Authorising Officer: UK Sponsor Role

Section A: What is an Authorising Officer?

When you are applying for a sponsor licence, you will be required to nominate certain key personnel to manage the sponsorship process, including an Authorising Officer.

An Authorising Officer is the senior individual within a UK business responsible for managing and overseeing compliance with Home Office sponsorship duties. This role is a key requirement for holding a sponsor licence and must be filled by someone in a position of authority, such as a company director or HR manager.

The Authorising Officer is accountable for ensuring the organisation adheres to UK Visas and Immigration (UKVI) rules, including reporting duties, record-keeping and preventing illegal working. Failure to meet these obligations can lead to licence suspension or revocation, putting the business’s ability to sponsor skilled foreign workers at risk.

1. Who can be an Authorising Officer?

The Authorising Officer (AO) must be the most senior person within your organisation responsible for the recruitment of migrant workers and ensuring compliance with all sponsor duties. They must be a paid member of staff or office-holder permanently based in the UK for the duration of their role.

From 31 December 2024, updated guidance clarifies that at least one Level 1 User must be a settled person, such as a British citizen or someone with indefinite leave to remain, who is also a director, employee or partner in the organisation. While this applies widely, sponsors should check route-specific guidance to confirm whether combining roles in a single person is acceptable.

For UK Expansion Worker sponsor licences, if there are no suitable staff based in the UK, an overseas worker may be appointed as the AO. However, they must obtain entry clearance specifically to oversee the UK expansion. Once in the UK, they must update their details in the Sponsorship Management System (SMS) and request an upgrade from a ‘Provisional’ licence to an ‘A-rating‘.

2. Who cannot be an Authorising Officer?

When assessing an application for a sponsor licence, UK Visas and Immigration (UKVI) will consider the background and suitability of both the employer and all nominated key personnel, where UKVI is the division of the Home Office responsible for sponsor licences.

To be eligible, the AO must not:

• Have unspent criminal convictions for a relevant offence.
• Have a history of non-compliance with sponsor requirements.
• Have been a key person at a sponsor whose licence was revoked in the last 12 months.
• Have been fined by UKVI in the past 12 months.
• Have been reported to UKVI for non-compliance.
• Be legally prohibited from being a company director.
• Be subject to a bankruptcy or debt relief restriction order or undertaking.
• Have failed to pay VAT or any other excise duty.

3. Can a legal representative be an authorising officer?

A legal representative cannot usually be appointed as the Authorising Officer (AO). The AO must be a senior member of the organisation responsible for compliance with sponsor licence duties. This means they must be directly employed by the sponsoring organisation and have authority over recruitment and compliance processes. While legal representatives can provide advice and manage administrative tasks through the Sponsorship Management System (SMS) as a Level 1 or Level 2 User, they cannot take on the AO role.

4. Does the authorising officer have to be a UK resident or British citizen?

In most cases, the AO must be permanently based in the UK for the entire period they hold the role. They do not have to be a British citizen but must have the right to work and live in the UK, e.g., holding Indefinite Leave to Remain, Settled Status, or a visa allowing them to work.

The only exception applies to UK Expansion Worker sponsor licences. If an organisation does not yet have a presence in the UK, an overseas employee can be appointed as the AO. However, they must obtain a visa to enter the UK to oversee the expansion and must update their details in the SMS once in the UK.

For all other sponsor licence types, the AO must meet the UK residency requirement and cannot be an overseas-based individual.

Section B: Authorising Officer duties & responsibilities

In broad terms, the Authorising Officer will be the individual with overall responsibility for the recruitment of migrant workers within the organisation applying for a sponsor licence and for ensuring that the duties placed on the sponsoring organisation are met. This will include monitoring migrant workers, keeping records and reporting any relevant changes.

The Authorising Officer will also be responsible for the activities of each individual using the sponsorship management system (SMS). The SMS is the Home Office portal that allows authorised users to administer day-to-day sponsorship duties and activities including, for example, assigning Certificates of Sponsorship (CoS) to migrant workers. The CoS contains a unique reference number that will allow new recruits to apply for a work visa.

There are two levels of user that can be authorised to access the SMS. These include Level 1 Users and Level 2 Users, where the Authorising Officer will be responsible for deciding how many staff need to have access to the SMS and what level of permission they can have.

A single Level 1 User will initially be named within the sponsor licence application. If the application is approved, they will be given access to the SMS, enabling them to appoint additional Level 1 Users, as well as Level 2 Users. Both types of SMS-user will have direct access to the online system, although Level 2 Users will have fewer permissions. However, in either case, it is important that no more SMS-users are appointed than are needed to manage the daily activities and licence of the sponsoring organisation, as the Authorising Officer will be ultimately responsible for the actions of anyone authorised to use the SMS.

In addition to the matters set out above, the Authorising Officer may also be required to liaise with UKVI both during and after the sponsor licence application. The Key Contact is the main point of contact between your organisation and UKVI, although UKVI may also contact the Authorising Officer. This means that the Authorising Officer must be available to respond to any queries raised by UKVI, not least throughout the application process.

1. Does an Authorising Officer have access to the SMS?

The Authorising Officer will not automatically have access to the SMS on the grant of a sponsor licence, not unless they have also been appointed as an SMS Level 1 User. If the Authorising Officer has not been named as the initial SMS Level 1 User within the licence application, but they would like to have access to the SMS, they will need to be added as either an SMS 1 Level or Level 2 User once the application has been approved.

Any Level 1 User will be responsible for carrying out the day-to-day management of the sponsor licence using the SMS, from assigning CoS and reporting migrant worker activities, to updating the sponsor licence details. The Level 1 User can also appoint additional SMS-users. Importantly, a Level 2 User will only be authorised to carry out limited SMS activities, including assigning CoS and reporting migrant worker activities on any CoS that they have personally assigned. This means that if the Authorising Officer would like to access and use all functions on the SMS, they should be appointed as a Level I User.

Ideally, to monitor and manage the activities of all SMS-users, the Authorising Officer should regularly access the SMS, to ensure that they are kept up-to-date with the latest news and messages from UKVI, and that all authorised users are abreast of any input or changes needed. The Authorising Officer should also ensure that the licence details are in order and overseeing any changes to key personnel.

Importantly, if you are applying for a licence on the UK Expansion Worker route and your Authorising Officer is based overseas at the time of the application, that person must be nominated as the initial Level 1 User. Once a licence has been granted, they will have access to the SMS to be able to appoint additional SMS-users, where necessary.

2. How to report a change in Authorising Officer

You must have an Authorising Officer in place throughout the life of your licence. This means that if your appointed officer is leaving the business, you must find a replacement and report this to the Home Office via the SMS.

Changes to your Authorising Officer must be reported via the SMS within 20 working days of the change, unless it involves replacing the Authorising Officer or Key Contact, in which case additional requirements such as signed declarations and supporting documentation apply.

To change your Authorising Officer, an authorised SMS Level 1 User must navigate the ‘Request changes to licence details’ on the SMS. After selecting the ‘Replace your Authorising Officer’ function, all mandatory fields must be completed before choosing ‘Next’ to continue. These fields require the personal details of the replacement Authorising Officer, including their title and name, as well as their immigration status, the expiry date of their leave to enter or leave to remain in the UK, together with their passport number.

The Level 1 User must next provide their name and position within the organisation, and date the ‘Request change of circumstances declaration’. They must tick the declaration box and electronically sign the declaration which states that the information given is, to the best of their knowledge and belief, true and correct, before selecting ‘Submit’. Once a request to replace an Authorising Officer has been submitted, changes to this request cannot be made.

The submission sheet and supporting documents have to be emailed to UKVI within 5 working days of submitting the application. Retain a copy of the submission sheet and a note of the change request reference number for your own records.

You can view the progress and outcome of the request using the SMS.

The SMS function to replace the Authorising Officer must only be used if this role is to be assumed by a different person. If the details of the existing officer simply need to be amended, the SMS Level 1 User should instead use the ‘Amend your current Authorising Officer’s details’ function. If the new AO will also be the Key Contact, the SMS Level 1 User will only need to complete one request. If this is the case, they can use either the ‘Replace your Authorising Officer’ or ‘Replace your Key Contact’ function.

3. Authorising Officer compliance breaches

Any failure on the part of the Authorising Officer to comply with their duties, including ensuring compliance on the part of all SMS-users, may result in action being taken against you as the sponsor licence holder. Depending on the gravity of the breach, this could include a decision to downgrade your sponsor licence, or to suspend or revoke your licence.

A decision to revoke your licence is only likely to be made where there has been a significant or systematic failing, and you are deemed to pose a serious threat to immigration control, typically following suspension of your licence pending investigation.

However, even in less serious cases of alleged breach, the consequences can be far-reaching. For example, having your licence downgraded will result in a time-limited action plan at a cost to you of £1,579, where you will not be permitted to assign fresh CoS until the measures set out in that plan have been implemented and your licence has been upgraded.

Where your Authorising Officer, or those whose activities they are responsible for, have failed to conduct prescribed right to work checks, and you are found to be employing illegal workers, this could also result in a civil penalty.

Section C: Authorising Officer & Home Office Audits

A Home Office audit can occur at any point during the life of a sponsor licence, and the Authorising Officer will be central to the inspection. UKVI’s assessment focuses not just on whether required systems exist but on whether they are actively used and monitored under the AO’s leadership. An audit can confirm compliance and strengthen UKVI’s trust in the sponsor, or it can expose weaknesses that lead to licence downgrading, suspension or revocation. For this reason, readiness should be an ongoing operational priority rather than a reaction to notice of a visit.

1. Audit triggers

UKVI may conduct a compliance visit for a variety of reasons. These include random spot checks, site visits linked to a new or renewal licence application, intelligence-led investigations following a reported concern, or follow-up after a previous audit identified weaknesses. Sudden increases in sponsored workers or repeated errors in reporting can also prompt scrutiny.

2. AO focus during audits

Inspectors will assess the AO’s direct involvement in compliance, including how they control SMS user access, ensure deadlines are met, and verify that assigned Certificates of Sponsorship meet eligibility requirements. They will want evidence of active leadership, not a passive or delegated approach.

3. Evidence requirements

The AO should be able to produce, without delay, records such as right to work checks for each sponsored worker, CoS assignment logs, evidence of role advertisements where required, and SMS access records showing who has made changes. Records must be complete, accurate and dated, with an audit trail showing who approved each action.

4. AO interview expectations

During an audit, the AO may be asked about how recruitment decisions are made, how compliance issues are identified and escalated, and what checks are done before and after a CoS is assigned. Inconsistent or hesitant answers can undermine confidence, so preparation and familiarity with current sponsor duties are essential.

5. Pre-audit readiness steps

A robust AO will schedule regular internal audits of all sponsor licence records, keep SMS access under review, and ensure all reporting is completed within the required timeframe. Compliance files should be maintained in a way that allows immediate retrieval of requested evidence. Any issues identified internally should be documented along with corrective actions taken.

6. Common audit failures

Frequent causes of adverse findings include incomplete right to work checks, delays in reporting changes to migrant worker circumstances, unauthorised SMS access, and an AO who cannot demonstrate oversight. Each of these can be avoided with consistent record-keeping, timely reporting, and active monitoring of all licence activities.

7. Unannounced visit protocols

If inspectors arrive without notice, the AO should take control of the situation. This includes greeting the inspection team, confirming their identification, notifying relevant internal stakeholders, and ensuring immediate access to requested records. The AO should remain present during interviews and site checks to address questions and clarify processes.

Conclusion

An AO who treats audit readiness as a standing responsibility, rather than an event-driven task, is far less likely to face adverse Home Office findings. Active oversight, accurate records, and clear protocols for both scheduled and unannounced visits protect the licence and demonstrate to UKVI that the sponsor is committed to maintaining high compliance standards.

Section D: Interaction Between AO, Key Contact and Level 1 User in Practice

While the Home Office guidance sets out the formal duties of the Authorising Officer, Key Contact and Level 1 User, it offers little on how these roles actually operate together in the real world. In practice, the effectiveness of a sponsor licence often depends less on the statutory definitions and more on how these individuals coordinate, share information and maintain oversight. Poor interaction between these roles is a common root cause of compliance breaches that result in licence downgrades or revocation. Understanding the operational relationship between them is therefore vital to maintaining both compliance and efficiency.

1. Practical roles overview

When applying for a sponsor licence, you will be required to nominate three key personnel: the Authorising Officer, a Key Contact and the initial SMS Level 1 User.

The Authorising Officer provides strategic oversight and holds ultimate responsibility for meeting sponsor duties. The Key Contact acts as the formal liaison with UKVI, ensuring queries, requests for evidence and updates are addressed promptly. The Level 1 User is the operational driver within the SMS, implementing updates, assigning Certificates of Sponsorship and reporting changes. Each role must be distinct in accountability, yet interlinked in communication and process.

As the main point of contact between your organisation and UKVI, the Key Contact will be mainly responsible for liaising with UKVI, either during the application process or after the grant of a sponsor licence. This could entail responding to requests made in writing for additional information or documentation to support the licence application. It could also be providing access to any UKVI compliance officer conducting a pre- or post-licence site visit to ensure that the sponsoring organisation is capable of meeting all its sponsor duties.

As the individual(s) responsible for carrying out the day-to-day management of the sponsor licence using the SMS, the Level 1 User will be responsible for all of the following:

• managing key personnel and licence details
• creating, assigning and viewing CoS
• applying for and assigning restricted CoS
• reporting changes to a migrant worker’s circumstances
• reporting changes to the sponsor’s own circumstances
• renewing CoS allocations and applying for additional CoS
• applying for the premium customer service
• tracking premium licence applications
• paying for and tracking the progress of action plans

For any Level 2 Users appointed by a Level 1 User, they will be responsible for creating and assigning CoS and reporting migrant worker activities on any CoS that they have created and assigned. However, their access to the SMS is more restricted than for a Level 1 User, for example, they cannot report on CoS assigned by Level 1 Users.

It is possible to appoint just one person to fill all the key personnel roles, although much will depend on the predicted size of the sponsored migrant workforce and the extent of the responsibilities that will arise from this. In a large organisation, or where you are looking to recruit a number of migrant workers to fill essential skills gaps in your business, you may want to appoint different people to each of the three roles. Additional Level 1 and Level 2 users may also be needed to be able to adequately meet your sponsor duties.

2. Day-to-day collaboration

A well-run sponsorship system typically sees the AO set policy, authorise major decisions and review compliance reports. The Level 1 User initiates operational tasks, such as updating migrant worker records or reporting changes in employment status. The Key Contact manages the flow of information with UKVI, often working closely with the Level 1 User to ensure responses are factually correct and supported by evidence. In practice, small organisations may combine these duties into one or two individuals, but the same principles of communication and accountability still apply.

3. Overlapping duties

Some functions naturally cross over. For example, reporting a change in a sponsored worker’s role requires the Level 1 User to make the SMS entry, the AO to ensure the change is compliant with visa conditions and the Key Contact to address any UKVI follow-up queries. Without clear protocols, duplication or omission of steps can occur, leading to inconsistent records or missed reporting deadlines.

4. Common operational challenges

In many organisations, the AO is appointed in name but has little day-to-day engagement with SMS operations. This can create blind spots, especially if the Level 1 User is unfamiliar with the wider compliance framework. Miscommunication between the Key Contact and Level 1 User can delay responses to UKVI, while unclear delegation may result in unapproved actions being taken in the SMS. Access issues, such as the AO not having their own login, can further limit oversight and weaken the audit trail.

5. Best practice coordination models

In small organisations, a single person may hold all three roles but should still separate functions in their workflow to avoid errors. In medium-sized businesses, the AO should receive monthly compliance summaries from the Level 1 User and maintain direct access to the SMS. In large organisations, it is best to establish a compliance team, with the AO chairing quarterly reviews, the Key Contact managing UKVI interactions and the Level 1 User leading on day-to-day SMS tasks, supported by additional Level 1 and Level 2 Users where needed.

6. Risk management strategies

Clear written procedures, role-specific checklists and regular internal audits reduce the risk of missed deadlines or incorrect reporting. Decisions affecting sponsored workers should be documented with both operational and strategic sign-off, ensuring an audit-ready trail of evidence. The AO should have sight of all key compliance actions, either through direct SMS access or through regular status reports, and any delegation should be documented to show maintained oversight.

Section E: AO Training and Development

The Authorising Officer role demands more than a one-off understanding of sponsor licence duties. To remain effective and audit-ready, an AO must continually develop their knowledge and skills in line with evolving immigration rules and Home Office expectations. Training is not just about meeting initial competency; it is about sustaining oversight, ensuring operational consistency, and maintaining the organisation’s ability to comply with sponsorship requirements over the long term.

1. Initial induction training

On appointment, an AO should receive targeted induction training covering the organisation’s sponsor duties, reporting obligations, record-keeping standards, and the operational use of the Sponsor Management System (SMS). This early stage is also the time to establish familiarity with key timelines, such as deadlines for reporting changes in sponsored worker circumstances, and to understand the internal processes for approving and recording sponsorship decisions.

2. Home Office and UKVI resources

Official guidance from the Home Office and UKVI should be a core reference point for any AO. This includes regularly updated sponsor guidance documents, bulletins issued via the SMS, and UKVI-hosted webinars or briefings. Subscribing to official update services ensures that the AO receives early notice of procedural or policy changes that may affect their role.

3. In-house compliance training

Internal training programmes should cover recruitment procedures, right to work check requirements, and escalation routes for compliance concerns. These sessions should be delivered not only to the AO but also to other key personnel, ensuring that the wider team understands its role in meeting sponsor licence obligations. Regular internal refreshers help maintain a culture of compliance and reduce the risk of process drift.

4. Third-party training providers

External training can deepen the AO’s understanding of complex compliance issues, provide practical case studies, and offer updates on best practice in licence management. Specialist providers often cover scenario-based learning, helping AOs prepare for real-world challenges such as responding to Home Office audits or managing high-risk sponsorship situations.

5. Refresher training schedule

An AO’s training should be reviewed and updated at least annually, or sooner if significant immigration rule changes occur. Refresher training is particularly important after any compliance breach, internal audit finding, or Home Office policy update. The schedule should be documented and incorporated into the organisation’s wider compliance framework.

6. Knowledge-sharing practices

To embed compliance within daily operations, AOs should actively share updates and learning with the Key Contact and Level 1 Users. This can take the form of briefings, email updates, or joint training sessions. Transparent communication ensures that operational staff and strategic oversight remain aligned in meeting sponsor obligations.

7. Training record-keeping

All AO training, whether internal or external, should be recorded with dates, content outlines, and attendance evidence. These records may be requested by UKVI during an audit to demonstrate that the AO is maintaining the necessary competence to perform the role effectively.

Section F: Summary

The Authorising Officer role is central to a UK sponsor licence, carrying ultimate responsibility for meeting all Home Office compliance obligations. The AO’s oversight of recruitment, record-keeping, and reporting directly impacts the organisation’s ability to sponsor overseas workers. Appointing a suitable, eligible, and capable individual is not only a licensing requirement but also a safeguard against compliance breaches that can lead to licence downgrades, suspension, or revocation.

Section G: Need assistance?

DavidsonMorris are UK sponsor licence specialists. We provide expert guidance to employers with sponsor licence application and ongoing compliance and management, including delivering training to key personnel such as authorising officers and providing advice on who can be appointed as an authorising officer.

We are also helping AOs with preparation for an eventual transition to the UKVI’s new Sponsor UK system.

For specific advice, contact us.

Section H: Authorising Officer FAQs

What is an Authorising Officer in UK visa sponsorship?

An Authorising Officer is a senior staff member appointed by a business to oversee its sponsor licence responsibilities. They ensure compliance with Home Office rules and manage key personnel related to sponsorship duties.

Who can be an Authorising Officer?

The Authorising Officer must be a senior and competent employee, typically in a leadership or compliance role. They must be based in the UK and not have any unspent criminal convictions or history of non-compliance with immigration rules.

What are the main responsibilities of an Authorising Officer?

They are responsible for ensuring the organisation complies with all sponsor duties, overseeing the Sponsor Management System (SMS), ensuring record-keeping is up to date, and responding to Home Office compliance visits or audits.

Can an Authorising Officer delegate their responsibilities?

While they can assign tasks to other key personnel, the Authorising Officer remains ultimately responsible for ensuring compliance with sponsorship duties.

Can an Authorising Officer be changed?

A change in Authorising Officer must be reported to the Home Office via the SMS within 20 working days.

What happens if the Authorising Officer fails to meet compliance duties?

Failure to meet compliance obligations can lead to a sponsor licence suspension, downgrading, or revocation, affecting the ability to sponsor migrant workers.

Does an Authorising Officer need to be an expert in immigration law?

While not a legal expert, they must understand the Home Office’s sponsorship requirements and ensure the organisation follows all relevant rules. Regular training and compliance checks can help maintain standards.

Section I: Glossary

Section J: Additional Resources and Links