Certificates of Sponsorship in 2026: Why Getting It Right Has Never Mattered More.

Assigning a Certificate of Sponsorship (COS) can feel like a routine administrative task. But in 2026, that "routine" task is one of the biggest risk points for sponsor licence holders, and getting it wrong is costing employers their licences, their staff, and in some cases, their businesses.

At a recent employer webinar, Tulia Group founder and solicitor Rumbidzai Bvunzawabaya broke down exactly what's changed, where employers keep going wrong, and what to do about it. Here's what every sponsor needs to know.

A COS Is a Promise, Not Just a Form

Think of a Certificate of Sponsorship as a permission slip, but also as a contract. When you assign one, you are telling the Home Office: we are employing this specific person, in this specific role, on these specific terms.

Everything on that certificate, the occupation code, the salary, the weekly hours, the work location has to match reality exactly. Because that certificate forms the legal basis of your worker's visa application and your ongoing obligations to the Home Office.

Get the numbers wrong, and it's not just a paperwork problem. It can mean a visa refusal for your employee, or a compliance breach for you.

Why 2026 Is Different

Sponsors who've held a licence for years may wonder why this all feels harder now. It's not your imagination. Several things have shifted:

Overseas recruitment has largely closed for care roles and many RQF Level 3 occupations, meaning most COS activity is now in-country switches and extensions under much closer scrutiny.

Compliance checks have intensified. The Home Office now runs in-person visits, digital checks, and critically cross-references sponsor data directly against HMRC payroll records.

A single underpaid pay period can now trigger a breach, sometimes without warning and without the chance to correct it first.

And crucially: most breaches Tulia sees aren't the result of employers deliberately gaming the system. They're avoidable errors, a salary that didn't rise with the going rate, an occupation code that doesn't quite match what someone actually does, an absence that was never logged on the Sponsorship Management System (SMS).

The Errors That Keep Coming Up

Salary mismatches. Pay must meet or exceed both the Home Office going rate for the occupation code and the National Minimum Wage, whichever is higher. Rates rise over time, so a COS issued years ago at a lower salary needs updating. Check payroll against current thresholds every single month.

Wrong occupation codes. Employers sometimes choose the closest-sounding code rather than the one that actually reflects day-to-day duties. The code determines the going rate and whether the role can be sponsored at all, so it has to be right.

Unreported changes. Sick leave, unpaid leave, reduced hours, and departures all need to be reflected on the SMS. If pay drops and the SMS isn't updated, that mismatch is exactly what data-matching is designed to catch.

Assigning a COS to a relative. This is a mandatory ground for revocation, easily missed, especially at renewal or extension stage when the same authorising officer processes it without a second thought.

The Real Cost of Getting It Wrong

The numbers tell their own story. Sponsor licence revocations have climbed sharply:

2021: 294

2022: 514

2023: 726

2024: 1,643

2025: 3,100

2026 (projected): 6,200 — with 1,545 already recorded in Q1 alone

Beyond revocation, illegal working penalties now run to £45,000 per worker for a first breach, rising to £60,000 for repeat breaches. A revoked licence can mean sponsored staff losing their right to work for you, and in the worst cases, workers being forced to leave the UK, sometimes after years of employment.

Timing Is Now Part of Compliance

New COS applications are currently taking around 18 weeks to process and can take longer if the Home Office requests further information. That means the gap between realising you need a new certificate and your worker having a visa decision can stretch beyond six months.

Waiting until a visa is close to expiring is no longer viable. Build COS renewal timelines into your workforce planning at least 20 weeks ahead, and keep track of every sponsored worker's expiry date well in advance.

A Quick Self-Check

Ask yourself:

Do you know the current going rate for every occupation code you sponsor under not the rate from when you first hired?

Do you check payroll against the required salary floor every month?

When did you last audit your SMS records?

Do you know when each sponsored worker's visa expires, and do you have a system to flag it in advance?

Are your dates, start date, visa timeline, visa switch, all consistent with each other?

If any of these gave you pause, that's worth acting on now, before it becomes a Home Office letter.

Getting Support

Sponsor licence compliance is unforgiving, but it's manageable with the right systems in place. Tulia Group supports employers with compliance checks, mock audits, SMS management, sponsor licence applications, and revocation representations, plus regular webinars (now run every two weeks given how fast the landscape is moving).

Getting it right the first time is always easier, cheaper, and less stressful than challenging a revocation after the fact.

For more information on Tulia's employer and sponsor services, visit tulia.org.uk/sponsors-employers.