Employer's Guide: Avoiding Fake Certificates of Sponsorship

For UK sponsor license holders and HR professionals

As a UK employer with a sponsor license, protecting your organization from CoS fraud is critical. Fraudulent CoS use can result in license suspension, compliance issues, and reputational damage. This guide provides practical steps for preventing and detecting fake CoS submissions.

Why Should Employers Care About Fake CoS Documents?

While most CoS fraud targets workers, employers face serious consequences when fraudulent documents are traced back to their license:

License suspension or revocation: Home Office may suspend your sponsor license if fraud is detected
Compliance downgrade: Your A-rating could be downgraded to B-rated, limiting your sponsorship ability
Financial penalties: Civil penalties up to £20,000 per illegal worker
Reputational damage: Association with immigration fraud harms your organization's reputation
Criminal liability: In extreme cases, directors can face criminal prosecution
Lost recruitment capability: Suspended licenses prevent hiring critical skilled workers

Critical risk: Fraudsters impersonate legitimate sponsors to create fake CoS documents. Your company name could be used without your knowledge, exposing you to compliance investigations.

How Does CoS Fraud Affect Legitimate Sponsors?

There are three primary ways employers encounter CoS fraud:

1. Impersonation Fraud

Scammers create fake documents claiming to be from your organization:

Use your company name and sponsor license number
Forge emails from fake accounts impersonating your HR staff
Create convincing-looking "CoS certificates" with your branding
Collect money from victims claiming to represent your company

2. Internal Fraud

Current or former staff misuse SMS access:

Unauthorized CoS assignments to non-existent positions
Selling CoS allocations to third parties
Creating false job descriptions to circumvent skill requirements

3. Third-Party Submission Fraud

Applicants submit fake CoS claims from supposedly other sponsors:

You hire someone who previously worked on a fraudulent CoS
Background checks reveal suspicious previous sponsorship
Home Office queries about CoS you didn't assign

Employer Compliance Checklist: Preventing CoS Fraud

Essential Protection Measures

Restrict SMS access: Limit Sponsorship Management System access to authorized staff only (Level 1 and 2 users)
Implement dual authorization: Require two people to approve each CoS assignment
Regular access audits: Review who has SMS access quarterly and remove departing staff immediately
Monitor CoS assignments: Reconcile assigned CoS against actual hires monthly
Secure communication: Only communicate about sponsorship from official company email addresses
Document verification: Verify all candidate documents before assigning CoS
Interview requirements: Always conduct proper interviews—never assign CoS without meeting candidates
Record keeping: Maintain detailed records of all CoS assignments and interview notes

How Can Employers Detect Third-Party CoS Fraud?

When reviewing CoS documents from candidates claiming previous UK employment:

Verification Steps:

Check the sponsor register: Verify the previous sponsor still holds a valid license
Contact the previous employer: Independently verify employment and CoS assignment
Examine document format: Legitimate sponsors don't typically provide PDF CoS certificates
Verify reference number format: CoS reference numbers follow specific patterns
Check timeline consistency: Dates should align with claimed employment history

Recommended: Use AI verification tools to analyze CoS documents submitted by candidates. This provides an additional layer of due diligence before proceeding with sponsorship.

What to Do If Your Company is Impersonated

If you discover fraudsters are using your company name to create fake CoS documents:

Report to Home Office immediately: Contact the Sponsor Compliance Team via your SMS account
Document the fraud: Collect examples of fraudulent documents using your name
Report to Action Fraud: File a report at actionfraud.police.uk
Alert your industry network: Warn professional associations and recruitment partners
Review SMS security: Ensure your systems haven't been compromised
Publish a warning: Post on your website clarifying your recruitment process
Monitor for continued abuse: Set up Google Alerts for your company name + "Certificate of Sponsorship"

Maintaining Sponsor License Compliance

Best practices to protect your sponsor license:

Documentation Requirements:

Keep complete records of all assigned CoS for at least 6 years
Maintain interview notes and recruitment justifications
Document right to work checks and qualification verifications
Record all communications with sponsored workers

Regular Compliance Activities:

Monthly SMS audits: Review all CoS assignments and sponsored worker records
Quarterly access reviews: Verify authorized users still need SMS access
Annual compliance training: Train HR staff on sponsor duties and fraud prevention
Update contact details: Keep Key Contact and Authorising Officer details current in SMS

Employer Responsibilities When Assigning CoS

Remember your legal duties when using your sponsor license:

Before Assigning a CoS:

Genuine vacancy exists and cannot be filled by settled workers
Job meets skill and salary thresholds for the visa route
Candidate has required qualifications and English language ability
You've conducted a proper recruitment process
You can demonstrate compliance with employment law
You have systems to monitor and report on sponsored workers

Red Flags for Employers: Suspicious Applications

Be cautious if an applicant:

Pressures you to assign CoS quickly without proper process
Offers to pay for the CoS or "reimburse" your costs
Has documents that don't match their claimed experience
Cannot be reached at provided contact details
Provides inconsistent information between applications
Has suspicious gaps or inconsistencies in employment history
Claims to have worked for sponsors who don't recognize them

Resources for UK Sponsor License Holders

Summary: Protecting Your Sponsor License

Key takeaways for employers:

Restrict SMS access to essential staff only
Implement dual authorization for CoS assignments
Monitor for unauthorized use of your company name in CoS fraud
Verify documents thoroughly before accepting claims of previous sponsorship
Report suspected fraud to Home Office and Action Fraud immediately
Maintain meticulous records to demonstrate compliance