How to Change Sponsor Licence Key Personnel

Change of Sponsor Licence Key Personnel: At a Glance

Employers can change sponsor licence key personnel during the life of the licence, including the Authorising Officer, Key Contact and Level 1 Users.

Most changes are made through the Sponsor Management System (SMS), but the correct process depends on whether the employer is amending an existing record, replacing a role holder, adding a new user or removing access.

Changes need to be sequenced carefully. Sponsors are required to maintain an eligible Authorising Officer and at least one eligible Level 1 User throughout the life of the licence, and a departing individual may hold several sponsor roles at the same time.

 

Section A: How to Change Sponsor Licence Key Personnel

 

Changing sponsor licence key personnel starts with identifying exactly what is changing and every sponsor role affected by the move. A departure, promotion or internal transfer can involve more than one Home Office record where the same individual acts as Authorising Officer, Key Contact and Level 1 User.

The employer then needs to establish the correct Home Office process, check that any replacement satisfies the requirements for the role and preserve appropriate SMS access throughout the handover.

Under the Home Office sponsor guidance, a sponsor is required to maintain an eligible Authorising Officer and at least one eligible Level 1 User throughout the life of its licence. Failure to maintain these mandatory personnel arrangements can result in revocation of the sponsor licence.

Succession planning is therefore particularly important where somebody is leaving the organisation. Removing the outgoing person’s SMS access before replacement arrangements are in place can leave the employer without effective Level 1 User access at the point it still needs to manage reporting, Certificates of Sponsorship or other sponsor licence activity.

Replacement personnel also need to satisfy the Home Office requirements applying to the particular role. Seniority within the business does not, by itself, establish eligibility to act as sponsor key personnel.

 

1. Which key personnel change do you need to make?

 

The first step is to identify the precise change required. The procedure will depend on whether the sponsor is amending information about an existing role holder, replacing that person, adding a new SMS user or removing access that is no longer required.

 

Situation	Action generally required
A different person is becoming Authorising Officer	Replace the Authorising Officer
The existing Authorising Officer remains in the role but their details have changed	Amend the Authorising Officer’s details
A different person is becoming Key Contact	Replace the Key Contact
The existing Key Contact remains in the role but their details have changed	Amend the Key Contact’s details
Another individual requires Level 1 SMS access	Add a Level 1 User, subject to the applicable eligibility requirements
An existing Level 1 User is leaving or no longer requires access	Remove or deactivate their SMS access once appropriate continuity arrangements are in place
The sponsor has no active Level 1 User able to access the SMS	Use the relevant Home Office sponsor change of circumstances process to restore Level 1 User access
The sponsor still has existing Level 2 Users	Review whether each user should be upgraded to Level 1, if eligible, or deactivated under the September 2026 transitional arrangements

 

2. Amending key personnel is different from replacing them

 

Employers should distinguish between amending an existing key personnel record and replacing the individual who holds the role.

If the same person remains in the role but their relevant details have changed, the sponsor will generally need to amend the existing record.

If responsibility is moving to another individual, the sponsor will generally need to replace the existing role holder.

A useful practical rule is:

Same person, new details = amend.

Different person taking over = replace.

The distinction affects which SMS function the employer should use and can also affect the Home Office checks, declarations and supporting evidence required for the change.

 

3. Check every role held by the outgoing individual

 

Before submitting a change, the sponsor should map every key personnel role, SMS permission and sponsorship responsibility held by the person who is leaving or changing duties.

An outgoing Authorising Officer may also be the Key Contact and the organisation’s only Level 1 User. Replacing that individual solely as Authorising Officer would leave the other positions and SMS access arrangements unresolved.

The sponsor should establish:

• which key personnel roles the individual currently holds;
• whether they have Level 1 SMS access;
• whether another active Level 1 User will remain;
• whether the proposed replacement satisfies the requirements for the relevant role;
• whether any supporting evidence will be required;
• whether other sponsor licence changes are taking place at the same time; and
• when the outgoing person’s SMS access should be removed.

Where the outgoing person is the sponsor’s only Level 1 User, sequencing becomes critical. Removing access before replacement arrangements are operational can leave the organisation unable to administer its sponsor licence through the normal SMS process.

A controlled changeover should preserve appropriate access, establish eligible replacement personnel, complete the required Home Office process and remove obsolete access once continuity has been secured.

 

4. Treat key personnel changes as a sponsor compliance process

 

Key personnel determine who carries senior responsibility for the sponsor licence, who communicates with the Home Office and who can carry out sponsorship activity through the SMS. Changes to those roles should therefore be built into the employer’s wider sponsor compliance controls.

Leaver, promotion and organisational-change procedures should identify whether the individual holds any sponsor licence role or SMS access before employment or responsibilities change. Where possible, replacement arrangements should be resolved before company email, telephone access or SMS credentials are disabled.

The objective is to complete the changeover without interrupting the sponsor’s ability to meet its reporting, record-keeping and wider sponsorship duties.

 

 

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Section B: When Do You Need to Change Sponsor Licence Key Personnel?

A change to sponsor licence key personnel may be required whenever the individuals responsible for managing the licence, communicating with the Home Office or operating the Sponsor Management System change, or where their recorded details are no longer accurate.

Common situations include where:

• an Authorising Officer, Key Contact or Level 1 User leaves the organisation;
• an employee moves to another role and no longer has responsibility for sponsorship;
• responsibility for immigration compliance moves to another department or senior manager;
• an existing key person no longer meets the requirements applying to their role;
• the organisation wants to appoint additional Level 1 Users to improve operational resilience;
• an external representative is appointed or ceases to act in a permitted sponsor role;
• the organisation restructures its HR, mobility or compliance function;
• the contact or personal details recorded for an existing key person change;
• an SMS user’s access needs to be withdrawn because they no longer require it; or
• historic SMS user arrangements need to be reviewed following organisational or Home Office system changes.

The sponsor should distinguish between a change to the person holding the role and a change to the details of the existing role holder.

Where the individual remains the same, the appropriate action may simply be to amend their details. Where responsibility is transferring to somebody else, the sponsor will generally need to replace the existing role holder or add the new user, depending on the role concerned.

 

1. Plan changes before the individual leaves

 

Where a departure is known in advance, the sponsor should identify the sponsorship implications before the individual’s employment or responsibilities end.

This should include checking:

• which sponsor key personnel roles the individual holds;
• whether they are also an SMS user;
• whether another active Level 1 User will remain;
• whether the proposed replacement satisfies the applicable Home Office requirements;
• whether supporting evidence will be needed;
• whether any time-sensitive sponsorship activity is due during the handover period; and
• when the outgoing person’s SMS access should be removed.

This is particularly important where the individual is the organisation’s only Level 1 User. If their account is deactivated before replacement access is established, the sponsor may lose the ability to make the required changes through the normal SMS process.

 

2. Key personnel changes should form part of leaver and organisational-change procedures

 

Sponsor licence responsibilities should be incorporated into the organisation’s normal leaver, promotion and restructuring procedures.

An employee leaving the business may trigger more than one sponsor licence action. For example, the individual may be recorded as Authorising Officer, Key Contact and Level 1 User at the same time. Their departure can therefore require several separate changes rather than a single update.

Similarly, a restructuring may change who has senior responsibility for immigration compliance, who communicates with the Home Office and which employees require SMS access.

Employers should therefore review the sponsor licence whenever there is a material change to the personnel responsible for sponsorship rather than waiting until an access problem or Home Office query exposes an outdated arrangement.

 

3. Do not leave mandatory sponsor roles unmanaged

 

Under the current sponsor guidance, a sponsor must maintain an eligible Authorising Officer and at least one eligible Level 1 User throughout the life of the licence.

Where one of these individuals is leaving, the sponsor should act promptly to ensure that the mandatory role continues to be properly filled and, in the case of Level 1 Users, that effective SMS access is maintained.

This is more than a matter of administrative convenience. Failure to maintain the required Authorising Officer and Level 1 User arrangements can have serious consequences for the sponsor licence.

 

 

 

 

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Section C: Check the Replacement Is Eligible Before Making the Change

Before replacing any sponsor licence key personnel, the employer should check that the proposed individual meets the Home Office requirements for the relevant role.

The eligibility requirements are not identical for every role. They can also depend on factors such as whether the individual is based in the UK, their immigration status, their relationship with the sponsoring organisation and whether they are an employee, director, partner, office holder or permitted external representative.

Employers should therefore avoid treating a key personnel change as a simple substitution of one person’s name for another. Eligibility should be checked before the change is submitted and, wherever possible, before the outgoing individual leaves.

 

1. General requirements for sponsor key personnel

 

Subject to specific exceptions within the sponsor guidance, key personnel generally need to satisfy requirements concerning their location, status, relationship with the sponsoring organisation and suitability.

Depending on the role and circumstances, relevant considerations can include whether the proposed individual:

• is based in the UK while carrying out the role, subject to applicable exceptions;
• has a valid National Insurance number, unless an exception applies;
• has the required relationship with the sponsoring organisation;
• is an employee, director, partner or otherwise falls within a category permitted for the relevant role;
• is not acting merely as a contractor or consultant engaged for a specific purpose where this would not satisfy the key personnel requirements;
• meets the suitability requirements applying to sponsor key personnel;
• has the immigration status required for the particular role, where relevant; and
• meets any additional requirements specific to the role they are being appointed to.

Home Office suitability considerations can include previous involvement with a sponsor whose licence was revoked, relevant criminal convictions or civil penalties, previous immigration or sponsorship non-compliance and other matters that raise concerns about the individual’s suitability to hold a key personnel position.

The precise requirements should be checked against the current sponsor guidance before an appointment is made.

 

2. Replacing the Authorising Officer

 

The Authorising Officer is the senior person responsible for the sponsor licence and for overseeing the activities of those who use the Sponsor Management System on behalf of the organisation.

A replacement Authorising Officer should therefore be selected carefully. The employer should confirm that the proposed individual satisfies the current requirements for the role and has sufficient authority within the organisation to exercise meaningful oversight of sponsorship activity.

The Authorising Officer does not automatically receive access to the Sponsor Management System simply because they hold that position. If the new Authorising Officer also needs to carry out SMS functions, the sponsor should ensure that appropriate Level 1 User arrangements are in place.

This distinction is particularly important where the outgoing Authorising Officer was also the organisation’s only Level 1 User. Replacing the Authorising Officer without dealing separately with SMS access could leave the sponsor without an operational Level 1 User.

Detailed eligibility requirements and responsibilities are considered separately in our guide to the Authorising Officer: Sponsor Licence Duties & Requirements.

 

3. Replacing the Key Contact

 

The Key Contact acts as a principal point of contact between the sponsor and the Home Office.

Before replacing the Key Contact, the sponsor should check that the proposed individual is permitted to hold the role and that their contact information is accurate and appropriate for ongoing Home Office communications.

The Key Contact can also hold another key personnel role where the applicable requirements are met. For example, the same individual can potentially act as both Authorising Officer and Key Contact.

Employers should nevertheless consider whether concentrating several sponsorship functions in one individual creates unnecessary operational dependency. If that person subsequently leaves or becomes unexpectedly unavailable, several elements of the sponsor’s governance arrangements may need to be replaced simultaneously.

 

4. Adding or replacing a Level 1 User

 

Level 1 Users have significant operational access to the sponsor licence through the SMS. Depending on the sponsor’s circumstances and the functions available to the user, Level 1 Users can carry out important sponsorship activities and make changes to the sponsor’s licence records.

The employer should therefore confirm both that the proposed user satisfies the Home Office requirements and that giving the individual Level 1 access is appropriate from an internal governance and security perspective.

Level 1 access should not be given simply because an employee occasionally assists with immigration administration. Sponsors should determine who genuinely requires SMS access and maintain appropriate control over the number and identity of users.

 

5. Check the primary Level 1 User requirements

 

Particular care is required when replacing the sponsor’s only Level 1 User.

Under the current sponsor guidance, sponsors generally need to maintain at least one Level 1 User who satisfies the Home Office requirements relating to their connection with the organisation and their status in the UK.

For sponsors subject to the current rules, this generally means having at least one Level 1 User who is:

• an employee, director or partner of the sponsoring organisation; and
• a settled worker, subject to the exceptions and transitional provisions contained in the sponsor guidance.

Transitional provisions apply to certain sponsors whose licence application was successful before 1 January 2025 and who have continuously held their sponsor licence. Depending on the circumstances, the relevant requirements may be satisfied by one Level 1 User or across two Level 1 Users, although sponsors should consider the Home Office recommendation to have at least one Level 1 User who independently satisfies both requirements.

This means that replacing an existing Level 1 User requires more than finding somebody who can operate the SMS. The sponsor should check whether removing that individual affects the organisation’s ability to satisfy the underlying Level 1 User requirements.

 

6. Can an external representative be appointed as a Level 1 User?

 

An appropriately permitted external representative can potentially be appointed as a Level 1 User where the Home Office requirements are met.

However, appointing an external immigration adviser or representative does not remove the sponsor’s obligation to maintain the required Level 1 User arrangements within or appropriately connected to the sponsoring organisation.

An employer should therefore not assume that giving its immigration adviser Level 1 access allows it to operate without the internally connected Level 1 User required under the sponsor guidance.

 

7. Different rules can apply to UK Expansion Worker sponsors

 

Different key personnel arrangements can apply to sponsors under the UK Expansion Worker route, particularly while the organisation is operating under a provisional sponsor licence rating.

For example, specific rules apply where the Authorising Officer is based overseas during the initial stage of the UK expansion, and restrictions can apply to changing or adding Level 1 Users while the licence remains provisionally rated.

UK Expansion Worker sponsors should therefore check the route-specific sponsor guidance before changing key personnel rather than relying solely on the general rules applying to established Worker sponsors.

 

8. SMS Users must maintain secure individual access

 

Eligibility is not the only consideration when appointing an SMS user. Sponsors also need to ensure that SMS access is properly controlled.

SMS users should use their own individual credentials and should not share passwords or multi-factor authentication passcodes. The email address associated with an SMS user should belong to that individual rather than being a shared mailbox used by several employees.

Mandatory multi-factor authentication for SMS users began rolling out from 3 September 2026. Employers changing Level 1 Users should therefore consider access and authentication arrangements as part of the handover, including whether the new user’s email address and other authentication details are accurate and accessible to that individual.

SMS users should also access their account as required and keep their personal and contact details up to date.

 

9. Eligibility should be checked before the SMS request

 

A common practical mistake is to identify a replacement based solely on their position within the business and only investigate the Home Office requirements when the change is being submitted.

The better approach is to establish eligibility first.

Before starting the change, the sponsor should confirm:

• which sponsor role or roles the individual will hold;
• whether they meet the requirements applying to each role;
• whether their immigration status satisfies any applicable requirement;
• whether their employment or other relationship with the sponsor is appropriate;
• whether there are any suitability concerns;
• whether they require SMS access;
• whether they already hold another sponsor key personnel role;
• whether the organisation will continue to satisfy the Level 1 User requirements after the change;
• whether any route-specific rules apply; and
• whether replacing the outgoing individual will leave any other required role or operational function uncovered.

Where there is uncertainty over eligibility, this should be resolved before the outgoing person’s role or SMS access is removed wherever possible.

 

 

 

 

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Section D: How to Replace Your Authorising Officer

Where a different individual is taking over responsibility as Authorising Officer, the sponsor will need to request the replacement of the existing Authorising Officer.

This is different from amending the existing Authorising Officer’s details. If the same person remains in the role but, for example, their contact information changes, the sponsor should use the appropriate amendment process rather than treating them as a new Authorising Officer.

Where the Authorising Officer is being replaced, the change can normally be requested by an existing Level 1 User through the Sponsor Management System.

 

1. Identify an eligible replacement Authorising Officer

 

The sponsor should first identify who will take over the Authorising Officer role and check that the individual meets the current Home Office requirements.

The change should ideally be planned before the existing Authorising Officer leaves the organisation. This provides time to check the proposed replacement’s eligibility, identify any supporting evidence that may be required and ensure that the sponsor’s SMS access arrangements will continue to operate.

The sponsor should also establish whether the outgoing Authorising Officer holds any additional sponsor roles.

In particular, check whether the individual is also:

• the Key Contact;
• a Level 1 User; or
• the organisation’s only Level 1 User.

Those roles and permissions need to be considered separately as part of the changeover.

 

2. Access the Sponsor Management System

 

An existing Level 1 User will normally make the request through the SMS.

For an Authorising Officer replacement, the relevant SMS process is accessed through:

Licence summary, applications and services → Request changes to licence details → Replace your Authorising Officer.

The Level 1 User should select the replacement function rather than the amendment function where a different person is taking over the role.

 

3. Enter the new Authorising Officer’s details

 

The sponsor will need to provide the information requested through the SMS about the proposed replacement Authorising Officer.

The information should be checked carefully against the organisation’s records before submission.

Errors in names, addresses, contact information or other relevant details can create avoidable problems with the request and with subsequent Home Office communications.

The sponsor should also ensure that the contact information being supplied is appropriate for the individual who will actually hold the role.

 

4. Complete the declaration and submit the request

 

Once the required information has been entered, the Level 1 User should complete the relevant declarations and submit the request through the SMS.

Submitting the request should not be treated as confirmation that the replacement has been accepted or that the change has been completed.

The sponsor should retain the change request details and continue to monitor the request until the position has been resolved.

 

5. Complete the submission sheet and provide supporting evidence

 

An Authorising Officer replacement generates a submission sheet through the SMS process.

The sponsor should complete the submission sheet and provide the supporting evidence required for the request in accordance with the Home Office instructions.

Where the Home Office requires a submission sheet, declaration or supporting documents following an SMS change request, these should generally be provided within 5 working days of the request.

If the Home Office subsequently asks for additional documents or information, sponsors should also respond within the timeframe specified in the request, which will generally be 5 working days under the current sponsor guidance.

Failure to provide required evidence within the applicable timeframe can result in the request being refused and may have wider consequences for the sponsor licence depending on the circumstances.

The employer should therefore not regard the electronic SMS submission as the end of the process.

 

6. Monitor the Authorising Officer change

 

The sponsor should monitor the request and any related Home Office communications until it is satisfied that the replacement Authorising Officer has been correctly recorded.

If the Home Office requests further information, clarification or supporting documents, the request should be dealt with promptly.

Once the change has been completed, the employer should update its internal sponsor licence records to identify the new Authorising Officer and retain an audit trail of the change.

 

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

 

Replacing the Authorising Officer does not, by itself, necessarily resolve the organisation’s SMS user arrangements.

The Authorising Officer and Level 1 User perform separate functions.

Authorising Officer role: who has senior responsibility for the organisation’s sponsorship arrangements?

Level 1 User role: who has operational access to the Sponsor Management System?

If the outgoing Authorising Officer is also the organisation’s only active Level 1 User, continuity of SMS access should be addressed before their departure wherever possible.

This is one of the most important practical checks when changing an Authorising Officer. An organisation can identify a suitable new Authorising Officer but still create a serious operational problem if it overlooks the outgoing individual’s separate Level 1 User access.

The sponsor must maintain an eligible Authorising Officer and at least one eligible Level 1 User throughout the life of the licence.

 

8. Can the new Authorising Officer also be the Key Contact?

 

Yes. The same individual can hold more than one sponsor key personnel role where they satisfy the requirements applying to each role.

Where the replacement Authorising Officer will also become the Key Contact, the SMS procedure allows the sponsor to indicate that the same individual will perform both roles. It is not necessary to make separate replacement requests for the Authorising Officer and Key Contact where the relevant SMS process permits both changes to be dealt with together.

The sponsor should nevertheless ensure that the individual meets the requirements for both roles.

 

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

 

Yes, provided the individual meets the requirements applying to the Level 1 User role as well as those applying to the Authorising Officer.

Being appointed Authorising Officer does not automatically give the individual SMS access. Where the new Authorising Officer also needs to operate the SMS, the sponsor should ensure that they are properly appointed as a Level 1 User.

This distinction should be reflected in the organisation’s internal sponsor governance arrangements.

 

10. Should one person hold several key personnel roles?

 

Combining roles can make sponsor licence administration simpler, particularly for smaller organisations, but employers should also consider operational resilience.

Where the Authorising Officer, Key Contact and only Level 1 User are all the same person, the organisation becomes heavily dependent on that individual.

Their unexpected resignation, illness, absence or loss of eligibility could affect senior oversight, Home Office communications and practical access to the SMS at the same time.

The question for employers is therefore not simply whether one person can hold several roles. Sponsors should also consider whether the arrangement provides appropriate continuity, oversight and control for the organisation’s sponsorship activities.

 

 

 

 

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Section E: How to Change Your Key Contact

The Key Contact is the sponsor’s principal point of contact with the Home Office. If the individual holding the role leaves the organisation, changes responsibilities or is otherwise no longer going to act as Key Contact, the sponsor should update its sponsor licence arrangements.

As with the Authorising Officer, the correct process depends on whether the sponsor is changing the person holding the role or simply updating the existing person’s details.

Where a different individual is taking over, the sponsor should use the process to replace the Key Contact. Where the same individual remains in the role but their details have changed, the sponsor should amend the existing Key Contact details.

 

1. Check whether the Key Contact needs to be replaced or amended

 

The sponsor should first establish the nature of the change.

A replacement will generally be required where the existing Key Contact:

• leaves the organisation;
• moves to another role and will no longer act as Key Contact;
• no longer meets the requirements applying to the role;
• ceases to act as the sponsor’s external representative, where applicable; or
• is otherwise being replaced by another individual.

If the existing person remains Key Contact but information about them has changed, the sponsor should normally amend the existing record rather than replace the individual.

The practical distinction remains:

Same person, new details = amend.

Different person taking over = replace.

 

2. Check the replacement Key Contact is eligible

 

Before submitting the change, the sponsor should confirm that the proposed replacement satisfies the Home Office requirements applying to the Key Contact role.

The sponsor should also ensure that the individual’s contact information is accurate and appropriate for ongoing communications with the Home Office.

If the proposed Key Contact will also hold another sponsor role, such as Authorising Officer or Level 1 User, the employer should check the requirements applying to each role separately.

 

3. Submit the Key Contact change through the SMS

 

An existing Level 1 User can normally request the change through the Sponsor Management System.

The Level 1 User should access the relevant licence-management function, select the appropriate Key Contact change and provide the information requested about the replacement individual.

The information should be checked carefully before submission. Inaccurate contact information can create practical problems where the Home Office subsequently needs to communicate with the sponsor.

Once submitted, the sponsor should retain the change request number and monitor the request through to completion.

 

4. Provide any information or evidence required by the Home Office

 

The evidential process for changing a Key Contact should not automatically be assumed to be identical to the process for replacing an Authorising Officer.

The sponsor should follow the instructions generated for the particular SMS request and provide any additional information or evidence requested by the Home Office.

Where the Home Office requires supporting information or documents, these should be supplied within the applicable deadline. Under the current sponsor guidance, where documents are required in support of a relevant change request, the applicable timeframe will generally be 5 working days.

Sponsors should retain evidence of what was submitted and when.

 

5. Monitor the Key Contact change

 

Submitting the request does not mean the sponsor should immediately regard the change as completed.

The employer should monitor the request and relevant Home Office communications and confirm that the sponsor licence records correctly reflect the new Key Contact.

Internal compliance records should also be updated so that employees responsible for sponsorship know who is acting as the organisation’s current Home Office contact.

 

6. Amending the existing Key Contact’s details

 

A replacement is not necessarily required simply because information about the existing Key Contact has changed.

If the same person remains Key Contact but relevant details have changed, the sponsor should use the appropriate SMS function to amend their details.

Employers should check the information actually recorded on the sponsor licence rather than assuming that updates made to internal HR systems will automatically be reflected in the SMS.

Maintaining accurate sponsor records is a separate compliance process from updating the organisation’s own personnel records.

 

7. Can the Key Contact also be the Authorising Officer?

 

Yes. The same individual can act as both Authorising Officer and Key Contact where they satisfy the requirements applying to both roles.

Where a new Authorising Officer is also going to become the Key Contact, the Sponsor Management System allows the sponsor to indicate that the same person will hold both positions. In these circumstances, the relevant replacement process can be used to deal with both roles rather than requiring unnecessary duplicate requests.

The sponsor should still check that the individual is eligible for both positions and that the arrangement provides appropriate governance for the organisation.

 

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

 

Potentially, yes. Holding the Key Contact role does not itself provide SMS access, but the same individual can also be appointed as a Level 1 User where they meet the applicable requirements.

If the individual requires operational access to the SMS, the sponsor should ensure that the appropriate Level 1 User appointment has been made rather than assuming that access follows automatically from being Key Contact.

 

9. Check whether the outgoing Key Contact holds other sponsor roles

 

Before completing the change, the sponsor should establish whether the outgoing Key Contact is also an Authorising Officer or SMS user.

Changing the Key Contact alone will not necessarily deal with those additional positions or permissions.

For example, where the outgoing Key Contact is also a Level 1 User, the sponsor should separately determine:

• whether their SMS access should be removed;
• whether another Level 1 User will remain;
• whether replacement Level 1 access needs to be arranged first; and
• whether the sponsor will continue to satisfy the Home Office Level 1 User requirements.

Each role and permission should therefore be reviewed individually as part of the changeover.

 

10. Consider resilience when combining key personnel roles

 

Although one individual can potentially hold several sponsor roles, employers should consider whether concentrating responsibility in one person creates unnecessary dependency.

If the same individual acts as Authorising Officer, Key Contact and the only Level 1 User, their unexpected departure could simultaneously affect senior sponsorship oversight, Home Office communications and practical access to the SMS.

For that reason, sponsors should consider not only whether a particular combination of roles is permitted, but whether their overall key personnel structure provides sufficient continuity and control.

 

 

 

 

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Section F: How to Add, Replace or Remove a Level 1 User

Level 1 Users carry out the day-to-day administration of the sponsor licence through the Sponsor Management System.

Because Level 1 access allows an individual to perform important sponsorship functions and make changes to the sponsor’s licence records, employers should control carefully who is given access and remove access when it is no longer required.

The sponsor must have at least one eligible Level 1 User throughout the life of the licence. When changing Level 1 Users, employers therefore need to consider both the eligibility of the proposed user and continuity of access to the SMS.

Changes involving Level 1 Users generally fall into four categories:

• adding another Level 1 User;
• replacing a Level 1 User who is leaving or changing responsibilities;
• removing or deactivating an existing user’s access; or
• amending the details of an existing user.

 

1. Adding another Level 1 User

 

Sponsors are not limited to having only one Level 1 User.

Appointing additional suitable Level 1 Users can provide operational resilience, particularly where sponsorship activity is managed by a team or where the organisation would otherwise depend entirely on one individual’s SMS access.

Before adding another Level 1 User, the sponsor should establish that the individual meets the applicable Home Office requirements and genuinely requires the level of access being granted.

The sponsor should consider:

• whether the individual satisfies the eligibility requirements for a Level 1 User;
• whether the sponsor will continue to satisfy the requirements relating to its primary Level 1 User arrangements;
• whether the individual genuinely needs access to the SMS;
• what sponsorship functions they will be responsible for;
• whether appropriate training and internal controls are in place;
• whether their individual email and authentication details are suitable for SMS access; and
• whether any route-specific restrictions apply.

An existing Level 1 User can use the relevant SMS user-management functionality to request the addition of another Level 1 User, subject to the Home Office process applying to that appointment.

 

2. Check the status of a new Level 1 User request

 

A request to add a Level 1 User should not be treated as completed simply because it has been submitted through the SMS.

Level 1 User records can display different statuses within the system, including:

• Requested;
• Active;
• Refused;
• Deactivated by sponsor; and
• Deactivated by UKVI.

Where a new Level 1 User request requires UKVI consideration, the sponsor should monitor the request and should not assume that operational access has been established while the user remains recorded as requested.

The sponsor should verify that the new user’s account has become active and that the individual can access the SMS before relying on them as part of the organisation’s operational continuity arrangements.

 

3. Replacing a Level 1 User who is leaving

 

Where a Level 1 User is leaving the organisation, the sponsor should plan the change before the individual’s departure wherever possible.

A controlled changeover should generally involve:

1. establishing whether the departing individual holds any other key personnel roles;
2. identifying an eligible replacement;
3. checking whether removing the existing user affects the sponsor’s compliance with the Level 1 User requirements;
4. arranging replacement or additional Level 1 User access;
5. confirming that appropriate SMS access will remain available;
6. removing the departing individual’s access when it is no longer required; and
7. verifying that the sponsor can continue carrying out its normal SMS functions.

The order of these steps can be critical.

If an organisation has only one Level 1 User and removes that person’s access before arranging a replacement, it may lose the ability to make the necessary personnel changes through the normal SMS process.

A useful principle is:

Preserve access before removing access.

 

4. Removing a Level 1 User

 

SMS access should not remain available indefinitely to somebody who no longer requires it.

Where an employee leaves the organisation, moves into a role with no sponsorship responsibilities or otherwise ceases to require SMS access, the sponsor should review and, where appropriate, remove or deactivate their access.

This should form part of the organisation’s normal leaver and access-control procedures.

Before deactivating the user, however, the sponsor should check whether:

• another eligible Level 1 User will remain active;
• the departing individual is the Level 1 User relied upon to satisfy the sponsor’s primary Level 1 User requirements;
• a replacement Level 1 User request has been completed rather than merely submitted;
• the individual also acts as Authorising Officer or Key Contact;
• any time-sensitive SMS activity is outstanding; and
• any pending sponsor licence request depends on the departing individual.

Employers should be particularly careful where the person holds several sponsor roles. Removing Level 1 access does not automatically replace the individual as Authorising Officer or Key Contact.

Each role should be checked and dealt with separately.

 

5. Changing the details of an existing Level 1 User

 

Where the individual remains a Level 1 User but relevant personal or contact details have changed, the sponsor should ensure that the user’s SMS information is kept current.

Maintaining accurate user information is an important part of sponsor licence administration and can also reduce the risk of access and authentication problems.

This has become particularly important following the introduction of mandatory multi-factor authentication for SMS users from September 2026.

Employers should ensure that SMS access is linked to the authorised individual’s own appropriate contact credentials and that changes to telephone numbers, email addresses or employment arrangements do not inadvertently prevent the user from accessing the system.

 

6. Use individual rather than shared SMS credentials

 

SMS accounts are intended for individual authorised users.

The email address used for an SMS user should belong to that individual rather than being a shared mailbox used by several employees. Passwords and multi-factor authentication passcodes should not be shared between colleagues.

This is important both for system security and accountability. The sponsor should be able to identify which authorised individual is responsible for actions carried out through the SMS.

When an employee leaves, employers should therefore consider SMS credentials separately from general access to shared HR or immigration mailboxes.

 

7. What if your only Level 1 User is leaving?

 

This is one of the highest-risk key personnel changeover scenarios.

If the sponsor still has access to the SMS, it should address replacement Level 1 User arrangements before the existing user leaves wherever practicable.

The employer should not wait until the individual’s account has been closed, their company email has been disabled, their authentication details are no longer accessible or nobody within the organisation can operate the SMS.

The sponsor should:

1. identify a suitable replacement;
2. check that the replacement satisfies the applicable Level 1 User requirements;
3. submit the appropriate request;
4. monitor the request through to completion;
5. verify that the replacement user’s account is active;
6. confirm that effective SMS access has been established; and
7. only then remove access that is no longer required, subject to the circumstances of the departure.

The sponsor should also establish whether the outgoing Level 1 User is its Authorising Officer or Key Contact and deal separately with those roles where necessary.

 

8. Check the primary Level 1 User requirements before removing an existing user

 

Replacing a Level 1 User is not simply an access-management exercise.

Under the current sponsor guidance, sponsors generally need to maintain at least one Level 1 User who satisfies requirements relating to their connection with the sponsoring organisation and their status in the UK.

For sponsors subject to the current requirements, this generally means having at least one Level 1 User who is both:

• an employee, director or partner of the sponsoring organisation; and
• a settled worker, subject to the relevant exceptions and transitional provisions.

Transitional provisions apply to certain sponsors whose licence application was successful before 1 January 2025 and who have continuously held their sponsor licence.

Employers should therefore check whether the outgoing user is the person currently relied upon to satisfy these requirements before removing them from the licence.

Appointing another person who can technically operate the SMS will not necessarily resolve the issue if the resulting Level 1 User structure does not satisfy the Home Office requirements.

 

9. Can an external immigration adviser replace your internal Level 1 User?

 

An appropriately permitted external representative can potentially be appointed as a Level 1 User where the relevant requirements are met.

However, appointing an external adviser does not remove the sponsor’s obligation to maintain the Level 1 User arrangements required by the sponsor guidance.

In particular, an organisation should not assume that an external immigration adviser can simply replace the internally connected Level 1 User that the sponsor is required to maintain.

Where an external representative is given SMS access, the sponsor should still maintain appropriate internal ownership and oversight of the sponsor licence.

 

10. Different rules for certain UK Expansion Worker sponsors

 

UK Expansion Worker sponsors can be subject to different Level 1 User arrangements, particularly while the sponsor licence has a provisional rating.

Specific restrictions can apply to changing or adding Level 1 Users during this stage.

A UK Expansion Worker sponsor should therefore check the route-specific sponsor guidance before making changes to its Level 1 User arrangements.

 

11. What if the Level 1 User has already left and nobody can access the SMS?

 

If the only Level 1 User has already left and there is genuinely no active Level 1 User able to access the Sponsor Management System, the organisation will not be able to follow the ordinary SMS process for appointing another user.

In these circumstances, the Home Office provides an alternative sponsor change of circumstances process through which the sponsor can request the addition of a new Level 1 User.

The process should not be treated as a general alternative to the SMS for all key personnel changes. It is intended for specified circumstances where the required action cannot be completed through normal SMS access.

Where SMS access has already been lost, the sponsor should act promptly to establish the correct process, restore appropriate Level 1 User access and identify whether the departure has also affected the Authorising Officer or Key Contact positions.

The process for sponsors with no active Level 1 User is considered in more detail in the next section.

 

 

 

 

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Section G: What If You Have No Active Level 1 User or Cannot Access the SMS?

Losing access to the Sponsor Management System can create an immediate operational and compliance problem for a sponsor.

Ordinarily, changes to key personnel are made by an authorised Level 1 User through the SMS. If the organisation’s only Level 1 User has already left, their account has been deactivated or there is otherwise no active Level 1 User able to access the system, the sponsor cannot simply follow the normal SMS procedure to appoint their replacement.

The Home Office provides an alternative sponsor change of circumstances process for specified situations where the sponsor has no Level 1 User with access to the SMS.

This process should not be treated as a general alternative method for making any sponsor licence change. Its use is limited to the circumstances permitted by the Home Office.

 

1. Check whether SMS access has actually been lost

 

Before using the alternative process, the sponsor should establish exactly what access remains.

Check whether:

• there is another active Level 1 User on the licence;
• the Authorising Officer is separately registered as a Level 1 User;
• another authorised Level 1 User can access the SMS;
• the problem concerns an individual’s login or multi-factor authentication rather than the absence of an authorised Level 1 User;
• an existing Level 1 User request is still pending rather than active; and
• the departing individual also held the Authorising Officer or Key Contact role.

The Authorising Officer does not automatically have SMS access simply because they hold that position. The sponsor should therefore check the actual SMS user arrangements rather than assuming that a senior member of staff can access the system.

 

2. What should you do if your only Level 1 User has already left?

 

If there is genuinely no active Level 1 User able to access the SMS, the sponsor should use the relevant Home Office sponsor change of circumstances process to request the addition of a new Level 1 User.

This provides a route for a sponsor that cannot make the necessary Level 1 User change through the SMS because it no longer has an authorised Level 1 User able to log in.

The sponsor should act promptly. Under the sponsor guidance, an organisation must maintain at least one eligible Level 1 User throughout the life of its sponsor licence.

Loss of the only Level 1 User should therefore not be treated merely as an IT access problem. It potentially affects one of the mandatory personnel requirements attached to the sponsor licence.

 

3. Appointing a new Level 1 User without SMS access

 

The sponsor will need to provide the information required by the Home Office about the organisation, its sponsor licence and the proposed new Level 1 User.

Before submitting the request, the employer should check that the proposed user meets the applicable eligibility requirements.

In particular, the sponsor should consider whether the proposed appointment will allow it to satisfy the Home Office requirements relating to its primary Level 1 User arrangements, including the applicable requirements concerning the individual’s relationship with the organisation and status in the UK.

The organisation should ensure that the request is made by an appropriate person and that all required declarations and supporting information are completed accurately.

The sponsor should retain a copy or record of the request and monitor communications from the Home Office.

Submitting the form does not mean that the proposed individual immediately has Level 1 User access. The sponsor should confirm that the appointment has been processed and that effective SMS access has been restored.

 

4. What if the Authorising Officer has also left?

 

The position requires additional attention where the person who has left was both the organisation’s only Level 1 User and its Authorising Officer.

The organisation potentially has two separate problems:

1. it needs to restore operational Level 1 User access to the SMS; and
2. it needs to replace the Authorising Officer.

Where the sponsor has no Level 1 User with SMS access, the Home Office change of circumstances process can be used in specified circumstances to replace the Authorising Officer where the proposed new Authorising Officer will also become the sponsor’s sole Level 1 User.

The sponsor should follow the current Home Office instructions carefully because the alternative form is not a general substitute for all of the key personnel functions normally available through the SMS.

If the departed individual was also the Key Contact, that role should also be identified and addressed as part of the wider recovery process.

 

5. Check every role held by the departed user

 

Loss of SMS access can distract employers from the wider key personnel position.

Where the only Level 1 User has left, the sponsor should establish whether that individual was also:

• the Authorising Officer;
• the Key Contact;
• responsible for assigning Certificates of Sponsorship;
• responsible for making worker reports;
• the main recipient of sponsorship-related Home Office communications; or
• responsible for maintaining the organisation’s sponsor compliance records.

The objective should be to restore both technical SMS access and effective organisational control of the sponsor licence.

 

6. What if the problem is multi-factor authentication rather than the absence of a Level 1 User?

 

Not every SMS access problem means that the sponsor has no Level 1 User.

Following the introduction of mandatory multi-factor authentication for SMS users from September 2026, an authorised user may sometimes have difficulty accessing the system because of their authentication arrangements rather than because their Level 1 status has ended.

The sponsor should therefore distinguish between:

• having no active Level 1 User;
• having an active Level 1 User who is experiencing an authentication or access problem; and
• having submitted a request for a new Level 1 User that has not yet become active.

The appropriate response can differ in each situation.

Sponsors should not share passwords or multi-factor authentication passcodes as a workaround for an access problem. SMS accounts are individual accounts and should only be used by the authorised person to whom the account belongs.

 

7. Preventing loss of SMS access

 

The most effective way to deal with loss of SMS access is to prevent it arising in the first place.

Sponsor licence administration should form part of the organisation’s employee leaver and succession-planning procedures.

Before a Level 1 User leaves, the employer should:

• identify all sponsor roles held by that individual;
• check whether another eligible Level 1 User will remain;
• identify and validate a replacement where required;
• submit any necessary Level 1 User request sufficiently early;
• monitor the request until the replacement user becomes active;
• confirm that the new user can access the SMS;
• transfer operational sponsorship responsibilities;
• review email and multi-factor authentication arrangements; and
• remove the outgoing user’s access when it is appropriate to do so.

Where appropriate, having more than one eligible and suitably trained Level 1 User can provide resilience if somebody resigns, is absent or becomes unexpectedly unavailable.

The organisation should nevertheless maintain proper access controls. Additional Level 1 Users should be appointed because there is a genuine operational reason for them to have access, rather than simply giving broad SMS permissions to numerous employees as a precaution.

 

8. Do not allow loss of access to cause wider sponsor breaches

 

Restoring SMS access may not be the only issue requiring attention.

The organisation should establish whether any sponsorship activity became due while access was unavailable, including worker reporting, Certificate of Sponsorship administration or other licence-management actions.

If deadlines have been missed or other compliance problems have arisen, these should be assessed separately rather than assuming that restoring Level 1 User access automatically resolves the underlying issue.

The sponsor should retain a clear internal record explaining what happened, when access was lost, what action was taken to restore it and whether any other sponsorship obligations were affected.

 

 

 

 

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Section H: Level 2 Users: September 2026 Changes

Sponsors should review any existing Level 2 User arrangements following changes to the Sponsor Management System introduced in September 2026.

The Level 2 User role is being phased out. From 9 September 2026, sponsors can no longer appoint new Level 2 Users.

This means an employer changing its sponsorship team should not plan to replace a departing Level 2 User by appointing another person as a new Level 2 User. Where another individual requires SMS access, the sponsor should instead consider whether that person needs Level 1 access and whether they meet the requirements to become a Level 1 User.

 

1. Can you appoint a new Level 2 User?

 

No. Sponsors can no longer add new Level 2 Users following the September 2026 changes.

Where a Level 2 User leaves the organisation or no longer requires access, the sponsor should not attempt to appoint another Level 2 User as their replacement.

Instead, the employer should consider what SMS functions need to be performed and whether an eligible individual should be appointed as a Level 1 User.

This should include consideration of the wider Level 1 User requirements rather than simply treating Level 1 status as the replacement name for the former Level 2 role.

 

2. What happens to existing Level 2 Users?

 

Existing Level 2 Users are subject to transitional arrangements.

Sponsors with existing Level 2 Users should review those accounts and determine whether each individual still requires access to the Sponsor Management System.

Where continued access is required and the individual meets the relevant requirements, the sponsor should upgrade the individual to Level 1 User status.

Where the individual no longer requires SMS access, their account should be deactivated.

Under the current transitional arrangements, sponsors must take the required action no later than 8 March 2027.

Any remaining Level 2 User accounts that have not been upgraded or deactivated by the end of the transitional period are due to be deactivated by the Home Office.

Employers should therefore not wait until the deadline before reviewing their existing accounts.

 

3. Should an existing Level 2 User become a Level 1 User?

 

Not automatically.

Level 1 access carries wider SMS functionality and responsibility. The employer should therefore consider whether the individual genuinely needs Level 1 access and whether they satisfy the applicable eligibility requirements.

The review should consider:

• what sponsorship functions the individual currently performs;
• whether they still require access to the SMS;
• whether they meet the requirements to become a Level 1 User;
• whether giving them wider Level 1 permissions is appropriate;
• whether they have received appropriate training;
• whether adequate internal access controls are in place;
• whether the organisation already has sufficient Level 1 User coverage; and
• whether the individual’s SMS access remains necessary following any changes to their employment or responsibilities.

Where the individual no longer requires SMS access, deactivation may be more appropriate than upgrading the account.

 

4. Do not assume every Level 2 User is eligible to become a Level 1 User

 

The fact that an individual was previously permitted to operate as a Level 2 User does not automatically establish that they meet the requirements to become a Level 1 User.

Before upgrading an existing Level 2 User, the sponsor should check the current Level 1 User requirements, including any requirements relating to the individual’s connection with the sponsoring organisation and their status in the UK.

The employer should also consider whether the organisation will continue to satisfy the requirements applying to its primary Level 1 User arrangements.

This is particularly important where the sponsor is using the September 2026 transition to redesign its wider SMS user structure.

 

5. Review Level 2 Users as part of a wider SMS access audit

 

The transition away from Level 2 Users provides sponsors with an opportunity to review their wider SMS access arrangements rather than simply converting every historic Level 2 account into a Level 1 account.

The review should address the following questions.

Who currently has SMS access?

Check all active users against current employees, representatives and sponsorship responsibilities.

Who actually needs access?

Remove unnecessary or obsolete access rather than automatically carrying historical arrangements forward.

Does the organisation have sufficient Level 1 User coverage?

Avoid unnecessary dependency on one individual where this could leave the organisation unable to administer its sponsor licence following an unexpected departure or absence.

Does the sponsor still satisfy the Level 1 User requirements?

Check whether the organisation has the required eligible Level 1 User arrangements rather than focusing only on the number of SMS accounts.

Are user details current?

Check that the information and individual contact credentials associated with authorised users remain accurate.

Are the access arrangements secure?

Check that SMS accounts are being used only by the individuals to whom they have been issued and that passwords and multi-factor authentication passcodes are not being shared.

 

6. Account for the September 2026 multi-factor authentication changes

 

The changes to SMS user management should also be considered alongside the introduction of mandatory multi-factor authentication for SMS users, which began rolling out from 3 September 2026.

When upgrading, replacing or otherwise reviewing SMS users, employers should check that each authorised user has appropriate individual access credentials and can complete the required authentication process.

SMS passwords and multi-factor authentication passcodes should not be shared between employees or used as a means of providing informal access to colleagues who do not have their own authorised account.

The email address associated with an SMS user should belong to the individual user rather than being a shared mailbox accessible by several members of the organisation.

These controls are important both for security and for maintaining accountability for actions carried out through the Sponsor Management System.

 

7. Build the 8 March 2027 deadline into your compliance calendar

 

Sponsors with existing Level 2 Users should record the 8 March 2027 deadline within their sponsor compliance calendar and complete their review sufficiently in advance.

For each existing Level 2 User, the organisation should record a clear decision:

• Upgrade – where the individual requires continued SMS access and is eligible to become a Level 1 User; or
• Deactivate – where the individual no longer requires access or should not be given Level 1 permissions.

The sponsor should then verify that the intended action has been completed rather than merely recorded internally.

For sponsors with established licences, this exercise can be particularly valuable because SMS user arrangements may have developed over several years and may no longer reflect the organisation’s current structure.

The September 2026 changes provide a clear point at which to rationalise those arrangements and ensure that SMS access reflects current responsibilities, eligibility requirements and sponsor governance.

 

 

 

 

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Section I: What Information & Evidence Will UKVI Require?

The information and evidence required when changing sponsor licence key personnel will depend on the type of change being made.

Employers should not assume that every personnel change requires the same documents or follows the same evidential process. The Sponsor Management System or relevant Home Office process should indicate what information must be provided and whether a submission sheet, declaration or supporting evidence is required.

The sponsor should follow the instructions generated for the particular request and retain a complete record of what was submitted.

Change	Information or evidence to consider
Replace Authorising Officer	Details of the proposed Authorising Officer, completed submission sheet and the supporting evidence required for the request
Amend Authorising Officer details	Corrected information relating to the existing Authorising Officer and any supporting information required by the Home Office
Replace Key Contact	Details of the proposed Key Contact and any information or evidence required for the particular change
Amend Key Contact details	Updated information for the existing Key Contact and any supporting information requested
Add or replace Level 1 User	Identity and contact information and details relevant to the individual’s eligibility and proposed SMS access
Remove Level 1 User	Details of the user whose access is to be removed or deactivated
No active Level 1 User	Information required under the Home Office sponsor change of circumstances process to establish new Level 1 User access
Existing Level 2 User	Information required to upgrade the individual to Level 1 User status, where eligible and appropriate, or to deactivate their access

 

1. Follow the instructions for the specific request

 

Where a change is submitted through the SMS, the sponsor should review all instructions produced as part of the submission process.

Depending on the type of request, this may include a submission sheet, declaration or instructions to provide supporting evidence.

The requirements should be followed for the specific change being made. Employers should not assume, for example, that replacing a Key Contact automatically carries exactly the same evidential requirements as replacing an Authorising Officer.

The Home Office SMS process specifically generates a submission sheet when an Authorising Officer is replaced. This should be completed and submitted with the supporting evidence required for the request.

 

2. Be aware of the 5 working day deadline

 

Timing is important where documents are required in support of a sponsor licence change.

Where an SMS request requires the sponsor to provide a submission sheet, declaration or supporting documents, these should generally be provided to the Home Office within 5 working days of the request.

If the Home Office subsequently asks the sponsor to provide additional documents or information, these will also generally need to be supplied within 5 working days, subject to the instructions given in the particular request.

Sponsors should therefore avoid submitting a key personnel change and then leaving the request unattended.

Before making a change that is likely to require evidence, it is sensible to identify and prepare the relevant documents so they can be supplied promptly after the SMS request is submitted.

 

3. Do not assume the SMS submission completes the process

 

A useful compliance principle is:

Do not treat the SMS submission screen as the end of the process.

Depending on the change, the sponsor may still need to:

• download and complete a submission sheet;
• provide supporting documents;
• respond to a request for further information;
• wait for Home Office consideration of the request;
• monitor the status of a new SMS user;
• confirm that the change has been implemented; and
• verify that the new user can access the SMS where relevant.

A key personnel change should only be treated as operationally complete once the sponsor has completed the required process and verified the resulting arrangements.

 

4. Check that the information submitted is accurate

 

Information submitted through the SMS should be checked carefully before the request is made.

This is particularly important for:

• names;
• dates of birth;
• contact details;
• email addresses;
• National Insurance information where required;
• the individual’s position within the organisation;
• their relationship with the sponsor; and
• the sponsor role or SMS access being requested.

Where an individual will become an SMS user, the email address should be their own appropriate individual email address rather than a shared mailbox used by multiple employees.

The sponsor should also ensure that any information submitted to the Home Office is consistent with the organisation’s internal records and any supporting documentation being provided.

 

5. Keep an internal record of the key personnel change

 

In addition to anything required by the Home Office, sponsors should maintain their own audit trail of key personnel changes.

The internal record should show:

• why the change was necessary;
• when the outgoing individual ceased or changed their role;
• which sponsor roles and SMS permissions they held;
• who was selected as the replacement;
• how the replacement’s eligibility was checked;
• who authorised the appointment internally;
• when the SMS request or alternative Home Office notification was submitted;
• the relevant submission or change-request reference;
• what supporting evidence was provided;
• when any further Home Office request was answered;
• when inappropriate SMS access was removed;
• when the replacement user’s access became active, where applicable; and
• when the organisation verified that the new arrangements were operating correctly.

This record can become important during a future Home Office compliance visit or internal sponsor licence audit, particularly where several personnel changes occurred as part of a restructuring, acquisition or change within the organisation’s HR or compliance function.

 

6. Retain evidence of the decision-making process

 

Good sponsor governance involves more than retaining a screenshot showing that a change was submitted.

Where appropriate, the sponsor should be able to demonstrate how it identified the replacement, checked their eligibility, authorised the appointment and preserved appropriate control of the sponsor licence during the transition.

This is particularly valuable where the change involved:

• the only Level 1 User;
• an individual holding several key personnel roles;
• an external representative;
• a significant organisational restructuring;
• loss of SMS access;
• a previous key person who had already left before the issue was identified; or
• circumstances that may raise wider sponsor compliance concerns.

The objective is to maintain a clear audit trail showing not only that the Home Office was notified correctly, but that the sponsor continued to exercise effective control over its licence throughout the change.

 

 

 

 

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Section J: How Long Does It Take to Change Sponsor Licence Key Personnel?

There is no single processing time that applies to every change of sponsor licence key personnel.

The timescale will depend on the type of request being made, whether the change requires Home Office consideration, whether supporting evidence is required, whether further information is requested and whether the sponsor is able to use the relevant post-licence priority service.

Employers should therefore distinguish between submitting a change and the change being processed, approved or made active.

This distinction is particularly important where the sponsor is replacing a Level 1 User. A request for a new Level 1 User should not be treated as completed merely because it has been submitted through the SMS. The sponsor should monitor the request and verify that the new user’s status has become active before relying on that individual for operational SMS access.

 

1. Different key personnel changes can have different processing requirements

 

Some changes are relatively straightforward, while others can require additional Home Office consideration or supporting evidence.

Factors affecting the overall timescale can include:

• the type of key personnel change being requested;
• whether the sponsor is amending an existing person’s details or replacing them;
• whether the change relates to an Authorising Officer, Key Contact or Level 1 User;
• whether the request generates a submission sheet;
• whether supporting documents are required;
• whether the Home Office requests further information;
• whether there are eligibility or suitability issues requiring consideration;
• whether another sponsor licence request is already pending;
• whether the sponsor has lost SMS access and needs to use an alternative process; and
• whether the request is eligible for priority consideration.

Employers should therefore avoid relying on a generic processing period when planning a key personnel change.

 

2. Plan personnel changes before the employee leaves

 

Where a departure is known in advance, the sponsor should use the available period to plan the change rather than waiting until the individual’s final day.

The employer should establish:

• which sponsor roles the individual holds;
• whether they are an SMS user;
• whether they are the organisation’s only Level 1 User;
• who will replace them;
• whether the proposed replacement is eligible;
• whether additional SMS access needs to be arranged;
• what information or supporting evidence is likely to be required;
• whether the change is likely to require Home Office consideration;
• whether any sponsorship activity is due during the changeover; and
• when the outgoing person’s access should be removed.

This provides the organisation with time to deal with the change without unnecessarily disrupting sponsor licence administration.

 

3. Allow time for supporting evidence

 

Where a change requires supporting evidence, employers should account for the evidential stage when planning the timetable.

For example, replacing an Authorising Officer generates a submission sheet and requires the sponsor to follow the Home Office instructions for providing the required supporting material.

Where documents are required in support of a relevant change request, they should generally be provided within 5 working days.

The sponsor should therefore have the relevant information and evidence available before making the request wherever possible.

Waiting until after submission to identify what documentation is available can create unnecessary time pressure and increase the risk of missing the applicable deadline.

 

4. What if the request remains pending?

 

Sponsors should actively monitor key personnel change requests rather than assuming that submission means completion.

Where the request remains outstanding, the employer should establish:

• the current status of the request;
• whether supporting documents have been provided;
• whether the Home Office has requested further information;
• whether any response deadline is running;
• whether another related request is pending; and
• whether the outstanding change affects other planned sponsorship activity.

If the Home Office requests further information or evidence, this should be addressed promptly and within the applicable timeframe.

 

5. A pending Level 1 User request is not the same as active SMS access

 

This distinction is particularly important when managing Level 1 User changes.

A new Level 1 User can appear with a status such as Requested while the appointment is being considered. The organisation should not treat that person as having effective Level 1 access until the account has become Active and the individual can use the SMS.

This matters where an existing Level 1 User is about to leave.

Removing the existing user’s access simply because the replacement request has been submitted can leave the sponsor without functioning Level 1 access if the replacement has not yet become active.

The safer approach is to verify operational continuity before removing access that the organisation still needs.

 

6. Consider other sponsorship activity during the changeover

 

A personnel change does not suspend the sponsor’s other responsibilities.

The organisation may still need to:

• assign Certificates of Sponsorship;
• make reports about sponsored workers;
• respond to Home Office correspondence;
• manage other sponsor licence changes;
• maintain required records; or
• meet other sponsorship deadlines.

If a personnel change affects the organisation’s ability to carry out these functions, the employer should consider the wider operational implications rather than looking at the key personnel request in isolation.

This is another reason why maintaining sufficient Level 1 User resilience can be important for organisations with regular sponsorship activity.

 

7. Can an urgent key personnel change be expedited?

 

Certain key personnel changes can be eligible for consideration under the Home Office’s post-licence priority service.

This can be relevant where an employer has an urgent operational need for a change to be considered, for example where Level 1 User arrangements are affecting the organisation’s ability to administer its sponsor licence.

Eligibility, availability and the procedure for obtaining priority consideration should be checked at the time the request is made.

Priority processing does not remove the requirement to submit the underlying change correctly, provide the required evidence or satisfy the relevant key personnel requirements.

It also does not guarantee that the underlying request will be approved.

The post-licence priority service is considered in more detail in the following section.

 

 

 

 

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Section K: Can You Use the Post-Licence Priority Service?

Certain changes to sponsor licence key personnel can be eligible for expedited consideration through the Home Office Worker and Temporary Worker Priority Change of Circumstance Service.

The service can be useful where an employer needs a key personnel change to be considered urgently, particularly where the change affects the organisation’s ability to administer its sponsor licence effectively.

However, priority treatment is not automatic. The request must fall within the changes currently accepted under the service, the sponsor must follow the prescribed priority process and the service must have capacity to accept the request.

Priority treatment also does not change the underlying eligibility requirements and does not guarantee that the requested change will be approved.

 

1. Which key personnel changes can use the priority service?

 

Under the current Home Office arrangements, eligible key personnel changes can include:

• adding a Level 1 User;
• changing a Level 1 User;
• replacing an Authorising Officer;
• amending an Authorising Officer’s details;
• replacing a Key Contact; and
• amending a Key Contact’s details.

The sponsor should check the current scope of the priority service when making the request, since the Home Office can change which post-licence applications and changes are eligible for priority consideration.

 

2. Submit the underlying change correctly first

 

The priority service does not replace the normal process for making the sponsor licence change.

The employer must first ensure that the underlying request has been made correctly through the appropriate Home Office process.

For example, if the organisation is replacing its Authorising Officer, it should use the relevant SMS function, provide the required information and complete the evidential steps associated with the Authorising Officer replacement.

The priority process concerns the speed at which an eligible request is considered. It does not correct an incomplete or incorrectly submitted change request.

 

3. Check that the request is eligible for priority consideration

 

Before seeking priority treatment, the sponsor should check the current Home Office eligibility requirements.

This should include confirming:

• that the type of key personnel change is currently included within the priority service;
• that the underlying request has been submitted through the correct process;
• that the sponsor satisfies the requirements for using the service;
• that any required supporting evidence is available;
• that there is no issue with the request that prevents it from being considered under the priority process; and
• that the sponsor is following the current Home Office procedure for requesting priority treatment.

Employers should check the current service requirements rather than relying on a procedure used for an earlier sponsor licence change, as the operational arrangements can change.

 

4. Priority service availability can be limited

 

Eligibility for the service does not necessarily mean that a priority slot will be available.

The Home Office operates the service subject to capacity and its current operational arrangements. Sponsors dealing with an urgent personnel change should therefore not build their compliance plan around an assumption that priority processing will definitely be available.

Where a departure is known in advance, the better approach is still to begin the key personnel change sufficiently early to preserve continuity of sponsor management and SMS access.

The priority service should not become a substitute for succession planning.

 

5. Priority treatment does not remove the evidence requirements

 

A request being accepted for priority consideration does not remove the sponsor’s responsibility to provide the information and evidence required for the underlying change.

Where a submission sheet, declaration or supporting documents are required, the sponsor should continue to comply with the applicable instructions and deadlines.

For relevant change requests requiring supporting documents, these will generally need to be provided within 5 working days.

Using the priority service while failing to provide the required evidence can undermine the underlying request.

 

6. Priority consideration does not guarantee approval

 

The priority service expedites consideration of an eligible request. It does not guarantee a favourable decision.

The proposed key person must still satisfy the relevant requirements and the Home Office can still request further information, consider suitability issues or refuse the underlying request where the applicable requirements have not been met.

Employers should therefore distinguish between:

Priority processing – faster consideration of an eligible request.

Approval – acceptance of the underlying sponsor licence change.

Paying for or obtaining priority treatment should not be presented internally as confirmation that the personnel change will be accepted.

 

7. When might priority consideration be useful?

 

The service may be particularly useful where a legitimate operational need makes the timing of the key personnel change important.

Examples can include circumstances where:

• a key person has left unexpectedly;
• a replacement Level 1 User is required to maintain effective SMS administration;
• a change in the Authorising Officer needs to be resolved promptly following an organisational change;
• the organisation has time-sensitive sponsorship activity requiring appropriate SMS access;
• a pending key personnel change is affecting the sponsor’s ability to manage its licence; or
• a planned transaction or restructuring requires sponsor governance arrangements to be regularised promptly.

Whether priority treatment is necessary should be assessed against the actual operational position rather than used automatically for every personnel change.

 

8. Priority service should not replace proper changeover planning

 

Where a key person’s departure is foreseeable, sponsors should normally plan the transition before the individual leaves.

A well-managed changeover should:

1. identify the roles held by the outgoing individual;
2. validate the proposed replacement;
3. preserve appropriate SMS access;
4. submit the necessary Home Office changes;
5. provide any required supporting evidence;
6. verify that the changes have been completed; and
7. retain an appropriate audit trail.

This approach reduces the risk that the sponsor becomes dependent on priority processing simply because the personnel change was identified too late.

Where priority treatment is genuinely required, it should be used as part of a controlled compliance process rather than as a substitute for one.

 

 

 

 

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Section L: Common Problems When Changing Sponsor Licence Key Personnel

Many problems with sponsor licence key personnel changes arise not because an employer cannot identify a replacement, but because the changeover is managed in the wrong order or one of the individual’s other sponsorship roles is overlooked.

Employers should treat the departure or replacement of key personnel as a controlled sponsor compliance process rather than simply updating a name on the Sponsor Management System.

The following are among the most common problems to avoid.

 

1. Waiting until the individual has already left

 

A common mistake is to deal with the sponsor licence implications only after the employee’s departure has been processed through HR.

By that stage:

• their company email account may have been disabled;
• their telephone or authentication arrangements may no longer be available;
• their SMS access may have been deactivated;
• the organisation may have lost its only active Level 1 User;
• there may be nobody immediately available who understands outstanding sponsorship activity; and
• the individual may also have been the Authorising Officer or Key Contact.

Sponsor licence responsibilities should therefore form part of the organisation’s normal leaver procedure.

Where the departure is known in advance, the sponsor should identify and validate the replacement and preserve appropriate SMS access before the outgoing individual’s access is removed.

 

2. Removing the only Level 1 User too early

 

Removing or deactivating the sponsor’s only Level 1 User before replacement access has been established can leave the organisation unable to administer its sponsor licence through the normal SMS process.

This can affect the organisation’s ability to make personnel changes, manage Certificates of Sponsorship, make required reports and carry out other sponsorship functions.

Where a replacement Level 1 User request has been submitted, the sponsor should not assume that this means replacement access is already operational.

The organisation should verify that the new user’s status is Active and that effective SMS access has been established before relying on that person as the replacement.

The practical rule is:

Preserve access before removing access.

 

3. Assuming the Authorising Officer automatically has SMS access

 

The Authorising Officer and Level 1 User roles are different.

Being appointed as Authorising Officer does not automatically give the individual access to the Sponsor Management System.

If the outgoing Authorising Officer was also the organisation’s only Level 1 User, simply replacing them as Authorising Officer may leave the sponsor without operational SMS access.

The employer should therefore check both:

• who will hold senior responsibility as Authorising Officer; and
• who will have authorised operational access as a Level 1 User.

Where the new Authorising Officer also needs SMS access, the organisation should ensure that the relevant Level 1 User arrangements are made.

 

4. Using the wrong amend or replace function

 

Sponsors should distinguish between updating the details of an existing key person and appointing somebody else to the role.

The basic distinction is:

Same person, new details = amend.

Different person taking over = replace.

Selecting the wrong process can cause confusion, delay or an inaccurate sponsor record.

Before starting the SMS request, establish whether the identity of the role holder is changing or whether only their recorded details need to be updated.

 

5. Appointing a replacement without checking eligibility

 

An employee’s seniority within the business does not automatically make them eligible to act as sponsor key personnel.

Before submitting a replacement request, the organisation should check the requirements applying to the particular role.

Depending on the circumstances, this can include requirements concerning:

• the individual’s location;
• their National Insurance number;
• their relationship with the sponsor;
• their employment, directorship, partnership or other permitted status;
• their immigration status;
• their suitability;
• whether they are an internal employee or permitted external representative; and
• any role-specific requirements.

The organisation should also consider whether changing a Level 1 User affects its ability to satisfy the Home Office requirements applying to its primary Level 1 User arrangements.

 

6. Allowing former employees to retain SMS access

 

At the other extreme, sponsors should not leave obsolete SMS access in place indefinitely.

Where an employee leaves or no longer has responsibility for sponsorship, their access should be reviewed and removed when it is no longer required.

Former employees should not retain unnecessary access to a system through which significant sponsorship functions can be performed.

SMS access should therefore be included within the organisation’s normal access-control and employee offboarding procedures.

The timing of deactivation should, however, be coordinated with the need to preserve appropriate Level 1 access during the handover.

 

7. Overlooking other roles held by the same person

 

One individual can potentially hold several sponsor key personnel roles.

For example, an employee may simultaneously be:

• Authorising Officer;
• Key Contact; and
• the organisation’s only Level 1 User.

If that employee leaves, replacing them in only one capacity will not resolve the other positions.

The sponsor should therefore map every role and permission held by the outgoing individual before making any change.

This is particularly important where the organisation has historically concentrated sponsorship responsibilities in one senior HR or compliance employee.

 

8. Sharing SMS passwords or multi-factor authentication details

 

Employers should not respond to an SMS access problem by allowing another employee to use somebody else’s account.

SMS accounts are individual user accounts. Passwords and multi-factor authentication passcodes should not be shared.

Likewise, the email address associated with an SMS user should belong to the individual user rather than being a shared mailbox used by several employees.

Where another employee needs SMS access, the correct approach is to establish authorised access for that individual rather than informally sharing another user’s credentials.

This is especially important following the introduction of mandatory multi-factor authentication for SMS users from September 2026.

 

9. Treating submission as confirmation that the change is complete

 

Submitting a request through the SMS does not necessarily mean that the change has been completed.

Depending on the request, the sponsor may still need to:

• complete a submission sheet;
• provide supporting documents;
• respond to a Home Office request for further information;
• wait for the request to be considered;
• monitor the status of a new Level 1 User; and
• confirm that the resulting sponsor records are correct.

For Level 1 User appointments in particular, a status of Requested should not be treated as equivalent to Active.

The sponsor should verify completion rather than relying solely on evidence that the request was submitted.

 

10. Missing the supporting evidence deadline

 

Where the Home Office requires a submission sheet, declaration or supporting evidence for the change, the sponsor should ensure that the required material is provided within the applicable timeframe.

For relevant change requests, documents will generally need to be provided within 5 working days.

Employers should therefore identify likely evidence requirements before submitting the request wherever possible.

A request should not be submitted and then left unattended on the assumption that the SMS submission itself has completed the process.

 

11. Ignoring a pending request

 

Key personnel requests should be monitored until they have been resolved.

If a request remains pending, the sponsor should check:

• whether supporting evidence has been provided;
• whether the Home Office has requested additional information;
• whether a response deadline is outstanding;
• whether another sponsor licence request is affecting the change;
• whether the proposed user has become active; and
• whether the pending change affects other sponsorship activity.

The organisation should maintain clear ownership of the request so that responsibility for monitoring it does not become lost during the personnel change itself.

 

12. Assuming an external adviser removes the need for internal Level 1 arrangements

 

An appropriately permitted external immigration adviser can potentially act as a Level 1 User where the relevant requirements are satisfied.

However, this does not remove the sponsor’s obligation to maintain the Level 1 User arrangements required by the Home Office guidance.

The organisation should therefore not assume that appointing an external adviser allows it to operate without the internally connected Level 1 User required under the applicable rules.

Internal ownership and oversight of sponsorship should remain clear even where external advisers assist with SMS administration.

 

13. Failing to consider other sponsor licence changes taking place at the same time

 

A key personnel change may occur as part of a wider organisational event, such as:

• a merger or acquisition;
• a TUPE transfer;
• a restructuring;
• a change of ownership;
• the opening or closure of a branch;
• a change to the organisation’s trading arrangements; or
• a wider change to its HR, global mobility or compliance function.

Changing the Authorising Officer, Key Contact or Level 1 Users does not necessarily discharge any separate sponsor reporting obligations arising from the underlying corporate event.

The employer should therefore consider the personnel change alongside any wider sponsor licence reporting or application requirements.

 

14. Failing to review existing Level 2 Users

 

Following the September 2026 SMS changes, sponsors should not overlook historic Level 2 User accounts.

No new Level 2 Users can be appointed from 9 September 2026. Existing Level 2 Users should be reviewed and either upgraded to Level 1 User status, where eligible and appropriate, or deactivated by the applicable transitional deadline of 8 March 2027.

A key personnel review is therefore an appropriate opportunity to audit all existing SMS users rather than considering only the individual who is currently leaving or being replaced.

 

15. Failing to verify the final position

 

A key personnel change should end with verification.

Once the relevant requests have been processed, the sponsor should confirm that:

• the correct Authorising Officer is recorded;
• the correct Key Contact is recorded;
• the required Level 1 Users are active;
• the organisation continues to satisfy the applicable Level 1 User requirements;
• new users can access the SMS successfully;
• obsolete user access has been removed;
• individual authentication arrangements are working;
• any supporting evidence requirements have been completed;
• related sponsor licence changes have been addressed; and
• the organisation’s internal sponsor records have been updated.

The changeover is not complete merely because somebody clicked Submit. It is complete when the sponsor has verified that its key personnel, SMS access and internal governance arrangements accurately reflect the intended position.

 

 

 

 

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Section M: Key Personnel Changeover Checklist

A sponsor licence key personnel change should be managed as a controlled compliance process rather than as a single SMS transaction.

DavidsonMorris recommends using the following seven-stage changeover protocol:

Identify → Validate → Preserve Access → Notify → Evidence → Verify → Audit

This approach is designed to reduce the risk of losing SMS access, appointing an ineligible replacement, overlooking another role held by the outgoing individual or assuming that a submitted Home Office request has already been completed.

 

1. Identify

 

Start by establishing exactly what is changing.

Identify the outgoing individual and map every sponsor licence role and SMS permission they currently hold.

Check whether they are:

• the Authorising Officer;
• the Key Contact;
• a Level 1 User;
• the organisation’s only Level 1 User;
• an existing Level 2 User;
• responsible for assigning Certificates of Sponsorship;
• responsible for making reports about sponsored workers;
• responsible for monitoring Home Office communications; or
• responsible internally for maintaining sponsor compliance records.

Do not assume that an employee holds only the sponsor role referred to in their job description. In smaller organisations in particular, one individual may simultaneously act as Authorising Officer, Key Contact and Level 1 User.

The sponsor should also identify why the change is taking place and the intended effective date.

This may be because of resignation, dismissal, promotion, internal transfer, restructuring, extended absence, a change of responsibilities, loss of eligibility or a wider corporate event.

 

2. Validate

 

Once the required replacement has been identified, check that the proposed individual is eligible for the role before submitting the change.

Depending on the role and circumstances, this should include checking:

• the requirements applying to the Authorising Officer, Key Contact or Level 1 User role;
• the individual’s relationship with the sponsoring organisation;
• whether they are appropriately based in the UK, subject to applicable exceptions;
• their National Insurance number position where relevant;
• their immigration status where this is relevant to eligibility;
• whether they meet the applicable suitability requirements;
• whether they are an employee, director, partner or otherwise fall within a permitted category;
• whether an external representative is permitted to hold the proposed role;
• whether the sponsor will continue to satisfy the primary Level 1 User requirements;
• whether route-specific requirements apply, including for UK Expansion Worker sponsors; and
• whether the individual requires SMS access in addition to holding another key personnel role.

If the proposed individual will hold more than one role, eligibility should be checked for each role separately.

The fact that somebody is eligible to act as Key Contact, for example, does not by itself establish that they satisfy the requirements to become a Level 1 User.

 

3. Preserve Access

 

Before removing or deactivating an outgoing SMS user, establish how the organisation will continue to access and operate the Sponsor Management System.

This stage is particularly important where the departing person is the sponsor’s only Level 1 User.

The sponsor should check:

• whether another eligible Level 1 User is already active;
• whether an additional or replacement Level 1 User needs to be requested;
• whether any replacement request has actually become active;
• whether the proposed new user can access the SMS successfully;
• whether there is time-sensitive sponsorship activity during the handover;
• whether individual email and multi-factor authentication arrangements are functioning correctly; and
• when the outgoing user’s access can safely be removed.

A request showing as Requested should not be treated as equivalent to an Active Level 1 User.

Where possible, the organisation should establish effective replacement access before removing access that it still needs.

Preserve access before removing access.

 

4. Notify

 

Once the replacement has been validated and the access implications have been addressed, complete the appropriate Home Office process.

The required action will depend on the circumstances.

Situation	Action
Same Authorising Officer, changed details	Amend the Authorising Officer’s details
Different Authorising Officer	Replace the Authorising Officer
Same Key Contact, changed details	Amend the Key Contact’s details
Different Key Contact	Replace the Key Contact
Additional operational SMS user required	Add an eligible Level 1 User
Existing Level 1 User no longer requires access	Remove or deactivate the user when appropriate
No active Level 1 User can access the SMS	Use the applicable Home Office sponsor change of circumstances process
Existing Level 2 User requires continued access	Assess eligibility and, where appropriate, upgrade to Level 1 User before the transitional deadline
Existing Level 2 User no longer requires access	Deactivate the account

For a replacement Authorising Officer, the relevant SMS path is:

Licence summary, applications and services → Request changes to licence details → Replace your Authorising Officer.

The sponsor should record when the relevant request was made and retain the submission or change-request reference.

 

5. Evidence

 

After making the request, check whether the Home Office requires a submission sheet, declaration or supporting documents.

For example, replacing an Authorising Officer generates a submission sheet which needs to be completed and provided with the supporting evidence required for the request.

Where documents are required in support of a relevant change request, these should generally be provided within 5 working days.

If the Home Office subsequently requests additional information or evidence, the sponsor should respond within the deadline specified in the request, generally within 5 working days under the current sponsor guidance.

The organisation should record:

• what evidence was required;
• who prepared it;
• when it was submitted;
• how it was submitted;
• the relevant reference number;
• whether further information was requested; and
• when any additional response was provided.

Do not assume that completing the SMS request means that all evidential requirements have been satisfied.

 

6. Verify

 

The sponsor should verify that the intended changes have actually taken effect.

This stage is essential because submitting a request is not the same as completing the changeover.

Check that:

• the correct Authorising Officer is recorded;
• the correct Key Contact is recorded;
• the required Level 1 Users are active;
• the organisation continues to satisfy the applicable Level 1 User requirements;
• new SMS users can access the system;
• individual authentication arrangements are working;
• obsolete access has been removed;
• former employees no longer have inappropriate SMS access;
• any required supporting evidence has been accepted or dealt with;
• there are no outstanding Home Office requests requiring action; and
• any related sponsor licence changes have also been addressed.

If a new Level 1 User is still showing as Requested, the organisation should not record the changeover as complete on the assumption that the user has operational access.

Verification should establish the actual position.

 

7. Audit

 

The final stage is to update the organisation’s internal sponsor compliance records and retain an audit trail of the change.

The audit record should document:

• the reason for the personnel change;
• the date the issue was identified;
• the outgoing individual’s roles and permissions;
• the date their responsibilities ended;
• the identity of the replacement;
• the eligibility checks carried out;
• the internal approval for the appointment;
• the Home Office change submitted;
• the date of submission;
• the supporting evidence provided;
• any further Home Office correspondence;
• the date the replacement became effective;
• the date any obsolete SMS access was removed;
• confirmation that operational SMS access was tested; and
• any associated changes to the organisation’s sponsorship governance procedures.

The employer should also consider whether the personnel change exposes a wider weakness in its sponsor management arrangements.

For example, if the unexpected departure of one employee left the organisation with no functioning SMS access, the sponsor may decide that its future governance model should include additional eligible and appropriately trained Level 1 Users.

 

8. Key Personnel Changeover Protocol

 

The complete process can be summarised as:

1. Identify – establish every sponsor role and permission affected by the change.
2. Validate – confirm that the proposed replacement satisfies the applicable requirements.
3. Preserve Access – maintain effective SMS access throughout the transition wherever possible.
4. Notify – use the correct SMS or Home Office process to make the change.
5. Evidence – provide the required submission sheet, declarations and supporting documents within the applicable timeframe.
6. Verify – confirm that the changes have taken effect and that the intended users can operate the SMS.
7. Audit – retain a complete internal record and address any weaknesses identified during the changeover.

Identify → Validate → Preserve Access → Notify → Evidence → Verify → Audit.

Following this sequence helps turn what could otherwise be an ad hoc personnel update into a controlled sponsor licence compliance process.

 

 

 

 

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Section N: What Happens If You Do Not Keep Key Personnel Up to Date?

Keeping sponsor licence key personnel up to date is a compliance requirement, not simply an administrative preference.

The Home Office expects sponsors to maintain appropriate key personnel throughout the life of the sponsor licence and to ensure that the individuals responsible for sponsorship continue to satisfy the requirements applying to their roles.

Particular importance attaches to the Authorising Officer and Level 1 User arrangements. Under the current sponsor guidance, a sponsor must have an eligible Authorising Officer and at least one eligible Level 1 User throughout the period in which it holds its licence.

Failure to maintain these mandatory personnel arrangements can place the sponsor licence at direct risk.

 

1. Failure to maintain an eligible Authorising Officer

 

The sponsor must have an eligible Authorising Officer throughout the life of its licence.

If the existing Authorising Officer leaves, becomes ineligible or otherwise ceases to perform the role, the organisation should take the necessary action to establish an eligible replacement.

This is particularly important because the Authorising Officer is the senior individual responsible for the organisation’s sponsor licence arrangements and oversight of those carrying out sponsorship activities.

Under the current Home Office sponsor guidance, failure to have an eligible Authorising Officer is a circumstance in which the Home Office will revoke the sponsor licence.

An employer should therefore not allow the Authorising Officer position to remain unresolved following a departure or organisational change.

 

2. Failure to maintain an eligible Level 1 User

 

The sponsor must also maintain at least one eligible Level 1 User throughout the life of the licence.

This requirement has both a compliance and an operational dimension.

Without an appropriate Level 1 User, the organisation may be unable to administer its sponsor licence effectively through the SMS. It may also be failing to satisfy a mandatory requirement of holding the licence.

Under the current sponsor guidance, failure to have at least one eligible Level 1 User is a circumstance in which the Home Office will revoke the sponsor licence.

This is why the departure of an organisation’s only Level 1 User should be treated as a priority sponsor compliance issue rather than merely as an internal access-management problem.

 

3. An active SMS account is not enough if the user is no longer eligible

 

Sponsors should not assume that the requirement is satisfied simply because somebody’s Level 1 User account remains active on the system.

The individual must continue to meet the applicable requirements.

For example, a former employee should not simply remain recorded as the organisation’s operational Level 1 User because their account has not yet been removed.

The sponsor should regularly check that the people recorded as its key personnel remain appropriately connected to the organisation, eligible for their roles and genuinely responsible for the functions attributed to them.

 

4. Outdated key personnel can affect the sponsor’s ability to comply with its wider duties

 

Even where an outdated personnel record does not itself immediately result in enforcement action, ineffective key personnel arrangements can contribute to wider sponsor compliance failures.

For example, inadequate personnel arrangements can lead to:

• required reports not being made;
• Home Office correspondence not being identified or answered;
• Certificate of Sponsorship activity being delayed or incorrectly managed;
• changes to sponsored workers not being reported correctly;
• organisation-level changes being overlooked;
• former employees retaining inappropriate SMS access;
• supporting evidence deadlines being missed; or
• the organisation being unable to demonstrate effective oversight of its sponsorship activity.

These issues should be assessed on their own facts and against the relevant sponsor duties. The potential Home Office response will depend on the particular breach and the applicable sponsor guidance.

 

5. Home Office compliance action can extend beyond the personnel change itself

 

If a key personnel problem exposes wider deficiencies in the organisation’s sponsorship arrangements, the Home Office may consider those issues as part of its broader assessment of sponsor compliance.

Depending on the circumstances and the nature of any wider breach, Home Office action can include measures such as:

• requesting further information or evidence;
• examining the sponsor’s compliance arrangements;
• conducting a compliance visit;
• refusing a particular sponsor request;
• downgrading the sponsor licence where the applicable rules permit;
• suspending the sponsor licence; or
• revoking the sponsor licence.

The applicable consequence will depend on the nature and seriousness of the issue and the relevant provisions of the sponsor guidance.

This broader discretionary compliance position should be distinguished from the specific requirement to maintain an eligible Authorising Officer and at least one eligible Level 1 User, where the current guidance provides for revocation if those mandatory arrangements are not maintained.

 

6. Key personnel problems can be identified during a Home Office compliance visit

 

The Home Office can examine the organisation’s sponsor management arrangements as part of a compliance visit or other investigation into the sponsor’s compliance with its duties.

The organisation may need to demonstrate that:

• the individuals recorded as key personnel are current;
• they satisfy the requirements applying to their roles;
• the Authorising Officer exercises appropriate oversight;
• SMS access is limited to authorised individuals;
• former employees do not retain inappropriate access;
• the organisation understands who is responsible for sponsorship functions;
• appropriate controls exist over SMS activity; and
• changes to personnel are identified and managed appropriately.

An organisation whose SMS records contain former employees, obsolete contact information or inappropriate user access may therefore face questions about the effectiveness of its wider sponsor governance.

 

7. Poor change management can create avoidable evidence problems

 

A sponsor may have made the correct personnel change but still create compliance difficulties if it cannot demonstrate what happened.

Employers should therefore retain an appropriate record showing:

• when the outgoing individual left or changed responsibilities;
• which sponsor roles they held;
• when the need for a replacement was identified;
• how the replacement’s eligibility was checked;
• when the Home Office request was made;
• what supporting evidence was provided;
• when the change became effective;
• when obsolete SMS access was removed; and
• how the organisation maintained sponsorship administration during the transition.

This audit trail can help the sponsor demonstrate that the change was identified, controlled and completed appropriately.

 

8. Do not wait for a Home Office problem before reviewing key personnel

 

Key personnel should be reviewed periodically as part of the organisation’s sponsor licence compliance arrangements.

A review is particularly appropriate following:

• senior employee departures;
• changes within HR, legal, global mobility or compliance teams;
• mergers and acquisitions;
• restructuring;
• TUPE transfers;
• changes of ownership or organisational structure;
• appointment or termination of external immigration advisers;
• changes to SMS user responsibilities; and
• Home Office changes to sponsor management requirements.

Employers should also periodically compare their active SMS users against current personnel records to identify obsolete accounts or individuals whose responsibilities have changed.

 

9. Treat key personnel continuity as part of sponsor governance

 

The objective is not merely to keep three names updated on a Home Office system.

Effective key personnel arrangements should ensure that the organisation maintains:

• clear senior responsibility for sponsorship;
• a reliable point of contact with the Home Office;
• secure and effective SMS access;
• appropriate segregation or oversight of sponsorship activity;
• continuity when employees leave or become unavailable; and
• a clear audit trail of significant sponsor licence decisions and changes.

For employers that sponsor workers regularly, key personnel continuity should therefore form part of the organisation’s wider immigration compliance framework.

The most effective approach is to identify personnel changes early, validate replacements before appointment, preserve operational access, complete the correct Home Office process, provide the required evidence, verify the final position and retain a clear audit trail.

Identify → Validate → Preserve Access → Notify → Evidence → Verify → Audit.

 

 

 

 

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Section O: How DavidsonMorris Can Help

Changes to sponsor licence key personnel can appear straightforward, but problems can arise where the outgoing individual holds several sponsor roles, the organisation is dependent on a single Level 1 User or there is uncertainty over whether a proposed replacement satisfies the Home Office requirements.

DavidsonMorris advises employers on the full range of sponsor licence management and compliance issues, including changes to Authorising Officers, Key Contacts and Sponsor Management System users.

We can support employers with planned personnel changes as well as urgent situations where a key person has already left or the organisation has lost effective access to the SMS.

 

1. Advice on replacing sponsor licence key personnel

 

We can advise on the correct procedure for replacing or amending sponsor licence key personnel, including:

• replacing an Authorising Officer;
• changing or updating a Key Contact;
• adding or replacing Level 1 Users;
• removing obsolete SMS users;
• reviewing existing Level 2 Users following the September 2026 changes;
• determining whether a change should be treated as an amendment or replacement;
• identifying where one individual holds several sponsor roles; and
• planning the sequence of changes to preserve effective sponsor management and SMS access.

 

2. Checking key personnel eligibility

 

Before a replacement is appointed, we can assess whether the proposed individual meets the Home Office requirements applying to the relevant role.

This can include reviewing:

• the individual’s relationship with the sponsoring organisation;
• their employment, directorship, partnership or other relevant status;
• UK-based requirements and applicable exceptions;
• immigration status requirements where relevant;
• National Insurance number requirements;
• suitability considerations;
• the requirements applying to internally connected Level 1 Users;
• the use of external representatives; and
• route-specific requirements, including those affecting UK Expansion Worker sponsors.

This can help identify eligibility problems before the employer submits the change or removes the outgoing individual’s access.

 

3. Managing the departure of your only Level 1 User

 

Where the organisation’s only Level 1 User is leaving, careful sequencing can be particularly important.

We can advise on establishing replacement arrangements, maintaining appropriate access during the handover and dealing with circumstances where the existing Level 1 User has already left.

If the sponsor has lost access to the SMS altogether, we can advise on the appropriate Home Office change of circumstances process and the steps required to restore compliant Level 1 User arrangements.

Where the departed individual was also the Authorising Officer or Key Contact, we can assess the complete key personnel position rather than dealing with the SMS access problem in isolation.

 

4. Supporting evidence and Home Office requests

 

Where a personnel change requires a submission sheet, declaration or supporting evidence, we can advise on the documents required and the applicable submission process.

We can also assist where the Home Office has requested additional information or evidence in connection with a change.

This can be particularly important where a response deadline is running or where the proposed replacement raises an eligibility or suitability issue requiring careful consideration.

 

5. Post-licence priority service

 

Where timing is important, we can advise on whether the relevant key personnel change is eligible for the Home Office’s post-licence priority service and assist with the priority process where appropriate.

Priority treatment does not guarantee approval, and the underlying request must still satisfy the applicable requirements. We can therefore review both the substantive change and the priority process rather than treating expedited consideration as a substitute for a compliant application.

 

6. Sponsor licence audits and governance

 

A key personnel change can also provide an opportunity to review the organisation’s wider sponsor management arrangements.

We can conduct sponsor licence compliance audits covering areas such as:

• current Authorising Officer and Key Contact arrangements;
• Level 1 User eligibility and access;
• historic or obsolete SMS accounts;
• SMS access controls and multi-factor authentication arrangements;
• internal responsibility for sponsor reporting;
• Certificate of Sponsorship controls;
• record-keeping systems;
• reporting processes;
• right to work procedures;
• leaver and organisational-change procedures;
• internal sponsor governance; and
• readiness for a Home Office compliance visit.

The objective is to identify weaknesses before they result in missed reporting obligations, inappropriate SMS access or wider sponsor compliance problems.

 

7. Support with complex organisational changes

 

Key personnel changes can sometimes be part of a much wider change to the sponsoring organisation.

This may include:

• mergers and acquisitions;
• TUPE transfers;
• corporate restructuring;
• changes of ownership;
• changes to branches or operating locations;
• changes within HR or global mobility functions; or
• changes to the organisation’s immigration adviser arrangements.

In these circumstances, replacing key personnel may be only one element of the sponsor licence implications.

We can assess the wider event to identify the relevant reporting, application and compliance requirements and help coordinate the required sponsor licence actions.

 

8. Speak to our sponsor licence specialists

 

If you need to change your Authorising Officer, Key Contact or Level 1 Users, or if a key person has already left and you are unsure what action is required, contact DavidsonMorris for specialist advice.

Early advice can be particularly important where the organisation’s only Level 1 User is leaving, SMS access has already been lost, a Home Office deadline is running or the personnel change forms part of a wider corporate restructuring.
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Section P: Frequently Asked Questions

 

Can the Authorising Officer also be a Level 1 User?

Yes. The same individual can act as both Authorising Officer and Level 1 User provided they meet the Home Office requirements applying to both roles.

Appointment as Authorising Officer does not automatically give the individual access to the Sponsor Management System. If the Authorising Officer also needs to carry out SMS functions, the sponsor should ensure that they are properly appointed as a Level 1 User.

 

Can the Authorising Officer and Key Contact be the same person?

Yes. The same individual can potentially act as both Authorising Officer and Key Contact where they satisfy the requirements for both roles.

Where a new Authorising Officer will also become the Key Contact, the relevant SMS process allows the sponsor to indicate that the same individual will perform both roles.

Employers should nevertheless consider operational resilience before concentrating several sponsor licence functions in one person.

 

Can a sponsor have more than one Level 1 User?

Yes. A sponsor can have more than one Level 1 User.

Having additional eligible and appropriately trained Level 1 Users can improve operational resilience by reducing dependence on a single individual for access to the Sponsor Management System.

Additional users should only be appointed where there is a genuine operational reason for them to have access. The sponsor remains responsible for controlling SMS access and ensuring that its Level 1 User arrangements satisfy the applicable Home Office requirements.

 

Can our immigration adviser be a Level 1 User?

An appropriately permitted external immigration adviser or representative can potentially be appointed as a Level 1 User where the relevant Home Office requirements are met.

However, appointing an external adviser does not remove the sponsor’s obligation to maintain the internally connected Level 1 User arrangements required under the sponsor guidance.

The organisation should therefore maintain appropriate internal responsibility and oversight even where an external adviser assists with SMS administration.

 

What happens if our only Level 1 User leaves?

If the departure is known in advance, the sponsor should arrange appropriate replacement Level 1 User access before the existing user’s access is removed wherever possible.

The sponsor should identify an eligible replacement, submit the relevant request, monitor its progress and verify that the new user has become active and can access the SMS.

If the only Level 1 User has already left and nobody can access the SMS, the sponsor can use the relevant Home Office sponsor change of circumstances process to request a new Level 1 User in the circumstances permitted by that process.

The sponsor should act promptly because it must maintain at least one eligible Level 1 User throughout the life of the licence.

 

What if our only Level 1 User was also the Authorising Officer?

The organisation will need to address both roles.

Replacing the Authorising Officer does not automatically restore Level 1 SMS access, and appointing a new Level 1 User does not by itself replace the Authorising Officer.

Where the sponsor has no Level 1 User able to access the SMS, the Home Office change of circumstances process can be used in specified circumstances to replace the Authorising Officer where the proposed new Authorising Officer will also become the sponsor’s sole Level 1 User.

The sponsor should also check whether the departed individual was the Key Contact or held any other sponsorship responsibilities.

 

Can we change key personnel while another SMS request is pending?

The effect of another pending request will depend on the type of change already under consideration and the further action the sponsor wants to take.

Before submitting another change, the sponsor should check the status of the existing request and whether the SMS permits the additional action.

Where several related changes are required, employers should consider the correct sequence rather than submitting overlapping requests without assessing how they interact.

This can be particularly important during a restructuring or where the same individual holds several key personnel roles.

 

Does changing key personnel affect Certificates of Sponsorship already assigned?

A change to the organisation’s key personnel does not, by itself, mean that Certificates of Sponsorship previously assigned to workers automatically cease to be valid.

However, the sponsor should consider whether the personnel change affects its ability to carry out ongoing sponsorship functions, including worker reporting, Certificate of Sponsorship administration and responding to Home Office communications.

If the personnel change forms part of a wider corporate change, separate sponsor licence implications may also arise and should be assessed independently.

 

Does the Home Office have to approve a new Authorising Officer?

A replacement Authorising Officer is not simply an internal appointment that can be treated as complete once the employer has selected the individual.

The sponsor must follow the relevant Home Office process to replace the Authorising Officer and provide the required information and supporting evidence.

The replacement request should therefore be monitored through to completion rather than assuming that the individual’s internal appointment means the sponsor licence record has already changed.

 

How do we replace an Authorising Officer through the SMS?

An existing Level 1 User can normally start the process through:

Licence summary, applications and services → Request changes to licence details → Replace your Authorising Officer.

The sponsor will need to provide the required details about the replacement and complete the relevant declaration. Replacing an Authorising Officer generates a submission sheet, and the sponsor should provide the required supporting evidence in accordance with the Home Office instructions.

 

How quickly do supporting documents need to be sent?

Where a relevant sponsor change request requires a submission sheet, declaration or supporting documents, the required material should generally be provided within 5 working days.

If the Home Office subsequently requests additional information or evidence, the sponsor should respond within the deadline stated in the request, generally within 5 working days under the current sponsor guidance.

Employers should therefore prepare likely evidence before submitting the change wherever possible.

 

Can we appoint a new Level 2 User?

No. Sponsors can no longer appoint new Level 2 Users following the changes introduced from 9 September 2026.

Where another individual requires SMS access, the employer should consider whether the person should be appointed as a Level 1 User and whether they satisfy the applicable requirements.

 

What happens to existing Level 2 Users?

Existing Level 2 Users are subject to transitional arrangements.

Sponsors should review each existing Level 2 User and either upgrade the individual to Level 1 User status, where they are eligible and continued access is appropriate, or deactivate the account.

The required action should be completed by 8 March 2027. Remaining Level 2 accounts are due to be deactivated by the Home Office after the transitional period.

 

Can employees share an SMS account?

No. SMS accounts are individual user accounts. Employees should not share SMS passwords or multi-factor authentication passcodes.

The email address associated with an SMS user should also belong to that individual rather than being a shared mailbox used by several employees.

If another employee needs SMS access, the sponsor should arrange authorised access for that individual rather than allowing them to use another person’s credentials.

 

Do we need to change the Key Contact if only their details have changed?

Not necessarily. If the same individual remains Key Contact but their relevant details have changed, the sponsor should generally amend the existing record rather than replace the Key Contact.

The same distinction applies when considering changes to an existing Authorising Officer:

Same person, new details = amend.

Different person taking over = replace.

 

Can we use the priority service for a key personnel change?

Certain key personnel changes are currently eligible for the Home Office’s post-licence priority service, including specified changes involving Level 1 Users, Authorising Officers and Key Contacts.

The sponsor should check current eligibility, availability and procedural requirements when the change is made.

Priority consideration does not guarantee approval and does not remove the requirement to provide any supporting evidence required for the underlying request.

 

What should we do after the key personnel change is completed?

The sponsor should verify the final position rather than simply retaining evidence that a request was submitted.

Check that:

• the correct Authorising Officer and Key Contact are recorded;
• the required Level 1 Users are active;
• new users can access the SMS;
• obsolete access has been removed;
• the organisation continues to satisfy the applicable key personnel requirements;
• there are no outstanding Home Office requests or evidence requirements; and
• the organisation’s internal sponsor compliance records have been updated.

The employer should retain an audit trail showing how the change was identified, managed and completed.
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Section Q: Key Personnel Changeover: Practical Summary

Changing sponsor licence key personnel is usually manageable where the employer identifies the change early, checks the replacement’s eligibility and follows the correct Home Office process.

The greatest risks tend to arise where an individual leaves unexpectedly, the organisation depends on a single Level 1 User, several sponsor roles are concentrated in one person or the employer assumes that submitting an SMS request means the change has already been completed.

The practical objective is to maintain compliant key personnel arrangements and effective control of the sponsor licence throughout the transition.

 

1. Establish exactly what is changing

 

Start by identifying whether the organisation needs to:

• replace its Authorising Officer;
• amend the existing Authorising Officer’s details;
• replace its Key Contact;
• amend the existing Key Contact’s details;
• add another Level 1 User;
• replace a departing Level 1 User;
• remove or deactivate an existing SMS user;
• restore Level 1 User access after losing access to the SMS; or
• deal with an existing Level 2 User under the September 2026 transitional arrangements.

The distinction between amending and replacing personnel should be made at the outset:

Same person, new details = amend.

Different person taking over = replace.

 

2. Map every role held by the outgoing individual

 

Do not consider the person’s roles in isolation.

An outgoing employee may simultaneously be the:

• Authorising Officer;
• Key Contact;
• only Level 1 User; and
• person responsible internally for day-to-day sponsor licence administration.

The employer should identify every role and permission affected by the departure before making changes to the SMS.

 

3. Check the replacement is eligible

 

Before appointing a replacement, check the current Home Office requirements for the relevant role.

Do not assume that somebody is eligible simply because they are sufficiently senior within the organisation or already work within HR.

Where the individual will hold more than one key personnel role, their eligibility should be considered against the requirements for each role.

Particular care should be taken when changing Level 1 Users to ensure the organisation continues to satisfy the Home Office requirements applying to its primary Level 1 User arrangements.

 

4. Preserve SMS access during the transition

 

Where the outgoing person is an SMS user, determine how access will be maintained before their account is removed.

This is especially important where they are the organisation’s only Level 1 User.

A replacement request being submitted does not necessarily mean the replacement user’s account is active. The employer should monitor the request and confirm that effective access has been established.

Preserve access before removing access.

 

5. Use the correct Home Office process

 

Most key personnel changes can be made through the Sponsor Management System by an existing Level 1 User.

Where there is no active Level 1 User able to access the SMS, the sponsor may need to use the relevant Home Office sponsor change of circumstances process for the circumstances covered by that process.

The alternative process should not be treated as a general substitute for the SMS.

 

6. Complete the evidence stage

 

Check whether the change generates a submission sheet or requires supporting information or evidence.

For example, replacing an Authorising Officer generates a submission sheet which should be completed and provided with the required supporting evidence.

Where documents are required for a relevant change request, these should generally be provided within 5 working days.

The sponsor should also respond promptly to any subsequent Home Office request for additional information or evidence within the deadline specified.

 

7. Verify that the change has actually been completed

 

Do not close the internal changeover process simply because the request has been submitted.

Verify that:

• the correct key personnel are recorded;
• required Level 1 Users are active;
• new SMS users can access the system;
• obsolete access has been removed;
• the organisation continues to satisfy the applicable key personnel requirements;
• supporting evidence requirements have been completed; and
• there are no outstanding Home Office requests requiring action.

 

8. Retain an audit trail

 

The organisation should retain an internal record showing what changed, why the change was necessary, how the replacement’s eligibility was checked, what was submitted to the Home Office and when the final arrangements were verified.

This provides evidence of the organisation’s sponsor governance and can be useful during an internal audit or Home Office compliance visit.

 

9. Key personnel changeover at a glance

 

Stage	Employer action
Identify	Establish every key personnel role and SMS permission affected
Validate	Check that the proposed replacement satisfies the applicable requirements
Preserve Access	Maintain appropriate Level 1 User access throughout the transition
Notify	Use the correct SMS or Home Office process
Evidence	Provide required declarations, submission sheets and supporting documents within the applicable timeframe
Verify	Confirm that the intended changes have taken effect and required SMS access is operational
Audit	Update internal records and retain evidence of the complete changeover

Identify → Validate → Preserve Access → Notify → Evidence → Verify → Audit.

Following this sequence helps the sponsor maintain continuity of responsibility, SMS access and compliance while its key personnel change.
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Section R: Further Sponsor Licence Guidance

Changing key personnel is one part of the wider responsibility of managing a sponsor licence. Employers should ensure that changes to the individuals responsible for sponsorship are considered alongside their broader sponsor management, reporting and compliance obligations.

The following DavidsonMorris guidance provides further information on related sponsor licence issues.

 

1. Sponsor Licence Management

 

Our Sponsor Licence Management: Employer Guide explains the wider framework for managing a sponsor licence after it has been granted, including ongoing administration, governance, reporting and compliance responsibilities.

 

2. Sponsor Licence Key Personnel

 

Our Sponsor Licence Key Personnel: Roles & Requirements guide explains who can act as sponsor key personnel, the requirements applying to the different roles and how the Authorising Officer, Key Contact and SMS users fit within the sponsor management structure.

 

3. Authorising Officer

 

Our Authorising Officer: Sponsor Licence Duties & Requirements guide considers the Authorising Officer role in detail, including eligibility, responsibilities, oversight of sponsorship activity and the relationship between the Authorising Officer and SMS users.

 

4. Key Contact

 

Our Key Contact: Sponsor Licence Role & Responsibilities guide explains the purpose of the Key Contact role, eligibility requirements and the individual’s position as a principal contact between the sponsor and the Home Office.

 

5. Level 1 User

 

Our Level 1 User: Sponsor Licence Role & Responsibilities guide covers eligibility, SMS permissions, user responsibilities and the requirements sponsors need to consider when appointing and maintaining Level 1 Users.

 

6. Sponsor Management System

 

Our Sponsor Management System (SMS): Employer Guide explains how the SMS is used to administer a sponsor licence, manage users, assign Certificates of Sponsorship, report changes and maintain sponsor information.

 

7. Sponsor Licence Reporting Duties

 

Key personnel changes can occur alongside wider changes affecting the sponsoring organisation or its sponsored workers. Employers should ensure that personnel changes do not result in separate reporting obligations being overlooked.

Our sponsor reporting guidance explains the types of changes that may need to be reported, the applicable procedures and the importance of maintaining accurate sponsor records.

 

8. Sponsor Licence Compliance

 

Our sponsor compliance guidance considers the wider duties that apply throughout the life of the sponsor licence, including record keeping, reporting, monitoring sponsored workers and maintaining effective systems for sponsorship compliance.

 

9. Home Office Compliance Visits

 

The Home Office can examine key personnel arrangements and SMS controls as part of its assessment of sponsor compliance.

Our guidance on Home Office compliance visits explains how visits operate, the areas that can be examined and how employers can prepare their sponsor management systems and records for scrutiny.

 

10. Sponsor Licence Suspension and Revocation

 

Where failures involving key personnel form part of wider sponsor non-compliance, the organisation may face Home Office enforcement action. The precise consequences depend on the nature of the breach and the applicable sponsor guidance.

Our separate guides to sponsor licence suspension and revocation explain these enforcement processes, the potential consequences for the organisation and its sponsored workers and the issues employers should consider when responding to Home Office action.

 

11. Business Changes and Sponsor Licences

 

A change of key personnel may be triggered by a merger, acquisition, restructuring, TUPE transfer, change of ownership or another corporate event.

Replacing the individuals recorded as sponsor key personnel does not necessarily satisfy the separate sponsor licence requirements arising from the underlying organisational change.

Employers undergoing a wider business change should therefore consider both the personnel implications and the separate sponsor licence reporting, application and compliance requirements created by the transaction or restructuring.
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Section S: Primary Home Office Guidance

Employers changing sponsor licence key personnel should check the current Home Office sponsor guidance and Sponsor Management System guidance before making the change.

Home Office requirements and SMS procedures can change. Sponsors should therefore use the version of the guidance in force when the change is being made rather than relying solely on procedures followed for an earlier personnel change.

 

1. Workers and Temporary Workers: Guidance for Sponsors

 

The Home Office Workers and Temporary Workers: Guidance for Sponsors sets out the principal requirements applying to sponsor licence holders, including the rules relating to sponsor key personnel.

Relevant provisions include requirements concerning:

• the Authorising Officer;
• the Key Contact;
• Level 1 Users;
• eligibility and suitability of key personnel;
• the required relationship between key personnel and the sponsoring organisation;
• the minimum Level 1 User arrangements that sponsors must maintain;
• the use of external representatives;
• changes to sponsor key personnel;
• the consequences of failing to maintain eligible mandatory key personnel; and
• route-specific exceptions and transitional provisions.

Sponsors should check the current version of the guidance whenever appointing or replacing key personnel.

 

2. Sponsor Management System Manuals

 

The Home Office publishes a series of Sponsor Management System manuals explaining how sponsors should use the SMS.

For key personnel changes, the relevant manuals include guidance on:

• requesting changes to sponsor licence details;
• replacing or amending the Authorising Officer;
• replacing or amending the Key Contact;
• adding and managing Level 1 Users;
• managing SMS user access;
• the status of SMS user requests;
• submission sheets and declarations; and
• the procedures for completing particular sponsor licence changes.

Employers should follow the current SMS manual relevant to the action they are taking rather than assuming that all key personnel changes follow the same process.

 

3. Sponsor Change of Circumstances Form

 

The Home Office provides a separate Sponsor Change of Circumstances Form for specified circumstances where the required action cannot be completed through the normal Sponsor Management System process.

This is particularly relevant where a sponsor has no active Level 1 User able to access the SMS.

Depending on the circumstances covered by the current form, it can be used for specified actions including:

• requesting the addition of a Level 1 User where there is no existing Level 1 User able to access the SMS;
• replacing the Authorising Officer where the proposed new Authorising Officer will also become the sponsor’s sole Level 1 User;
• surrendering the sponsor licence; and
• requesting dormant status where the applicable requirements are met.

The form should not be treated as a general alternative to the SMS for ordinary key personnel changes.

Where an authorised Level 1 User can access the SMS and the required function is available through the system, the sponsor should use the normal SMS process.

 

4. Worker and Temporary Worker Priority Change of Circumstance Service

 

The Home Office also publishes guidance on the Worker and Temporary Worker Priority Change of Circumstance Service.

The service can provide expedited consideration for specified post-licence requests, including eligible changes involving:

• Level 1 Users;
• Authorising Officers; and
• Key Contacts.

The sponsor should check the current eligibility requirements, service availability, application procedure and evidential requirements before requesting priority treatment.

Priority consideration does not guarantee approval of the underlying change.

 

5. Check the guidance in force when making the change

 

Sponsor management procedures continue to develop. The September 2026 changes affecting Level 2 Users and multi-factor authentication demonstrate why employers should not rely indefinitely on historic SMS procedures.

Before changing key personnel, sponsors should confirm:

• the current eligibility requirements for the proposed individual;
• the correct SMS function or alternative Home Office process;
• the information required for the request;
• whether a submission sheet or declaration is generated;
• whether supporting documents are required;
• the applicable deadline for providing evidence;
• whether the request is eligible for priority consideration; and
• whether any transitional or route-specific rules apply.

This should be incorporated into the organisation’s normal sponsor licence change-management process rather than relying on internal procedures that may have been written under an earlier version of the Home Office guidance.
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Section T: Conclusion

Changing sponsor licence key personnel should be treated as a controlled compliance process rather than a routine administrative update.

Employers need to identify precisely what is changing, determine every sponsor role held by the outgoing individual, confirm that any proposed replacement meets the applicable Home Office requirements and ensure that effective Sponsor Management System access is maintained throughout the transition.

This is particularly important where the departing individual is the organisation’s Authorising Officer, only Level 1 User or holds several key personnel roles simultaneously.

The sponsor must maintain an eligible Authorising Officer and at least one eligible Level 1 User throughout the life of the licence. Failure to maintain these mandatory arrangements can place the sponsor licence at direct risk of revocation.

 

1. Plan key personnel changes before the individual leaves

 

Where a departure is known in advance, employers should use the available time to plan the changeover.

This should include:

• identifying every sponsor role and SMS permission held by the outgoing individual;
• selecting an appropriate replacement;
• checking the replacement’s eligibility before appointment;
• determining whether additional Level 1 User access is required;
• preserving effective SMS access during the transition;
• identifying any supporting evidence requirements;
• completing the appropriate Home Office process;
• monitoring the request through to completion; and
• removing obsolete access when it is appropriate to do so.

Waiting until an employee has already left can turn a straightforward personnel change into an urgent sponsor compliance problem, particularly where the organisation loses its only active Level 1 User.

 

2. Do not confuse submission with completion

 

Submitting a key personnel change through the SMS is not necessarily the end of the process.

The sponsor may still need to complete a submission sheet, provide supporting evidence, respond to further Home Office enquiries or wait for a requested Level 1 User to become active.

Employers should therefore monitor each request and verify the resulting sponsor licence arrangements before treating the change as complete.

Where a new Level 1 User is required, the organisation should confirm that the user’s status is Active and that the individual can access the SMS rather than relying solely on evidence that the request has been submitted.

 

3. Maintain secure and resilient SMS access

 

SMS access should be limited to authorised individuals who genuinely require it. Users should have their own individual accounts, email addresses and authentication arrangements and should not share passwords or multi-factor authentication passcodes.

At the same time, employers should consider whether dependence on a single Level 1 User creates unnecessary operational risk.

Where appropriate, maintaining more than one eligible and properly trained Level 1 User can provide continuity if an individual resigns, is absent or becomes unexpectedly unavailable.

Existing Level 2 Users should also be reviewed under the September 2026 transitional arrangements and either upgraded to Level 1 User status, where eligible and appropriate, or deactivated by 8 March 2027.

 

4. Keep an audit trail of every change

 

The organisation should retain a clear record of significant key personnel changes.

This should show who left or changed responsibilities, which roles were affected, how the replacement’s eligibility was checked, what was submitted to the Home Office, what evidence was provided and when the final arrangements were verified.

A documented changeover process can help demonstrate effective sponsor governance during an internal compliance review or Home Office compliance visit.

 

5. Use a controlled key personnel changeover process

 

A practical framework for managing sponsor licence key personnel changes is:

Identify → Validate → Preserve Access → Notify → Evidence → Verify → Audit.

1. Identify every role, permission and responsibility affected by the change.
2. Validate the proposed replacement against the applicable Home Office requirements.
3. Preserve Access so the organisation can continue administering its sponsor licence.
4. Notify the Home Office using the correct SMS or alternative process.
5. Evidence the change by providing any required declarations, submission sheets and supporting documents within the applicable timeframe.
6. Verify that the intended changes have taken effect and required SMS access is operational.
7. Audit the completed change and retain an appropriate internal record.

Following this sequence helps employers maintain continuity of sponsor management while ensuring that key personnel records, SMS access and internal governance remain aligned with the organisation’s actual sponsorship arrangements.
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Section U: Glossary

 

Term	Meaning
Authorising Officer	The senior person responsible for the sponsor licence and for overseeing the organisation’s sponsorship arrangements and the activities of those who use the Sponsor Management System. A sponsor must maintain an eligible Authorising Officer throughout the life of its sponsor licence.
Key Contact	The individual who acts as a principal point of contact between the sponsoring organisation and the Home Office. The Key Contact can potentially also hold another sponsor key personnel role where the applicable requirements are met.
Level 1 User	An authorised user with operational access to the Sponsor Management System and permission to carry out sponsor management functions available to that user. A sponsor must maintain at least one eligible Level 1 User throughout the life of its licence. Additional Level 1 Users can be appointed where the relevant requirements are satisfied.
Level 2 User	A historic category of SMS user with more limited system permissions than a Level 1 User. New Level 2 Users can no longer be appointed from 9 September 2026. Existing Level 2 Users are subject to transitional arrangements and should be upgraded to Level 1 User status, where eligible and appropriate, or deactivated by 8 March 2027.
Sponsor Management System (SMS)	The Home Office online system used by licensed sponsors to administer their sponsor licence and carry out sponsorship functions. Depending on the sponsor and user permissions, functions can include managing sponsor information and SMS users, assigning Certificates of Sponsorship and reporting relevant changes.
Key Personnel	The individuals appointed to specified roles in connection with the management of the sponsor licence. For the purposes of this guide, the principal roles are the Authorising Officer, Key Contact and Level 1 Users, together with the transitional position of existing Level 2 Users.
Amend	Updating relevant information about an individual who continues to hold the same sponsor key personnel role. A practical distinction is: Same person, new details = amend.
Replace	Changing the individual who holds a particular sponsor key personnel role. A practical distinction is: Different person taking over = replace.
Active Level 1 User	A Level 1 User whose account is active and available for authorised use of the Sponsor Management System. A request to appoint a Level 1 User should not be treated as equivalent to active access while the user’s status remains Requested.
Primary Level 1 User Requirements	The requirements governing the Level 1 User arrangements a sponsor must maintain, including requirements relating to the user’s connection with the sponsoring organisation and status in the UK, subject to applicable exceptions and transitional provisions. Sponsors should check these requirements before removing or replacing an existing Level 1 User.
Submission Sheet	A document generated as part of certain Sponsor Management System change requests which must be completed and provided in accordance with the relevant Home Office instructions. Replacing an Authorising Officer generates a submission sheet. The sponsor should complete the required process and provide the supporting evidence requested by the Home Office.
Sponsor Change of Circumstances Form	A Home Office process available for specified sponsor licence changes that cannot be completed through the normal SMS process in the circumstances covered by the form. This can include requesting a new Level 1 User where the sponsor has no active Level 1 User able to access the SMS and, in specified circumstances, replacing an Authorising Officer who will also become the sponsor’s sole Level 1 User. The form is not a general alternative to the SMS for ordinary key personnel changes.
Post-Licence Priority Service	A Home Office service that can provide expedited consideration of specified changes and requests made by existing Worker and Temporary Worker sponsors. Eligible changes can include specified requests involving Level 1 Users, Authorising Officers and Key Contacts. Priority treatment does not guarantee approval of the underlying request.
Multi-Factor Authentication (MFA)	An additional security process used to verify the identity of an SMS user when accessing the Sponsor Management System. Mandatory multi-factor authentication for SMS users began rolling out from 3 September 2026. SMS users should not share passwords or MFA passcodes with other employees.
Certificate of Sponsorship (CoS)	An electronic sponsorship record assigned by a licensed sponsor to an eligible worker for use in connection with an application under a relevant sponsored work route. Level 1 Users can have responsibilities relating to the management and assignment of Certificates of Sponsorship through the SMS.
Sponsor Compliance	The systems, controls and activities used by a sponsor to comply with its Home Office sponsorship duties, including reporting, record keeping, monitoring sponsored workers, maintaining accurate licence information and controlling access to the SMS. Maintaining eligible and current key personnel forms part of the sponsor’s wider compliance framework.
Sponsor Licence Revocation	The withdrawal of a sponsor licence by the Home Office. Under the current sponsor guidance, failure to maintain an eligible Authorising Officer or at least one eligible Level 1 User is a circumstance in which the Home Office will revoke the sponsor licence.
Key Personnel Changeover Protocol	The practical framework used in this guide for managing changes to sponsor licence key personnel: Identify → Validate → Preserve Access → Notify → Evidence → Verify → Audit. The protocol is designed to help employers manage the personnel change while maintaining appropriate sponsorship oversight, SMS access, evidence and internal governance.

 

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Section V: Useful Links

 

Resource	URL
Sponsorship information for employers and educators	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Workers and Temporary Workers: Guidance for Sponsors – Part 1: Apply for a Licence	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-1-apply-for-a-licence
Workers and Temporary Workers: Guidance for Sponsors – Part 3: Sponsor Duties and Compliance	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance
Sponsor Management System (SMS) User Manuals	https://www.gov.uk/government/collections/sponsorship-management-system-sms-user-manuals
Sponsorship Management System: SMS Manual	https://www.gov.uk/government/publications/sponsorship-management-system-sms-manual
Sponsor Change of Circumstances Form	https://www.gov.uk/government/publications/change-of-circumstances-form-sponsors
Worker and Temporary Worker Priority Change of Circumstance Service	https://www.gov.uk/government/publications/worker-and-temporary-worker-priority-service-request-form
Sponsor Licence Key Personnel: Roles & Requirements	https://www.davidsonmorris.com/sponsor-licence-key-personnel/
Authorising Officer: Sponsor Licence Duties & Requirements	https://www.davidsonmorris.com/sponsor-licence-authorising-officer/
Sponsor Management System (SMS): Employer Guide	https://www.davidsonmorris.com/sponsor-management-system/
Sponsor Licence Compliance	https://www.davidsonmorris.com/sponsor-licence-compliance/
Home Office Sponsor Compliance Visits	https://www.davidsonmorris.com/ukvi-compliance-visit/
Sponsor Licence Suspension	https://www.davidsonmorris.com/sponsor-licence-suspension/
Sponsor Licence Revocation	https://www.davidsonmorris.com/sponsor-licence-revocation/

 

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