Level 1 User: Sponsor Licence Role & Responsibilities

Sponsor Licence Level 1 User: At a Glance

The Level 1 User is one of the most important operational roles in the management of a sponsor licence. While the Authorising Officer has overall responsibility for the organisation’s sponsorship arrangements and oversight of SMS users, the Level 1 User carries out much of the day-to-day activity through the Sponsor Management System (SMS).

This can include assigning Certificates of Sponsorship, requesting CoS allocations, applying for Defined Certificates of Sponsorship, reporting changes relating to sponsored workers, updating information about the organisation, managing certain SMS user arrangements, withdrawing Certificates of Sponsorship and monitoring messages from UK Visas and Immigration (UKVI).

For employers, the role goes beyond operating an online system. The Level 1 User often sits at the point where workforce or business changes need to be recognised, assessed for their sponsorship implications and translated into accurate and timely SMS action.

A change may already be known to HR, payroll or a line manager, but that does not by itself satisfy the sponsor’s duties. The information still needs to reach the sponsorship function, the immigration implications need to be understood and any required SMS action completed within the applicable timeframe.

Employers therefore need to consider who they appoint, what access and authority they give them, how relevant information reaches them, how their activity is supervised and what controls apply to their use of the SMS.

The role has become more significant following changes to SMS user management introduced during 2026, including mandatory multi-factor authentication, new controls for inactive SMS user accounts and the withdrawal of the Level 2 User role. Sponsors should review whether their Level 1 User arrangements provide sufficient operational capability and resilience while keeping powerful SMS permissions appropriately controlled.

 

Section A: What is a Level 1 User on a Sponsor Licence?

A Level 1 User is an individual authorised to access the Sponsor Management System on behalf of a licensed sponsor and perform the principal day-to-day sponsorship activities available through the system.

The SMS is the Home Office online system used by licensed sponsors to administer their licence, manage Certificates of Sponsorship, maintain information about sponsored workers and the organisation, and complete specified reporting and licence-management actions.

Level 1 Users therefore hold substantial operational responsibility. They do more than view sponsor information: depending on the sponsor’s circumstances, they may assign Certificates of Sponsorship, make CoS-related requests, report worker changes, update sponsor information, withdraw Certificates and manage certain other SMS users.

The sponsor organisation remains responsible for ensuring these activities are carried out correctly. The Authorising Officer also has responsibility for the conduct of SMS users and should retain appropriate oversight of how Level 1 access is used.

 

1. What does a Level 1 User do?

 

A Level 1 User performs the sponsor’s day-to-day operational activity through the SMS.

Their functions can include:

 

• assigning Certificates of Sponsorship to eligible workers;
• requesting increases to Certificate of Sponsorship allocations;
• applying for Defined Certificates of Sponsorship where required;
• reporting relevant changes in the circumstances of sponsored workers;
• reporting certain changes relating to the sponsoring organisation;
• withdrawing Certificates of Sponsorship where appropriate;
• viewing information held about the sponsor licence;
• accessing messages and notifications from the Home Office;
• requesting additional Level 1 Users where permitted;
• managing certain SMS user arrangements; and
• carrying out other permitted sponsor management functions.

 

The precise activity undertaken by each Level 1 User will depend on the organisation.

A smaller employer may have one individual dealing with most sponsorship administration. A larger sponsor may divide responsibility across several Level 1 Users, with different people handling recruitment, Certificates of Sponsorship, worker reporting or other areas of licence management.

Whatever the structure, responsibilities need to be clearly allocated so that required actions are not missed because each person assumes somebody else is dealing with them.

 

2. Level 1 User vs Authorising Officer

 

The Level 1 User and Authorising Officer perform different functions within the sponsor management structure.

The Authorising Officer has senior responsibility for the organisation’s sponsorship arrangements, including oversight of SMS users and how the sponsor licence is managed.

The Level 1 User is primarily responsible for operational activity through the Sponsor Management System.

In practical terms:

Authorising Officer → overall responsibility, governance and SMS-user oversight

Level 1 User → day-to-day SMS operation

The same person can hold both roles where the relevant requirements are satisfied, but appointing somebody as a Level 1 User does not transfer the organisation’s wider sponsorship responsibility to them.

This is particularly important where SMS administration is delegated to HR personnel, another employee or an external representative. Operational activity can be delegated; the sponsor’s compliance responsibilities remain with the organisation.

 

3. Level 1 User vs Key Contact

 

The Key Contact is principally the organisation’s main point of contact with UKVI in relation to the sponsor licence.

The Level 1 User performs a different function, with operational access to the SMS.

Appointment as Key Contact does not itself provide Level 1 User permissions. If the Key Contact also needs to carry out Level 1 functions, they must be appointed appropriately and satisfy the relevant requirements.

One person can hold more than one key personnel role. Depending on the organisation, the same individual could act as Authorising Officer, Key Contact and Level 1 User.

Whether combining these roles is appropriate will depend on the size of the organisation, sponsorship volume, number of sponsored workers and the employer’s wider governance arrangements.

 

4. Why is the Level 1 User important?

 

The Level 1 User is important because sponsor compliance frequently depends on information being converted into action.

Consider an employer that changes a sponsored worker’s role, salary or working arrangements. HR may update its records and payroll may also be informed, but where the change engages the sponsor’s reporting duties, those internal steps alone do not necessarily satisfy the organisation’s obligations.

The information needs to reach somebody who can identify the sponsorship consequence, verify the facts and determine what action is required.

A well-managed process should therefore operate broadly as follows:

Business or HR event → identify sponsorship implications → verify information → obtain appropriate approval → complete required SMS action → retain supporting evidence

The Level 1 User commonly sits at the operational centre of that process.

This is why Level 1 access should not be treated as another HR system permission. The individual needs access to relevant information, enough sponsorship knowledge to recognise when action may be required and a clear escalation route where the position is uncertain.

 

5. Does every sponsor need a Level 1 User?

 

Yes. Licensed sponsors must maintain at least one qualifying Level 1 User throughout the life of the sponsor licence.

Failure to maintain the required Level 1 User arrangements can expose the licence to enforcement action, including revocation, subject to the specific exceptions and remedial processes that apply in particular circumstances.

Employers therefore need to look beyond the initial Level 1 User appointment made when the licence is obtained.

Problems can arise where:

 

• the only Level 1 User leaves the organisation;
• the individual is absent for an extended period;
• their SMS account becomes inactive;
• their responsibilities change internally;
• the Level 1 User no longer satisfies the applicable requirements;
• their contact details prevent them from completing authentication; or
• nobody else within the organisation understands how the sponsor licence is being administered.

 

Sponsors should review Level 1 User arrangements periodically rather than waiting until SMS access is urgently required.

For organisations sponsoring significant numbers of workers, dependence on a single individual can also create unnecessary business continuity risk.

The objective is to maintain sufficient Level 1 capability to operate the licence effectively while keeping SMS access appropriately controlled.

 

6. What happens if a sponsor has no active Level 1 User?

 

A sponsor without an active and eligible Level 1 User can face serious operational and compliance consequences.

The Home Office introduced a specific inactive-account process during 2026. An SMS user account can be treated as inactive where the user has not accessed the system for 12 months. Where this applies, the Home Office can contact the Authorising Officer and affected Level 1 User, giving the user a period in which to log in, check their details and update them where necessary.

If the process leaves the sponsor with no active Level 1 User, the Home Office can suspend the sponsor licence and give the organisation 28 days to nominate an eligible replacement. If the sponsor does not do so, the licence will normally be revoked.

The inactive-user regime makes Level 1 User continuity a live sponsor compliance issue. Employers should maintain active, eligible users and workable cover arrangements before access becomes critical.

 

 

 

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Section B: Who Can Be a Level 1 User?

Choosing who should act as a Level 1 User is an important sponsor licence governance decision. The individual may be given significant authority within the Sponsor Management System, including the ability to assign Certificates of Sponsorship, report changes to UKVI and manage certain other SMS users.

Sponsors therefore need to consider two separate questions:

 

1. Is the individual legally eligible to be appointed as a Level 1 User?
2. Is the individual operationally suitable to perform the role effectively?

 

These questions are related but not identical.

An individual may satisfy the Home Office eligibility requirements but still be a poor practical choice because they lack sufficient authority, access to information, sponsorship knowledge or availability. Equally, an experienced HR professional may be operationally strong but unable to hold the role if they do not satisfy the applicable Home Office requirements.

The sponsor should therefore assess both eligibility and practical suitability before granting Level 1 access.

 

1. What are the eligibility requirements for a Level 1 User?

 

Level 1 Users form part of the sponsor’s key personnel arrangements and must satisfy the applicable Home Office requirements concerning eligibility, suitability and connection with the sponsoring organisation.

As a general rule, a sponsor must maintain at least one qualifying Level 1 User who is appropriately connected with the organisation and satisfies the relevant settled-worker and UK-based requirements, subject to specified exceptions.

The normal requirements can include considerations such as:

 

• whether the individual is an employee, director or partner of the sponsoring organisation where required;
• whether they are based in the UK while carrying out the role, subject to limited exceptions;
• whether they are a settled worker where the rules require this;
• whether they have a valid National Insurance number unless an exception applies;
• whether their relationship with the sponsor satisfies the key personnel rules;
• whether they have any relevant immigration or sponsor compliance history;
• whether there are criminality or suitability concerns; and
• whether they fall within a category of person who cannot ordinarily act as key personnel.

 

Sponsors should check the current Home Office requirements before making an appointment because the precise rules differ depending on factors such as when the licence was granted and whether a specific exception applies.

 

2. What is the primary Level 1 User requirement?

 

For sponsors operating under the current framework, at least one Level 1 User must satisfy the Home Office requirements for the organisation’s primary internal Level 1 User.

In general, this means the sponsor should have at least one Level 1 User who is:

 

• an employee, director or partner of the sponsoring organisation; and
• a settled worker, unless a specified exception applies.

 

This internal Level 1 capability is important because the Home Office does not permit sponsors to rely solely on an external representative as their only Level 1 User.

The purpose is to ensure that the sponsor retains direct internal responsibility and operational control over its licence.

 

3. What are the transitional rules for sponsors licensed before 1 January 2025?

 

There are transitional arrangements for sponsors whose successful sponsor licence application was made before 1 January 2025 and who have held their licence continuously since then.

Under the transitional framework, the sponsor must maintain:

 

• at least one Level 1 User who is an employee, director or partner of the sponsoring organisation; and
• at least one Level 1 User who is a settled worker.

 

These requirements can be satisfied by the same person or, depending on the sponsor’s arrangements, by two different Level 1 Users.

This means an older sponsor licence structure may not look identical to the position for a sponsor first licensed under the newer framework.

Employers should therefore avoid assuming that historical key personnel arrangements remain compliant simply because they were acceptable when the licence was first granted. The current position should be checked against the rules that now apply to that sponsor.

 

4. Does a Level 1 User have to be an employee?

 

Not every Level 1 User necessarily has to be an employee of the sponsor.

However, the sponsor must still maintain the required internal Level 1 User arrangements described above.

Additional Level 1 Users can potentially include other eligible individuals, such as:

 

• a paid member of staff or office holder;
• an eligible person working for an organisation engaged to deliver all or part of the sponsor’s HR function; or
• a qualifying UK-based representative.

 

The precise eligibility rules should be checked before appointment.

Sponsors should not assume that any contractor, consultant or third party can simply be given Level 1 access. Home Office restrictions apply to key personnel, and individuals engaged solely for a specific contracted purpose may not satisfy the ordinary requirements.

The key question is not simply whether somebody works with the organisation, but whether their relationship with the sponsor fits within the categories permitted by the Home Office.

 

5. Can an immigration adviser or representative be a Level 1 User?

 

Yes, an eligible UK-based immigration adviser or representative can potentially be appointed as an additional Level 1 User after the sponsor licence has been granted.

However, an external representative cannot simply replace the sponsor’s internal Level 1 User requirement.

In particular, where the sponsor has only one Level 1 User, that person cannot ordinarily be a representative.

This distinction is important.

An external adviser may assist with:

 

• Certificate of Sponsorship administration;
• SMS reporting;
• changes to sponsor details;
• interpretation of sponsorship requirements;
• checking whether an event needs to be reported;
• supporting sponsor licence audits; and
• maintaining consistency in sponsorship administration.

 

However, appointing an external representative does not outsource the sponsor’s compliance responsibility.

The sponsor remains responsible for the licence and for ensuring that information provided to the Home Office is accurate.

There also needs to be an effective communication process between the employer and the representative.

An adviser cannot report a change they have not been told about.

For example, if a sponsored employee changes work location but the immigration adviser is never informed, the existence of an externally managed SMS arrangement does not solve the underlying compliance failure.

The internal information flow remains critical.

 

6. Can a representative be the only Level 1 User?

 

No. A sponsor should not rely solely on an external representative as its only Level 1 User.

The organisation must maintain the required internal Level 1 capability and ensure there is at least one appropriately eligible person connected with the sponsor itself.

This helps ensure that responsibility for sponsorship remains within the organisation rather than being transferred entirely to an external adviser.

Where an external representative is also appointed, the sponsor should define clearly which tasks are handled internally and which are delegated.

A useful model is:

HR identifies event → internal sponsor function verifies facts → immigration implications assessed → authorised Level 1 User or adviser completes SMS action → evidence retained

The allocation of tasks may vary, but the sponsor remains responsible throughout.

 

7. Can a director or partner be a Level 1 User?

 

Yes. A director, partner or other qualifying senior individual within the organisation can potentially act as a Level 1 User where they satisfy the applicable requirements.

For smaller businesses, this may be a sensible arrangement because the individual can have visibility across recruitment, staffing and organisational changes.

However, seniority alone does not make somebody an effective Level 1 User.

The person also needs to be capable of dealing with the operational requirements of sponsorship.

A managing director who rarely accesses the SMS, has little involvement with sponsored workers and relies entirely on others to identify reporting issues may provide weaker operational control than a properly trained HR professional with direct access to the relevant information.

The appointment should therefore reflect how the sponsor licence actually operates in practice.

 

8. Can the Authorising Officer also be the Level 1 User?

 

Yes, provided the individual satisfies the applicable requirements.

In many organisations, particularly smaller employers, the Authorising Officer may also hold Level 1 User access.

The two roles should nevertheless be understood separately.

The Authorising Officer has overall responsibility for the organisation’s sponsorship arrangements and for the conduct of SMS users. Level 1 User status provides the operational ability to perform functions through the SMS.

An Authorising Officer does not automatically have SMS access simply because they hold the Authorising Officer role.

Where the same individual performs both functions, employers should still maintain appropriate controls around significant SMS activity.

For example, the fact that the Authorising Officer can personally assign Certificates of Sponsorship does not remove the need for the organisation to verify that the proposed sponsorship is appropriate before the CoS is assigned.

 

9. Can the Key Contact also be a Level 1 User?

 

Yes. The same individual can potentially act as both Key Contact and Level 1 User where the relevant requirements are met.

The functions remain different.

The Key Contact acts as the principal contact between the sponsor and UKVI, while the Level 1 User has operational access to the Sponsor Management System.

Appointment as Key Contact does not itself provide Level 1 User permissions.

Combining the roles may be practical for smaller organisations. Larger sponsors may prefer to separate them across different members of the immigration, HR or compliance team.

The correct structure will depend on the organisation rather than on a single model that applies to every sponsor.

 

10. Are Level 1 Users required to be based in the UK?

 

As a general rule, key personnel, including Level 1 Users, are expected to be based in the UK while performing their role.

There are, however, limited exceptions.

One of the most important is under the UK Expansion Worker route, where special provisions can allow an overseas-based Authorising Officer to perform Level 1 User functions in circumstances permitted by the sponsor guidance.

Employers should therefore avoid treating the UK-based requirement as absolute without checking whether a route-specific exception applies.

For most sponsors, however, Level 1 User arrangements should be built around individuals who are based in the UK and able to perform the role effectively from within the organisation’s sponsorship structure.

 

11. UK Expansion Worker exception

 

The UK Expansion Worker route is subject to specific provisions that can depart from the ordinary Level 1 User framework.

Where an overseas business is establishing a UK presence and the relevant sponsor guidance permits it, an overseas-based Authorising Officer can initially act as the Level 1 User.

In certain circumstances, that individual may also be permitted to assign their own Certificate of Sponsorship in order to obtain permission to come to the UK.

This is an important exception to the ordinary rules concerning Level 1 User location and self-assignment of a CoS.

Because the exception is route-specific, sponsors should not apply it outside the circumstances permitted under the UK Expansion Worker provisions.

Detailed UK Expansion Worker requirements should be considered separately rather than using this Level 1 User article as a substitute for route-specific sponsor guidance.

 

12. Who should an employer choose as its Level 1 User?

 

The strongest Level 1 User is generally somebody who combines appropriate authority with access to the information needed to operate the licence correctly.

The individual should ideally:

 

• understand the organisation’s sponsor duties;
• understand how the Sponsor Management System is used;
• have access to relevant HR and recruitment information;
• know which workers are sponsored;
• understand the organisation sufficiently to recognise significant corporate or operational changes;
• be able to identify events that may require immigration action;
• have sufficient authority to obtain information from colleagues;
• understand when an issue needs to be escalated;
• be sufficiently detail-oriented to complete SMS actions accurately;
• understand the security obligations attached to SMS access; and
• be available to deal with time-sensitive sponsorship matters.

 

Knowledge of the business is particularly important.

Many sponsor reporting failures begin outside the immigration function. A line manager changes somebody’s duties. Payroll alters a salary. A worker moves office. A sponsored employee stops attending work. The corporate structure changes. A new work location opens.

The immigration significance may not be obvious to the person making the original decision.

An effective Level 1 User therefore needs to be connected to the organisation’s wider HR and management processes so that relevant information reaches the sponsorship function.

 

13. Should the Level 1 User work in HR?

 

There is no universal requirement for the Level 1 User to be an HR professional.

However, HR personnel frequently perform the role because many of the events that affect sponsored workers are already managed through HR processes.

Examples include:

 

• recruitment;
• onboarding;
• changes to job roles;
• salary changes;
• absences;
• changes in working arrangements;
• changes of work location;
• termination of employment; and
• record keeping.

 

This can make HR a natural location for operational sponsor licence management.

But the employer should avoid assuming that ordinary HR knowledge automatically amounts to sponsor compliance expertise.

A Level 1 User needs to understand the immigration consequences of relevant employment events and when specialist advice may be required.

 

14. What makes a good Level 1 User?

 

A good Level 1 User does more than know how to navigate the SMS.

They understand why an SMS action is being taken.

That distinction is important.

An individual who has learned which buttons to press may be able to complete a report, but they may not recognise that a particular event needs reporting in the first place.

Effective Level 1 Users therefore combine:

sponsorship knowledge + organisational knowledge + access to information + SMS competence + appropriate authority + security awareness

They should also understand the limits of their own role.

Complex questions concerning changes to employment, salary, occupation codes, corporate restructuring, sponsor eligibility or a worker’s immigration status may require further assessment before anything is entered into the SMS.

The Level 1 User should be able to recognise when to stop, verify the position and escalate the issue rather than making assumptions.

 

 

 

 

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Section C: What Can a Level 1 User Do on the Sponsor Management System?

The Level 1 User has broad operational permissions within the Sponsor Management System. These permissions allow the individual to carry out many of the actions required to manage workers and maintain the sponsor licence.

Having technical permission to perform an action through the SMS does not, however, mean that the action should automatically be taken.

Every significant SMS action should sit within the sponsor’s wider compliance framework.

For example, the ability to assign a Certificate of Sponsorship does not determine whether the proposed worker and role satisfy the relevant immigration requirements. Similarly, the ability to report a change does not determine whether the change itself is permissible under the worker’s immigration route.

The Level 1 User therefore needs to distinguish between:

SMS permission → what the system allows the user to do

Immigration compliance → whether the proposed action is legally and procedurally appropriate

This distinction is fundamental to effective sponsor licence management.

 

1. What permissions does a Level 1 User have?

 

Level 1 Users can perform a wide range of sponsor management functions through the SMS.

Depending on the sponsor’s circumstances, these can include:

 

• assigning Certificates of Sponsorship;
• requesting increases to annual CoS allocations;
• applying for Defined Certificates of Sponsorship;
• reporting changes concerning sponsored workers;
• reporting certain changes concerning the sponsoring organisation;
• withdrawing Certificates of Sponsorship;
• viewing sponsor licence information;
• viewing information relating to key personnel;
• accessing Home Office messages;
• requesting additional Level 1 Users;
• managing certain existing SMS users; and
• performing other sponsor management functions available to their user account.

 

These are significant permissions.

Employers should therefore ensure Level 1 access is given only to individuals who genuinely need it and who understand both the system and the compliance consequences of the actions they perform.

 

2. Can a Level 1 User assign a Certificate of Sponsorship?

 

Yes. Assigning Certificates of Sponsorship is one of the principal functions available to a Level 1 User.

However, the CoS should only be assigned once the sponsor has established that the proposed sponsorship is appropriate and that the information being entered is accurate.

Depending on the immigration route and circumstances, checks may need to cover matters such as:

 

• the identity of the proposed worker;
• the relevant immigration route;
• the proposed job;
• whether the role is genuine;
• the correct occupation code;
• the worker’s duties;
• salary;
• working hours;
• work location;
• proposed employment dates;
• the type of Certificate of Sponsorship required;
• applicable skill and salary requirements;
• any route-specific eligibility requirements; and
• whether the organisation has obtained the necessary internal approval to sponsor the worker.

 

The Level 1 User should not treat CoS assignment as a data-entry exercise.

A stronger internal process is:

Recruitment decision → immigration eligibility assessment → sponsorship approval → CoS information verified → Level 1 User assigns CoS → assignment checked and recorded

This helps prevent inaccurate Certificates of Sponsorship being created because information has been copied directly from a recruitment request without appropriate immigration checks.

 

3. Can a Level 1 User assign a Certificate of Sponsorship to themselves?

 

Sponsors need to exercise particular care where an SMS User is also the person who is to be sponsored.

Home Office rules restrict self-assignment of Certificates of Sponsorship in the ordinary sponsorship framework and also contain provisions concerning assignment where specified personal relationships exist between the SMS User and the person being sponsored.

The Level 1 User should therefore not assume that a CoS can be assigned merely because the SMS technically allows the transaction to be attempted.

The applicable route and current Home Office requirements should be checked before assignment.

There are also specific route-based exceptions.

Under the UK Expansion Worker provisions, for example, circumstances can arise in which an overseas-based Authorising Officer acting as the relevant Level 1 User is permitted to assign their own Certificate of Sponsorship in order to obtain permission to come to the UK.

This is a specific exception and should not be treated as a general self-assignment rule.

Where the Level 1 User, their partner, a close relative or another person connected with the SMS User is the proposed sponsored worker, the current Home Office rules should be checked before the CoS is assigned.

 

4. Can a Level 1 User request additional Certificates of Sponsorship?

 

Yes. Level 1 Users can carry out functions relating to the sponsor’s Certificate of Sponsorship allocation, including requesting an increase where appropriate.

Employers should not treat an allocation request as simply ordering additional certificates for future use.

The request should be based on a genuine anticipated sponsorship requirement and supported by appropriate information where required.

Before making an allocation request, the sponsor should understand:

 

• how many Certificates of Sponsorship are currently available;
• how many sponsored workers are expected to be recruited;
• which routes will be used;
• why the additional allocation is required;
• whether recruitment plans are sufficiently developed; and
• what supporting information may be required by the Home Office.

 

The Level 1 User may perform the SMS transaction, but the underlying business case should come from the organisation’s genuine recruitment requirements.

 

5. Can a Level 1 User apply for a Defined Certificate of Sponsorship?

 

Yes. Where a Defined Certificate of Sponsorship is required, an authorised Level 1 User can submit the relevant request through the SMS.

The information provided should be checked carefully before submission.

Depending on the circumstances, this can include information concerning:

 

• the proposed occupation;
• job title;
• job description;
• occupation code;
• salary;
• working hours;
• work location; and
• other information relevant to the proposed sponsorship.

 

The Defined CoS request should reflect the role the organisation genuinely intends the worker to perform.

If the role changes materially between the request and the intended assignment, the sponsor should establish the correct immigration and sponsorship position before proceeding.

 

6. Can a Level 1 User report changes concerning sponsored workers?

 

Yes. Reporting relevant changes affecting sponsored workers is an important Level 1 User function.

Potentially reportable events can include changes relating to matters such as:

 

• employment;
• job role;
• salary;
• work location;
• working arrangements;
• absence;
• delayed start;
• cessation of employment; and
• other circumstances covered by the sponsor reporting rules.

 

Not every employment change is treated in the same way under the sponsorship system.

Some events require an SMS report. Some may require further immigration action. Others may be permissible without a new application but still need to be recorded or assessed.

The Level 1 User therefore needs sufficient information to determine what has actually happened before completing an SMS report.

Detailed rules concerning which events must be reported and the applicable deadlines belong within the separate Sponsor Reporting Duties guidance. The important point for Level 1 User governance is that information about potentially relevant changes reaches the sponsorship function quickly enough for the correct action to be identified and completed.

 

7. Can a Level 1 User report changes to the sponsoring organisation?

 

Yes. Level 1 Users can use the SMS to report certain changes relating to the sponsoring organisation.

These can include changes to information held by the Home Office about the sponsor and its operations.

However, employers should distinguish between an ordinary change of sponsor information and a more significant corporate event.

Events such as:

 

• mergers;
• acquisitions;
• changes in ownership;
• TUPE transfers;
• corporate restructuring;
• insolvency;
• business sales;
• changes to branches or linked entities; and
• other structural changes

 

can have consequences that go beyond updating information through the SMS.

Depending on the circumstances, the organisation may need to consider whether the existing sponsor licence remains appropriate, whether a new licence is required, how sponsored workers are affected and what notifications need to be made.

The Level 1 User should therefore avoid assuming that every organisational change can be resolved simply by selecting an option within the SMS.

Significant corporate events should be escalated for immigration assessment before the relevant restructuring is implemented wherever possible.

 

8. Can a Level 1 User withdraw a Certificate of Sponsorship?

 

Yes. Level 1 Users can withdraw a Certificate of Sponsorship through the SMS where withdrawal is appropriate.

This is a distinct function from reporting that sponsorship or employment has ended.

Before withdrawing a CoS, the Level 1 User should establish:

 

• which Certificate of Sponsorship is affected;
• why withdrawal is being considered;
• whether the worker has already used the CoS in an immigration application;
• whether another SMS action is more appropriate;
• whether the worker’s immigration position may be affected; and
• whether specialist advice is required before action is taken.

 

Because withdrawal can have significant consequences, it should not be used simply as a method of correcting an error without first checking the appropriate procedure.

 

9. Can a Level 1 User manage other SMS users?

 

Level 1 Users have functions relating to the management of other SMS users, but the precise permissions need to be understood correctly.

A Level 1 User can, where permitted, request the appointment of another Level 1 User. The request is subject to the applicable Home Office process and eligibility requirements. It should not be treated as though the existing user can simply create another unrestricted Level 1 account without further control.

Level 1 Users can also perform certain functions relating to existing SMS users, including deactivating users where permitted.

There are limits to these permissions. For example, a Level 1 User cannot simply deactivate their own account through the same user-management process.

Similarly, sponsors should distinguish between a user being able to update their own permitted account details and having unrestricted authority to alter another Level 1 User’s personal account information.

The practical governance principle is straightforward:

SMS user access should be actively managed, individually attributable and restricted to people who continue to require it.

 

10. What happens to Level 2 Users?

 

The Home Office is withdrawing the Level 2 User role.

From 9 September 2026, sponsors have not been able to appoint new Level 2 Users.

Existing Level 2 Users are subject to transitional arrangements. Sponsors should review these accounts and decide whether the individual:

 

• still requires SMS access;
• is eligible to become a Level 1 User;
• should be upgraded to Level 1 User status where appropriate; or
• should have their existing access deactivated.

 

The transition is due to conclude after 8 March 2027, when the Level 2 User role will cease.

Sponsors should not automatically convert every historic Level 2 User into a Level 1 User.

Level 1 permissions are broader, and the Home Office recommends keeping the number of Level 1 Users to the minimum necessary while maintaining sufficient users to manage the licence effectively and provide appropriate cover.

The withdrawal of Level 2 access therefore provides an opportunity to review the organisation’s entire SMS access structure.

 

11. Can a Level 1 User access Home Office messages?

 

Yes. Level 1 Users can access messages and communications made available through the Sponsor Management System.

Monitoring these communications should form part of routine sponsor licence management.

Organisations should decide who is responsible for checking messages and what happens when something requiring action is received.

A message should not simply be read and left within the system.

A stronger process is:

Home Office message received → responsibility allocated → implications assessed → required action completed → evidence retained → Authorising Officer informed where appropriate

This becomes particularly important where several Level 1 Users have access to the SMS. Without a defined owner, each user may assume another person is dealing with the communication.

 

12. Does SMS permission mean the Level 1 User has authority to make the decision?

 

No.

This distinction is particularly important for employers with several Level 1 Users.

The SMS may technically allow an individual to perform a particular function, but the organisation can still require internal approval before that action is taken.

For example, a Level 1 User may technically be able to:

 

• assign a Certificate of Sponsorship;
• submit a CoS allocation request;
• report a significant worker change;
• request another Level 1 User; or
• make changes to sponsor information.

 

That does not necessarily mean the organisation wants every Level 1 User to make those decisions independently.

Employers can establish internal approval controls according to the significance of the action.

For example:

Routine worker report → designated Level 1 User

New Certificate of Sponsorship → immigration eligibility check + recruitment/HR approval + Level 1 assignment

Significant salary or role change → immigration assessment + HR approval + Level 1 SMS action

Corporate restructuring → senior management/legal/immigration assessment + authorised SMS action

This separates system access from decision-making authority.

 

13. Why should employers control Level 1 User permissions carefully?

 

The actions carried out through the SMS can affect individual workers and the sponsor licence itself.

Incorrect information can be submitted to the Home Office. Certificates of Sponsorship can be assigned inaccurately. Reports can be made incorrectly. Important communications can be overlooked. User accounts can remain active after they are no longer required.

The Authorising Officer also has responsibility for the conduct of SMS users.

Employers should therefore avoid giving Level 1 access simply because an employee works in HR or may occasionally need sponsorship information.

Instead, the sponsor should ask:

 

• Does this person genuinely need Level 1 access?
• Are they eligible?
• What functions will they perform?
• What training have they received?
• What actions can they take without further approval?
• What actions must be escalated?
• Who reviews their activity?
• Who provides cover when they are unavailable?
• How will their access be removed when no longer required?

 

The objective is not to minimise Level 1 Users at the expense of operational resilience. It is to maintain enough authorised users to manage the licence effectively, but no more than are reasonably necessary.

 

 

 

 

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Section D: Level 1 User Responsibilities

The Level 1 User’s responsibilities extend beyond knowing how to operate the Sponsor Management System. Effective performance of the role depends on the individual receiving accurate information, understanding its potential sponsorship significance and taking the correct action within the required timeframe.

The sponsor organisation remains responsible for compliance with its sponsor duties, while the Authorising Officer has responsibility for appropriate oversight of SMS users. The Level 1 User provides much of the operational capability through which those responsibilities are implemented.

This means Level 1 User responsibilities should form part of a wider organisational process rather than being treated as an isolated administrative function.

 

1. Keeping sponsor licence information accurate

 

Level 1 Users should help ensure that information maintained through the SMS remains accurate and that relevant changes are dealt with appropriately.

This requires more than periodically checking information displayed on the system.

The Level 1 User needs access to reliable information from across the organisation.

Depending on the employer, relevant information may originate from:

 

• HR;
• recruitment;
• payroll;
• finance;
• line managers;
• senior management;
• legal or compliance teams;
• global mobility;
• individual sponsored workers; and
• external immigration advisers.

 

The organisation should establish how information from these sources reaches the sponsorship function.

A Level 1 User cannot maintain accurate SMS information if significant changes take place elsewhere in the organisation without being communicated to them.

 

2. Making reports within the applicable deadlines

 

Where an event has to be reported through the SMS, the Level 1 User should ensure the required action is completed within the applicable Home Office timeframe.

The precise reporting deadline depends on the type of event and the relevant sponsor duty.

Employers should avoid designing internal processes around the assumption that information can be passed to the Level 1 User on the final day of the Home Office reporting period.

A stronger internal control is to require potentially reportable events to be notified to the sponsorship function as soon as they are identified.

This creates time to:

 

• establish what has happened;
• verify the relevant facts;
• determine whether a report is required;
• consider whether further immigration action is necessary;
• obtain any required internal approval;
• complete the SMS action; and
• retain evidence of what was done.

 

Internal reporting deadlines should therefore generally be shorter than the maximum period allowed by the Home Office.

 

3. Ensuring Certificates of Sponsorship are accurate

 

Certificate of Sponsorship accuracy is a significant Level 1 User responsibility.

Before assignment, the information entered into the SMS should correspond with the role and sponsorship arrangements that have actually been approved.

Depending on the circumstances, this may require verification of:

 

• the worker’s identity;
• the relevant immigration route;
• job title;
• occupation code;
• job description and duties;
• salary;
• working hours;
• work location;
• employment dates;
• the type of CoS being assigned;
• any relevant route-specific requirements; and
• other information included on the CoS.

 

The Level 1 User should not simply copy information from a recruitment request without checking that the information has been appropriately verified.

Where information appears inconsistent, incomplete or unusual, assignment should be paused until the position has been established.

Accuracy at this stage is preferable to attempting to correct a Certificate of Sponsorship after an error has been made.

 

4. Acting on changes affecting sponsored workers

 

Level 1 Users need to receive information about changes affecting sponsored workers and determine what sponsorship action is required.

Potentially relevant events can include:

 

• changes to job role or duties;
• salary changes;
• changes to working hours;
• changes of work location;
• remote or hybrid working arrangements where relevant;
• promotion;
• absence;
• delayed employment start;
• resignation;
• dismissal;
• redundancy;
• termination of sponsorship; and
• other changes affecting the basis on which the worker is sponsored.

 

Where possible, material employment changes affecting sponsored workers should be assessed for their immigration implications before they are implemented.

This is particularly important where the proposed change could affect the worker’s continued eligibility under their existing immigration permission.

The organisation should avoid a process where HR implements the change first and only later asks the Level 1 User whether anything needs to be reported.

A stronger process is:

Proposed employment change → identify sponsored-worker status → immigration assessment → approval or adjustment → implementation → required SMS action

 

5. Maintaining appropriate SMS user access

 

Level 1 Users with relevant permissions can play an important role in maintaining appropriate SMS access arrangements.

The sponsor should know:

 

• who currently has SMS access;
• what user status each individual holds;
• why each individual needs access;
• whether they remain eligible;
• whether their contact details are current;
• whether their account remains active;
• whether they can complete multi-factor authentication;
• whether their responsibilities have changed; and
• whether access should be removed.

 

Former employees and individuals who no longer require access should not remain as unmanaged SMS users.

The withdrawal of the Level 2 User role also means sponsors should review existing Level 2 accounts and decide deliberately whether an individual genuinely needs to become a Level 1 User or whether their SMS access should end.

 

6. Monitoring Home Office messages

 

Level 1 Users should ensure Home Office messages made available through the SMS are monitored and acted on where necessary.

Where several Level 1 Users exist, responsibility for checking messages should be allocated rather than assumed.

The organisation should have a process for:

checking → identifying significance → allocating responsibility → taking action → recording completion

Messages requiring senior attention should be escalated to the Authorising Officer or other appropriate personnel.

The sponsor should not rely on the assumption that an important Home Office communication will necessarily be sent separately to somebody outside the SMS.

 

7. Escalating sponsor compliance issues

 

A Level 1 User should know when an issue requires further assessment rather than simply attempting to resolve everything through the SMS.

Potential escalation issues can include:

 

• a significant change to a sponsored worker’s role;
• a material salary reduction or restructuring of pay;
• a change in working arrangements that may affect sponsorship;
• significant or unexplained absence;
• concerns about a worker’s right to work;
• possible illegal working;
• an inaccurate Certificate of Sponsorship;
• a missed reporting deadline;
• an incorrect previous SMS report;
• a merger or acquisition;
• a change in ownership;
• TUPE or corporate restructuring;
• suspected non-compliance;
• Home Office enquiries;
• notification of a compliance visit; or
• other circumstances that may affect the sponsor licence.

 

The Level 1 User does not need to make every legal or strategic decision personally.

An important part of competent licence management is recognising when specialist advice, senior approval or Authorising Officer involvement is required.

 

8. Maintaining an audit trail

 

Sponsors should be able to demonstrate how significant sponsorship decisions and SMS actions were managed.

A useful audit trail may show:

 

• what event occurred;
• when the organisation became aware of it;
• who provided the information;
• what information was checked;
• what sponsorship assessment was made;
• who approved the action;
• what SMS action was taken;
• when the action was completed;
• what supporting evidence was retained; and
• whether any follow-up action was required.

 

This can be particularly important where a sponsor later needs to explain why a particular Certificate of Sponsorship was assigned or how a reportable event was handled.

The audit trail should demonstrate a functioning compliance process rather than merely preserve a screenshot of the final SMS transaction.

 

9. What is the Level 1 User governance chain?

 

A well-managed sponsorship system should connect business activity with immigration compliance.

A useful governance model is:

Business or HR event

↓

Potential sponsorship consequence identified

↓

Relevant facts verified

↓

Immigration implications assessed

↓

Required action authorised

↓

Level 1 User completes SMS action

↓

Evidence retained

↓

Authorising Officer or compliance oversight where appropriate

This model helps prevent two common weaknesses.

The first is where the Level 1 User receives information but does not understand its significance.

The second is where relevant information never reaches the Level 1 User at all.

Both can result in sponsor compliance failures even where the organisation technically has appropriately appointed key personnel.

 

10. Is the Level 1 User personally responsible for sponsor compliance?

 

The sponsor organisation remains responsible for complying with its sponsor duties.

The Level 1 User has important operational responsibilities, but appointing somebody to the role does not transfer the organisation’s sponsor obligations to that individual.

The Authorising Officer also has responsibility for appropriate oversight and for the conduct of SMS users.

Where a compliance failure occurs, the employer should therefore consider both the individual action and the organisational system surrounding it.

For example, a Level 1 User may miss a report because they made an individual error.

Alternatively, the report may have been missed because:

 

• HR never notified the sponsorship function;
• responsibility was unclear;
• the Level 1 User had not been trained;
• the individual was absent and no cover existed;
• the organisation had no reporting procedure;
• the relevant manager did not understand sponsorship obligations; or
• the Level 1 User was expected to manage an unreasonable volume of sponsorship activity without adequate support.

 

Effective remediation should address the root cause rather than simply attributing the failure to the individual who held the SMS account.

A useful principle is:

The Level 1 User operates the compliance process; they should not become the organisation’s entire compliance process.

 

11. What should the Authorising Officer know about Level 1 User activity?

 

The Authorising Officer should maintain sufficient oversight to understand how the sponsor licence is being operated and whether SMS users are performing their functions appropriately.

The level of detail required will depend on the size and complexity of the organisation, but oversight may include visibility of:

 

• who holds Level 1 User access;
• significant Certificates of Sponsorship assigned;
• CoS allocation requirements;
• material sponsored worker changes;
• significant organisational changes;
• missed or potentially late reports;
• identified SMS errors;
• Home Office correspondence;
• compliance concerns;
• user access and security issues;
• training requirements; and
• results of internal sponsor licence audits.

 

The Authorising Officer does not necessarily need to perform every SMS transaction personally.

The objective is meaningful oversight rather than duplication of the Level 1 User’s administrative work.

 

 

 

 

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Section E: Level 1 User Access, Security and Multi-Factor Authentication

Access to the Sponsor Management System gives Level 1 Users significant authority to act on behalf of the sponsoring organisation. Employers therefore need to treat SMS access as a controlled compliance permission rather than an ordinary administrative login.

Each Level 1 User should have their own authorised account, use their own credentials and comply with the Home Office security requirements that apply to SMS access.

This has become particularly important following the Home Office’s phased introduction of mandatory multi-factor authentication (MFA) during 2026 and the introduction of measures dealing with inactive SMS user accounts.

These changes reinforce an important principle of sponsor licence management:

SMS access should be individual, secure, current, necessary and capable of being attributed to the person who performed the action.

 

1. How does a Level 1 User access the Sponsor Management System?

 

A Level 1 User accesses the Sponsor Management System using their individual SMS user account.

The account is associated with the authorised user rather than being a general organisational account that can be passed between members of staff.

This individual accountability is important because Level 1 Users can perform significant actions through the system, including assigning Certificates of Sponsorship, reporting worker changes and updating sponsor information.

The sponsor should therefore know:

 

• who has SMS access;
• why they have access;
• what functions they perform;
• whether their account details remain accurate;
• whether they remain eligible to hold the role; and
• whether they still require access.

 

SMS access should not become a historic permission that remains indefinitely simply because somebody was once involved in sponsorship administration.

 

2. Can Level 1 Users share SMS login details?

 

No. SMS login credentials are individual and should not be shared.

A Level 1 User should not provide their password or multi-factor authentication passcode to another person.

Employers should therefore avoid practices such as:

 

• using a generic HR SMS account;
• allowing several employees to use one Level 1 User login;
• keeping SMS credentials in a shared password document;
• passing authentication codes between colleagues;
• allowing somebody to operate the SMS while logged in as another user; or
• continuing to use the credentials of somebody who has left the organisation.

 

Sharing SMS passwords or MFA passcodes can amount to a serious breach of the sponsor management requirements and can expose the sponsor licence to compliance action, including potential revocation.

If another employee needs to carry out SMS functions, the correct solution is to consider whether that individual should be appointed as an appropriate SMS User rather than allowing them to use somebody else’s account.

 

3. What is multi-factor authentication for SMS Users?

 

Multi-factor authentication adds an additional security step to the SMS login process.

Instead of relying solely on an SMS user ID and password, the authorised user also has to complete an additional authentication step using the contact information associated with their account.

The Home Office began the phased introduction of mandatory MFA for SMS Users on 3 September 2026, with implementation across sponsors being rolled out during the following months.

Mandatory MFA applies to organisations granted a sponsor licence on or after 9 September 2026, while existing sponsors are being brought within the new arrangements through the phased rollout.

Sponsors should therefore ensure that their SMS user records contain accurate individual contact details and that Level 1 Users are able to complete the required authentication process.

 

4. How does SMS multi-factor authentication work?

 

The precise authentication process depends on the information held for the Level 1 User and the stage of the MFA process.

Where the Level 1 User has a valid mobile telephone number recorded, authentication can involve a one-time passcode being sent by text message.

Where the relevant mobile information is not available, authentication can involve the code being sent to the email address associated with the user account.

Additional identity information, including date of birth in specified circumstances, can also form part of the authentication and account-management process.

One-time authentication codes are time-limited and should be treated as confidential security information.

They should not be forwarded or shared with colleagues, external advisers or other individuals.

 

5. Why does MFA matter for sponsor licence management?

 

MFA makes the individual nature of SMS access more significant.

Historically, an organisation with weak internal controls might have treated one person’s SMS credentials as though they were effectively shared departmental access.

The MFA framework reinforces that this is not an appropriate operating model.

Each authorised user should have:

 

• their own SMS account;
• their own credentials;
• accurate personal contact details;
• access to the relevant authentication method; and
• responsibility for activity performed through their account.

 

This also creates a business continuity issue.

If the organisation relies on one Level 1 User and that individual is unexpectedly unavailable, another employee should not simply use their credentials and authentication information.

The sponsor needs an authorised access structure capable of continuing to operate without compromising SMS security.

 

6. Can another employee use the Level 1 User’s account if they are absent?

 

No. Another employee should not use the Level 1 User’s account simply because the authorised user is on holiday, absent through illness or otherwise unavailable.

The fact that an SMS action is urgent does not make credential sharing appropriate.

If the organisation needs more than one person to be able to carry out Level 1 functions, it should consider appointing additional eligible Level 1 Users in advance.

This is why continuity planning should form part of the sponsor’s SMS governance.

The organisation should ask:

 

• Who can operate the licence if the principal Level 1 User is unavailable?
• Does that person have their own authorised access?
• Are they appropriately trained?
• Can they complete MFA?
• Do they know where sponsorship records are maintained?
• Do they understand outstanding CoS and reporting activity?

 

Cover arrangements should exist before an absence occurs rather than being improvised after access becomes necessary.

 

7. How often should a Level 1 User access the SMS?

 

The Home Office recommends that a Level 1 User accesses the Sponsor Management System at least once a month.

This should be understood as a minimum routine management discipline rather than a substitute for dealing with events when they arise.

An organisation actively sponsoring workers may need to access the SMS much more frequently.

During routine access, the Level 1 User should consider reviewing:

 

• Home Office messages;
• sponsor licence information;
• key personnel details;
• current SMS users;
• outstanding Certificate of Sponsorship matters;
• CoS allocation where relevant;
• recent worker changes;
• organisational changes;
• pending sponsorship requirements; and
• any unresolved compliance matters.

 

The monthly recommendation should not be confused with a reporting deadline.

If a reportable event occurs, the required action should be completed within the applicable timeframe rather than waiting until the next scheduled monthly login.

 

8. What is an inactive SMS user account?

 

The Home Office has introduced controls designed to address SMS accounts that are no longer being actively used.

An SMS user account can be considered inactive where the user has not accessed the system for 12 months.

This is significant for sponsors that retain Level 1 Users who were appointed historically but rarely or never access the SMS.

Where the inactive-user process applies, the Home Office can contact the Authorising Officer and the affected Level 1 User.

The Level 1 User is then given a period of three months from the relevant Home Office contact to log into the SMS, check their details and update them where necessary.

Sponsors should not wait for the Home Office to identify inactive accounts.

User activity should be reviewed internally as part of routine sponsor licence governance.

 

9. Can an inactive Level 1 User account put the sponsor licence at risk?

 

Yes.

The risk becomes particularly serious where the inactive-user process leaves the organisation without an active qualifying Level 1 User.

Where this occurs, the Home Office can suspend the sponsor licence and give the organisation 28 days to nominate an eligible Level 1 User.

If the sponsor fails to nominate an eligible Level 1 User within the required period, the licence will normally be revoked.

The compliance sequence can therefore become:

12 months without SMS access → account treated as inactive → Home Office contact → three-month opportunity to reactivate/update → no active qualifying Level 1 User → sponsor licence suspension → 28 days to nominate an eligible Level 1 User → normally revocation if not resolved

This makes inactive-user management considerably more than an IT housekeeping issue.

It is a sponsor licence continuity issue.

 

10. What if the sponsor has only one Level 1 User?

 

Operating with a single Level 1 User can create significant dependency on one individual.

It is possible for some sponsors to operate effectively with one Level 1 User, particularly where sponsorship activity is limited, but the organisation should understand the resulting continuity risk.

Problems can arise if the individual:

 

• leaves unexpectedly;
• becomes seriously ill;
• takes extended leave;
• loses access to their authentication method;
• becomes ineligible;
• fails to access the SMS for an extended period; or
• is otherwise unable to perform the role.

 

The sponsor should also remember that where it has only one Level 1 User, that individual cannot ordinarily be an external representative.

The organisation must maintain the required internal Level 1 capability.

Where the sponsor loses effective Level 1 access, it should use the applicable Home Office process to restore appropriate access rather than attempting to operate through another person’s credentials.

 

11. What happens to existing Level 2 User accounts?

 

The security and access review should also include any remaining Level 2 User accounts.

From 9 September 2026, sponsors have not been able to appoint new Level 2 Users.

Existing Level 2 Users are subject to transitional arrangements and should be reviewed before the role is withdrawn after 8 March 2027.

For each Level 2 User, the sponsor should determine whether:

 

• the individual still needs direct SMS access;
• their current functions remain necessary;
• they satisfy the requirements to become a Level 1 User;
• their responsibilities justify broader Level 1 permissions;
• they have received suitable training; or
• their account should instead be deactivated.

 

Sponsors should not automatically upgrade every Level 2 User.

The transition should be used as an opportunity to rationalise SMS access and establish a deliberate Level 1 User structure.

 

12. Should sponsors minimise the number of Level 1 Users?

 

The objective is not to have the fewest possible Level 1 Users regardless of operational need.

The Home Office approach is that sponsors should avoid having more Level 1 Users than necessary while maintaining sufficient eligible users to manage the licence effectively and provide appropriate cover.

These considerations have to be balanced.

Too few Level 1 Users can create:

 

• single-person dependency;
• absence risk;
• delayed reporting;
• inability to assign CoS when required;
• poor business continuity; and
• excessive workload on one individual.

 

Too many Level 1 Users can create:

 

• unnecessary distribution of powerful SMS permissions;
• unclear accountability;
• inconsistent sponsorship decisions;
• greater security exposure;
• difficulty supervising activity; and
• accounts remaining active after they are no longer needed.

 

The appropriate approach is therefore:

enough Level 1 Users to provide effective management and resilience, but no more than are reasonably necessary.

 

13. Level 1 User security checklist

 

Sponsors should periodically check that their Level 1 User security arrangements remain effective.

The review should confirm:

 

• every Level 1 User has an individual SMS account;
• credentials are not shared;
• MFA passcodes are not shared;
• user contact details are accurate;
• users can complete the applicable MFA process;
• all current users still require access;
• all current users remain eligible;
• inactive accounts are identified;
• former users are dealt with appropriately;
• remaining Level 2 accounts are being reviewed;
• the organisation has sufficient Level 1 cover;
• users understand their security responsibilities; and
• the Authorising Officer has appropriate visibility of SMS user arrangements.

 

The review should form part of wider sponsor licence governance rather than being treated solely as an IT security exercise.

 

 

 

 

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Section F: How Many Level 1 Users Should a Sponsor Have?

There is no single number of Level 1 Users that will be appropriate for every sponsor.

The correct number depends on the organisation’s size, the number of sponsored workers, the volume and complexity of sponsorship activity, the way responsibilities are divided internally and the level of business continuity required.

The Home Office approach is that sponsors should not have more Level 1 Users than are necessary, while maintaining enough eligible users to manage the sponsor licence effectively and provide appropriate cover.

Employers therefore need to balance two competing risks:

Too few Level 1 Users → dependency, absence risk and operational failure

Too many Level 1 Users → unnecessary access, weaker control and unclear accountability

The objective should be a deliberate Level 1 User structure that provides sufficient operational resilience without distributing powerful SMS permissions more widely than necessary.

 

1. Can a sponsor have more than one Level 1 User?

 

Yes. A sponsor can have multiple Level 1 Users where the individuals satisfy the applicable requirements and there is an operational reason for them to have access.

Additional Level 1 Users can provide important resilience.

For example, where only one individual can operate the SMS, routine sponsorship activity can become dependent on that person being available.

This can create problems during:

 

• annual leave;
• sickness absence;
• parental leave;
• business travel;
• unexpected departure;
• periods of heavy recruitment;
• internal restructuring; or
• other circumstances where the principal user is unavailable.

 

Having appropriately trained additional Level 1 Users can reduce this dependency.

However, every additional user increases the number of people able to carry out significant actions through the SMS. The decision to add users should therefore be based on genuine operational need rather than convenience.

 

2. Should a sponsor appoint multiple Level 1 Users?

 

For many sponsors, appointing more than one Level 1 User will be a sensible business continuity measure.

This does not mean every sponsor needs a large group of users.

A small employer sponsoring one or two workers may have relatively limited SMS activity and may be able to operate effectively with a carefully managed structure involving one principal Level 1 User and appropriate contingency arrangements.

A large employer sponsoring hundreds of workers across multiple locations may require several Level 1 Users to manage recruitment, CoS assignment, reporting and licence administration effectively.

The decision should be based on the actual sponsorship workload and compliance risk.

 

3. What factors determine how many Level 1 Users are needed?

 

Employers should consider a range of factors when determining the appropriate number of Level 1 Users.

These include:

 

• the number of sponsored workers;
• the volume of international recruitment;
• the number of Certificates of Sponsorship assigned;
• the frequency of sponsored worker changes;
• the number of organisational locations;
• the complexity of the sponsor’s structure;
• the number of immigration routes used;
• the volume of reporting activity;
• the availability of existing Level 1 Users;
• the need for holiday and sickness cover;
• the organisation’s reliance on external immigration advisers;
• the degree of specialist sponsorship knowledge available internally;
• the organisation’s working hours and operational model; and
• the need to avoid excessive dependency on one individual.

 

A sponsor with relatively few workers can still require more than one Level 1 User where its circumstances create significant continuity risk.

Conversely, a large organisation should not automatically give SMS access to a large number of employees simply because several people work within HR.

 

4. What happens if the only Level 1 User is unavailable?

 

Where a sponsor relies on a single Level 1 User, the organisation needs to understand what would happen if that individual became unexpectedly unavailable.

The issue is particularly important because another employee cannot simply use the absent Level 1 User’s SMS credentials or MFA passcode.

The sponsor should consider:

 

• whether another eligible person could be appointed;
• how quickly additional access could be established;
• whether any reports are approaching their deadlines;
• whether Certificates of Sponsorship need to be assigned;
• whether Home Office communications require attention;
• whether pending organisational changes need to be reported; and
• whether the absence could leave the sponsor without an active qualifying Level 1 User.

 

A planned absence should be easier to manage because responsibilities can be transferred in advance.

Unexpected absence presents a greater risk, which is why sponsors should consider resilience before a problem occurs.

 

5. Should every member of the HR team be a Level 1 User?

 

Usually, no.

Working within HR does not automatically create a need for Level 1 SMS access.

Many HR employees may need to provide information to the sponsorship function without needing permission to perform actions through the SMS themselves.

For example:

Recruitment team → provides information about new hires

HR adviser → provides information about employment changes

Payroll → confirms salary information

Line manager → reports changes in duties, location or attendance

Level 1 User → assesses sponsorship action and operates SMS

This structure can provide effective information flow without giving every contributor direct access to the sponsor licence.

The question should therefore be:

Does this person need to perform Level 1 SMS functions?

rather than:

Does this person work in HR?

 

6. Do Level 1 Users have to be senior employees?

 

Not necessarily.

The Level 1 User needs to satisfy the applicable Home Office requirements and should have sufficient authority, knowledge and organisational access to perform the role effectively.

This does not mean every Level 1 User has to be a director or senior executive.

In many organisations, experienced HR, immigration or global mobility professionals may be better placed to carry out day-to-day SMS activity than members of the senior leadership team.

The key considerations are whether the individual:

 

• is eligible;
• understands sponsorship requirements;
• has access to relevant information;
• can obtain information from other teams;
• has sufficient authority to challenge incomplete or inaccurate requests;
• understands when escalation is required; and
• can perform SMS functions accurately and securely.

 

Seniority can help, but competence and organisational integration are more important than job title alone.

 

7. How can larger sponsors structure Level 1 User responsibilities?

 

Larger sponsors may benefit from a tiered sponsor licence governance model.

For example:

Authorising Officer

↓

Head of Immigration / Global Mobility / Senior HR

↓

Designated Level 1 Users

↓

HR / recruitment / payroll / line managers / business units

Under this model, the Authorising Officer retains overall responsibility and oversight while operational activity is handled by appropriately trained Level 1 Users.

Responsibilities can then be allocated according to function.

For example:

 

• one Level 1 User may primarily manage CoS assignment;
• another may manage sponsored worker reporting;
• another may provide absence and continuity cover;
• a senior Level 1 User may deal with complex or unusual cases; and
• an external immigration adviser may provide additional specialist support where appropriate.

 

The important point is that responsibilities should be documented and understood.

Where several Level 1 Users exist, employers should avoid creating a structure where everybody has access but nobody has clear ownership.

 

8. How does the removal of Level 2 Users affect the number of Level 1 Users?

 

The withdrawal of the Level 2 User role requires sponsors to reconsider their SMS access arrangements.

Historically, some organisations used Level 2 Users for restricted operational functions while reserving broader permissions for Level 1 Users.

With no new Level 2 Users permitted from 9 September 2026 and the role due to cease after 8 March 2027, sponsors need to decide how those functions will be handled in future.

This does not mean every Level 2 User should automatically become a Level 1 User.

For each individual, the employer should ask:

 

• What SMS functions do they currently perform?
• Are those functions still required?
• Could an existing Level 1 User perform them?
• Does the individual genuinely need direct SMS access?
• Are they eligible to become a Level 1 User?
• Are broader Level 1 permissions appropriate?
• Have they received sufficient training?
• Would removing their access create a continuity problem?

 

Some sponsors may need additional Level 1 Users as a result of the transition.

Others may find that historic Level 2 accounts are no longer necessary.

The correct outcome should follow from an access review rather than automatic conversion.

 

9. What does the “minimum necessary access” principle mean?

 

The minimum necessary access principle does not mean operating the sponsor licence with the smallest possible number of users.

It means avoiding unnecessary access while retaining sufficient operational capability.

A sponsor should therefore aim for:

enough Level 1 Users to manage sponsorship effectively and provide continuity, but no more than are reasonably necessary.

This approach helps balance:

 

• security;
• accountability;
• business continuity;
• workload;
• operational responsiveness; and
• Authorising Officer oversight.

 

It also makes it easier to train users properly and monitor the actions being taken through the SMS.

 

10. How often should the number of Level 1 Users be reviewed?

 

The organisation should review its Level 1 User structure periodically and whenever a significant change occurs.

A review may be appropriate where:

 

• a Level 1 User leaves;
• a Level 1 User changes role;
• the organisation increases international recruitment;
• the sponsored workforce grows significantly;
• new business locations open;
• the organisation restructures;
• responsibility for immigration moves between teams;
• an external adviser is appointed or removed;
• the organisation identifies reporting delays or other compliance weaknesses;
• a Level 1 User account becomes inactive;
• the sponsor experiences difficulty obtaining timely SMS access; or
• existing Level 2 Users need to be dealt with as part of the withdrawal of that role.

 

The review should consider both whether additional users are required and whether existing users should retain access.

 

11. Level 1 User capacity and resilience test

 

Sponsors can use the following questions to test whether their current Level 1 User arrangements remain appropriate:

 

• How many active Level 1 Users do we currently have?
• Does each user still need access?
• Does each user remain eligible?
• When did each user last access the SMS?
• Can each user complete MFA?
• Who handles routine worker reporting?
• Who assigns Certificates of Sponsorship?
• Who monitors Home Office messages?
• Who manages CoS allocation requirements?
• Who provides cover during absence?
• What happens if our principal Level 1 User leaves tomorrow?
• Could we continue to meet reporting deadlines?
• Would we still be able to assign an urgent CoS?
• Does the Authorising Officer know who currently has SMS access?
• Are responsibilities clearly divided between users?
• Do any historic users still have access unnecessarily?
• Have remaining Level 2 Users been reviewed?
• Are all Level 1 Users appropriately trained?

 

If the organisation cannot answer these questions confidently, its Level 1 User structure may need further review.

 

 

 

 

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Section G: Level 1 User Governance & Internal Controls

Effective Level 1 User management depends on the systems surrounding the individual as much as the individual themselves.

A Level 1 User may be experienced, properly trained and competent in using the Sponsor Management System, but they cannot act on information they do not receive. Equally, giving a Level 1 User access to large volumes of HR information does not ensure compliance if there is no process for identifying which events have sponsorship consequences.

Employers should therefore build internal controls that connect ordinary business and HR activity with sponsor licence management.

The central governance question is:

How does an event occurring somewhere within the organisation reach the appropriate sponsorship decision-maker and result in the correct SMS action?

This requires defined information flows, responsibilities, approval processes, evidence and oversight.

 

1. What information should HR provide to the Level 1 User?

 

HR is frequently one of the principal sources of information for Level 1 Users because many sponsorship-relevant events arise through the employment relationship.

The Level 1 User or sponsorship function may need to be informed about matters including:

 

• proposed international recruitment;
• new sponsored workers;
• changes to job title;
• changes to job duties;
• changes to occupation;
• promotions;
• salary increases or reductions;
• changes to working hours;
• changes of work location;
• remote or hybrid working arrangements where relevant;
• delayed employment start dates;
• significant or unexplained absence;
• extended unpaid leave;
• resignation;
• dismissal;
• redundancy;
• changes affecting immigration status;
• cessation of sponsorship; and
• other changes affecting the basis on which the individual is sponsored.

 

The objective is not necessarily for every HR employee to understand the detailed sponsor reporting rules.

Instead, HR personnel should understand which types of event need to be escalated to the sponsorship function for assessment.

This creates a practical division of responsibility:

HR identifies and communicates the employment event → sponsorship function determines the immigration consequence

 

2. How should information flow to the Level 1 User?

 

The information flow should be deliberate rather than dependent on informal conversations.

A useful process is:

Proposed employment or business change

↓

HR or relevant business function identifies that a sponsored worker or sponsor licence may be affected

↓

Level 1 User or immigration function is notified

↓

Relevant facts are verified

↓

Immigration and sponsorship implications are assessed

↓

Change is approved, adjusted or escalated

↓

Required SMS action is completed

↓

Evidence is retained

This is stronger than a process in which the Level 1 User only discovers changes when periodically checking HR records.

Where possible, the sponsorship assessment should occur before a material employment change is implemented.

 

3. Should the Level 1 User approve employment changes?

 

Not necessarily.

The Level 1 User does not have to become the organisation’s HR decision-maker simply because a proposed employment change has sponsorship implications.

Different functions may retain different responsibilities.

For example:

Business manager → proposes operational change

HR → assesses employment implications

Immigration function or adviser → assesses sponsorship implications

Appropriate manager → authorises change

Level 1 User → completes required SMS action

The same individual may perform more than one of these functions in a smaller organisation.

What matters is that the employer understands which decision is being made and who has authority to make it.

 

4. Who should authorise Level 1 User SMS actions?

 

The appropriate level of internal authorisation can vary according to the significance of the SMS action.

Routine actions may be delegated to a trained Level 1 User, while higher-risk actions may require additional approval.

An internal authority matrix could distinguish between matters such as:

 

SMS or Sponsorship Activity	Possible Internal Control
Routine sponsored worker report	Designated Level 1 User
Certificate of Sponsorship assignment	Eligibility check + sponsorship approval + Level 1 User assignment
Defined CoS request	Recruitment/immigration verification + authorised Level 1 submission
Significant salary or role change	HR + immigration assessment before SMS action
Potential sponsor breach	Escalation to Authorising Officer and appropriate adviser
Corporate restructuring	Senior management/legal/immigration assessment before SMS action
Additional Level 1 User request	Authorised access decision + eligibility check

 

The precise matrix should reflect the organisation’s size and structure.

The principle is that possession of an SMS permission does not necessarily provide unrestricted internal authority to exercise it.

 

5. What evidence should be retained of Level 1 User activity?

 

The sponsor should retain sufficient evidence to demonstrate how important sponsorship actions were identified, assessed and completed.

Depending on the action, this may include:

 

• the original HR or recruitment request;
• job description;
• salary information;
• working hours;
• work location information;
• internal sponsorship assessment;
• approval to sponsor;
• CoS information;
• copies or records of relevant SMS activity;
• evidence of worker changes;
• correspondence concerning the change;
• internal approval records;
• evidence of escalation;
• Home Office communications; and
• records showing when required action was completed.

 

The objective is not to create unnecessary paperwork for every routine SMS action.

The sponsor should, however, be capable of reconstructing significant sponsorship decisions if they are later questioned during an internal audit or Home Office compliance activity.

 

6. What controls should apply to Certificate of Sponsorship assignment?

 

CoS assignment should be subject to a defined control process because incorrect Certificates of Sponsorship can create immigration and sponsor compliance problems.

A robust process can operate as follows:

Recruitment request

↓

Sponsorship eligibility assessed

↓

Role, occupation code, salary, hours and location verified

↓

Internal sponsorship approval obtained

↓

Level 1 User assigns CoS

↓

Assignment checked

↓

Supporting evidence retained

For higher-volume sponsors, a second-person check can provide an additional control before or immediately after assignment.

The employer should also ensure that the information ultimately entered into the SMS corresponds with the information that was assessed and approved.

 

7. What training should Level 1 Users receive?

 

Level 1 User training should extend beyond learning how to navigate the Sponsor Management System.

Depending on the individual’s responsibilities, training should cover:

 

• the organisation’s sponsor duties;
• the role of key personnel;
• Certificate of Sponsorship controls;
• sponsored worker reporting;
• organisational reporting;
• record-keeping requirements;
• SMS user management;
• SMS security;
• multi-factor authentication;
• internal approval procedures;
• reporting deadlines;
• Home Office communications;
• recognising potential compliance breaches;
• escalation procedures; and
• circumstances requiring specialist immigration advice.

 

The level of training should reflect the functions the individual actually performs.

A Level 1 User responsible only for limited routine administration may require a different level of operational training from the person responsible for managing a large sponsored workforce and assigning substantial numbers of Certificates of Sponsorship.

 

8. Should Level 1 User training be updated when the rules change?

 

Yes.

Sponsor guidance, immigration requirements and the Sponsor Management System can change.

Training should therefore be treated as an ongoing process rather than something completed once when the individual is appointed.

The 2026 SMS changes provide a clear example.

Level 1 Users need to understand developments including:

 

• the phased introduction of mandatory multi-factor authentication;
• individual account and contact-detail requirements;
• the inactive-user regime;
• the importance of regular SMS access;
• the withdrawal of the Level 2 User role; and
• the implications of these changes for business continuity and user management.

 

Where the Home Office changes sponsorship rules affecting CoS assignment, reporting or sponsor duties, the organisation should assess whether Level 1 User procedures and training need to be updated.

 

9. Should employers audit Level 1 User activity?

 

Yes. Periodic review of Level 1 User activity can help identify weaknesses before they become significant sponsor compliance problems.

An internal review can examine:

 

• who currently holds Level 1 access;
• whether each user remains eligible;
• whether access remains necessary;
• when users last accessed the SMS;
• whether contact information is current;
• whether MFA can be completed;
• whether Home Office messages are being monitored;
• whether reporting deadlines are being met;
• whether Certificates of Sponsorship have been assigned accurately;
• whether sponsored worker information corresponds with HR records;
• whether payroll information corresponds with sponsored salary information;
• whether work locations remain accurate;
• whether former users have been dealt with appropriately;
• whether Level 2 User transition arrangements have been addressed;
• whether Level 1 Users have received current training; and
• whether identified errors have been corrected and investigated.

 

The audit should test what happens in practice rather than merely confirm that the organisation has a written sponsor licence policy.

 

10. What oversight should the Authorising Officer provide?

 

The Authorising Officer should maintain meaningful oversight of the sponsor licence and the conduct of SMS users without necessarily duplicating every operational task performed by Level 1 Users.

Appropriate oversight can include regular visibility of:

 

• the number of sponsored workers;
• current Level 1 Users;
• significant CoS activity;
• CoS allocation requirements;
• material sponsored worker changes;
• significant organisational changes;
• Home Office correspondence;
• identified errors;
• potential breaches;
• late or potentially late reports;
• SMS access issues;
• training requirements;
• results of internal compliance reviews; and
• corrective actions.

 

For a smaller sponsor, this oversight may be relatively informal but should still be effective.

For a larger organisation, formal reporting to the Authorising Officer may be more appropriate.

The objective is for the Authorising Officer to understand whether the organisation’s sponsorship arrangements are functioning effectively rather than simply appearing as a named key person on the licence.

 

11. What does good Level 1 User governance look like?

 

Good governance creates a repeatable process connecting business activity with sponsor compliance.

The core model is:

Business or HR event

↓

Sponsorship consequence identified

↓

Relevant facts verified

↓

Immigration implications assessed

↓

Appropriate action authorised

↓

Level 1 User completes SMS action

↓

Evidence retained

↓

Authorising Officer or compliance oversight

The value of this model is that it does not depend entirely on one individual remembering every sponsorship rule.

Instead, sponsorship compliance is integrated into the organisation’s wider HR and business processes.

 

12. Level 1 User governance checklist

 

Employers should be able to answer the following questions:

 

• Do we know who all our Level 1 Users are?
• Does each user remain eligible?
• Does each user genuinely need SMS access?
• Are responsibilities allocated between users?
• Do HR and managers know which events should be escalated?
• Are sponsored workers clearly identifiable within our HR systems?
• Do Level 1 Users receive employment changes promptly?
• Are material changes assessed before implementation where possible?
• Is CoS assignment subject to verification and approval?
• Are significant SMS actions evidenced?
• Are Home Office messages monitored?
• Are reporting deadlines tracked?
• Do Level 1 Users know when to escalate?
• Are users appropriately trained?
• Is training updated when requirements change?
• Are SMS accounts periodically reviewed?
• Is there appropriate absence and departure cover?
• Does the Authorising Officer receive sufficient information to provide meaningful oversight?
• Are errors investigated for wider systemic causes?
• Could the organisation demonstrate these controls during a Home Office compliance visit?

 

A weakness identified through this review does not necessarily mean the organisation has breached its sponsor duties. It can, however, identify an area requiring corrective action before the weakness results in a compliance failure.

 

 

 

 

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Section H: What Happens When a Level 1 User Leaves or Changes Role?

A Level 1 User leaving the organisation, changing role or becoming unavailable can create an immediate sponsor licence management risk if the employer has not planned for continuity.

The issue is not simply whether the individual still appears on an internal HR system. Their departure can affect SMS access, key personnel arrangements, reporting capability, Certificate of Sponsorship activity and the organisation’s ability to maintain the required Level 1 User structure.

Sponsors should therefore treat Level 1 User departures as a specific sponsor compliance event.

The core objective is:

identify the change → assess its effect on Level 1 coverage → preserve operational continuity → update the sponsorship arrangements → remove inappropriate access → retain evidence

 

1. What should happen when a Level 1 User leaves the organisation?

 

Where a Level 1 User is leaving the sponsoring organisation, the employer should assess the sponsor licence implications before or as part of the individual’s departure process.

The review should establish:

 

• whether the individual is currently recorded as a Level 1 User;
• whether they hold any other key personnel role;
• whether they are the organisation’s only Level 1 User;
• whether they are the person satisfying an internal Level 1 User requirement;
• whether they are the sponsor’s only qualifying settled-worker Level 1 User where that requirement applies;
• whether another eligible Level 1 User is already in place;
• whether another person needs to be appointed;
• whether there are outstanding SMS actions;
• whether any CoS assignments or requests are pending;
• whether there are outstanding sponsored worker reports;
• whether Home Office communications require action; and
• how the departing individual’s SMS access will be dealt with.

 

This review should ideally take place before the individual’s final working day.

Waiting until after departure can leave the sponsor without access to information, knowledge or an appropriately structured Level 1 User function.

 

2. Should a replacement Level 1 User be appointed before the existing user leaves?

 

Where the departure could leave the sponsor without sufficient Level 1 User coverage, replacement arrangements should normally be addressed before the existing user leaves wherever possible.

This is particularly important where the departing individual is:

 

• the only Level 1 User;
• the principal person operating the SMS;
• the only internal Level 1 User satisfying the applicable requirements;
• the only Level 1 User with sufficient sponsorship knowledge;
• responsible for active CoS assignments;
• responsible for ongoing worker reporting; or
• the only person monitoring Home Office communications.

 

A planned departure gives the sponsor an opportunity to establish replacement arrangements and complete an orderly handover.

The organisation should avoid relying on the departing user’s credentials after they have left.

Another employee cannot simply continue operating the SMS through the former user’s account.

 

3. What should be included in a Level 1 User handover?

 

A structured handover can reduce the risk of sponsorship matters being overlooked when responsibility transfers between users.

The handover should consider:

 

• current sponsored workers;
• recently assigned Certificates of Sponsorship;
• Certificates of Sponsorship awaiting assignment;
• Defined CoS requests;
• CoS allocation requirements;
• pending worker changes;
• upcoming reporting deadlines;
• recent organisational changes;
• outstanding Home Office communications;
• known compliance issues;
• current SMS users;
• inactive-user concerns;
• remaining Level 2 User transition issues;
• internal sponsorship records;
• relevant internal approval processes;
• contact details for external immigration advisers;
• scheduled internal audits or compliance reviews; and
• any unresolved immigration or sponsorship matters.

 

The objective is to transfer responsibility and information, not passwords or authentication credentials.

The incoming Level 1 User should operate through their own properly authorised SMS account.

 

4. Should the departing Level 1 User share their password with the replacement?

 

No.

A departing Level 1 User should never transfer their SMS password, MFA passcode or other authentication credentials to a replacement user.

The replacement should be given their own authorised access through the appropriate process.

A handover should transfer:

knowledge + records + responsibilities + outstanding actions

It should not transfer:

passwords + MFA codes + personal SMS credentials

This distinction protects the security and individual accountability of the Sponsor Management System.

 

5. What if the Level 1 User changes job within the organisation?

 

A change of internal role does not necessarily mean the individual must stop being a Level 1 User.

The sponsor should, however, reassess whether the appointment remains appropriate.

Questions to consider include:

 

• Does the individual remain eligible?
• Do they still need SMS access?
• Will they continue to perform sponsorship functions?
• Will they still have access to the information needed to perform the role?
• Do they retain sufficient authority?
• Will their contact details change?
• Does another employee now have operational responsibility for sponsorship?
• Should responsibility be transferred?

 

For example, an HR manager who moves into an unrelated commercial role may technically remain employed by the sponsor but no longer be an appropriate person to retain powerful Level 1 permissions.

Access should follow operational need rather than employment status alone.

 

6. What if the Level 1 User is absent for a long period?

 

Extended absence should trigger a review of the sponsor’s operational resilience.

Potential circumstances include:

 

• long-term sickness absence;
• parental leave;
• sabbatical;
• extended overseas assignment;
• secondment; or
• another prolonged period away from normal duties.

 

The employer should establish whether another authorised Level 1 User can perform the required functions during the absence.

If not, it may be necessary to appoint another eligible Level 1 User.

The sponsor should not respond to the absence by allowing another employee to use the absent user’s SMS credentials.

The organisation should also consider whether a prolonged absence could result in the individual’s SMS account becoming inactive if the account is not accessed for 12 months.

 

7. What if the Level 1 User leaves unexpectedly?

 

An unexpected departure can create a more immediate problem because there may be little or no opportunity for a structured handover.

The sponsor should quickly establish:

 

• whether another active Level 1 User exists;
• whether the organisation continues to satisfy the applicable Level 1 User requirements;
• whether any urgent reporting deadlines are approaching;
• whether any Certificates of Sponsorship need to be assigned;
• whether Home Office communications require attention;
• whether the former user’s access needs to be dealt with; and
• whether an eligible replacement needs to be appointed.

 

The organisation should also secure relevant sponsorship records and identify any matters the departing user had been managing.

This is one reason why sponsor licence records should be held within an appropriate organisational system rather than existing solely within an individual employee’s personal email folders or working files.

 

8. What if the departing person is the only Level 1 User?

 

This should be treated as a priority sponsor licence issue.

Sponsors are required to maintain the applicable qualifying Level 1 User arrangements throughout the life of the licence, subject to the specific exceptions and remedial processes provided by the Home Office.

If the only Level 1 User is leaving, the organisation should not assume that it can operate indefinitely without replacing them.

Where the departure is known in advance, the employer should address replacement arrangements before the individual leaves wherever possible.

Where the loss of the Level 1 User occurs unexpectedly, the sponsor should act promptly to establish the correct process for restoring compliant Level 1 User arrangements.

The organisation should not attempt to solve the problem by continuing to use the former employee’s account.

 

9. What if the sponsor no longer has an active qualifying Level 1 User?

 

Failure to maintain the required Level 1 User arrangements can place the sponsor licence at risk.

The Home Office guidance provides specific processes in certain circumstances, including the inactive-user regime.

As explained above, where the inactive-user process results in a sponsor having no active Level 1 User, the Home Office can suspend the sponsor licence and provide a period of 28 days for the sponsor to nominate an eligible Level 1 User.

If the sponsor does not resolve the position within the applicable period, the licence will normally be revoked.

This remedial process should not be treated as a substitute for proper continuity planning.

The sponsor should aim to maintain compliant Level 1 User arrangements continuously rather than waiting for Home Office intervention.

 

10. How should a former Level 1 User’s SMS access be managed?

 

When an individual no longer requires Level 1 access, their SMS user status should be dealt with through the appropriate Sponsor Management System process.

The sponsor should not leave unnecessary accounts in place simply because the individual historically performed the role.

Access management should form part of the organisation’s wider leaver process.

A practical workflow is:

HR receives notice of departure

↓

Identify sponsor licence/key personnel responsibilities

↓

Assess replacement requirement

↓

Transfer sponsorship work and records

↓

Establish replacement access where required

↓

Deal with former user’s SMS access

↓

Verify that sponsor licence arrangements remain compliant

This should operate alongside ordinary IT and employment offboarding procedures.

 

11. Should Level 1 User departures form part of the HR leaver process?

 

Yes.

One of the strongest controls is to integrate sponsor licence responsibilities into the organisation’s ordinary leaver process.

When HR is notified that an employee is leaving, the leaver checklist should ask whether the person is:

 

• an Authorising Officer;
• a Key Contact;
• a Level 1 User;
• an existing Level 2 User during the transitional period;
• responsible for sponsored worker records;
• responsible for right to work processes; or
• otherwise involved in sponsor licence compliance.

 

This reduces the risk that sponsorship responsibilities are overlooked because the employee’s departure is treated only as an HR and IT matter.

 

12. What if the Level 1 User is also the Authorising Officer?

 

Where the departing Level 1 User also acts as the Authorising Officer, the sponsor needs to address both roles.

Replacing the individual as a Level 1 User does not automatically resolve the Authorising Officer position.

The organisation should separately consider:

 

• who will assume overall responsibility for sponsorship;
• whether the proposed replacement satisfies the applicable Authorising Officer requirements;
• how the relevant key personnel change should be handled;
• who will have operational Level 1 access;
• how oversight will continue during the transition; and
• whether any outstanding compliance matters require immediate attention.

 

The same principle applies where the departing Level 1 User also acts as Key Contact.

Each key personnel function should be considered separately even where several roles were previously held by one individual.

 

13. Should the sponsor audit the licence when a key Level 1 User leaves?

 

Where the departing individual had significant responsibility for sponsorship, their departure can provide a useful trigger for a focused sponsor licence review.

The review could examine:

 

• current sponsored workers;
• recent Certificates of Sponsorship;
• outstanding CoS requirements;
• recent worker reports;
• pending employment changes;
• Home Office messages;
• key personnel details;
• SMS users;
• inactive accounts;
• reporting processes;
• record keeping;
• known compliance concerns; and
• outstanding corrective actions.

 

This can help identify issues that might otherwise disappear with the departing employee’s institutional knowledge.

 

14. Level 1 User departure checklist

 

Where a Level 1 User is leaving or ceasing to perform the role, the sponsor should consider the following:

 

• Confirm the individual’s final working date.
• Identify every sponsor licence role they hold.
• Check whether another active Level 1 User exists.
• Confirm that the sponsor will continue to satisfy the applicable qualifying Level 1 User requirements.
• Identify an eligible replacement where required.
• Start the replacement process early enough to preserve continuity.
• Review outstanding Certificates of Sponsorship.
• Review outstanding reporting matters.
• Review Home Office communications.
• Transfer relevant sponsorship records.
• Document outstanding compliance issues.
• Ensure the replacement receives appropriate training.
• Ensure the replacement uses their own SMS credentials.
• Do not transfer passwords or MFA passcodes.
• Deal with the former user’s SMS access appropriately.
• Update internal responsibility matrices.
• Notify relevant HR, recruitment and management personnel of the new sponsorship contact.
• Consider whether the departure justifies a focused sponsor licence audit.
• Confirm that the Authorising Officer retains appropriate oversight.
• Retain evidence of the handover and changes made.

 

 

 

 

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Section I: Level 1 User Mistakes, Compliance Risks & Sponsor Licence Consequences

Level 1 User mistakes can have consequences beyond the individual SMS transaction in which the error occurs.

Because Level 1 Users perform many of the operational functions through which sponsor duties are implemented, repeated errors, inaccurate information, late reporting or weak controls can indicate wider problems with the organisation’s sponsor licence management.

The Home Office may therefore look beyond the immediate mistake and consider whether the sponsor has effective systems for managing sponsored workers and complying with its duties.

This distinction is important:

Individual error → identify and correct the immediate problem

Systemic weakness → identify why the error was possible and strengthen the compliance system

Effective remediation should address both where necessary.

 

1. What are the most common Level 1 User mistakes?

 

Common problems can include:

 

• missing sponsor reporting deadlines;
• entering inaccurate information into the SMS;
• assigning a Certificate of Sponsorship using incorrect information;
• using the wrong occupation code;
• recording an incorrect salary;
• recording inaccurate working hours or work locations;
• failing to identify a reportable worker change;
• failing to report an organisational change;
• taking SMS action before the immigration implications have been assessed;
• failing to monitor Home Office messages;
• retaining unnecessary SMS users;
• allowing accounts to become inactive;
• sharing SMS credentials or MFA passcodes;
• failing to maintain adequate Level 1 User cover;
• failing to remove or replace users who leave the organisation; and
• failing to escalate significant compliance concerns.

 

Some errors may be capable of straightforward correction. Others can affect a worker’s immigration position or expose the sponsor to Home Office scrutiny.

The appropriate response depends on what happened, why it happened and whether the problem indicates a wider compliance weakness.

 

2. What happens if a Level 1 User misses a reporting deadline?

 

Missing a sponsor reporting deadline can amount to a failure to comply with the sponsor’s reporting duties.

The employer should establish the facts immediately rather than ignoring the issue because the deadline has already passed.

The review should consider:

 

• what event occurred;
• when it occurred;
• when the organisation became aware of it;
• when the Level 1 User became aware of it;
• what reporting requirement applied;
• why the report was not made on time;
• whether action can still be taken through the SMS;
• whether further notification or advice is required;
• whether the worker’s immigration position is affected; and
• whether the failure exposes a wider weakness in the reporting process.

 

The fact that a report is already late does not mean the sponsor should simply leave the SMS unchanged.

The organisation should establish the appropriate corrective action and retain evidence explaining what occurred and how the issue was addressed.

 

3. What if the Level 1 User enters incorrect information into the SMS?

 

An SMS error should be assessed according to its nature and significance.

Examples can include:

 

• incorrect worker information;
• incorrect employment dates;
• incorrect salary information;
• incorrect work location;
• incorrect job information;
• incorrect sponsor details;
• an inaccurate report; or
• information entered against the wrong sponsored worker.

 

The Level 1 User should not attempt to conceal the mistake or create further inaccurate entries in an attempt to make the records appear consistent.

The sponsor should establish the correct information, identify the appropriate mechanism for correcting or explaining the error and consider whether specialist advice is required.

Where the mistake is significant, the organisation should also investigate how it occurred.

 

4. What happens if a Certificate of Sponsorship contains an error?

 

Errors on a Certificate of Sponsorship require particular care because the CoS may form the basis of the worker’s immigration application.

Potential errors can involve:

 

• occupation code;
• job title;
• job duties;
• salary;
• working hours;
• work location;
• employment dates;
• worker details;
• route information; or
• other sponsorship information.

 

The appropriate response can depend on whether the CoS has merely been created, has been assigned, or has already been used in an immigration application.

The sponsor should therefore avoid applying a generic correction process to every CoS error.

Before taking further action, the Level 1 User should establish:

 

• what information is wrong;
• what the correct information should be;
• how material the difference is;
• whether the CoS has been assigned;
• whether the worker has used it;
• whether the error affects route eligibility; and
• what corrective mechanism is appropriate.

 

Where necessary, specialist immigration advice should be obtained before further SMS action is taken.

 

5. What if the Level 1 User assigns a CoS without proper approval?

 

A Level 1 User may technically have permission within the SMS to assign a Certificate of Sponsorship, but the organisation should still maintain appropriate internal controls over sponsorship decisions.

If a CoS has been assigned without proper approval, the sponsor should determine:

 

• whether the proposed worker is eligible;
• whether the role satisfies the relevant requirements;
• whether the information on the CoS is accurate;
• whether the CoS has been used;
• whether the sponsorship would have been approved if the correct process had been followed;
• whether the assignment needs corrective action; and
• why the internal control failed.

 

The issue may indicate that SMS permissions and internal authority have not been adequately separated.

Corrective action may therefore require both dealing with the individual CoS and strengthening the organisation’s approval process.

 

6. What if HR does not tell the Level 1 User about a worker change?

 

This is a common example of why sponsor compliance cannot depend solely on the Level 1 User.

If HR, payroll or a line manager makes a change affecting a sponsored worker without informing the sponsorship function, the Level 1 User may have no opportunity to assess or report the event.

Examples can include:

 

• a salary reduction;
• a promotion;
• a change in duties;
• a change of work location;
• a reduction in working hours;
• extended absence;
• a change in working arrangements; or
• termination of employment.

 

The immediate issue should be assessed and corrected where necessary.

However, the sponsor should also examine the information flow that allowed the event to bypass the sponsorship function.

The appropriate remediation may include:

 

• updating HR procedures;
• adding sponsorship checks to employment-change forms;
• training line managers;
• introducing sponsored-worker flags within HR systems;
• requiring immigration approval before specified changes; and
• introducing escalation procedures.

 

This addresses the underlying compliance weakness rather than merely dealing with the missed report.

 

7. Can Level 1 User mistakes affect the sponsor licence?

 

Yes.

Level 1 User errors can contribute to findings that the sponsor has failed to comply with its sponsor duties.

The seriousness of the risk will depend on the circumstances, including:

 

• the nature of the error;
• whether the error affected a sponsored worker;
• whether inaccurate information was provided to the Home Office;
• whether the failure was isolated or repeated;
• whether the sponsor identified the problem itself;
• whether appropriate corrective action was taken;
• whether effective compliance systems existed;
• whether similar problems affect other workers; and
• the sponsor’s wider compliance history.

 

Potential Home Office action can range from enquiries and requests for information through to more serious sponsor licence enforcement action where the relevant grounds are met.

Depending on the nature and seriousness of the compliance issues, this can include action affecting the sponsor’s licence status, suspension or revocation.

 

8. Can Level 1 User problems lead to a Home Office compliance visit?

 

Weak sponsor licence management can become relevant during Home Office compliance activity.

A compliance visit may examine how the organisation manages sponsorship in practice, including its systems, records and key personnel arrangements.

The Home Office may consider matters such as:

 

• who operates the SMS;
• how Level 1 Users are trained;
• how sponsored worker changes are identified;
• how reporting deadlines are managed;
• how Certificates of Sponsorship are controlled;
• how SMS access is secured;
• how the Authorising Officer provides oversight;
• whether HR records correspond with sponsorship records;
• whether sponsored workers are performing the roles recorded for them; and
• whether identified compliance weaknesses have been addressed.

 

A sponsor should therefore be able to explain not merely who its Level 1 Users are, but how its Level 1 User arrangements function within the wider compliance system.

 

9. What if a Level 1 User shares their password or MFA passcode?

 

SMS passwords and multi-factor authentication passcodes must not be shared.

Credential sharing undermines the security and individual accountability of the Sponsor Management System and can expose the sponsor licence to serious compliance action.

The Home Office guidance warns that sharing passwords or MFA passcodes may result in revocation of the sponsor licence.

If credential sharing is discovered, the sponsor should act promptly.

This may include:

 

• stopping the practice immediately;
• securing the affected account;
• establishing who accessed the SMS;
• reviewing what actions were performed;
• checking whether inaccurate or unauthorised changes were made;
• reviewing whether additional authorised users are required;
• retraining relevant personnel; and
• strengthening internal SMS security controls.

 

The organisation should not normalise credential sharing as a practical solution to staff absence or workload.

 

10. What if the sponsor has no active Level 1 User?

 

Having no active qualifying Level 1 User can create a serious sponsor licence risk.

Sponsors are expected to maintain the required Level 1 User arrangements throughout the life of the licence, subject to the applicable exceptions and specific remedial processes.

Under the inactive-user regime, where the process results in the sponsor having no active Level 1 User, the Home Office can suspend the sponsor licence and give the organisation 28 days to nominate an eligible Level 1 User.

If the sponsor does not resolve the position within the required period, the licence will normally be revoked.

This reinforces why Level 1 User continuity should be monitored proactively rather than addressed only after access has been lost.

 

11. What should a sponsor do when it discovers a Level 1 User mistake?

 

The response should be structured and proportionate to the problem.

A useful remediation process is:

1. Identify the issue

Establish exactly what has happened.

2. Preserve the facts

Retain the relevant records, communications and SMS information.

3. Assess the immigration consequences

Determine whether a sponsored worker, Certificate of Sponsorship or immigration application is affected.

4. Assess the sponsor compliance consequences

Determine whether a sponsor duty has been breached or a reporting deadline missed.

5. Take appropriate corrective action

Correct the position using the appropriate process rather than improvising further SMS entries.

6. Escalate where necessary

Involve the Authorising Officer, senior management or specialist immigration advisers where appropriate.

7. Identify the root cause

Determine why the error occurred.

8. Strengthen controls

Update procedures, training, responsibilities or information flows where required.

9. Check for similar problems

Establish whether the same weakness may have affected other sponsored workers or SMS activity.

10. Retain evidence of remediation

Document the problem, the assessment and the action taken.

 

12. Why is root-cause analysis important?

 

Simply correcting the visible SMS error may not resolve the underlying compliance problem.

For example:

Problem: a salary reduction was reported late.

The immediate response may be to deal with the late report.

But the root cause could be:

 

• payroll did not know the employee was sponsored;
• HR did not tell the Level 1 User;
• the Level 1 User did not understand the reporting requirement;
• responsibility was unclear;
• the principal Level 1 User was absent;
• there was no deadline-tracking process; or
• the organisation had no pre-change immigration check.

 

Each cause requires a different corrective response.

A sponsor that repeatedly fixes individual SMS entries without correcting the system producing the errors remains exposed to further compliance failures.

 

13. Should the sponsor check other workers after discovering an error?

 

Where the error could indicate a wider systemic problem, yes.

For example, if one sponsored worker’s salary was changed without immigration review because payroll did not know they were sponsored, the employer should consider whether other sponsored workers may have been affected by the same process.

Similarly, if one CoS was assigned using an incorrect occupation code because the organisation has no independent verification procedure, recent CoS assignments may warrant review.

The scope of any review should be proportionate to the issue identified.

Potential checks can include:

 

• recent CoS assignments;
• current sponsored worker salaries;
• job titles and duties;
• work locations;
• working hours;
• recent HR changes;
• reporting records;
• SMS user access;
• Home Office communications; and
• outstanding compliance actions.

 

This can help determine whether the issue was genuinely isolated or evidence of a broader weakness.

 

14. Should sponsors keep a record of Level 1 User errors?

 

Material errors and corrective action should be appropriately documented.

A compliance record can help show:

 

• what happened;
• when the issue was discovered;
• who investigated it;
• what the correct position was;
• whether a sponsored worker was affected;
• what corrective action was taken;
• whether advice was obtained;
• what caused the problem;
• what controls were changed; and
• whether follow-up checks were completed.

 

This is particularly valuable where the organisation later needs to explain the circumstances during a sponsor licence audit or Home Office compliance visit.

The record should be factual and accurate rather than created retrospectively to suggest that a process existed when it did not.

 

15. Can a strong compliance system prevent every Level 1 User error?

 

No compliance system can guarantee that human error will never occur.

The purpose of sponsor licence governance is to reduce the likelihood of errors, identify them quickly and prevent individual mistakes from developing into repeated or systemic failures.

A strong system provides:

 

• clear responsibilities;
• appropriate training;
• reliable information flows;
• verification before significant SMS actions;
• controlled access;
• business continuity;
• deadline management;
• Authorising Officer oversight;
• periodic audit; and
• effective remediation when problems arise.

 

This allows the organisation to move from reactive sponsor administration towards active sponsor licence governance.

 

16. Level 1 User risk warning signs

 

Employers should investigate warning signs such as:

 

• only one person understanding how the sponsor licence operates;
• SMS passwords being shared;
• MFA codes being passed between employees;
• Level 1 Users rarely accessing the SMS;
• nobody being responsible for Home Office messages;
• HR making sponsored worker changes without immigration review;
• Certificates of Sponsorship being assigned directly from recruitment requests without verification;
• uncertainty about who currently has SMS access;
• former employees remaining recorded as users;
• repeated late reports;
• inconsistent CoS information;
• Level 1 Users receiving no sponsorship training;
• the Authorising Officer having little visibility of sponsorship activity;
• outstanding Level 2 accounts not being reviewed;
• no absence cover;
• no audit trail for significant SMS actions; or
• the same compliance problem recurring after it was supposedly corrected.

 

These warning signs do not necessarily establish that a sponsor duty has already been breached.

They indicate areas where the organisation should investigate and strengthen its controls.

 

 

 

 

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Section J: Level 1 User Compliance Checklist

Level 1 User compliance should be managed throughout the individual’s involvement with the sponsor licence, from the initial appointment through to ongoing access reviews and eventual departure or replacement.

The following checklist provides employers with a practical framework for reviewing Level 1 User arrangements.

It should be adapted to the size, structure and sponsorship activity of the organisation rather than treated as a substitute for the sponsor’s wider compliance procedures.

 

1. Before appointing a Level 1 User

 

Before appointing an individual, the sponsor should establish that they satisfy the applicable Home Office requirements and are suitable to perform the role.

 

• Confirm the individual’s identity.
• Confirm their relationship with the sponsoring organisation.
• Check whether they are an employee, director or partner where this is required.
• Confirm whether they satisfy the applicable settled-worker requirement.
• Confirm that the sponsor will continue to satisfy its primary internal Level 1 User requirements.
• Check whether the transitional rules for sponsors licensed before 1 January 2025 apply.
• Confirm that the individual is UK-based where required.
• Check whether any route-specific exception applies, including relevant UK Expansion Worker provisions.
• Confirm the individual has a valid National Insurance number unless an exception applies.
• Check the applicable key personnel eligibility and suitability requirements.
• Confirm the individual is not excluded because of the nature of their relationship with the sponsor.
• Where the proposed user is an external representative, confirm that the appointment is permitted and that the sponsor retains the required internal Level 1 User.
• Confirm there are no relevant suitability or compliance concerns preventing appointment.
• Establish why the individual requires Level 1 access.
• Define the functions they will perform.
• Confirm they have sufficient authority and access to relevant information.
• Confirm they can meet the security requirements associated with SMS access.

 

The appointment decision should therefore test both:

Home Office eligibility + operational suitability

 

2. On appointment as a Level 1 User

 

Once the appointment is being made, the sponsor should ensure the individual’s access is established correctly.

 

• Use the appropriate Home Office process for the appointment.
• Ensure the user has their own individual SMS account.
• Ensure accurate personal contact information is provided.
• Confirm the user can access the SMS.
• Confirm the user understands the applicable MFA process.
• Ensure passwords and MFA passcodes are treated as confidential.
• Do not use shared HR or departmental credentials.
• Record the individual’s sponsorship responsibilities internally.
• Notify relevant HR, recruitment, payroll and management personnel of the individual’s role where appropriate.
• Explain which matters should be escalated to the Level 1 User.
• Confirm the individual’s internal authority to carry out different SMS functions.

 

Appointment should not simply result in the individual receiving access and being expected to work out the role themselves.

 

3. Level 1 User induction checklist

 

A newly appointed Level 1 User should receive an induction appropriate to the functions they will perform.

This should cover relevant areas such as:

 

• the organisation’s sponsor licence structure;
• the role of the Authorising Officer;
• the role of the Key Contact;
• other Level 1 Users;
• the sponsor’s immigration routes;
• current sponsored workers;
• the Sponsor Management System;
• Certificate of Sponsorship controls;
• CoS allocation procedures;
• Defined CoS procedures where relevant;
• sponsored worker reporting;
• organisational reporting;
• record keeping;
• SMS security;
• multi-factor authentication;
• Home Office messages;
• internal approval procedures;
• reporting deadlines;
• escalation procedures;
• internal audit processes;
• business continuity arrangements; and
• circumstances requiring specialist immigration advice.

 

Training should focus not only on how to perform SMS actions, but also on when an action is required and why it is being taken.

 

4. Monthly Level 1 User checks

 

The Home Office recommends that a Level 1 User accesses the SMS at least once a month.

As part of a routine monthly review, the Level 1 User can consider checking:

 

• Home Office messages;
• outstanding sponsorship actions;
• recent sponsored worker changes;
• pending Certificates of Sponsorship;
• CoS allocation levels where relevant;
• Defined CoS activity where relevant;
• recent organisational changes;
• key personnel information;
• SMS user access;
• potentially inactive accounts;
• outstanding compliance matters;
• upcoming recruitment requiring sponsorship; and
• any actions requiring Authorising Officer oversight.

 

The monthly access recommendation is not a substitute for acting when a reportable event occurs.

Required SMS actions should be completed within the applicable timeframe rather than held until the next routine review.

 

5. Certificate of Sponsorship checklist

 

Before assigning a Certificate of Sponsorship, the Level 1 User should ensure the organisation has completed the appropriate sponsorship checks.

Depending on the route and circumstances, these may include:

 

• confirm the worker’s identity;
• confirm the correct immigration route;
• confirm the role is genuine;
• confirm the correct occupation code;
• verify the job title;
• verify the job description and duties;
• verify salary;
• verify working hours;
• verify work location;
• confirm proposed employment dates;
• confirm the correct type of CoS is being used;
• check applicable route-specific requirements;
• confirm the required internal sponsorship approval has been obtained;
• check for any restrictions affecting assignment by the particular SMS User;
• check any potential self-assignment or personal-relationship issue before assignment;
• verify the information entered into the SMS against the approved information;
• complete any required second-person check under the organisation’s procedures; and
• retain appropriate supporting evidence.

 

The preferred control sequence is:

eligibility assessment → verification → internal approval → CoS assignment → quality check → evidence

 

6. Sponsored worker change checklist

 

When the Level 1 User becomes aware of a change affecting a sponsored worker, the following process can be used:

 

• Identify exactly what has changed.
• Confirm when the change occurred or is due to occur.
• Establish whether the change has already been implemented.
• Check the worker’s current sponsorship details.
• Assess whether the change affects immigration eligibility.
• Determine whether an SMS report is required.
• Identify the applicable reporting deadline.
• Determine whether a new immigration application or other action may be required.
• Escalate complex or uncertain cases before taking action.
• Complete the appropriate SMS action.
• Retain evidence of the change and action taken.
• Update internal HR or sponsorship records where required.

 

Where possible, potentially material employment changes should reach the sponsorship function before implementation.

 

7. Organisational change checklist

 

Changes affecting the sponsoring organisation should also be assessed for immigration consequences.

The Level 1 User should ensure appropriate consideration is given to events such as:

 

• change of address;
• opening or closing locations;
• changes to organisational details;
• mergers;
• acquisitions;
• changes in ownership;
• TUPE transfers;
• corporate restructuring;
• business sales;
• insolvency;
• changes involving branches or linked entities; and
• other material corporate changes.

 

The checklist should establish:

 

• what is changing;
• when the change will take effect;
• which legal entity currently holds the sponsor licence;
• whether sponsored workers are affected;
• whether an SMS report is sufficient;
• whether a new sponsor licence may be required;
• whether Certificates of Sponsorship are affected;
• whether worker immigration applications may be required; and
• what Home Office notifications need to be made.

 

Significant corporate changes should not be treated as routine SMS administration without first assessing their sponsor licence consequences.

 

8. SMS access and security checklist

 

The sponsor should periodically verify that Level 1 User access remains secure and appropriate.

 

• Confirm every Level 1 User has their own account.
• Confirm passwords are not shared.
• Confirm MFA passcodes are not shared.
• Check that user contact details remain accurate.
• Confirm users can complete the applicable MFA process.
• Check whether every user still requires access.
• Confirm every user remains eligible.
• Check when each user last accessed the SMS.
• Identify accounts approaching or reaching prolonged inactivity.
• Check that former employees do not retain inappropriate access.
• Review external representative access.
• Review remaining Level 2 User accounts during the transitional period.
• Confirm sufficient Level 1 User cover exists.
• Confirm the Authorising Officer knows who currently has SMS access.

 

Access should be actively managed rather than allowed to accumulate over the life of the sponsor licence.

 

9. Annual Level 1 User review

 

In addition to routine monitoring, sponsors should consider carrying out a more structured periodic review of their Level 1 User arrangements.

An annual review can consider:

 

• whether the sponsor still has the correct Level 1 User structure;
• whether each user remains eligible;
• whether each user still needs access;
• whether the number of users remains proportionate;
• whether responsibilities are clearly allocated;
• whether the organisation has adequate absence cover;
• whether SMS accounts are active;
• whether MFA arrangements are functioning;
• whether user contact information is current;
• whether Level 1 Users have received appropriate refresher training;
• whether internal procedures reflect current Home Office requirements;
• whether reporting deadlines have been met;
• whether CoS assignment controls are working;
• whether Home Office messages are being monitored;
• whether identified errors have been remediated;
• whether the Authorising Officer has meaningful oversight; and
• whether the organisation could demonstrate effective Level 1 User governance during a Home Office compliance visit.

 

The annual review should be supplemented by event-driven reviews whenever significant organisational or personnel changes occur.

 

10. Level 1 User departure checklist

 

When a Level 1 User leaves or ceases to perform the role:

 

• identify their final working date;
• identify every sponsor licence role they hold;
• confirm whether another active Level 1 User exists;
• check whether the sponsor continues to satisfy the applicable qualifying Level 1 User requirements;
• identify and appoint an eligible replacement where required;
• review outstanding CoS activity;
• review outstanding worker reports;
• review Home Office messages;
• transfer relevant records;
• transfer outstanding responsibilities;
• ensure the replacement receives appropriate training;
• ensure the replacement uses their own SMS credentials;
• do not transfer passwords or MFA passcodes;
• deal with the departing user’s SMS access appropriately;
• update internal responsibility matrices;
• inform relevant internal teams of the new sponsorship contact; and
• consider whether a focused compliance audit is appropriate.

 

11. Level 1 User compliance visit readiness checklist

 

Sponsors should also consider whether their Level 1 User arrangements could withstand scrutiny during a Home Office compliance visit.

The organisation should be able to explain:

 

• who the Level 1 Users are;
• why each person has been appointed;
• how their eligibility was assessed;
• what responsibilities each user performs;
• how they are trained;
• how SMS access is secured;
• how sponsored worker changes reach them;
• how reporting deadlines are controlled;
• how Certificates of Sponsorship are approved and assigned;
• how organisational changes are identified;
• how Home Office messages are monitored;
• how absence cover operates;
• how errors are identified and remediated;
• how user access is reviewed;
• how the Authorising Officer provides oversight; and
• what evidence exists to demonstrate that these processes operate in practice.

 

The strongest evidence is usually not a policy document alone, but a combination of documented procedures and records showing that the procedures are actually followed.

 

12. Quick Level 1 User compliance test

 

Employers can use the following questions as a rapid health check:

 

• Do we have at least one active qualifying Level 1 User?
• Do we know which eligibility rules apply to our licence?
• Does each Level 1 User still need access?
• Can each user access the SMS and complete MFA?
• Has every Level 1 User accessed the SMS recently?
• Are passwords and MFA passcodes kept individual?
• Do we have adequate cover if our principal Level 1 User is unavailable?
• Do HR and managers know when to contact the sponsorship function?
• Are sponsored worker changes assessed before implementation where appropriate?
• Are Certificates of Sponsorship checked before assignment?
• Are reporting deadlines tracked?
• Are Home Office messages monitored?
• Do Level 1 Users know when to escalate a problem?
• Does the Authorising Officer know how the licence is being operated?
• Have former or unnecessary users been dealt with?
• Have remaining Level 2 User accounts been reviewed?
• Are errors investigated for root cause?
• Could we demonstrate our controls to the Home Office today?

 

If the answer to several of these questions is no, the sponsor should consider a more detailed review of its Level 1 User arrangements.

 

 

 

 

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Section K: Level 1 User vs Authorising Officer, Key Contact & Level 2 User

The Level 1 User forms part of the sponsor licence key personnel structure, but the role is different from the Authorising Officer and Key Contact.

Historically, sponsors could also appoint Level 2 Users with more restricted SMS permissions. That role is now being withdrawn, making the distinction between strategic responsibility, Home Office contact and operational SMS access increasingly important.

In broad terms:

Authorising Officer → senior responsibility and oversight

Key Contact → principal contact between the sponsor and the Home Office

Level 1 User → principal operational Sponsor Management System user

Level 2 User → historic restricted SMS role being phased out

The same individual can hold more than one role where the relevant requirements are satisfied, but employers should still understand the separate function attached to each appointment.

 

1. What is the difference between a Level 1 User and an Authorising Officer?

 

The Authorising Officer and Level 1 User perform different functions within sponsor licence governance.

The Authorising Officer is the senior person responsible for the sponsor licence arrangements and for overseeing the activities of SMS users.

The Level 1 User is principally responsible for carrying out operational functions through the Sponsor Management System.

A useful distinction is:

Authorising Officer → oversight, accountability and governance

Level 1 User → operational SMS administration and implementation

For example, a Level 1 User may:

 

• assign a Certificate of Sponsorship;
• request additional CoS allocation;
• submit a Defined CoS request;
• report a sponsored worker change;
• report relevant organisational information;
• manage certain SMS user functions;
• withdraw a Certificate of Sponsorship; and
• monitor Home Office messages.

 

The Authorising Officer should ensure that the organisation has suitable systems, appropriate personnel and effective oversight of these activities.

The distinction does not mean the Authorising Officer is detached from operational compliance. The role requires meaningful oversight of how the sponsor licence is being managed.

 

2. Can the Authorising Officer also be a Level 1 User?

 

Yes, provided the individual satisfies the applicable requirements for both roles.

This arrangement is common, particularly in smaller organisations where one senior employee may have both strategic responsibility for the sponsor licence and operational responsibility for the SMS.

Where one person holds both roles, the employer should still distinguish between the functions they are performing.

For example:

As Authorising Officer → they oversee the sponsor licence and SMS users

As Level 1 User → they perform authorised actions through the SMS

Combining the roles can simplify responsibility, but it can also increase dependency on one individual.

The sponsor should therefore consider absence cover, succession planning and whether another eligible Level 1 User is needed for operational resilience.

 

3. Does the Authorising Officer have to use the SMS?

 

The Authorising Officer role is principally concerned with responsibility and oversight rather than requiring the individual personally to perform every SMS action.

Operational activity can be carried out by authorised Level 1 Users.

However, the Authorising Officer should have sufficient visibility to understand how the licence is being operated.

This can include oversight of:

 

• who has SMS access;
• CoS activity;
• significant sponsored worker changes;
• significant organisational changes;
• compliance issues;
• Home Office communications;
• reporting failures;
• audit findings; and
• corrective action.

 

An Authorising Officer should not become merely a name recorded on the sponsor licence with no practical knowledge of the organisation’s sponsorship arrangements.

 

4. What is the difference between a Level 1 User and the Key Contact?

 

The Key Contact is the principal point of contact between the sponsoring organisation and the Home Office.

The Level 1 User, by contrast, is principally concerned with operating the Sponsor Management System.

The distinction can be summarised as:

Key Contact → communication relationship with the Home Office

Level 1 User → operational SMS access and activity

These roles can overlap in practice, particularly in smaller organisations, but they remain conceptually different.

 

5. Can the Key Contact also be a Level 1 User?

 

Yes, where the individual satisfies the applicable requirements for each role.

A sponsor may therefore have one individual acting as:

 

• Authorising Officer;
• Key Contact; and
• Level 1 User;

 

where permitted and appropriate.

Alternatively, the functions may be divided between several individuals.

The appropriate structure depends on the organisation’s size, internal expertise and sponsorship activity.

Whatever structure is adopted, responsibilities should be clearly understood internally.

 

6. What is the difference between a Level 1 User and a Level 2 User?

 

Historically, Level 2 Users were SMS users with more restricted permissions than Level 1 Users.

Level 1 Users have broader operational capabilities and play a more significant role in sponsor licence administration.

The distinction is becoming transitional because the Home Office is withdrawing the Level 2 User role.

No new Level 2 Users can be appointed from 9 September 2026.

Existing Level 2 Users need to be upgraded to Level 1 User status, where they satisfy the requirements and Level 1 access is appropriate, or their accounts should be deactivated by 8 March 2027.

The Level 2 User role ceases after that date.

 

7. Should every existing Level 2 User become a Level 1 User?

 

No.

The withdrawal of Level 2 Users should trigger an access review rather than automatic conversion.

For each existing Level 2 User, the sponsor should consider:

 

• what functions the individual currently performs;
• whether those functions are still required;
• whether the individual still needs direct SMS access;
• whether an existing Level 1 User could perform the work;
• whether the individual satisfies the Level 1 User requirements;
• whether broader Level 1 permissions are appropriate;
• whether additional training is required; and
• whether removing the account would create a business continuity problem.

 

The objective should be to redesign the sponsor’s SMS user structure around operational need and appropriate access rather than simply reproducing the historic Level 2 User population at Level 1.

 

8. Can an external immigration adviser be a Level 1 User?

 

A UK-based representative can, subject to the applicable requirements, be appointed as an additional Level 1 User after the sponsor licence has been granted.

However, a representative cannot be nominated as the Level 1 User at the initial sponsor licence application stage.

In addition, where the sponsor has only one Level 1 User, that person cannot simply be an external representative. The sponsor needs to maintain the applicable internal qualifying Level 1 User arrangements.

An external Level 1 User can nevertheless provide useful additional support with matters such as:

 

• complex SMS actions;
• CoS activity;
• technical sponsorship issues;
• Home Office correspondence;
• compliance remediation; and
• support during periods of high sponsorship activity.

 

The sponsor should clearly define which functions are handled internally and which are handled by the adviser.

 

9. Does using an external Level 1 User transfer responsibility to the adviser?

 

No.

Using an immigration adviser or other permitted representative to assist with SMS activity does not transfer the sponsor’s compliance responsibilities away from the sponsoring organisation.

The sponsor remains responsible for complying with its sponsor duties.

It therefore needs appropriate controls over the information provided to the adviser and the actions being carried out.

A sensible operating model can be:

Internal HR/business function → provides accurate information

↓

Internal sponsor licence owner → verifies and authorises action

↓

External Level 1 User/adviser → performs agreed SMS function

↓

Internal sponsor governance → retains oversight and evidence

Outsourcing SMS activity should not mean outsourcing organisational awareness of the sponsor licence.

 

10. How do the key sponsor licence roles work together?

 

A well-structured sponsor licence function separates responsibility without creating operational gaps.

For example:

Authorising Officer

Provides senior ownership, oversight and accountability.

↓

Key Contact

Supports the formal communication relationship with the Home Office.

↓

Level 1 User

Performs authorised operational actions through the Sponsor Management System.

↓

HR / Recruitment / Payroll / Managers

Provide the underlying employment and business information required to identify sponsorship events.

The arrows should not be interpreted as a strict organisational hierarchy in every business. The structure illustrates how the functions can connect.

 

11. Sponsor licence key personnel comparison

 

Role	Primary Function	Typical Focus
Authorising Officer	Senior responsibility and oversight	Governance, compliance oversight and conduct of SMS users
Key Contact	Principal Home Office contact	Communication between sponsor and Home Office
Level 1 User	Operational SMS user	CoS, reporting, SMS administration, user functions and operational licence management
Level 2 User	Historic restricted SMS user	Limited operational SMS functions; role being withdrawn

 

These functions can be held by different individuals or, where permitted, combined within the same person.

The correct structure should provide both:

clear accountability + sufficient operational resilience

 

12. Which role should deal with a sponsor compliance problem?

 

The answer depends on the nature and seriousness of the issue.

A Level 1 User may identify the problem because they are closest to the operational SMS activity.

For example, they may discover:

 

• a late worker report;
• an incorrect CoS;
• a salary discrepancy;
• an unreported work-location change;
• an inactive SMS account;
• a missed Home Office communication; or
• another potential sponsor duty failure.

 

The Level 1 User should not necessarily attempt to resolve a significant issue alone.

A suitable escalation model is:

Level 1 User identifies issue

↓

Facts verified

↓

Authorising Officer informed where appropriate

↓

Specialist immigration advice obtained where required

↓

Corrective action authorised and completed

↓

Root cause investigated

↓

Controls strengthened

This ensures operational problems receive the appropriate level of organisational attention.

 

13. Can one person perform all the key personnel roles?

 

In some organisations, one individual may perform multiple key personnel functions where they satisfy the applicable requirements.

This can be practical for smaller sponsors.

However, concentration of several functions in one person creates dependency.

The sponsor should consider what would happen if that individual:

 

• was unexpectedly absent;
• became seriously ill;
• went on extended leave;
• changed role;
• left the organisation; or
• lost the ability to perform one or more of the roles.

 

Even where one person performs several key personnel functions, the organisation should maintain sufficient institutional knowledge and continuity arrangements to prevent the sponsor licence becoming dependent entirely on that individual.

 

14. Which sponsor licence role is responsible for compliance?

 

The sponsor itself remains responsible for complying with its sponsor duties.

The key personnel structure allocates important functions within that wider organisational responsibility.

The Authorising Officer provides senior oversight.

The Level 1 User performs significant operational SMS functions.

The Key Contact performs the relevant communication role.

Other employees, including HR, recruitment, payroll and line managers, may also play important parts in ensuring that information reaches the sponsorship function.

Sponsor compliance should therefore not be treated as the personal responsibility of a single Level 1 User.

The more accurate model is:

Sponsoring organisation → responsible for sponsor compliance

Authorising Officer → senior oversight of sponsorship arrangements and SMS users

Level 1 User → operational implementation through the SMS

Wider business → provides the information and controls required to support compliance

 

 

 

 

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Section L: Sponsor Licence Level 1 User FAQs

 

What is a Level 1 User on a sponsor licence?

A Level 1 User is an authorised user of the Home Office Sponsor Management System with broad permissions to manage operational aspects of an organisation’s sponsor licence.

Depending on the licence and immigration routes involved, Level 1 User functions can include assigning Certificates of Sponsorship, requesting CoS allocations, applying for Defined Certificates of Sponsorship, reporting sponsored worker and organisational changes, managing certain SMS users, withdrawing Certificates of Sponsorship and accessing Home Office messages.

The Level 1 User is therefore a central operational role within sponsor licence management.

 

Does every sponsor licence need a Level 1 User?

Yes. Sponsors need to maintain the applicable qualifying Level 1 User arrangements throughout the life of the sponsor licence, subject to the specific exceptions and remedial provisions in the sponsor guidance.

The Level 1 User is necessary because many of the sponsor’s operational duties have to be implemented through the Sponsor Management System.

Failure to maintain the required Level 1 User arrangements can place the sponsor licence at risk.

 

Who can be a Level 1 User?

The answer depends partly on whether the individual is intended to satisfy the sponsor’s primary Level 1 User requirements or is being appointed as an additional user.

Under the current rules, sponsors will normally need at least one primary Level 1 User who is both:

 

• an employee, director or partner within the sponsoring organisation; and
• a settled worker.

 

Specified exceptions apply.

Different arrangements can also apply to sponsors whose successful sponsor licence application was made before 1 January 2025 and who have held the licence continuously since then.

Additional Level 1 Users can include other permitted individuals, including certain UK-based representatives and individuals providing relevant HR functions, subject to the applicable requirements.

 

Does a Level 1 User have to be a settled worker?

The sponsor needs to consider which Level 1 User is being relied upon to satisfy the applicable qualifying requirements.

For sponsors under the current primary Level 1 User rules, at least one primary Level 1 User will normally need to be both an employee, director or partner of the sponsor and a settled worker, unless a specified exception applies.

For sponsors operating under the transitional arrangements following a successful application made before 1 January 2025, the requirements can operate differently. The sponsor currently needs at least one Level 1 User who is an employee, director or partner and at least one Level 1 User who is a settled worker. These requirements can be satisfied by the same person or by different Level 1 Users.

Employers should therefore assess their licence against the rules applicable to their circumstances rather than assuming every Level 1 User has identical eligibility requirements.

 

Does a Level 1 User have to be an employee?

Not every Level 1 User necessarily has to be an employee.

The applicable rules allow certain other individuals to hold Level 1 User access, depending on the circumstances.

However, the sponsor must still maintain the required internal qualifying Level 1 User arrangements.

For the primary Level 1 User requirement under the current rules, the relevant person will normally need to be an employee, director or partner within the sponsoring organisation as well as satisfying the applicable settled-worker requirement, unless an exception applies.

 

Can a director be a Level 1 User?

Yes, a director can act as a Level 1 User where they satisfy the applicable requirements.

Whether appointing a director is operationally appropriate will depend on their involvement in sponsorship.

In some smaller organisations, a director may actively manage the sponsor licence. In a larger organisation, day-to-day SMS work may be better performed by appropriately trained HR, immigration or global mobility personnel.

 

Can an immigration adviser be a Level 1 User?

A permitted UK-based representative can be appointed as an additional Level 1 User after the sponsor licence has been granted, subject to the applicable requirements.

A representative cannot, however, be nominated as the Level 1 User at the initial sponsor licence application stage.

The sponsor must also retain the required internal qualifying Level 1 User arrangements. If the sponsor has only one Level 1 User, it cannot simply rely on an external representative as that sole user.

 

Can the Authorising Officer be the Level 1 User?

Yes. The same person can act as both Authorising Officer and Level 1 User where they satisfy the requirements for both roles.

The functions nevertheless remain different.

The Authorising Officer is concerned with senior responsibility and oversight of the sponsor licence and SMS users, while the Level 1 User performs operational functions through the Sponsor Management System.

 

Can the Key Contact also be the Level 1 User?

Yes, provided the individual satisfies the applicable requirements.

The Key Contact is principally concerned with the sponsor’s contact relationship with the Home Office, while the Level 1 User is principally concerned with operational SMS activity.

One individual may hold both roles, or the responsibilities can be divided between different people.

 

How many Level 1 Users can a sponsor have?

There is no single number that is appropriate for every sponsor.

The sponsor should maintain enough eligible Level 1 Users to manage its sponsorship activity effectively and provide appropriate operational resilience, while avoiding unnecessary SMS access.

The Home Office recommends that sponsors do not have more Level 1 Users than are necessary.

The correct number will depend on factors such as the number of sponsored workers, recruitment volume, organisational complexity, frequency of SMS activity and the need for absence cover.

 

Should a sponsor have more than one Level 1 User?

For many employers, having more than one appropriately trained Level 1 User can provide useful business continuity.

A sponsor relying entirely on one individual can face operational problems if that person becomes ill, takes extended leave or leaves unexpectedly.

However, appointing additional users should not become an exercise in giving SMS access to everybody within HR.

The appropriate model is:

minimum necessary access + sufficient operational resilience

 

What can a Level 1 User do on the Sponsor Management System?

Level 1 Users have broad SMS permissions.

Depending on the relevant sponsor licence and route, functions can include:

 

• assigning Certificates of Sponsorship;
• requesting additional CoS allocation;
• applying for Defined Certificates of Sponsorship;
• reporting sponsored worker changes;
• reporting relevant organisational changes;
• withdrawing Certificates of Sponsorship;
• requesting additional Level 1 Users;
• managing permitted user functions;
• accessing Home Office communications; and
• carrying out other authorised sponsor licence administration.

 

Having technical permission to perform an SMS action does not necessarily mean the individual has unrestricted internal authority to make the underlying business or sponsorship decision.

 

Can a Level 1 User assign Certificates of Sponsorship?

Yes. CoS assignment is one of the important operational functions available to Level 1 Users.

Before assignment, the sponsor should ensure that the worker and role satisfy the relevant immigration requirements and that the information entered onto the Certificate of Sponsorship is accurate.

Employers should also operate appropriate internal approval and verification procedures rather than treating CoS assignment as a purely administrative task.

 

Can a Level 1 User assign a Certificate of Sponsorship to themselves?

This requires careful consideration of the applicable route and sponsor guidance rather than relying on a blanket rule.

Special provisions apply in certain circumstances, including the UK Expansion Worker route, where an overseas-based Authorising Officer or Level 1 User can in relevant circumstances assign their own Certificate of Sponsorship to obtain permission to come to the UK.

Where a Level 1 User, another key person or someone personally connected to the SMS user is being sponsored, the applicable rules should be checked before the CoS is assigned.

Sponsors should avoid assuming that possession of the technical SMS permission automatically makes self-assignment appropriate.

 

Can a Level 1 User request more Certificates of Sponsorship?

Yes. Level 1 Users can perform relevant CoS allocation functions through the Sponsor Management System.

The employer should monitor its sponsorship requirements and ensure requests are supported by accurate information and a genuine recruitment need.

The Level 1 User should understand the distinction between the relevant types of Certificate of Sponsorship and the processes applying to the immigration routes used by the organisation.

 

Can a Level 1 User add another Level 1 User?

A Level 1 User can use the relevant SMS function to request another Level 1 User.

This should not be understood as the existing user having unrestricted power simply to create another fully authorised Level 1 User account.

The proposed user needs to satisfy the applicable requirements and the Home Office assesses the request.

The sponsor should also have an internal process for approving additional SMS access before the request is made.

 

Can a Level 1 User deactivate another SMS user?

Level 1 Users have user-management functions within the SMS and can deactivate other users where permitted.

A Level 1 User cannot simply deactivate their own account through the same process.

User-management actions should form part of a controlled access process, particularly when an employee leaves, changes role or no longer requires SMS access.

 

Can Level 1 Users share an SMS account?

No.

Each authorised SMS user should use their own individual account.

Passwords and MFA passcodes must not be shared.

This is important both for security and for maintaining individual accountability for activity carried out through the Sponsor Management System.

Credential sharing can expose the sponsor licence to serious compliance action.

 

Does a Level 1 User need multi-factor authentication?

The Home Office began the phased introduction of mandatory SMS multi-factor authentication in September 2026.

Organisations granted a sponsor licence on or after 9 September 2026 have mandatory MFA enabled, with the Home Office rolling the requirement out more widely across existing sponsors.

Level 1 Users should therefore ensure that their individual contact information is accurate and that they can complete the applicable authentication process.

MFA credentials and one-time passcodes must not be shared with other users.

 

How often should a Level 1 User log into the SMS?

The Home Office recommends that a Level 1 User accesses the Sponsor Management System at least once a month.

This can help the sponsor monitor Home Office messages, maintain familiarity with the system and identify outstanding matters.

Monthly access should not, however, be treated as a substitute for meeting reporting deadlines. Where an event requires action within a particular timeframe, the sponsor should act within that timeframe.

 

What happens if a Level 1 User does not use their account?

An SMS user account can become inactive where it has not been accessed for 12 months.

Under the current inactive-user process, the Home Office can contact the Authorising Officer and the affected inactive Level 1 User. The user then has three months from that contact to log into the SMS and check and update their details as necessary.

Sponsors should not wait for this process before reviewing inactive or unnecessary accounts.

 

Can a sponsor licence be suspended if there is no active Level 1 User?

Yes, in the circumstances covered by the Home Office inactive-user process.

Where that process leaves the sponsor without an active Level 1 User, the Home Office can suspend the sponsor licence and give the organisation 28 days to nominate an eligible Level 1 User.

If the position is not resolved within the applicable period, the licence will normally be revoked.

Sponsors should therefore maintain Level 1 User continuity proactively.

 

What happens to Level 2 Users?

The Level 2 User role is being withdrawn.

No new Level 2 Users can be appointed from 9 September 2026.

Existing Level 2 Users should be upgraded to Level 1 User status where they are eligible and Level 1 access is appropriate, or their accounts should be deactivated by 8 March 2027.

The Level 2 User role ceases after 8 March 2027.

Sponsors should use the transition as an opportunity to review who genuinely needs SMS access rather than automatically upgrading every existing Level 2 User.

 

What happens if a Level 1 User leaves the company?

The sponsor should review the position promptly and, where possible, before the individual leaves.

The employer should establish whether another qualifying Level 1 User remains in place, whether a replacement is required, whether outstanding sponsorship matters need to be transferred and how the departing user’s SMS access should be dealt with.

The departing user should not transfer their password or MFA credentials to their replacement.

Where the departing person is the only Level 1 User, replacement arrangements should be treated as a priority.

 

What happens if the only Level 1 User is on holiday or sick?

The organisation may find itself unable to perform important SMS actions if it relies entirely on one unavailable user.

Another employee cannot simply use that person’s credentials.

Sponsors should therefore consider absence cover as part of their Level 1 User structure, particularly where they have frequent sponsorship activity or reporting obligations.

Planned resilience is preferable to trying to establish emergency access after an urgent SMS action becomes necessary.

 

Is the Level 1 User personally liable for sponsor licence breaches?

The sponsoring organisation remains responsible for complying with its sponsor duties.

The Level 1 User nevertheless performs important functions on the sponsor’s behalf and is expected to use the SMS properly and securely.

The Authorising Officer also has responsibility for oversight of the sponsor licence arrangements and SMS users.

Employers should therefore avoid treating sponsor compliance as the personal responsibility of the Level 1 User alone.

Effective compliance requires organisational systems involving HR, recruitment, payroll, management and appropriate senior oversight.

 

What happens if a Level 1 User makes a mistake?

The appropriate response depends on the nature and significance of the error.

The sponsor should establish:

 

• what happened;
• what information should have been recorded;
• whether a reporting deadline has been missed;
• whether a Certificate of Sponsorship or immigration application is affected;
• whether corrective SMS action is available;
• whether specialist advice is required;
• whether the error indicates a wider compliance problem; and
• what changes are needed to prevent recurrence.

 

The sponsor should not attempt to conceal an error or create further inaccurate SMS entries to make the records appear consistent.

 

Can Level 1 User mistakes lead to sponsor licence revocation?

Potentially, depending on the nature and seriousness of the compliance failure and whether the relevant grounds for enforcement action are met.

A single administrative mistake should not automatically be equated with sponsor licence revocation.

However, serious or repeated failures involving matters such as inaccurate sponsorship information, insecure SMS access, failure to maintain required key personnel arrangements or wider breaches of sponsor duties can expose the organisation to Home Office enforcement action.

Where an error is identified, the sponsor should assess both the immediate problem and its underlying cause.

 

How should an employer choose a Level 1 User?

The strongest candidate is usually someone who combines eligibility with operational competence.

The individual should ideally:

 

• satisfy the applicable Home Office requirements;
• understand the organisation;
• have access to relevant HR and recruitment information;
• understand sponsor duties;
• be comfortable using the SMS;
• work accurately;
• understand the importance of deadlines;
• protect their account credentials;
• have sufficient authority to challenge incomplete or inaccurate requests;
• know when to escalate an issue; and
• have sufficient time to perform the role properly.

 

The role should not be allocated solely according to seniority or administrative convenience.

 

What is the biggest Level 1 User compliance risk?

One of the most significant risks is treating the Level 1 User as nothing more than an SMS administrator.

The Level 1 User sits at the point where events occurring within the organisation have to be recognised as potential sponsorship events and translated into accurate and timely SMS action.

If HR, recruitment, payroll and managers do not provide the necessary information, even an experienced Level 1 User may be unable to meet the sponsor’s obligations.

The stronger model is therefore:

business event → sponsorship consequence identified → facts verified → action authorised → Level 1 User completes SMS action → evidence retained → oversight maintained

 

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Section M: Conclusion: Managing the Level 1 User Role Effectively

The Level 1 User is one of the most important operational roles within the UK sponsor licence system.

Although the role is often described in terms of access to the Sponsor Management System, its practical importance extends considerably further.

The Level 1 User sits at the point where recruitment decisions, employment changes, organisational developments and sponsor compliance obligations have to be translated into accurate and timely action through the SMS.

For employers, effective Level 1 User management therefore requires more than appointing somebody who is technically eligible to hold the role.

 

1. The Level 1 User is not simply an SMS administrator

 

The Sponsor Management System is the mechanism through which many sponsor licence functions are performed, but the Level 1 User needs to understand the significance of the actions being taken through it.

A Level 1 User may be responsible for operational activity including:

 

• assigning Certificates of Sponsorship;
• requesting CoS allocations;
• applying for Defined Certificates of Sponsorship;
• reporting sponsored worker changes;
• reporting relevant organisational changes;
• withdrawing Certificates of Sponsorship;
• managing permitted SMS user functions;
• monitoring Home Office communications; and
• supporting the organisation’s wider sponsor licence administration.

 

Each of these actions can have immigration and compliance consequences.

The Level 1 User therefore needs to understand not merely which button to select within the SMS, but why an action is required, whether the underlying information is accurate and whether the proposed action is appropriate.

 

2. Employers need to maintain a qualifying Level 1 User

 

Sponsors need to maintain the applicable qualifying Level 1 User arrangements throughout the life of the sponsor licence, subject to the specific exceptions and transitional provisions within the sponsor guidance.

For sponsors operating under the current primary Level 1 User rules, this will normally mean maintaining at least one primary Level 1 User who is both:

 

• an employee, director or partner within the sponsoring organisation; and
• a settled worker.

 

Specified exceptions apply.

Different transitional arrangements can apply where the successful sponsor licence application was made before 1 January 2025 and the licence has been held continuously since then.

Employers should therefore understand which requirements apply to their licence rather than assuming that every Level 1 User is subject to precisely the same appointment criteria.

 

3. Level 1 User access should balance security and resilience

 

The objective should not be to have either the smallest or largest possible number of Level 1 Users.

The sponsor needs enough authorised users to operate the licence effectively and maintain continuity, while avoiding unnecessary access to the Sponsor Management System.

The practical principle is:

minimum necessary access + sufficient operational resilience

Too few users can leave the organisation dependent on one person.

Too many users can weaken security, accountability and control.

The appropriate number should reflect the size and complexity of the organisation, the number of sponsored workers, recruitment volume, frequency of SMS activity and the need for absence cover.

 

4. Sponsor compliance depends on information reaching the Level 1 User

 

A Level 1 User cannot report an event they do not know has happened.

This makes internal information flow one of the most important aspects of Level 1 User governance.

Relevant information may originate from:

 

• HR;
• recruitment;
• payroll;
• line managers;
• finance;
• global mobility;
• legal teams;
• corporate management; and
• the sponsored worker.

 

The employer should ensure that relevant events are identified and communicated to the sponsorship function promptly.

The strongest model is:

Business event

↓

Potential sponsorship consequence identified

↓

Relevant facts verified

↓

Immigration implications assessed

↓

Appropriate action authorised

↓

Level 1 User completes required SMS action

↓

Evidence retained

↓

Appropriate oversight maintained

 

5. SMS access should remain individual and secure

 

Each Level 1 User should operate through their own authorised SMS account.

Passwords and MFA passcodes should not be shared.

Credential sharing should not be used as a solution to:

 

• annual leave;
• sickness absence;
• high workloads;
• staff departures;
• urgent CoS assignments; or
• insufficient numbers of authorised users.

 

If the organisation regularly needs another person to access the SMS, it should consider whether that individual should be properly appointed and authorised rather than allowing them to use another person’s credentials.

Secure access and operational continuity should be designed into the Level 1 User structure.

 

6. Level 1 User arrangements need active management

 

Appointing a Level 1 User should not be treated as the end of the process.

The sponsor should continue to review:

 

• whether each user remains eligible;
• whether each user still needs access;
• whether user details remain current;
• whether MFA arrangements are functioning;
• whether accounts remain active;
• whether sufficient absence cover exists;
• whether Level 1 Users are appropriately trained;
• whether responsibilities remain clearly allocated;
• whether former employees have been dealt with appropriately;
• whether the organisation’s SMS user structure reflects current operational needs; and
• whether changes to Home Office requirements require procedures to be updated.

 

The Home Office recommendation that Level 1 Users access the SMS at least monthly also reinforces the importance of active rather than passive licence management.

 

7. The withdrawal of Level 2 Users requires an access review

 

The withdrawal of the Level 2 User role provides sponsors with a specific reason to review their SMS access arrangements.

No new Level 2 Users can be appointed from 9 September 2026, and existing Level 2 Users need to be dealt with before the role ceases after 8 March 2027.

Employers should not automatically upgrade every Level 2 User to Level 1.

Instead, the review should establish:

 

• whether the individual still requires SMS access;
• which functions they need to perform;
• whether existing Level 1 Users can perform those functions;
• whether the individual is eligible to become a Level 1 User;
• whether broader Level 1 permissions are appropriate; and
• whether additional training and governance controls are required.

 

This provides an opportunity to redesign SMS access around current business requirements rather than historic user arrangements.

 

8. Level 1 User mistakes should trigger remediation, not concealment

 

Errors can occur even where an organisation has established compliance systems.

What matters is how the sponsor responds.

Where a Level 1 User mistake is identified, the organisation should:

identify → verify → assess → correct → escalate where necessary → investigate root cause → strengthen controls → check for wider impact → retain evidence

Correcting the immediate SMS entry may not be sufficient if the error resulted from a wider weakness in HR processes, training, approval procedures, information flow or oversight.

The sponsor should therefore distinguish between an isolated administrative mistake and evidence of a systemic compliance problem.

 

9. The Authorising Officer should maintain meaningful oversight

 

The Level 1 User may perform the day-to-day SMS work, but sponsor licence management should not become detached from the Authorising Officer.

The Authorising Officer should maintain sufficient visibility to understand:

 

• who has SMS access;
• how the licence is being operated;
• whether significant sponsorship issues have arisen;
• whether reporting systems are functioning;
• whether CoS controls are effective;
• whether Level 1 Users are appropriately trained;
• whether compliance weaknesses have been identified; and
• whether corrective action is being completed.

 

The Level 1 User and Authorising Officer therefore perform different but complementary functions.

Level 1 User → operational implementation

Authorising Officer → senior oversight

Sponsoring organisation → responsibility for sponsor compliance

 

10. Employer action points

 

Employers reviewing their Level 1 User arrangements should consider the following actions:

 

• Identify every current Level 1 User.
• Confirm which user satisfies the sponsor’s primary qualifying requirements.
• Check that each Level 1 User remains eligible.
• Confirm that each user still requires SMS access.
• Review when each user last accessed the SMS.
• Confirm that individual MFA arrangements are working.
• Check that passwords and MFA passcodes are not being shared.
• Review whether the organisation has sufficient absence cover.
• Document Level 1 User responsibilities.
• Review internal authority for CoS assignment and other significant SMS actions.
• Check how HR, recruitment, payroll and managers communicate sponsored worker changes.
• Confirm that Home Office messages are monitored.
• Review the organisation’s reporting controls.
• Review CoS assignment controls.
• Assess whether Level 1 Users require refresher training.
• Review inactive and unnecessary accounts.
• Address remaining Level 2 User arrangements before the transition deadline.
• Ensure Level 1 User departures form part of the HR leaver process.
• Confirm that the Authorising Officer has meaningful oversight.
• Consider whether a wider sponsor licence compliance audit is required.

 

11. Final employer perspective

 

The Level 1 User should be viewed as part of the organisation’s sponsor licence control framework rather than simply as the employee who has access to the SMS.

The most effective arrangements combine:

eligible users

+

appropriate SMS access

+

secure individual credentials

+

accurate HR and recruitment information

+

clear internal authority

+

current training

+

business continuity

+

audit and remediation

+

Authorising Officer oversight

Together, these controls allow the Level 1 User to perform the role effectively while helping the sponsoring organisation maintain control of its wider sponsor licence obligations.

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Section N: Glossary

The following glossary explains the principal sponsor licence and Sponsor Management System terms used throughout this guide.

Term	Meaning
Authorising Officer	The Authorising Officer is the senior person responsible for the organisation’s sponsor licence arrangements and for overseeing the activities of Sponsor Management System users. The Authorising Officer does not necessarily perform every operational SMS function personally. Day-to-day SMS activity can be undertaken by authorised Level 1 Users. The Authorising Officer should nevertheless maintain meaningful oversight of how the sponsor licence is being managed.
Certificate of Sponsorship (CoS)	A Certificate of Sponsorship is an electronic sponsorship record assigned by a licensed sponsor to a worker who is being sponsored under an eligible immigration route. It is not a physical certificate. The CoS contains information about the worker, the sponsoring organisation and the role for which sponsorship is being provided. Level 1 Users can perform important CoS functions through the Sponsor Management System, including assignment, subject to the applicable route requirements and internal sponsor controls.
CoS Allocation	A CoS allocation refers to the number of relevant Certificates of Sponsorship available to a sponsor for assignment under routes where an allocation applies. Level 1 Users can carry out relevant allocation functions through the Sponsor Management System, including requesting additional allocation where required. Sponsors should monitor their anticipated recruitment requirements rather than waiting until an urgent sponsorship need arises before reviewing available CoS capacity.
Defined Certificate of Sponsorship	A Defined Certificate of Sponsorship is a type of CoS used for specified Skilled Worker applications made from outside the UK. Rather than relying on an annual allocation in the same way as an Undefined CoS, the sponsor applies for a Defined CoS through the Sponsor Management System when required. Level 1 Users can perform the relevant Defined CoS functions through the SMS.
Undefined Certificate of Sponsorship	An Undefined Certificate of Sponsorship is used for sponsorship circumstances where a Defined CoS is not required, subject to the rules of the relevant immigration route. For sponsors using routes where an allocation applies, the organisation needs to monitor the number of available Undefined CoS and its anticipated sponsorship requirements.
Home Office	The Home Office is the UK government department responsible for immigration, nationality and the sponsorship system. It grants and regulates sponsor licences, operates the Sponsor Management System and can undertake sponsor compliance activity and enforcement action.
Key Contact	The Key Contact is the individual who acts as the principal point of contact between the sponsoring organisation and the Home Office. The role is different from that of the Level 1 User, although the same individual can hold both roles where the applicable requirements are satisfied. In broad terms: Key Contact → Home Office contact function Level 1 User → operational SMS function
Key Personnel	Key personnel are the individuals appointed to specified sponsor licence roles. The principal roles include the Authorising Officer, Key Contact and Level 1 User. These roles perform different functions within the sponsorship system and are subject to Home Office requirements.
Level 1 User	A Level 1 User is an authorised Sponsor Management System user with broad operational permissions for managing aspects of the sponsor licence. Depending on the licence and immigration routes involved, Level 1 User functions can include:   assigning Certificates of Sponsorship; requesting additional CoS allocation; applying for Defined Certificates of Sponsorship; reporting sponsored worker changes; reporting relevant organisational changes; withdrawing Certificates of Sponsorship; performing permitted SMS user-management functions; and accessing Home Office communications.   The Level 1 User is an operational role and should not be confused with the Authorising Officer’s wider oversight function.
Level 2 User	A Level 2 User is the historic restricted SMS user role that is being withdrawn from the sponsorship system. No new Level 2 Users can be appointed from 9 September 2026. Existing Level 2 Users need to be upgraded to Level 1 User status where they are eligible and Level 1 access is appropriate, or their accounts should be deactivated by 8 March 2027. The Level 2 User role ceases after 8 March 2027.
Multi-Factor Authentication (MFA)	Multi-factor authentication is an additional security process used when accessing the Sponsor Management System. Rather than relying only on an SMS user ID and password, the user is also required to complete an additional authentication step using the applicable Home Office process. The Home Office began the phased introduction of mandatory SMS MFA in September 2026, with organisations granted a sponsor licence on or after 9 September 2026 having mandatory MFA enabled. Passwords and MFA passcodes must remain individual and should not be shared with other users.
Primary Level 1 User	The primary Level 1 User is the Level 1 User relied upon to satisfy the applicable core Level 1 User requirements for the sponsor licence. Under the current rules, sponsors will normally need at least one primary Level 1 User who is both:   an employee, director or partner within the sponsoring organisation; and a settled worker.   Specified exceptions apply, and transitional arrangements can apply to sponsors whose successful sponsor licence application was made before 1 January 2025 and who have held their licence continuously since then.
Settled Worker	For sponsor licence key personnel purposes, settled worker is a Home Office sponsorship term used when determining whether an individual satisfies specified key personnel requirements. Sponsors should apply the definition contained in the current sponsor guidance to the individual’s circumstances rather than relying solely on the everyday meaning of being “settled” in the UK.
Sponsor	A sponsor is the organisation holding the sponsor licence and authorised by the Home Office to sponsor eligible workers under the immigration routes covered by its licence. The sponsoring organisation remains responsible for complying with its sponsor duties even where individual functions are delegated to Level 1 Users, HR personnel or external immigration advisers.
Sponsor Duties	Sponsor duties are the obligations organisations accept when they hold a sponsor licence. These include requirements relating to matters such as:   reporting; record keeping; monitoring sponsored workers; co-operating with the Home Office; preventing abuse of the immigration system; and maintaining appropriate sponsor licence arrangements.   Level 1 Users perform important operational functions through which some of these duties are implemented, but responsibility for sponsor compliance remains with the sponsoring organisation.
Sponsor Licence	A sponsor licence is the Home Office authorisation that allows an eligible organisation to sponsor qualifying workers under specified UK immigration routes. Holding a licence carries ongoing compliance obligations. The sponsor must maintain appropriate systems, key personnel and records throughout the life of the licence.
Sponsor Management System (SMS)	The Sponsor Management System is the Home Office online system used by licensed sponsors to administer their sponsor licence. Functions available through the SMS include activities relating to:   Certificates of Sponsorship; sponsored worker reporting; organisational reporting; key personnel; SMS users; licence administration; and Home Office communications.   The Level 1 User is the principal operational user of the SMS.
Sponsored Worker	A sponsored worker is an individual whose immigration permission is based on sponsorship by a licensed organisation under an applicable sponsored work route. The sponsor may have reporting, monitoring and record-keeping responsibilities in relation to the worker throughout the period of sponsorship.
Sponsorship Reporting	Sponsorship reporting refers to the process of notifying the Home Office about specified changes affecting sponsored workers or the sponsoring organisation. Many reports are made through the Sponsor Management System by an authorised Level 1 User. The precise event, reporting requirement and applicable deadline should be determined under the relevant sponsor guidance.
SMS User	An SMS User is an individual authorised to access the Sponsor Management System through their own account. SMS access is individual. User IDs, passwords and MFA passcodes should not be shared between employees, advisers or other users.
Inactive SMS User	An inactive SMS user is a user whose account has not been accessed for the period specified by the Home Office inactive-user regime. Under the current arrangements, an account can become inactive after 12 months without access. The Home Office can contact the Authorising Officer and affected inactive Level 1 User, after which the Level 1 User has three months from that contact to log into the SMS and check and update their details as necessary. If the process leaves the sponsor without an active Level 1 User, this can lead to sponsor licence suspension and a 28-day period to nominate an eligible Level 1 User, with revocation normally following if the position is not resolved.
SMS Security	SMS security refers to the controls used to protect Sponsor Management System access and ensure that only authorised individuals operate sponsor accounts. Important controls include:   individual user accounts; confidential passwords; confidential MFA passcodes; accurate user contact information; appropriate access levels; regular access reviews; prompt management of leavers; and removal of unnecessary user access.
Sponsor Compliance Visit	A sponsor compliance visit is Home Office compliance activity used to assess whether an organisation is meeting the requirements associated with its sponsor licence. The Home Office may examine matters including HR systems, sponsored worker records, recruitment practices, reporting arrangements, key personnel, SMS management and the organisation’s wider compliance controls. Level 1 User arrangements may therefore form part of the sponsor’s overall compliance position.
Sponsor Licence Suspension	Sponsor licence suspension is enforcement action that can be taken by the Home Office where concerns arise about a sponsor’s compliance and the relevant suspension grounds are engaged. A suspended sponsor faces restrictions while the Home Office considers the licence position. Where suspension occurs, the organisation should establish the grounds, relevant deadlines and appropriate response promptly.
Sponsor Licence Revocation	Sponsor licence revocation means the Home Office has withdrawn the organisation’s sponsor licence. Revocation is a serious outcome that can affect the organisation’s ability to sponsor workers and can have consequences for existing sponsored workers. Failures relating to SMS security, key personnel arrangements or wider sponsor duties can contribute to enforcement action where the relevant grounds are met.
UK Expansion Worker	UK Expansion Worker is a sponsored immigration route within the Global Business Mobility framework for eligible overseas businesses establishing a UK presence. Special sponsor licence and key personnel provisions can apply because an organisation using the route may initially have no suitable UK-based employee available to perform the usual sponsorship roles. In relevant circumstances, an overseas-based Authorising Officer or Level 1 User can operate under these special arrangements, including provisions allowing the individual to assign their own Certificate of Sponsorship to obtain permission to come to the UK. These are route-specific exceptions and should not be treated as the general rule for Level 1 Users.

 

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Section O: Useful Links & Related Guidance

Employers managing Level 1 Users should use the current Home Office sponsor guidance and Sponsor Management System manuals alongside their own internal sponsor licence procedures.

The Home Office updated the principal SMS user-access manual on 11 September 2026. It confirms that Level 1 Users can access all applicable SMS functions, subject to licence-status restrictions, and contains the current processes for requesting Level 1 Users, managing user access and viewing Home Office messages.

 

Resource	URL
Home Office Sponsor Guidance GOV.UK — Sponsorship: Guidance for Employers and Educators	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Home Office Sponsorship Management Roles GOV.UK — UK Visa Sponsorship for Employers: Sponsorship Management Roles	https://www.gov.uk/uk-visa-sponsorship-employers/sponsorship-management-roles
Sponsor Management System Manual 1 GOV.UK — Introduction to the Sponsorship Management System: SMS Manual 1	https://www.gov.uk/government/publications/use-the-sponsorship-management-system-sms-user-manual
Managing a Sponsor Licence Through the SMS GOV.UK — Manage Your Sponsorship Licence: SMS Manual 2	https://www.gov.uk/government/publications/manage-your-sponsorship-licence-sms-user-manual
Creating & Assigning Certificates of Sponsorship GOV.UK — SMS Guide 8: Creating and Assigning a CoS	https://www.gov.uk/government/publications/creating-and-assigning-a-cos-sms-guide-8

 

 

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