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UK Sponsor Licence and Certificate of Sponsorship (CoS): What Employers Need to Know

  • Writer: Veranika Rusakovich
    Veranika Rusakovich
  • Jul 7
  • 6 min read

Updated: Jul 8

The Problem


Most UK employers cannot legally hire overseas workers without a Sponsor Licence. Many find a strong candidate, only to discover they don't yet hold one.


Key points:

  • A Sponsor Licence is required before most UK employers can hire overseas workers.

  • A Certificate of Sponsorship (CoS) is issued only after licence approval.

  • Employers remain responsible for compliance after sponsorship approval.


Why a UK Sponsor Licence Matters


This creates a direct barrier to international recruitment.


If nothing is done, this typically leads to:

  • Lost candidates. Good hires don't wait – they'll accept an offer elsewhere.

  • Unfilled roles. Vacancies stay open longer than they need to.

  • Compliance risk. If you already have a licence but aren't managing it properly, small mistakes can lead to Home Office action – including against employees you're already sponsoring.


The Solution


Most of this is preventable. At a high level, it comes down to four things:

  • Preparing a compliant licence application

  • Setting up HR and record-keeping systems

  • Assigning the right sponsorship roles internally

  • Ongoing monitoring of sponsored employees


These steps form the foundation of a compliant UK sponsorship system. Get them right from the start, and overseas hiring becomes a manageable, repeatable process rather than a risk.


UK Sponsor Licence guide by Zabulis Legal

What Is a UK Sponsor Licence?


A Sponsor Licence is required for most UK employers to hire overseas workers legally. It's permission from the Home Office, most commonly used to sponsor workers under the Skilled Worker route.


Without a Sponsor Licence, a UK employer cannot assign a Certificate of Sponsorship.


Who needs a Sponsor Licence?


  • UK employers hiring overseas workers;

  • companies recruiting Skilled Workers;

  • organisations sponsoring eligible visa routes.


How a UK Sponsor Licence Works, Step by Step


The process generally follows three stages:

1. The employer gets licensed. UKVI reviews the business and approves a Sponsor Licence.

2. The employer assigns a CoS. Once licensed, the employer issues a Certificate of Sponsorship – a digital reference number – for the specific worker and role.

3. The worker applies for their visa. The worker uses the CoS reference number to apply, alongside their own evidence.


Each stage depends on the previous one being completed correctly. A Certificate of Sponsorship is always required before a worker can apply for a Skilled Worker visa.


The table below shows which responsibilities belong to the employer and which belong to the sponsored worker throughout the process.


Stage

Employer

Worker

Apply for a Sponsor Licence

Responsible

Receive Sponsor Licence approval

Responsible

Assign a Certificate of Sponsorship (CoS)

Responsible

Apply for a Skilled Worker visa

Responsible

Start employment

Both

Both

Meet ongoing compliance requirements

Responsible

Follow visa conditions


Two Types of Certificate of Sponsorship


Not all CoS are the same. There are two types:

  • Defined CoS – generally used when the worker is applying from outside the UK

  • Undefined CoS – generally used when the worker is already in the UK, for example switching from another visa


Employers usually hold an annual allocation of Undefined CoS, while Defined CoS are requested individually for each worker. Using the wrong type can cause delays or refusal.


Key Requirements for a UK Sponsor Licence


To get a licence, an employer generally needs:

  • Proof the business is genuine and actively trading (company registration, bank statements, insurance)

  • Named people responsible for managing sponsorship duties

  • Basic systems for record-keeping and tracking sponsored staff


There's also a fee, based on business size – currently £611 for small or charitable organisations, and £1,682 for medium or large ones (correct as of June 2026 – worth confirming before you apply).


Small and charitable businesses can apply for a Sponsor Licence — there's no minimum company size to be eligible.


Ongoing Responsibilities Under a UK Sponsor Licence


Getting the licence is just the start. Once approved, employers need to:

  • Carry out right-to-work checks before someone starts

  • Keep accurate records – payroll, contracts, qualifications, salary evidence

  • Report relevant changes (role, salary, location) within 10 working days

  • Keep pay above the required threshold, in practice, not just on paper


Learn more about Sponsor Licence Compliance and the ongoing duties employers must meet after obtaining a licence.


Common Mistakes With a UK Sponsor Licence


The same issues come up again and again:

  • Choosing the wrong CoS type

  • Picking the wrong job classification code

  • Missing the 10-working-day reporting window

  • Records that don't match what's actually happening day to day


What Happens If the Home Office Finds a Problem?


Non-compliance with sponsor duties can lead to serious Home Office action. These risks increase in severity depending on the level of non-compliance:

  • Downgrade – limited ability to sponsor new workers until issues are resolved

  • Suspension – temporary inability to assign new Certificates of Sponsorship

  • Revocation – loss of sponsor status, which can also affect the immigration status of employees already being sponsored


Revocation is the outcome employers most need to avoid.


For more on how the Home Office investigates non-compliance, see GOV.UK guidance on Sponsor Licence Suspension and Revocation.


How Zabulis Legal Can Help With Your UK Sponsor Licence


Many employers approach us after identifying a suitable overseas candidate, only to realise they cannot proceed because they do not yet hold a Sponsor Licence.


We help employers apply for Sponsor Licences, assign Certificates of Sponsorship correctly, and maintain ongoing compliance with Home Office requirements.


Why Choose Us


  • UK business immigration focus

  • Advice from a Solicitor of England & Wales

  • Support with sponsor licence applications and compliance

  • Assistance with Home Office audits and enforcement action


UK Sponsor Licence & CoS Guide | Zabulis Legal

Speak to Our Team


We can assess your eligibility, prepare the Sponsor Licence application, draft supporting documents, and help you remain compliant after approval. Speak to our team if you are planning to hire overseas workers or have already identified a candidate and need a Sponsor Licence.



Frequently Asked Questions About UK Sponsor Licences


Can I hire someone from abroad without a UK Sponsor Licence?

No. A Sponsor Licence is required to employ most overseas workers in the UK.

A Sponsor Licence allows an employer to sponsor workers. A Certificate of Sponsorship is issued for a specific worker. A visa is what the worker ultimately applies for, using the CoS reference number.

Processing times depend on UKVI workload and service type. Confirm current timeframes on GOV.UK or speak with us before planning around a specific date.

Yes. Small and charitable organisations can apply and pay a lower licence fee, though the same eligibility and compliance requirements apply.

A suspended licence means no new Certificates of Sponsorship can be assigned until the Home Office concludes its investigation. Existing sponsored workers are usually unaffected during this period.


This article is for general information only and does not constitute legal advice. Immigration rules and fees change frequently – always check GOV.UK or speak with us before acting.


Legally reviewed by: Vincentas Zabulis, LL.M (UCL), Solicitor (England & Wales), Managing Partner, Zabulis Legal.


Technical Compliance Reference


The section below is a condensed reference summary for HR teams, compliance officers, and advisers. It is not required reading to understand the article above.


Defined vs Undefined CoS


Feature

Defined CoS

Undefined CoS

Applicant location

Outside the UK

Inside the UK (including switching)

How allocated

Requested individually via SMS

Drawn from an annual allocation granted by UKVI

Typical UKVI processing

Within one working day

Drawn from existing allocation, no separate approval step


Ключевые роли в Sponsor Management System (SMS)


  • Authorising Officer – senior person accountable for overall sponsor compliance

  • Key Contact – primary point of contact with UKVI (can be the same person as the Authorising Officer)

  • Level 1 User – manages day-to-day SMS activity; must be employed by or contracted to the sponsor


Appendix D record-keeping – core categories


  • Right-to-work documents

  • Payroll records

  • Contracts of employment

  • Copies of relevant professional qualifications

  • Evidence supporting the salary and SOC code decision


Sponsor licence fees (as at 16 June 2026)

Sponsor type

Fee

Small or charitable

£611

Medium or large

£1 682


Immigration Skills Charge (as at 16 June 2026)


Sponsor type

Rate per year of sponsorship

Small or charitable

£480

Medium or large

£1 320


Civil penalties for illegal working (as at 16 June 2026)


Breach type

Maximum penalty per worker

First breach

£45 000

Repeat breach

£60 000


Note: All figures are subject to change. Confirm current rates on GOV.UK before relying on them.


Sources and Official Guidance



Changelog

  • 7 July 2026: Confirmed sponsor licence fees, Immigration Skills Charge, and civil penalty figures as at 16 June 2026.


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