On 14th July 2025, the UK Visas and Immigration (UKVI) issued an important letter to sponsors, detailing significant changes to the Skilled Worker visa framework, with a particular focus on Certificates of Sponsorship (COS).
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These updates, effective from 22nd July 2025, introduce stricter requirements for Defined Certificates of Sponsorship (DCOS) and Undefined Certificates of Sponsorship (uCOS), alongside clarifications on the Immigration Salary List (ISL) and the new Temporary Shortage List (TSL). Sponsors must act promptly to ensure compliance, as failure to meet these deadlines and criteria could lead to application rejections and disruptions to workforce planning.
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A key change affects outstanding DCOS requests for out-of-country applications. Any DCOS not aligned with Regulated Qualifications Framework (RQF) Level 6, the ISL, or the TSL by 22nd July will be rejected outright. Similarly, previously granted DCOS requests that do not meet these standards must be assigned before the same deadline, or they will also face rejection.
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This tight timeline means sponsors must urgently review all pending applications to confirm they meet the updated eligibility criteria, ensuring roles align with the specified skill or shortage lists. For DCOS applications falling under “transitional arrangements,” there is some flexibility, though strict conditions apply. These applications, if non-compliant by 22nd July, will be rejected but can be resubmitted after this date, provided they meet the necessary requirements.
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For workers applying to extend their stay from overseas, either with a valid visa or within 14 days of visa expiry, sponsors must clearly indicate eligibility by including “TRANSITIONAL ARRANGEMENTS APPLY” at the start of the job description field. This ensures the application is processed under the correct framework, avoiding unnecessary delays or refusals.
For in-country uCOS assigned after 22nd July, sponsors face additional scrutiny. If the role is not RQF Level 6, ISL, or TSL, the COS must explicitly explain how the worker qualifies under transitional arrangements, for instance, by demonstrating continuous Skilled Worker visa status since before 22nd July 2025.
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Without this clarification, applications are likely to be rejected, placing a significant responsibility on sponsors to provide accurate and detailed documentation.
The letter also sheds light on the relationship between the ISL and the newly introduced TSL, which will operate in parallel. Unlike ISL roles, TSL roles will not benefit from discounted application fees or reduced salary thresholds. Instead, salary requirements will follow the “going rates” under Option A or Option F, depending on when the worker first joined the Skilled Worker route.
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The key advantage of TSL inclusion is that the standard salary threshold may not apply if the going rate is lower, offering employers some flexibility in recruiting for shortage occupations.To streamline the process, the COS form will be updated to allow sponsors to specify whether a role falls under the ISL or TSL. This change aims to improve clarity and efficiency in applications.
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However, with the 22nd July deadline looming, sponsors must act swiftly to review their recruitment strategies, update documentation, and ensure compliance to avoid disruptions. Proactive engagement with these new rules is crucial for maintaining smooth visa processes and supporting workforce needs.
