Certificate of Sponsorship Allocation After July 2025

A Guide for UK Employers With Sponsor Licences on Certificate of Sponsorship Assignment

In this article, our UK Immigration Lawyers highlight the July 2025 changes made to the allocation of a certificate of sponsorship for new sponsored employees and offer guidance on how employers can avoid the refusal of their applications for a certificate of sponsorship allocation.

Contact our specialist UK Immigration Solicitors for expert immigration legal advice.

The July 2025 sponsor licence changes

On 22 July 2025, the UK government made sweeping changes to the Skilled Worker Visa as part of the first phase of the 2025 Immigration White Paper. The government intends to reduce the reliance of UK employers on overseas labour, ultimately restricting the use of the Skilled Worker Visa to highly skilled and well-paid individuals.

Sponsor licence holders need to understand the new rules and how they impact their sponsorship of new employees from overseas, as well as how the transitional rules for existing employees will affect the company.

The Home Office changes focus on:

The reclassification of standard occupational codes (SOC), and
The tightening of eligibility criteria for sponsorship under the Skilled Worker route.

The July 2025 changes to certificate of sponsorship allocation

The four main changes affecting an employer’s certificate of sponsorship allocation are:

The Appendix Skilled Occupations in the immigration rules have been amended. The list separates job roles by skill level. Employers need to verify both the SOC code and the skill level before assigning a certificate of sponsorship to a Skilled Worker Visa applicant.

The higher skill threshold as sponsored jobs must now meet RQF Level 6 (the equivalent of degree level) to qualify for sponsorship. The increase in skill level removes around 180 previously eligible jobs that fell within RQF Levels 3–5.
The standard occupational code classification was updated to align with the new skill classifications. Employers must ensure that job roles align with the updated SOC codes.
The general salary threshold increased to £41,700. There are adjusted minimum salaries for skilled workers in PhD-level roles, new entrants, and shortage occupations.

Why have certificates of sponsorship refusals increased since July 2025

Since July 2025, sponsor licence holders have been reporting an increase in certificate of sponsorship refusals. The four refusal reasons are:

Jobs are no longer eligible to qualify for sponsorship on a Skilled Worker Visa.
Sponsored jobs do not meet the new salary requirements.
Incorrect standard occupational codes used.
Employers and key personnel do not fully understand the Home Office transitional provisions, as some RQF 3–5 roles remain valid for existing sponsored workers until July 2028. However, new applicants cannot be sponsored for these roles.

Assigning a certificate of sponsorship under the new immigration rules

To successfully assign a certificate of sponsorship to a successful recruit who requires a Skilled Worker Visa, the employer must:

Use the updated Skilled Worker Visa occupation list to verify the role remains eligible for Work Visa sponsorship.
Ensure the job meets both the salary threshold for the job and the RQF Level 6 skill level.
Talk to a Sponsorship Licence Lawyer about the July 2025 changes.
Invest in bespoke training for HR staff and key personnel to help them understand the rule changes.
Ask Immigration Solicitors to carry out a sponsor licence mock audit to check current operations and procedures.
Review training advice and procedure guidance for key personnel and HR staff.

The five steps businesses need to take to comply with the new Skilled Worker Visa changes and certificate of sponsorship rules

Here are our UK Immigration Lawyers' top five tips for employers on how to comply with the post-July 2025 rules:

Audit your existing sponsored roles and the standard occupational codes to review if jobs where you are recruiting for staff can still meet the Skilled Worker Visa eligibility criteria and flag up any sponsored employees who currently qualify for sponsorship but would not so in future because they no longer meet the job, salary or qualifications criteria
Make sure all job vacancy adverts and job descriptions are consistent with the remaining jobs that qualify applicants for a Skilled Worker Visa.
Check that salaries on offer meet the circumstances of the recruit. For example, if they qualify as a new entrant.
Track and diary up sponsored employees who fall under the transitional rules until 2028. Report changes in job roles.
Correctly follow the certificate of sponsorship allocation process.

The certificate of sponsorship allocation process

To assign a certificate of sponsorship, HR and key personnel staff should:

Check the updated list of standard occupational classification codes and match the correct code to the sponsored job.
Double-check the job meets the skill and salary thresholds. An employer can use the Home Office’s salary calculator to ensure the sponsored worker’s salary aligns with both the general threshold and the going rate for the role.
Ensure they are not relying on old standard occupational classification codes. Staff should always refer to the latest Appendix Skilled Occupations and cross-check the SOC code before submission on SMS.
Ensure there is sufficient information in the job description to prove that the job qualifies under the new rules.
Ensure the transitional rules are only used with existing sponsored employees and not new ones.
Talk to Sponsorship Licence Lawyers for ad hoc certificate of sponsorship legal advice or employ an Immigration Solicitor to provide a full Sponsor Licence Management Service.
Stay updated, as the immigration rules will be subject to further change.

The consequences for employers of not following the post-July 2025 rules on certificate of sponsorship allocation

These are a few of the potential consequences of non-compliance with the post-July 2025 certificate of sponsorship rules:

The certificate of sponsorship application will be refused, thus delaying or preventing the employment of the overseas worker.
The Home Office could decide to hold an audit. An audit could result in the suspension or downgrading of the licence.
The business could face reputational and operational damage through the loss of its licence, especially if the licence is revoked. Licence revocation means all existing sponsored employees would need to find new jobs with other sponsor licence holders or face Work Visa curtailment.

Talk to the Immigration Lawyers at OTS Solicitors

In the ever-changing world of immigration law, UK business owners with sponsor licences need access to specialist legal advice from Sponsorship Licence Lawyers.

At OTS Solicitors, our specialist lawyers are committed to providing the up-to-date, practical and technical legal advice your business needs to stay on top of the complexities of certificate of sponsorship allocation and licence compliance.

Our services range from one-off legal advice on specific licence queries to sponsor licence troubleshooting if your licence is at risk of sponsor licence suspension or revocation, to sponsor licence training and the full Sponsor Licence Management Service.

At OTS Solicitors, our award-winning business immigration team will guide your staff through the highly complex and changing system of sponsor licence sponsorship.

Contact our specialist UK Immigration Solicitors for expert immigration legal advice.

Appointments are available at our offices in central London, as well as by phone or Zoom consultation.

Our lawyers speak Arabic, Armenian, Farsi, French/Mauritian Creole, Spanish, Tamil, Tagalog/Ilonggo and Urdu/Punjabi.

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