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Home Office Reverses Refusal of 21 Undefined CoS Request After PAP Challenge

Our client's request for 21 Undefined Certificates of Sponsorship was refused without explanation. We challenged it through Pre-Action Protocol correspondence, and the Home Office accepted the decision was wrong and confirmed a fresh request would be treated as priority.

Nara SolicitorsNara Solicitors
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Home Office Reverses Refusal of 21 Undefined CoS Request After PAP Challenge
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We are pleased to share another success story from our team.

Our client came to us after the Home Office refused their request for 21 Undefined Certificates of Sponsorship. They had submitted the request through the Sponsor Management System to renew the Certificates of Sponsorship for workers they already employed. Nothing about it was unusual. They had even included supporting documents voluntarily to make the position clear.

So the refusal came as a surprise.

What troubled us most was how the decision had been reached. The Home Office had not come back to ask for anything further. There was no request for more information, no query, no chance to clarify. The refusal simply landed.

And when we read it properly, the reasons did not hold up. The letter did not explain itself in any way we could follow, and it plainly had not engaged with the documents our client had already provided. It read as though conclusions had been reached without the evidence in front of the decision maker being looked at at all.

For a sponsor, that is a real problem. These workers were already employed by our client. Their Certificates of Sponsorship needed renewing, and an unexplained refusal left the business with no idea what had gone wrong or how to fix it.

How we approached it

We have seen this kind of decision before, so we knew the options.

The obvious route would have been to tell the client to submit a fresh request and hope for a better result. We did not advise that. Putting in the same request again, with the same documents, gives no guarantee of a different answer, and it does nothing to address a decision that was wrong in the first place.

Instead, we challenged the refusal head on. We did this through Pre-Action Protocol (PAP).

Our PAP set out clearly why the decision could not stand. The Home Office had failed to give proper reasons, and it had failed to take account of the documentation submitted as part of the original request. Both are problems a court would take seriously.

If you have had a sponsor licence or CoS decision you simply cannot make sense of, speak to us. A flawed decision can very often be challenged.

The outcome

The response did not just soften the position. It reversed it.

In its PAP reply, the Home Office accepted outright that it had got the original decision wrong, stating: "We have reviewed your PAP and can confirm that the decision dated 29 April 2026 was incorrectly reached."

It then told us how it would put matters right: "Please instruct your client to submit a new request via the Sponsor Management System (SMS) and this request will be treated as priority."

This was exactly the result our client needed. The refusal has been accepted as flawed, and rather than waiting in the ordinary queue, the fresh request will now be dealt with as a priority.

What this case tells you

A few points are worth drawing out, because they come up again and again.

A refusal is not always the end of the road. If a decision gives no clear reasons, or ignores the evidence you put in, there may well be grounds to challenge it.

How you respond is just as important as the fact that you respond. Quietly resubmitting after an unexplained refusal often means going round the same loop. A properly drafted PAP letter forces the Home Office to look again and to justify what it has done.

And timing counts. Workers depend on these certificates. The sooner a bad decision is challenged, the sooner the position can be corrected.

How we can help

At NARA Solicitors, we deal with sponsor licence applications, Certificate of Sponsorship requests, compliance, and challenges to Home Office decisions. We also carry out compliance audits to help sponsors stay on top of their duties before problems arise.

You can read more of our success stories to see how we have helped other sponsors overturn refusals and protect their workforce.

If you are facing an unexplained or unfair refusal, we are here to help. We will review the decision and tell you honestly where you stand.

Book a consultation with NARA Solicitors today.

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