Section A: What is an SMS Level 1 User?
An SMS Level 1 User is an individual authorised by a sponsor licence holder to carry out operational sponsorship tasks through the Sponsor Management System (SMS). The role sits at the centre of day-to-day licence administration and is the mechanism through which most sponsor duties are discharged in practice. While the sponsor organisation and its Authorising Officer retain overall responsibility for compliance, the actions taken by Level 1 Users on the SMS directly shape the sponsor’s risk profile and are closely scrutinised by UKVI during audits and enforcement action.
The Sponsor Management System is the Home Office’s digital platform for administering sponsor licences. Access to the system is restricted to nominated key personnel. Through the SMS, sponsors assign Certificates of Sponsorship, report prescribed changes relating to sponsored workers and the organisation, maintain licence details and receive compliance communications from UKVI. The system functions as the formal reporting and control interface between the sponsor and UKVI and is the primary evidence source used by the Home Office to assess whether sponsor duties are being met in practice.
1. Role of the SMS Level 1 User
The SMS Level 1 User is responsible for carrying out routine sponsorship activity using the system. This includes assigning and managing Certificates of Sponsorship, submitting mandatory reports within required timeframes, updating sponsor and worker records and responding to system notifications issued by UKVI. The role is operational rather than strategic, but errors made at this level are treated by the Home Office as failures of the sponsor’s compliance systems.
Although Level 1 Users have broad access to SMS functions, they do not hold legal responsibility in their personal capacity. UKVI enforcement action is taken against the sponsor licence holder, not the individual user. In practice, however, Home Office caseworkers will examine the accuracy, timing and consistency of actions taken by Level 1 Users when assessing whether the sponsor has met its duties. Weak SMS management is routinely cited in licence downgrades, suspensions and revocations.
2. Relationship with other key personnel
The Level 1 User operates alongside other key personnel roles recorded on the sponsor licence. These include the Authorising Officer, who has overall responsibility for sponsorship compliance and internal systems, and the Key Contact, who acts as the primary point of contact with UKVI. Level 2 Users may also be appointed to carry out limited SMS functions under the control of a Level 1 User.
The Authorising Officer decides how SMS access is structured within the organisation and is accountable for the conduct of all SMS users, including external representatives. Where responsibilities are poorly defined or overly delegated, UKVI will treat this as a governance failure rather than an individual mistake. For this reason, the Home Office expects sponsors to exercise clear oversight of Level 1 Users and to limit access to those who genuinely need it to perform their role.
3. Why the Level 1 User role matters in compliance terms
Sponsor licence breaches commonly stem from ongoing compliance failures recorded through the SMS. Late reporting, inaccurate entries, failure to withdraw Certificates of Sponsorship or incorrect handling of changes in worker circumstances are all assessed by reference to SMS records. In enforcement cases, UKVI routinely relies on system audit trails to demonstrate that a sponsor failed to meet its duties.
For sponsors, the practical implication is that the Level 1 User role needs to be treated as a controlled compliance function rather than a purely administrative task. Decisions about who holds SMS access, how many Level 1 Users are appointed and how their activity is supervised can materially affect the sponsor’s exposure to compliance action.
Section B: Who can act as an SMS Level 1 User?
Eligibility to act as an SMS Level 1 User depends on when the appointment is made and the sponsor’s licence structure. The Home Office applies different expectations at application stage compared with appointments made after a licence has been granted. Sponsors that apply a blanket rule without understanding these distinctions often expose themselves to avoidable compliance risk.
1. Eligibility at sponsor licence application stage
When applying for a sponsor licence, the organisation is required to nominate an initial Level 1 User on the online application form. At this stage, the Home Office expects the individual to be an employee, director or partner of the sponsoring organisation. The role cannot be filled by a third party at application stage.
In most cases, the initial Level 1 User is expected to be a settled worker. This includes British and Irish citizens and individuals who hold indefinite leave to remain or settled status. The Home Office treats this requirement as part of its assessment of organisational control and accountability at the point a licence is granted. Exceptions apply only in limited and route-specific circumstances, such as certain international agreement sponsors and UK Expansion Worker sponsors, which are subject to separate structural rules.
2. Eligibility after a licence has been granted
Once a sponsor licence is in place, additional Level 1 Users can be appointed through the SMS. These individuals do not always need to be settled workers, but they must be lawfully based in the UK and have permission to work. UKVI expects sponsors to be able to demonstrate that any additional Level 1 User has genuine authority to perform sponsorship functions and is subject to appropriate internal oversight.
At least one Level 1 User should continue to be an employee, director or partner of the sponsor organisation. While external appointments are permitted, UKVI does not accept a compliance structure that places full operational control of the SMS outside the sponsoring business.
3. Legal representatives and third-party providers
UK-based legal representatives and third-party HR providers can be added as Level 1 Users after a licence has been granted. Legal representatives must first be formally appointed on the SMS before access can be enabled. In all cases, the sponsor remains fully responsible for any action taken on its behalf.
UKVI expects sponsors to retain active oversight where third parties are appointed. During audits, caseworkers routinely examine contractual arrangements, reporting controls and escalation processes to assess whether the sponsor has improperly delegated its duties. Over-reliance on third-party Level 1 Users is frequently treated as a governance weakness rather than a mitigation.
4. Location and suitability requirements
All Level 1 Users must be based in the UK for the period during which they hold SMS access. Level 1 Users are expected to be based in the UK while holding SMS access. UKVI assesses location and organisational control rather than the technical method of system access.
Individuals must also meet Home Office suitability requirements, including checks relating to immigration status, compliance history and criminal convictions. These checks are carried out when the licence is assessed and can be repeated at any point during the licence validity period or following changes to key personnel.
Sponsors should assume that Level 1 User appointments will be reviewed retrospectively if compliance concerns arise. Selecting individuals who lack experience, authority or continuity is a common factor in enforcement action.
Section C: Who cannot act as an SMS Level 1 User?
The Home Office applies strict suitability and control requirements to anyone given Level 1 User access. Individuals who fall outside these requirements are treated as posing a compliance risk to the sponsor licence. Appointing an ineligible person, even unintentionally, can itself form the basis of enforcement action.
1. Individuals excluded by role or location
An SMS Level 1 User cannot be someone who is based outside the UK. Overseas representatives, advisers or group company staff do not qualify, regardless of seniority or corporate relationship. Temporary workers supplied by an employment agency are also excluded from acting as Level 1 Users. The Home Office does not accept that such individuals provide sufficient continuity or organisational control.
Contractors and consultants engaged for a specific project or short-term assignment are similarly unsuitable where their relationship with the sponsor does not give them ongoing authority over sponsorship functions. UKVI looks beyond job titles and examines the substance of the arrangement when assessing compliance.
2. Insolvency, disqualification and compliance history
Individuals with an undischarged bankruptcy cannot act as Level 1 Users. Nor can anyone who has been disqualified as a director under the Company Directors Disqualification Act 1986. These restrictions reflect the Home Office’s assessment of financial and governance risk rather than the technical ability to operate the SMS.
UKVI will also take into account an individual’s past involvement in sponsor licence breaches. Where a person has previously been associated with a sponsor that was downgraded, suspended or revoked, their appointment as a Level 1 User may trigger enhanced scrutiny or refusal to accept the change.
3. Criminal convictions and immigration offences
A person cannot act as a Level 1 User if they have relevant unspent criminal convictions as defined in Annex L4 of the sponsor guidance. This includes convictions relating to immigration offences, fraud, dishonesty or any offence that UKVI considers relevant to the discharge of sponsor duties.
The Home Office does not limit its assessment to formal convictions alone. Where there is evidence of behaviour that calls into question an individual’s reliability or integrity, UKVI may determine that they are unsuitable to hold SMS access. These assessments are discretionary and are often made in the context of wider compliance concerns.
4. Practical compliance implications
Sponsors should not treat eligibility checks as a one-off exercise. Changes in personal circumstances, immigration status or compliance history can affect a Level 1 User’s suitability over time. UKVI expects sponsors to monitor continued eligibility and to remove SMS access promptly where an individual no longer meets the requirements. Failure to do so is frequently cited in enforcement decisions.
Section D: How many SMS Level 1 Users can be appointed?
The Home Office allows sponsors a degree of flexibility in deciding how many Level 1 Users they appoint, but that flexibility is framed by expectations around control, oversight and effective governance. Problems arise where sponsors either restrict access too tightly or, at the other extreme, distribute Level 1 access too widely without adequate supervision.
1. Appointment limits at application stage
At the point of applying for a sponsor licence, only one Level 1 User can be nominated. That individual must be an employee, director or partner of the sponsoring organisation. Third parties cannot be appointed at this stage, and UKVI uses the identity of the initial Level 1 User as part of its assessment of whether the organisation has suitable internal systems to manage sponsorship duties.
If the sponsor licence is granted, that initial Level 1 User becomes the gatekeeper for further SMS access. Until access is in place and operational, no additional users can be added.
2. Appointments after licence grant
Once a sponsor licence has been granted, additional Level 1 Users and Level 2 Users can be added through the SMS. There is no fixed numerical cap on the number of Level 1 Users a sponsor can appoint. However, UKVI expects the number to be proportionate to the size, structure and sponsorship activity of the organisation.
Sponsors are expected to ensure that Level 1 User access remains under the control of an employee, director or partner of the organisation and that any loss of internal access is addressed promptly. Where all Level 1 Users are external representatives, this is routinely treated as a compliance weakness during audits, particularly if the sponsor is unable to demonstrate active oversight of SMS activity.
3. Interaction with Authorising Officer and Key Contact roles
There can only be one Authorising Officer and one Key Contact on a sponsor licence. Either or both of these roles can also be held by a Level 1 User, provided the individual meets the eligibility requirements for each position. Where roles are split between different individuals, each must be separately recorded on the SMS and granted the appropriate access level.
UKVI does not require the Authorising Officer or Key Contact to have SMS access as a matter of form, but in practice sponsors often grant access to allow effective oversight. Where senior personnel lack visibility of SMS activity, this can undermine the sponsor’s ability to demonstrate adequate compliance systems.
4. UK Expansion Worker provisional rating scenarios
Sponsors applying under the UK Expansion Worker route are subject to a provisional rating where the Authorising Officer is based overseas at the point of application. In these cases, the overseas Authorising Officer also acts as the initial Level 1 User. While the licence holds a provisional rating, no additional Level 1 Users can be added and changes to key personnel are restricted.
The licence can only be upgraded to an A-rating once the Authorising Officer has been granted entry clearance, entered the UK and updated their details on the SMS. Only after the licence has been uprated can the sponsor add further Level 1 Users or restructure SMS access. Failure to understand this sequencing is a common source of operational delay for expansion sponsors.
5. Governance considerations
UKVI expects sponsors to strike a balance between resilience and control. Having too few Level 1 Users can leave the sponsor exposed if access is lost due to staff departure or absence. Having too many can weaken accountability and increase the risk of inconsistent reporting. Decisions on the number of Level 1 Users should be documented and capable of explanation in the event of a compliance audit.
Section E: SMS Level 1 User duties
SMS Level 1 Users carry out the operational functions through which sponsor duties are discharged. While the Home Office does not treat the role as personally accountable for compliance, UKVI assesses sponsor performance largely by reference to the accuracy, timing and consistency of actions taken on the SMS. For that reason, the scope of Level 1 User duties needs to be clearly understood and tightly controlled.
1. Certificate of Sponsorship management
A core responsibility of the Level 1 User is the assignment and management of Certificates of Sponsorship. This includes assigning Defined and Undefined CoS to prospective sponsored workers, ensuring the information entered reflects the genuine role and employment conditions and withdrawing a CoS where the role is no longer available or the application is not proceeding.
Level 1 Users can also request increases to the sponsor’s allocation of Undefined CoS where this is permitted under the relevant route. UKVI expects these requests to be supported by credible workforce planning and compliance history. Poor quality or speculative requests can trigger wider scrutiny of the licence.
2. Reporting changes and sponsor notifications
Level 1 Users are responsible for submitting mandatory reports through the SMS when prescribed changes occur. These include reportable events relating to sponsored workers, such as non-attendance on the first day of work, unauthorised absence, changes in job duties, salary or work location and early termination of employment. Reports must be submitted within the timescales set out in sponsor guidance.
Organisational changes also need to be reported where required, including changes to trading address, corporate structure or ownership. The Home Office does not distinguish formally between minor and major changes. What matters is whether a change falls within the categories specified in the guidance and whether it is reported accurately and on time.
3. Managing SMS users and licence information
Level 1 Users have authority to add and remove Level 2 Users and, once the licence has been granted, to add additional Level 1 Users. They can update contact details for SMS users, view licence information and access system messages issued by UKVI. These messages often contain compliance instructions or requests for information and should be monitored regularly.
Although Level 1 Users can manage SMS access, the Authorising Officer remains responsible for oversight. UKVI expects sponsors to have internal controls governing who is appointed, what training is provided and how activity is reviewed.
4. Access to priority services
Where available, Level 1 Users can submit requests for priority or expedited Home Office services through the SMS and track the progress of those requests. Availability varies by route and capacity and is subject to change. Sponsors should not assume that expedited processing will be available or appropriate in all cases.
5. Compliance risk considerations
Errors made on the SMS are rarely treated as isolated administrative mistakes. UKVI uses SMS audit trails to assess whether sponsors have effective systems and controls in place. Repeated late reports, inconsistent data entries or failure to take corrective action following system messages are commonly cited in licence downgrades and suspensions. For sponsors, the practical risk lies not in individual errors but in patterns of SMS use that suggest weak governance.
Section F: What is the difference between Level 1 and Level 2 Users?
Understanding the distinction between Level 1 and Level 2 Users is central to structuring SMS access in a way that supports compliance rather than undermines it. UKVI does not view these roles as interchangeable. Each carries different permissions, expectations and risk implications for the sponsor.
1. Scope of access and authority
Level 1 Users are granted broad operational access to the Sponsor Management System. They can carry out most routine sponsorship functions, including assigning and withdrawing Certificates of Sponsorship, submitting sponsor and worker reports, managing SMS users and accessing system messages from UKVI. Their activity shapes the sponsor’s compliance record and is closely examined during audits.
Level 2 Users have more limited permissions. Their access is restricted to specific functions assigned to them by a Level 1 User. In most cases, this includes assigning Certificates of Sponsorship and reporting worker activity, but only in relation to CoS they have personally assigned or that have been transferred to them. They cannot manage SMS users, amend core licence details or submit certain categories of report.
2. Appointment and eligibility differences
Level 2 Users can only be appointed after a sponsor licence has been granted. Unlike Level 1 Users, they may be temporary staff supplied by an employment agency or individuals with a more limited relationship to the sponsor, provided they are lawfully based in the UK and meet suitability requirements.
At least one Level 1 User should be an employee, director or partner of the sponsor organisation. This requirement reflects UKVI’s expectation that ultimate operational control of the SMS sits within the business itself. There is no equivalent requirement for Level 2 Users.
3. Compliance and risk implications
Although Level 2 Users have narrower permissions, their actions still form part of the sponsor’s compliance record. Errors made by Level 2 Users are treated in the same way as errors made by Level 1 Users for enforcement purposes. The distinction lies not in liability but in governance. UKVI expects sponsors to use Level 2 access to delegate limited tasks while retaining central control through Level 1 Users.
Where sponsors rely heavily on Level 2 Users without adequate supervision, or where responsibilities are blurred between user levels, UKVI often concludes that internal controls are weak. Clear role definitions and documented oversight are therefore as important as the technical allocation of SMS permissions.
Section G: Changing, adding or removing SMS Level 1 Users
Changes to SMS Level 1 Users are treated by the Home Office as changes to key personnel and form part of the sponsor’s ongoing reporting obligations. How these changes are handled, and how quickly access is restored where it is lost, can materially affect the sponsor’s compliance position.
1. Making changes through the SMS
In most cases, changes to Level 1 Users are made directly through the Sponsor Management System by an existing Level 1 User. This includes adding additional Level 1 Users, removing access where an individual no longer performs the role and updating contact details. UKVI expects these changes to be recorded promptly and accurately.
Where a sponsor continues to operate with SMS access but fails to update user details, this is commonly identified during audits and treated as a record-keeping failure rather than a technical oversight.
2. Loss of SMS access scenarios
If a sponsor no longer has a Level 1 User with active SMS access, the system cannot be used to report changes or add new users. This most often arises where the only Level 1 User leaves the organisation unexpectedly or access is removed without a replacement in place.
In these circumstances, the sponsor is required to notify UKVI using the appropriate change of circumstances process outside the SMS to request that a new Level 1 User be added. Sponsors are expected to act quickly. Prolonged periods without SMS access are treated as a governance failure and frequently trigger further scrutiny.
3. Information required for new appointments
When adding or changing a Level 1 User, the sponsor must provide full contact details for the individual. The address supplied must correspond to the sponsor’s main trading address or an approved branch or head office recorded on the licence. Email addresses should be secure and personal to the individual, not shared inboxes.
Where available, the individual’s National Insurance number should be provided. UKVI uses this information to carry out background checks and to link the individual to its internal compliance and immigration records.
4. Ongoing monitoring and audit risk
UKVI does not treat Level 1 User changes as administrative housekeeping. In enforcement cases, caseworkers routinely examine the timing of appointments and removals, the continuity of SMS access and whether the sponsor maintained effective control during transition periods. Weak change management around Level 1 Users is a common factor in licence downgrades and suspensions.
Section H: Penalties for non-compliance
Where SMS Level 1 User activity reveals failures in sponsorship management, enforcement action is taken against the sponsor licence holder rather than the individual user. UKVI assesses compliance by reference to how the licence has been operated in practice, with SMS records forming a central part of the evidential picture.
1. Licence downgrades and action plans
Where UKVI identifies compliance failings that are capable of being remedied, the sponsor licence may be downgraded from an A-rating to a B-rating. This is commonly linked to late reporting, inaccurate SMS entries, poor record keeping or inadequate oversight of SMS users.
A sponsor that is downgraded is required to pay for and complete a Home Office action plan within the specified timeframe. During the action plan period, the sponsor is restricted from assigning Certificates of Sponsorship to new overseas recruits. Failure to meet the requirements of the action plan can result in further enforcement action.
2. Suspension and revocation
More serious or systemic compliance failures can result in suspension or revocation of the sponsor licence. Suspension is used where UKVI considers that further investigation is required. During suspension, the sponsor cannot assign new Certificates of Sponsorship and may be subject to a compliance visit.
Revocation is the most severe outcome. Where a licence is revoked, the sponsor immediately loses the ability to sponsor workers under any route. Existing sponsored workers are affected, as their visas are curtailed and they are required to find alternative sponsorship or leave the UK. In practice, revocation often follows sustained weaknesses in SMS management rather than a single error.
3. How Level 1 User activity feeds into enforcement decisions
UKVI does not treat SMS errors in isolation. Caseworkers look for patterns that suggest ineffective systems, inadequate training or poor governance. Repeated late reports, inconsistent data entries, failure to act on system messages or delays in withdrawing Certificates of Sponsorship are frequently cited as indicators that the sponsor has not met its duties.
Although Level 1 Users do not carry personal liability, their actions are treated as actions of the sponsor. Where enforcement action is taken, UKVI will rely heavily on SMS audit trails to support its decision. For sponsors, weak control of Level 1 User activity is often the underlying reason enforcement action escalates beyond informal engagement.
Section I: Best practice for sponsor licence holders
Effective use of SMS Level 1 Users is a governance issue rather than a purely administrative one. UKVI assesses sponsor compliance by looking at how sponsorship functions are embedded within the organisation, how access is controlled and whether there is evidence of ongoing oversight. Best practice is therefore shaped by risk management rather than convenience.
1. Maintaining continuous and controlled SMS access
Sponsors are expected to maintain effective access to the SMS throughout the life of the licence. While short periods of disruption can occur, prolonged gaps where no Level 1 User has access are treated as evidence of weak internal controls. Sponsors should plan for staff turnover, absence and role changes and ensure there is sufficient resilience without expanding access unnecessarily.
Access should be limited to those who genuinely require it. UKVI routinely questions arrangements where Level 1 access is widely distributed or where the sponsor cannot explain why particular individuals were given control of the system.
2. Training, oversight and internal controls
Level 1 Users should receive role-specific training that reflects current sponsor guidance and route-specific requirements. Generic HR training is rarely sufficient. UKVI expects sponsors to be able to demonstrate that SMS users understand reporting timeframes, the scope of reportable events and how to identify issues that require escalation.
Oversight should sit with the Authorising Officer or another senior individual with clear accountability. Regular internal reviews of SMS activity, including spot checks of recent reports and CoS assignments, are an effective way to identify emerging issues before they escalate into enforcement action.
3. Use of legal representatives and third parties
Where legal representatives or third-party HR providers are appointed as Level 1 Users, sponsors should document the scope of their authority and retain decision-making control. UKVI treats all actions taken by representatives as actions of the sponsor and does not accept lack of internal visibility as a defence.
Sponsors should carry out due diligence before appointing any external Level 1 User and review those appointments periodically. Where a representative’s involvement becomes routine rather than advisory, UKVI may conclude that the sponsor has improperly delegated its duties.
4. Monitoring continued eligibility and suitability
Eligibility to act as a Level 1 User is not static. Changes in immigration status, employment relationship or personal circumstances can affect suitability. Sponsors are expected to monitor continued eligibility and to remove SMS access promptly where an individual no longer meets the requirements.
UKVI carries out background checks on Level 1 Users when licences are assessed and can repeat those checks at any time. Where an unsuitable individual remains in post, enforcement action is directed at the sponsor rather than the individual concerned.
5. Audit readiness
In compliance visits and enforcement cases, UKVI routinely asks how SMS access is managed, who carries out day-to-day reporting and how errors are identified and corrected. Sponsors that can demonstrate structured decision-making, documented oversight and proportionate access controls are better placed to withstand scrutiny than those relying on informal arrangements.
Section J: Summary
An SMS Level 1 User role sits at the sharp end of sponsor licence compliance. It is where Home Office rules are applied in real time and where most enforcement problems begin. Sponsors often assume the risk lies in eligibility or policy, but in practice it is day-to-day SMS use that determines whether a licence remains secure. Who has access, how decisions are made, and how quickly issues are reported all feed directly into UKVI’s assessment of control and credibility. The legal responsibility stays with the sponsor, but weak governance around Level 1 Users is one of the most common triggers for audits, downgrades and licence loss. Treating SMS access as a controlled compliance function rather than an admin task materially reduces exposure.
Section K: Need assistance?
Managing SMS access and Level 1 User activity is one of the areas where sponsors most often underestimate compliance risk. Problems rarely arise from a lack of intent to comply. They arise because operational decisions about access, delegation and reporting are made without a full understanding of how UKVI assesses sponsor behaviour in practice.
Sponsor licence holders often seek advice after issues have already emerged, such as missed reports, inconsistent SMS records, loss of access following staff departures or Home Office queries triggered by system activity. At that stage, options can be more limited and enforcement risk higher.
DavidsonMorris provides specialist advice and support to sponsor licence holders on sponsor licence management, compliance audits and training for Level 1 Users, as well as support during Home Office audits and enforcement action. Early intervention is usually more effective than reactive defence once compliance concerns have been raised.
Section L: SMS Level 1 Users FAQs
What is an SMS Level 1 User?
An SMS Level 1 User is an individual authorised by a sponsor licence holder to manage day-to-day sponsorship activity using the Sponsor Management System. They carry out operational tasks such as assigning Certificates of Sponsorship, submitting reports and managing SMS users, but legal responsibility for compliance remains with the sponsor.
Who can be appointed as a Level 1 User?
The initial Level 1 User named in a sponsor licence application should be an employee, director or partner of the sponsor and is usually expected to be a settled worker. After a licence has been granted, additional Level 1 Users can be appointed, including UK-based legal representatives or third-party HR providers, provided eligibility and suitability requirements are met.
What are the main responsibilities of a Level 1 User?
Level 1 Users manage Certificates of Sponsorship, submit mandatory reports, update sponsor and worker records, manage SMS access and monitor system messages from UKVI. Their actions form part of the sponsor’s compliance record and are reviewed during audits.
Can a sponsor have more than one Level 1 User?
Yes. There is no fixed limit on the number of Level 1 Users a sponsor can appoint after a licence has been granted. At least one Level 1 User should remain an employee, director or partner of the sponsor to ensure internal control of SMS activity.
What happens if a Level 1 User leaves the organisation?
If SMS access is lost because the only Level 1 User leaves, the sponsor cannot make changes through the system. In these cases, the sponsor needs to notify UKVI using the appropriate change process to restore access. Delays in doing so can attract compliance scrutiny.
Can SMS management be outsourced?
Sponsors can appoint UK-based legal representatives or third-party HR providers as Level 1 Users after licence grant. However, the sponsor remains fully responsible for all actions taken on its behalf and is expected to retain oversight and decision-making control.
What are the consequences of poor Level 1 User management?
Weak SMS management can lead to sponsor licence downgrades, action plans, suspension or revocation. UKVI relies heavily on SMS records when assessing compliance, and patterns of error or delay are often treated as evidence of inadequate systems rather than isolated mistakes.
Section L: Glossary
| Term | Definition |
|---|---|
| Sponsor Management System (SMS) | The Home Office online system used by licensed sponsors to manage sponsorship activity, submit reports and administer Certificates of Sponsorship. |
| SMS Level 1 User | An individual authorised to carry out operational sponsorship functions on the SMS, including reporting and user management, on behalf of a sponsor licence holder. |
| Sponsor licence | Permission granted by the Home Office allowing an organisation to sponsor workers under the UK’s sponsored work visa routes. |
| Authorising Officer | The senior individual recorded on the sponsor licence who holds overall responsibility for sponsorship compliance and oversight of SMS users. |
| Key Contact | The person recorded on the sponsor licence as the main point of contact with UKVI on sponsorship-related communications. |
| Level 2 User | An SMS user with limited permissions who can carry out specific sponsorship tasks under the control of a Level 1 User. |
| Certificate of Sponsorship (CoS) | A digital record assigned by a sponsor to a worker, enabling them to apply for a sponsored work visa. It is not a physical certificate. |
| Defined CoS | A type of Certificate of Sponsorship used where the worker is applying for entry clearance from outside the UK under routes that require a defined allocation. |
| Undefined CoS | A type of Certificate of Sponsorship drawn from the sponsor’s annual allocation for eligible routes, typically used for in-country applications or where the route does not require a defined allocation. |
| UK Visas and Immigration (UKVI) | The Home Office division responsible for administering sponsor licences, deciding visa applications and taking compliance and enforcement action against sponsors. |
| Sponsor duties | The ongoing obligations on a sponsor licence holder, including reporting, record keeping, monitoring of sponsored workers and cooperation with UKVI compliance activity. |
| Compliance visit | A Home Office audit or site visit to assess whether the sponsor is meeting sponsor duties, including how the SMS is operated and how HR systems support sponsorship. |
| Sponsor licence downgrade | A compliance outcome where UKVI reduces a sponsor’s rating from A to B, usually requiring payment for an action plan and restricting the sponsor’s ability to assign new CoS. |
| Action plan | A paid Home Office plan imposed following a downgrade, setting out the steps and timeframe for a sponsor to improve compliance and regain an A-rating. |
| Sponsor licence suspension | A temporary enforcement measure preventing a sponsor from assigning new Certificates of Sponsorship while UKVI investigates compliance concerns. |
| Sponsor licence revocation | The removal of a sponsor’s permission to sponsor workers, usually following serious or sustained breaches of sponsor duties, resulting in curtailment of sponsored workers’ permission. |
| Provisional rating | A rating applied to UK Expansion Worker sponsor licences where the Authorising Officer is overseas at grant, restricting certain SMS actions until the licence is upgraded to an A-rating. |
Section M: Additional resources and links
| Resource | What it covers | Link |
|---|---|---|
| Sponsor guidance: Part 1 | Overview of sponsor licences, key personnel roles, suitability requirements and how UKVI assesses compliance. | https://www.gov.uk/government/publications/sponsor-a-worker-guidance-for-employers-and-educators-part-1-apply-for-a-licence |
| Sponsor guidance: Part 2 | Detailed sponsor duties, reporting requirements, record keeping and compliance expectations. | https://www.gov.uk/government/publications/sponsor-a-worker-guidance-for-employers-and-educators-part-2-sponsor-a-worker |
| Sponsor guidance: Part 3 | Compliance visits, enforcement action, downgrades, suspensions and revocation procedures. | https://www.gov.uk/government/publications/sponsor-a-worker-guidance-for-employers-and-educators-part-3-sponsor-duties-and-compliance |
| Appendix D: Record keeping | Documents sponsors are expected to retain for sponsored workers and key personnel. | https://www.gov.uk/government/publications/sponsor-a-worker-guidance-appendix-d-keeping-records |
| Annex L4: Suitability checks | Criminality, immigration history and suitability criteria for sponsor key personnel, including Level 1 Users. | https://www.gov.uk/government/publications/sponsor-a-worker-guidance-appendix-l-suitability-requirements |
| Sponsor Management System guidance | Practical guidance on using the SMS, including user roles, reporting functions and system access. | https://www.gov.uk/uk-visa-sponsorship-employers/sponsor-management-system-sms |






