Authorising Officer: Compliance Guide

authorising officer sms


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.

The following comprehensive guide to the Authorising Officer role looks at who can and cannot fill this position, together with a detailed account of the Authorising Officer’s responsibilities and duties, as well as how to report a change in the person filling this role.


Who can be an Authorising Officer?

The Authorising Officer must be the most senior person within your organisation that is responsible for the recruitment of all migrant workers and ensuring that all of your sponsor duties are met, provided you are approved for a licence. Additionally, they must be either a paid member of staff or office-holder that is permanently based in the UK for the period of time that they will fill the key personnel role which they have been appointed to.

The only exception to this rule is if you are applying for a UK Expansion Worker sponsor licence, where you can appoint an overseas worker as your Authorising Officer if you do not have suitable staff based in the UK to fill this role. However, the Authorising Officer must be granted entry clearance for the purpose of work on the UK expansion of your business.


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 deemed by UKVI as suitable for this role, this means that the Authorising Officer must not have any unspent criminal convictions for a relevant offence, nor a history of non-compliance with sponsor requirements. The Authorising Officer must also not:

  • be guilty of any previous immigration violations
  • have been a key person with a sponsor that had its licence 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.


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.


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, overseeing any changes to key personnel and renewing the licence prior to its expiry.

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.


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.

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.

From the ‘Submission successful’ screen, the submission sheet must be printed, completed and sent to UKVI by post, together with any supporting documentation, if applicable. The submission sheet declaration must be signed by the new Authorising Officer. A copy of the submission sheet and a note of the change request reference number should be retained 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. Additionally, 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.


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 £1,476, 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 for whom activities they are responsible, 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.


Other sponsor licence key personnel

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.

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 and licence renewal 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.


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. For specific advice, contact us.


Authorising officer FAQs

Does Authorising Officer have access to SMS?

The Authorising Officer will not automatically have access to the sponsorship management system (SMS), not unless they are also appointed as an SMS Level 1 User in the sponsor licence application. However, they can subsequently be added as an SMS-user.

What does Authorising Officer mean?

The Authorising Officer refers to the person with overall responsibility for the recruitment of migrant workers within the organisation applying for a sponsor licence. They will also be responsible for managing the activities of those using the sponsorship management system.

How do I change my Authorising Officer on SMS?

To change your Authorising Officer on the sponsorship management system (SMS), an authorised SMS Level 1 User must access the online system, navigating the ‘Request changes to licence details’ function and selecting ‘Replace your Authorising Officer’, before providing relevant details.

Can Authorising Officer be Level 1 User?

An Authorising Officer can also be appointed as a Level 1 User, either if they are nominated in the sponsor licence application as the initial Level 1 User or added as a Level 1 User once the licence is granted.

Last updated: 3 September 2023


Founder and Managing Director Anne Morris is a fully qualified solicitor and trusted adviser to large corporates through to SMEs, providing strategic immigration and global mobility advice to support employers with UK operations to meet their workforce needs through corporate immigration.

She is a recognised by Legal 500 and Chambers as a legal expert and delivers Board-level advice on business migration and compliance risk management as well as overseeing the firm’s development of new client propositions and delivery of cost and time efficient processing of applications.

Anne is an active public speaker, immigration commentator, and immigration policy contributor and regularly hosts training sessions for employers and HR professionals

About DavidsonMorris

As employer solutions lawyers, DavidsonMorris offers a complete and cost-effective capability to meet employers’ needs across UK immigration and employment law, HR and global mobility.

Led by Anne Morris, one of the UK’s preeminent immigration lawyers, and with rankings in The Legal 500 and Chambers & Partners, we’re a multi-disciplinary team helping organisations to meet their people objectives, while reducing legal risk and nurturing workforce relations.

Legal Disclaimer

The matters contained in this article are intended to be for general information purposes only. This article does not constitute legal advice, nor is it a complete or authoritative statement of the law, and should not be treated as such. Whilst every effort is made to ensure that the information is correct at the time of writing, no warranty, express or implied, is given as to its accuracy and no liability is accepted for any error or omission. Before acting on any of the information contained herein, expert legal advice should be sought.

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