CoS Allocations: The Challenges Facing Care Providers and Other UK Sponsors

Tetiana Deren

13.07.2026

Key Takeaways

UK sponsors need an allocation of undefined Certificates of Sponsorship before they can sponsor any Skilled Worker who is already in the UK, including staff needing a visa extension.
Every increase request goes through the Sponsorship Management System, where a single 2,000-character box must justify each role, so incomplete detail is a common reason for delay or refusal.
Standard processing can take up to 18 weeks; paying the £350 priority fee targets five working days, but only around 120 priority slots open at 7am each weekday and sell out within minutes.
The Home Office increasingly asks for bank statements, organisation charts, contracts and proof of genuine vacancies, giving sponsors just five working days to reply.
Care providers face the sharpest pressure because overseas recruitment of new care workers closed on 22 July 2025, forcing reliance on staff already in the UK amid record licence revocations.
A refusal can only be challenged by judicial review, which is slow and costly, so the realistic response is usually to prepare thoroughly and reapply.

If your organisation holds a UK sponsor licence, the ability to keep and recruit overseas staff depends on having enough Certificates of Sponsorship (CoS) available. Yet many employers discover, often at the worst possible moment, that securing extra certificates from the Home Office has become slow, unpredictable and heavily scrutinised. This is especially true for care providers, but the same obstacles now affect sponsors across every sector.

What is a Certificate of Sponsorship allocation?

A CoS allocation is the pool of certificates the Home Office grants you to sponsor workers, and you must have one before you can sponsor anyone applying for a Skilled Worker visa from inside the UK. In practice this covers visa extensions, employees moving into a different role with you, and people switching from another route such as the Student, Graduate or partner (dependant) visas.

These in-country certificates are known as “undefined” CoS. There is a separate “defined” CoS process for candidates applying from outside the UK, and those are requested one case at a time rather than as a block allocation.

The Home Office normally sets your annual allocation by looking at how many certificates you used the previous year. If your needs grow, you can ask for an increase at any point during the year, provided you can show a real business reason for it.

How do you request an increase to your CoS allocation?

You request an increase through the Sponsorship Management System (SMS), the secure online portal sponsors use to make requests and report changes to the Home Office. The system gives you one text box of up to 2,000 characters (spaces included) to make your entire case, so precision matters.

For each worker and role you want to add, you generally need to set out:

The person’s full name, date of birth, nationality and current immigration status in the UK.
The job title and a short description of the duties.
The occupation code you will sponsor the role under, which must appear in an eligible table in Appendix Skilled Occupations of the Immigration Rules.
The salary, and an explanation of how it meets both the minimum threshold and the “going rate” for that occupation code. If you are relying on lower salary thresholds through “tradeable points” — for example because the worker is a “new entrant” (broadly, someone early in their career) or holds a relevant PhD — you should say so and explain why.

Because that single box has to hold every one of these details, employers seeking several certificates at once, such as when a group of current staff all have visas expiring around the same time, often find it almost impossible to fit everything in.

One further restriction catches many employers out: the Home Office will usually reject “speculative” requests, meaning requests for certificates where you have not yet identified the specific worker and are simply anticipating future vacancies. That makes genuine workforce planning difficult.

How long does a CoS allocation request take?

Standard processing can take up to 18 weeks, which is rarely workable when staff have visas expiring in the meantime. To avoid that wait, most sponsors pay a priority fee of £350 to have the request considered on a faster track.

The priority service aims to decide the request within five working days, counted from the day after payment clears. That timeframe is a target rather than a guarantee, and it can slip when the Home Office asks for more information.

Why is the priority service so hard to secure?

The bottleneck is supply: the Home Office accepts a minimum of only around 120 priority requests each weekday, while receiving far more than that every day. The service opens at 7am, and the available slots are typically gone within minutes. Employers regularly spend several weeks trying before they succeed, all while a worker’s visa expiry date draws closer.

What extra information does the Home Office ask for?

Even after you win a priority slot, the Home Office is increasingly following up with detailed requests for evidence before it will decide. Depending on the case, it may ask for some or all of the following:

Six months of bank statements for every account held by your business and any related companies.
An organisation chart showing exactly where each sponsored role sits within the structure.
An explanation of how you will fund the proposed salaries.
Employment contracts for all sponsored workers you already employ under the same occupation code.
Evidence of why the roles cannot be filled from your existing workforce.
Evidence that the vacancy is genuine, which can extend to showing signed contracts for new work that directly creates the need for the certificates.

You are normally given just five working days to respond. Assembling this volume of documents to a tight deadline is a real strain, particularly for smaller employers without a dedicated compliance team.

What happens after the Home Office decides?

There are three possible outcomes. The Home Office may grant the full number of certificates you asked for, grant a smaller number if it is not persuaded the whole request is justified, or refuse the request entirely.

The decision sits largely within the Home Office’s discretion. It cannot be appealed in the ordinary sense; the only formal challenge is judicial review, where a court examines whether the decision was made lawfully. Judicial review is expensive and can take many months, so for most sponsors the practical route is to address the concerns raised and submit a fresh request.

What are the risks if an allocation is delayed or refused?

The consequences reach well beyond the immigration file and into workforce planning, compliance and employment law. If you have staff whose visas are about to expire and no certificate available to support an extension, you face a difficult choice.

One option is to dismiss the worker once their right to work ends, with all the operational and employment-law difficulty that brings. The other is to submit the worker’s extension application before the certificate is ready, which can preserve their position for a time. But that route carries its own risk: the applicant will have a tight deadline to upload a valid CoS, and if it is not provided the Home Office can reject the application as invalid.

While a valid application is pending, the individual should usually keep the right to work, but you must carry out the correct right-to-work check and monitor the position closely, because that right can be lost, for example if the Home Office rejects the application. Get this wrong and the penalties are severe: a civil penalty for illegal working of up to £45,000 per worker for a first breach and £60,000 per worker for a repeat breach, alongside possible action against your sponsor licence.

Why is the care sector under the most pressure?

Care providers face all the usual difficulties at once, and several sector-specific pressures on top. Chronic staff shortages and high turnover create a constant need to recruit, and the sector has long relied on overseas workers to fill vacancies.

That reliance has collided with policy change. Following the government’s May 2025 immigration White Paper, the care worker route closed to new applicants from overseas on 22 July 2025. Employers can no longer bring in new care staff from abroad and must instead sponsor people already in the UK. Existing care workers can still extend and switch within the UK until 22 July 2028, and a worker switching into a care role generally needs to have worked for that sponsor for at least three months first.

At the same time, Home Office scrutiny of the sector has intensified and sponsor licence revocations have reached record levels, so care providers are both more dependent on the CoS system and more exposed if anything goes wrong.

Can the Home Office be challenged on unreasonable demands?

Yes, and the care sector has a recent example in its favour. In R (Hartford Care Group Ltd) v Secretary of State for the Home Department [2024] EWHC 3308 (Admin), the High Court found that the Home Office had acted “irrationally” in refusing certificates because the care provider could not supply contracts guaranteeing fixed hours. The court accepted that guaranteed-hours contracts are simply not standard in the care sector, so demanding them was unreasonable.

The ruling is a helpful reminder that Home Office decisions are not beyond challenge. In practice, though, judicial review remains a last resort because of its cost and the time it takes to conclude.

How can sponsors improve their chances of success?

The most effective approach is to treat every request as if the Home Office will scrutinise it and ask for supporting evidence. Practical steps include:

Keeping strong HR and compliance systems, and a clear record of past compliance, so that a request does not raise concerns.
Requesting an increased allocation as far in advance as possible, rather than waiting until visas are close to expiring.
Putting as much detail as you can into the initial SMS request, including exactly how each sponsorship requirement is met.
Preparing the likely supporting documents in advance, on the assumption that the Home Office will ask for them.
Taking specialist immigration advice, especially if a previous request has been refused or reduced, to identify what further evidence is needed and how best to present the case.

How Sterling Law can help

Sterling Law supports employers and sponsors through the entire CoS allocation process, from preparing a well-evidenced increase request to responding to Home Office information requests within tight deadlines. We also advise on right-to-work checks, sponsor licence compliance and the options available when an allocation is delayed or refused. If your organisation is planning ahead or has already run into difficulty, our immigration team can help you protect both your workforce and your licence.

To discuss your situation, contact Sterling Law to arrange a consultation.