UNITED KINGDOM: Transitional Arrangements – Further Details on the Global Business Mobility Routes

April 4, 2022


On 11 April 2022, the Intra-Company Transfer and Intra-Company Graduate Trainee routes are being replaced by two new Global Business Mobility routes, as previously reported on – respectively, the Senior or Specialist Worker route and the Graduate Trainee route.

Further guidance on the transitional arrangements to ease the introduction of these new routes has now been published, which is summarised below:

  • organisations applying for a Senior or Specialist Worker route sponsor licence from 11 April must pay the ‘large’ company Home Office fee of £1,476 when applying for a licence, unless they meet the ‘small’ or ‘charitable’ company definitions;
  • when assigning a Certificate of Sponsorship (CoS) to a worker under the Senior or Specialist Worker route, the sponsor must pay the higher CoS fee, regardless of their company size, status, or the individual’s duration of employment;
  • applications for sponsor licences (as well as applications for additional routes to existing licences held) in the Intra-Company routes made before 11 April but outstanding on or after 11 April will be decided upon under the policy in place at 10 April, however, if successful, will be granted a licence in the Senior or Specialist Worker route (if the Intra-company Transfer route was applied for) and the Graduate Trainee route (if the Intra-company Graduate Trainee route was applied for), with appropriate CoS allocations being issued in accordance with the numbers requested in the licence application;
  • for existing sponsor licence holders in the Intra-Company Transfer and Intra-Company Graduate Trainee routes:
    • these licences will be automatically updated to add the Senior or Specialist Worker and the Graduate Trainee routes, respectively, with the same licence rating;
    • suspended, revoked or dormant licences will not be updated (although licences upgraded following a reversed suspension will be);
    • the existing Intra-Company Transfer and Intra-Company Graduate Trainee routes shall remain present on the licence to allow ongoing reporting for CoS assigned in these categories, however no active CoS will be allocated on the licence;
    • if the existing licence does not currently possess the Intra-Company Graduate Trainee route, it will be automatically added to the existing licence if either of the following scenarios apply:
      • the sponsor has requested an allocation of CoS for the Intra-Company Graduate Trainee route at any time since 1 December 2020; or
      • the sponsor has previously assigned a CoS to a graduate trainee – this includes on the Intra-Company Graduate Trainee route, or the Graduate trainee sub-category of the Tier 2 (Intra-Company Transfer) route in place before 1 December 2020;
    • where the transitional updates apply, CoS allocations held in the Intra-Company Transfer and Intra-Company Graduate Trainee routes at the close of 10 April will be automatically carried over to the Senior or Specialist Worker and the Graduate Trainee routes (up to a maximum of 20), respectively (with the ability to make “ad hoc” requests for additional CoS continuing)
    • requests for additional Intra-Company Transfer route CoS submitted before 11 April but that remain outstanding at that date will, if granted, be automatically done so in the Senior or Specialist Worker route
    • requests for additional Intra-Company Gradate Trainee route CoS submitted before 11 April but that remain outstanding at that date will not be considered – instead, a resubmission for CoS under the Graduate Trainee route will need to be made
  • for CoS assigned under the Intra-Company Transfer and Intra-Company Graduate Trainee routes before 9am on 11 April 2022 and that remain unused and valid (i.e. not used in a visa application and has not expired), at that time and date, the worker can continue to rely upon it and their application will be considered in the Senior or Specialist Worker or the Graduate Trainee routes, respectively
  • visa applications submitted before 9am on 11 April 2022 using CoS assigned to them in the Intra-Company Transfer and Intra-Company Graduate Trainee routes will be decided upon in accordance with the relevant Immigration Rules for the relevant route in force on 10 April 2022

Individuals and organisations impacted by this development are encouraged to contact a Newland Chase immigration specialist for case-specific advice. For general advice and information on immigration and business travel to the UK, please contact us.

This immigration update is for informational purposes only and is not a substitute for legal or scenario-specific advice. Furthermore, it is important to note that immigration announcements are subject to sudden and unexpected changes. Readers are encouraged to reach out to Newland Case for any case- or company-specific assessments.