switch into Skilled Worker permission from inside the country.

Their presence in the UK is not enough to answer the question.

What is a Certificate of Sponsorship?

The name is slightly misleading.

There is no embossed certificate and no piece of paper conferring immigration permission.

A Certificate of Sponsorship is an electronic record created within the Sponsorship Management System.

It contains information about:

  • the worker
  • the sponsor
  • the sponsored route
  • the job
  • the occupation code
  • salary
  • weekly working hours
  • start and end dates
  • work location
  • PAYE details
  • recruitment information
  • any relevant maintenance certification
  • other information required for the particular route

When the certificate is assigned, it receives a unique reference number.

The worker uses that reference when making their immigration application.

A copy of the CoS can be provided to the worker if useful, but the reference number is what connects the sponsorship to the application.

More importantly, the information entered onto the CoS becomes part of the sponsor’s Home Office record.

It should be treated accordingly.

The job description on the CoS needs to be real

There is very little space for creative drafting here.

The CoS should reflect the role the worker is genuinely being employed to perform.

The job title, description, salary, hours and occupation code should make sense together.

If the company has recruited a Financial Controller, the CoS should describe the Financial Controller role.

It should not describe a substantially more senior finance position because that produces a more convenient occupation code.

Nor should a genuine senior role be reduced to a vague sentence such as:

“Managing company finances and carrying out general finance duties.”

That tells the Home Office very little.

The description should be concise but sufficiently specific to show what the employee is responsible for.

Accuracy matters beyond the visa decision.

Once the individual starts employment, the sponsor is responsible for ensuring that they are actually carrying out the role for which they were sponsored.

A significant mismatch between the CoS and the real job can therefore become a sponsor compliance issue later.

Get the salary and hours right before assignment

The salary entered on the CoS should reflect what the worker will actually be paid.

The Skilled Worker guidance requires the employer to provide the PAYE scheme through which the worker will pay income tax and National Insurance, unless there is a legitimate reason PAYE does not apply.

The Home Office can check sponsored workers’ pay against HMRC data.

This is another reason not to think of the CoS as paperwork prepared solely for the visa application.

If the business states that the worker will receive £48,000 per year and payroll later shows £42,000, there needs to be a lawful explanation for the difference.

The same principle applies to working hours.

Salary eligibility can depend on the hours being worked, and the going-rate calculation can be affected by part-time or other working arrangements.

The contract, payroll arrangements and CoS should therefore be aligned before assignment.

What does it cost to assign the CoS?

As at September 2026, the Certificate of Sponsorship fee for a Skilled Worker is £525.

That fee is paid by the sponsor when the certificate is assigned.

A further Immigration Skills Charge may also be payable.

For certificates assigned under the current rates, the Immigration Skills Charge is:

  • £480 for the first 12 months for a small or charitable sponsor
  • £1,320 for the first 12 months for a medium or large sponsor
  • £240 for each additional six months for a small or charitable sponsor
  • £660 for each additional six months for a medium or large sponsor

Exemptions apply in specified circumstances, including certain occupation codes and other situations set out in the rules.

The business should therefore check the cost before deciding how long to sponsor the worker.

A five-year Certificate of Sponsorship carries a materially larger Immigration Skills Charge than a shorter period.

That may be perfectly appropriate, particularly where long-term employment is intended, but it should be a deliberate commercial decision.

The employer must bear the sponsorship charges

The CoS fee is a sponsor cost.

For Skilled Worker Certificates assigned from 31 December 2024, the sponsor must not recoup the CoS fee or associated administrative costs from the sponsored worker.

The Immigration Skills Charge must also be paid by the sponsor and must not be passed to the worker.

This needs to be understood outside the immigration team too.

A payroll deduction, repayment clause or recruitment arrangement designed to recover prohibited sponsorship charges can create sponsor compliance consequences even if the immigration team itself had no intention of breaching the rules.

Employers can legitimately agree how other costs are dealt with where the law permits it, but sponsorship charges subject to Home Office restrictions should be kept separate.

Should the sponsor certify maintenance?

The CoS also asks whether the sponsor wishes to certify the worker’s financial requirement.

Where the sponsor is eligible to do so, certifying maintenance can mean the worker does not have to provide separate evidence that they hold the required funds.

By certifying maintenance, however, the employer is making an undertaking.

For the worker, the sponsor is confirming that it will, if necessary, maintain and accommodate them up to the end of their first month of employment, subject to the minimum amount specified by the Home Office.

The current minimum for the worker is £1,270.

If maintenance is not certified and the worker is required to meet the financial requirement, they will need to satisfy it through the permitted evidence.

A worker who has already been in the UK with permission for at least 12 months at the date of application will normally meet the financial requirement automatically.

This is therefore a decision to make consciously when assigning the certificate.

It should not be ticked because somebody assumes it is the usual answer.

Timing the Certificate of Sponsorship

The CoS has a limited life.

The worker must use it in a valid immigration application within three months of the date it was assigned.

There is another timing rule.

The worker cannot normally make the application more than three months before the employment start date recorded on the certificate.

The assignment date, intended visa application date and planned job start therefore need to work together.

Assigning a certificate months before the worker is ready to apply can create an avoidable expiry problem.

Waiting until the last moment can create a different problem if something needs to be corrected.

Good sponsorship timing leaves enough room for the worker to prepare the application without assigning the CoS so early that it becomes unusable.

What happens if the start date changes?

International recruitment does not always run to schedule.

The worker may need to serve notice.

A visa application may take longer than expected.

Relocation plans can change.

A family matter may delay travel.

The sponsor guidance recognises that start dates can move.

If the start date changes before the worker has applied, or before a decision has been made, the sponsor can normally record the change using a sponsor note on the CoS.

After the worker has been granted immigration permission, there is greater flexibility for a modest delay.

A sponsored worker should normally start the role no later than 28 days after the latest of the relevant dates identified in the sponsor guidance, which can include the CoS start date, the date their immigration permission becomes valid, or the date they are notified of the grant.

Where a worker will start later than the permitted period, the sponsor needs to consider whether it will continue sponsoring them and make the relevant SMS report within the required timeframe.

The important point is that a delayed start should not simply be ignored.

The worker still has to make a visa application

Assigning the CoS does not grant immigration permission.

It gives the worker the sponsorship reference they need for the next stage.

The worker then makes their own Skilled Worker application.

Depending on their circumstances, this may involve providing evidence of identity, English language ability, finances, criminal records certificates, ATAS clearance or other required material.

The Home Office makes the decision.

A correctly assigned CoS is therefore necessary, but it is not a guarantee of approval.

This is an important expectation to manage with recruitment teams.

“CoS assigned” should not be recorded internally as “visa approved”.

They are different events.

“Employers sometimes think their part is finished once the CoS has been assigned. I would treat it as a handover point. The sponsorship information needs to be right, the worker then needs to make the correct application, and the employer still needs to verify the eventual permission before employment starts.”

Abdul Jabbar, Principal Immigration Adviser

The immigration system is now digital

For current sponsored work applications, successful applicants will generally receive an eVisa as proof of their UK immigration status.

The move to digital status is now substantially complete for sponsored workers. From 1 July 2026, the Home Office stopped issuing entry clearance vignettes to new successful applicants, subject to limited arrangements for people without an accepted passport or identity document.

For employers, this makes the online right to work process particularly important.

A visa approval email is not itself proof that the person has the right to work.

The employer needs to complete the correct right to work check.

Do not skip the right to work check because you sponsored the visa

This is probably one of the most important practical points in the entire process.

The employer assigned the Certificate of Sponsorship.

It knows the visa application was approved.

It may have helped the worker throughout the process.

A right to work check is still required.

For a worker holding an eVisa, the employer will normally conduct an online check using the Home Office right to work service.

That check should confirm the individual’s identity, that they have permission to work and that the permission covers the employment being offered.

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

Depending on the circumstances, the sponsor may also need to retain evidence of the worker’s date of entry to the UK.

Sponsoring somebody does not create a substitute for the statutory right to work process.

Can the worker start before the date on the CoS?

Potentially.

Once immigration permission has been granted and has become valid, a sponsored worker can generally start the sponsored role before the start date recorded on the CoS.

The employer must first have completed the appropriate right to work check.

There is normally no need to report that the worker started earlier once permission has already been granted.

The key point is the validity of their immigration permission.

Not simply the fact that the employer would like them to begin.

The first day should match the sponsorship

By the time the sponsored worker begins employment, several strands should come together.

The person doing the job should be the person sponsored.

The job should be the job described.

The salary should be the salary stated.

The hours should reflect the arrangement assessed for Skilled Worker purposes.

The work location should be consistent with the sponsorship information.

The right to work check should have been completed.

Relevant records should be retained.

The people responsible for sponsor compliance should know that the worker has started.

This is the point at which sponsorship moves from recruitment into compliance.

What happens afterwards matters just as much as what happened during the visa application.

A practical sequence for sponsoring a Skilled Worker

For a typical employer, the process should look broadly like this:

1. Confirm that sponsorship is actually required

Check the worker’s current immigration position and whether they already have permission to undertake the proposed work.

2. Confirm that Skilled Worker is the appropriate route

Consider whether the worker and the commercial arrangement fit the route.

3. Assess the job

Establish the genuine duties, occupation code, skill level, salary, hours and working arrangements.

4. Assess the worker

Consider their current immigration status, ability to switch where relevant, English language position and any other individual requirements that could affect the application.

5. Establish which CoS is required

A Skilled Worker applying from outside the UK normally requires a Defined CoS.

A Skilled Worker applying for permission to stay from within the UK normally requires an Undefined CoS.

6. Obtain the certificate if necessary

Apply for a Defined CoS or additional Undefined allocation where the business does not already have the certificate available.

7. Review the CoS before assigning it

Check names, passport details, occupation code, job description, salary, hours, work address, dates and any route-specific answers.

8. Assign the CoS and pay the applicable charges

The sponsor pays the Certificate of Sponsorship fee and, where applicable, the Immigration Skills Charge.

9. The worker makes the immigration application

The CoS reference forms part of their application. It does not itself grant permission.

10. Wait for the immigration decision

Do not confuse CoS assignment with visa approval.

11. Complete the right to work check

Once permission is granted and valid, complete the appropriate check before employment begins.

12. Onboard the worker into sponsor compliance

Make sure relevant HR and sponsorship records are in place and that the people responsible for compliance know the worker has started.

None of these steps is particularly dramatic.

The value lies in doing them in the right order.

Common mistakes after a sponsor licence is granted

Several problems are avoidable.

Assigning the CoS too early

The certificate then risks expiring before the worker is in a position to make the application.

Choosing the occupation code from the job title alone

Occupation codes are based on the substance of the job, not the label the company has chosen.

Looking only at the general salary threshold

The going rate may be higher, or a different salary option may apply.

Using an Undefined CoS for a worker applying from overseas

A Skilled Worker applying for entry clearance normally needs a Defined CoS.

Assuming an overseas candidate can automatically qualify

The worker still needs to meet their own immigration requirements.

Treating the CoS as something that can be corrected casually

Some information can be addressed through a sponsor note. Other errors can require the certificate to be withdrawn and a new one assigned.

It is better to review before submission.

Letting the worker start because the employer sponsored them

Sponsorship does not remove the requirement for a compliant right to work check.

Forgetting that the role must remain the role that was sponsored

Sponsorship obligations continue once recruitment ends.

The Certificate of Sponsorship is not simply a record of what was intended at the application stage. It becomes part of the benchmark against which the sponsored employment can later be assessed.

Frequently asked questions

Can I sponsor someone as soon as my sponsor licence is approved?

Potentially, yes.

The employer still needs to confirm that the role and worker meet the relevant requirements and that the correct Certificate of Sponsorship is available.

If a Defined CoS is required, it must normally be requested separately.

What is the difference between a Defined and Undefined CoS?

For Skilled Worker applications, a Defined CoS is used where the worker is applying for entry clearance from outside the UK.

An Undefined CoS is normally used where the Skilled Worker is applying for permission to stay from within the UK.

Undefined Certificates come from the sponsor’s annual allocation. Defined Certificates are requested when needed.

How long does a Defined CoS take?

GOV.UK currently states that Defined CoS applications are usually approved within one working day.

A case can take longer if UKVI requires further checks.

Employers should therefore avoid guaranteeing a one-day turnaround to a candidate.

How long does a Certificate of Sponsorship last?

The worker must normally use the CoS in an immigration application within three months of the date it was assigned.

The application also cannot normally be made more than three months before the employment start date shown on the CoS.

Does a Certificate of Sponsorship guarantee the Skilled Worker visa?

No.

The CoS confirms the employer’s sponsorship and information about the proposed job.

The worker must still make a valid application and satisfy the relevant Immigration Rules.

Can the employee pay for their Certificate of Sponsorship?

The sponsor must pay the Skilled Worker CoS fee and must not recoup that fee or associated administrative costs from the sponsored worker.

The Immigration Skills Charge must also be borne by the sponsor.

What is the current Skilled Worker CoS fee?

As at September 2026, the Certificate of Sponsorship fee for a Skilled Worker is £525.

An Immigration Skills Charge may also be payable.

Can a sponsored worker start work as soon as their visa is approved?

Their immigration permission must be valid and the employer must first carry out the appropriate right to work check.

Approval of the application should not be treated by itself as completion of the employer’s right to work process.

Sponsorship works best when the stages remain separate

The period immediately after a sponsor licence is granted can move quickly.

A business has been waiting to recruit.

The candidate may be waiting overseas.

There may be a notice period, project deadline or planned start date.

That creates pressure to assign the Certificate of Sponsorship as quickly as possible.

Speed is useful when the underlying position has already been checked.

It is less useful when the CoS becomes the point at which the employer first considers the occupation code, salary or worker’s immigration position.

The better sequence is straightforward.

Understand the job.

Understand the worker.

Choose the correct sponsorship route and certificate.

Check the information.

Assign the CoS.

Let the worker make the immigration application.

Verify the eventual right to work.

Then allow the sponsored employment to begin.

Once the worker starts, a different stage of the sponsor relationship begins.

The question is no longer whether the employee can be sponsored.

It is whether the business continues to sponsor them correctly.

Next in the Employing International Talent series: Sponsor Licence Responsibilities After Approval

Preparing to sponsor an employee?

If your business holds a sponsor licence and is preparing to sponsor a Skilled Worker, we can consider the proposed role, occupation code, salary, Certificate of Sponsorship and worker’s immigration position as part of a Free Case Assessment.

Tell us about the business, the job and the person you intend to sponsor.

We can then consider whether Knightsbridge Immigration can as

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