Section C. How to get a Sponsor Licence

An organisation that meets the relevant eligibility and suitability requirements can apply to the Home Office for a sponsor licence.

The application process requires more than completing an online form. The organisation needs to determine which sponsorship routes it requires, appoint suitable key personnel, prepare the required supporting evidence and demonstrate that it is capable of meeting its sponsor duties.

The application should therefore be prepared around the organisation that will actually employ and sponsor the workers.

1. How do you apply for a sponsor licence?

The sponsor licence application process broadly involves:

Confirm eligibility and suitability

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Identify the sponsorship routes required

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Appoint key personnel

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Prepare supporting documents and information

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Complete the online sponsor licence application

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Pay the applicable application fee

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Submit the required supporting evidence

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Respond to any Home Office enquiries or compliance activity

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Receive the Home Office decision

The organisation should complete the preparatory work before submitting the online application.

2. Which sponsor licence should you apply for?

The organisation needs to identify the routes under which it intends to sponsor workers.

Sponsor licences are broadly divided between Worker and Temporary Worker routes.

For many employers recruiting overseas workers into longer-term roles, the principal route will be Skilled Worker.

Other routes apply to particular categories of sponsored work.

The organisation should apply for the routes that correspond with its genuine recruitment requirements rather than assuming that one sponsor licence category automatically covers every form of sponsored employment.

3. Who makes the sponsor licence application?

The application is made on behalf of the organisation seeking the licence.

Before applying, it is important to identify the correct legal entity.

For businesses operating through groups or multiple entities, the applicant should establish:

Which entity will employ the workers?

Which entity requires permission to sponsor them?

Which entity is providing the supporting evidence?

The sponsor licence is granted to the licensed organisation and cannot simply be treated as belonging to the wider corporate group.

4. Appointing key personnel

As part of the application, the organisation must nominate the individuals who will undertake the required sponsor management roles.

These include:

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

The individuals nominated must satisfy the applicable Home Office requirements.

The same person can hold more than one key personnel role where the relevant requirements are met.

5. What documents are required for a sponsor licence application?

Most sponsor licence applications require supporting documents.

The requirements are principally set out in Appendix A to the sponsor guidance.

The precise documents depend on factors such as:

• the type of organisation;
• how long it has been operating;
• whether it is subject to registration or regulation;
• the sponsorship routes being requested; and
• the circumstances of the application.

Applicants should therefore determine the evidence required for their particular organisation rather than relying on a generic document checklist.

6. How many supporting documents are required?

For many applications, the sponsor guidance requires the organisation to provide a specified minimum number of documents from the documents permitted under Appendix A.

However, the precise documentary requirement varies according to the type of organisation and the circumstances.

Certain organisations can be subject to different evidential requirements, while additional information or documents can be required for particular routes or applications.

The correct approach is therefore to work through the current Appendix A requirements for the specific applicant.

7. Additional information about the organisation

The Home Office can require information beyond the core supporting documents.

Depending on the application, this can include information about:

• the organisation;
• its activities;
• operating hours;
• organisational structure;
• the roles it intends to sponsor;
• proposed workers;
• salary and working arrangements; and
• why sponsorship is required.

The information should be consistent with the organisation’s supporting evidence and actual business operations.

8. Preparing the sponsor licence application

Before submitting the application, the organisation should check that the information provided across the application is consistent.

For example:

Legal entity name should correspond with the supporting evidence.

Trading and operating information should reflect the organisation’s actual activities.

Key personnel should satisfy the relevant requirements.

Proposed sponsored roles should correspond with genuine recruitment requirements.

Supporting documents should relate to the organisation making the application.

Inconsistencies can result in Home Office enquiries and can undermine confidence in the application.

9. Submitting the online application

Sponsor licence applications are made using the Home Office online application process.

The organisation will provide information about itself, the routes for which it wishes to be licensed and its nominated key personnel.

The applicable sponsor licence application fee is paid as part of the process.

Home Office fees can change, so the organisation should check the current fee applicable to its circumstances when applying.

10. Submitting supporting evidence

The required supporting documents and information must be provided in accordance with the procedure and deadline specified by the Home Office.

Applicants should ensure that:

• all required evidence has been identified;
• documents satisfy the applicable requirements;
• information is legible and complete;
• documents relate to the correct organisation; and
• submission takes place within the applicable timeframe.

The organisation should not assume that UKVI will give it an opportunity to correct every evidential deficiency after submission.

11. What happens after the application is submitted?

The Home Office will assess whether the organisation meets the requirements for a sponsor licence.

UKVI can:

• consider the application and supporting evidence;
• request further information or documents;
• make additional enquiries; and
• undertake pre-licence compliance activity.

The organisation should monitor correspondence relating to the application and respond within any deadlines imposed by the Home Office.

12. Home Office compliance visits before approval

UKVI can conduct a compliance check before deciding whether to grant the licence.

The purpose can include assessing whether the organisation genuinely operates as described and whether it has systems capable of meeting its sponsor duties.

The Home Office can examine matters such as:

• recruitment;
• HR systems;
• right to work processes;
• worker monitoring;
• record keeping;
• reporting arrangements;
• proposed sponsored roles; and
• understanding of sponsor duties.

Applicants should therefore have functioning compliance arrangements when they apply.

13. How long does a sponsor licence application take?

Home Office processing times are subject to change and should be checked when the application is made.

Processing can also take longer where UKVI:

• requests additional evidence;
• makes further enquiries; or
• conducts compliance activity.

Employers should therefore build sufficient time into international recruitment plans.

A proposed worker cannot simply begin sponsored employment because the organisation has submitted a sponsor licence application.

14. Sponsor licence priority processing

An eligible applicant may be able to request expedited consideration through the Home Office’s pre-licence priority service, subject to the current eligibility requirements, availability and applicable fee.

Priority processing does not relax the substantive requirements for obtaining a licence and does not guarantee that the application will be approved.

Where UKVI needs further evidence or compliance activity, this can affect the overall timetable.

15. What happens if the sponsor licence is approved?

Where the application is successful, the organisation will be granted a sponsor licence for the approved routes.

The organisation can then access the sponsorship system through its authorised users and begin using the licence in accordance with the applicable requirements.

Depending on the route and worker, further steps can include:

Licence granted

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Appropriate CoS obtained or available

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CoS assigned

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Worker makes immigration application

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Immigration permission granted

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Prescribed right to work check completed

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Sponsored employment

Grant of the sponsor licence does not itself grant immigration permission to any worker.

16. What happens if the sponsor licence application is refused?

Where the Home Office refuses the application, the organisation will not be able to sponsor workers under the licence it applied for.

There is no general statutory right of appeal against refusal of a sponsor licence application.

The organisation should examine the reason for refusal before deciding what to do next.

Depending on the circumstances, this can involve considering whether:

• the Home Office has made an error;
• an available error-correction process is relevant;
• the problem can be remedied before a new application;
• restrictions apply to reapplying; or
• legal challenge should be considered.

Submitting the same application again without addressing the reason for refusal can result in the same outcome.

17. Preparing before you apply

A practical pre-application review should cover:

Applicant

Correct legal entity identified.

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Routes

Correct Worker or Temporary Worker routes selected.

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Key personnel

Suitable individuals appointed.

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Documents

Appendix A requirements identified and evidence prepared.

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Roles

Proposed sponsorship requirements understood.

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Systems

HR and compliance processes capable of meeting sponsor duties.

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History

Previous immigration or sponsor compliance issues identified.

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Application

Information checked for accuracy and consistency.

This preparation reduces avoidable application risk and helps ensure that the organisation is ready to operate as a licensed sponsor if approval is granted.

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Section D. Key Personnel

A sponsor licence must be managed by individuals appointed to specific key personnel roles. These roles form part of the Home Office’s system for ensuring that responsibility for sponsorship is allocated to appropriate people within or connected with the sponsoring organisation.

The principal key personnel roles are:

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

The same individual can hold more than one of these roles where the relevant requirements are met.

The organisation remains responsible for compliance with its sponsor duties regardless of how responsibilities are divided between its key personnel.

1. What is the Authorising Officer?

The Authorising Officer is the senior and competent person responsible for the actions of the organisation’s staff and representatives who use the Sponsor Management System.

The role should therefore be held by an appropriately senior person with sufficient authority within the organisation to oversee sponsorship.

The Authorising Officer does not necessarily need to carry out the organisation’s routine SMS administration personally.

Their role is principally one of responsibility and oversight.

The organisation should ensure that the Authorising Officer understands the significance of the sponsor licence and has sufficient visibility of the systems used to manage sponsored workers.

2. What does the Authorising Officer do?

The Authorising Officer should maintain appropriate oversight of the organisation’s sponsorship arrangements.

In practical terms, this can include ensuring that:

• appropriate individuals are responsible for sponsorship activity;
• sponsor duties are understood;
• the organisation has systems for identifying reportable events;
• SMS access is appropriately controlled;
• sponsored worker compliance is monitored; and
• significant sponsor licence risks are escalated.

The Authorising Officer should not be treated simply as a name required for the sponsor licence application.

3. What is the Key Contact?

The Key Contact acts as the main point of contact between the sponsoring organisation and the Home Office in relation to the sponsor licence.

The Key Contact can therefore receive communications concerning sponsorship matters.

The role is distinct from that of the Authorising Officer.

The Authorising Officer provides senior oversight of sponsorship, while the Key Contact primarily provides the communication link with the Home Office.

4. What is a Level 1 User?

A Level 1 User is responsible for carrying out day-to-day sponsor management activity through the Sponsor Management System.

Level 1 Users can undertake a broad range of SMS functions permitted by the Home Office.

Depending on the circumstances and the permissions available, these can include:

• managing licence information;
• assigning Certificates of Sponsorship;
• reporting changes relating to sponsored workers;
• reporting relevant organisational changes;
• managing certain SMS users; and
• undertaking other sponsor management functions.

Because Level 1 Users can carry out significant actions on behalf of the sponsor, access to the SMS should be carefully controlled.

5. Can the same person hold all three roles?

Yes, one individual can potentially act as:

Authorising Officer + Key Contact + Level 1 User

provided they satisfy the Home Office requirements applying to each role.

This is common in smaller organisations.

Larger sponsors may prefer to separate the roles between different individuals to provide greater operational resilience and oversight.

The appropriate structure will depend on the organisation.

6. Can an external adviser act as key personnel?

External representatives can undertake certain sponsorship functions where permitted by the sponsor guidance.

However, the Home Office places requirements on who can perform particular roles and on the organisation’s own involvement in managing its licence.

An organisation should therefore not assume that it can outsource responsibility for the sponsor licence entirely to an immigration adviser.

Even where an external representative is permitted to access or assist with the SMS, the licensed organisation remains responsible for complying with its sponsor duties.

7. Who can be appointed as key personnel?

The Home Office imposes requirements relating to the people appointed to key personnel roles.

Depending on the particular role and circumstances, the sponsor guidance can impose requirements concerning matters such as:

• the person’s relationship with the organisation;
• their status and location;
• relevant criminal convictions or penalties;
• previous involvement in sponsor licence compliance problems; and
• other suitability considerations.

The organisation should check the current sponsor guidance before making an appointment.

8. Key personnel and sponsor suitability

The Home Office can consider the suitability of individuals involved in managing a sponsor licence.

An appointment can create problems where the proposed individual has relevant immigration, criminal or sponsor compliance history.

This is particularly important where an individual has previously been involved with an organisation whose sponsor licence was subject to Home Office enforcement.

The applicant should therefore assess key personnel before naming them in the sponsor licence application.

9. What happens if key personnel leave the organisation?

Key personnel arrangements need to remain current throughout the life of the licence.

If an Authorising Officer, Key Contact or SMS user leaves the organisation or ceases to perform the relevant role, the sponsor should take the action required under the sponsor guidance.

This can include updating the licence and appointing an appropriate replacement.

The organisation should not wait until it needs to undertake an urgent sponsorship action before discovering that its recorded personnel or SMS access arrangements are no longer workable.

10. Maintaining Level 1 User coverage

Sponsors should ensure they retain appropriate Level 1 User access to the SMS.

Reliance on a single operational user can create risk if that person:

• resigns;
• becomes unavailable;
• is absent for an extended period; or
• otherwise loses access.

The organisation should structure SMS access so that required sponsor activity can continue when personnel change.

This is particularly important because sponsor reporting requirements can be subject to strict time limits.

11. SMS security

Sponsor Management System access should be treated as privileged regulatory access.

Users should not share their SMS credentials with other individuals.

The organisation should maintain control over:

• who has access;
• what access they have;
• whether access remains necessary; and
• whether users remain eligible to hold their roles.

Access should be reviewed when employees change roles or leave the organisation.

12. Key personnel and internal governance

The formal Home Office roles should sit within a wider internal governance structure.

For example:

Authorising Officer

Senior sponsor oversight

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Level 1 Users

Operational SMS management

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HR / Recruitment / Payroll

Identify sponsorship events

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Line Managers

Escalate worker changes

This helps ensure that information reaches the individuals capable of taking the required sponsorship action.

The Level 1 User cannot report a change that nobody within the business tells them has occurred.

13. Key personnel and Home Office compliance

During Home Office compliance activity, UKVI can examine how the organisation manages its sponsor licence.

The organisation should be able to explain:

Who has overall responsibility?

Who communicates with the Home Office?

Who operates the SMS?

How are relevant changes identified?

How are those changes communicated to the sponsor team?

How is SMS access controlled?

The Home Office can therefore look beyond the names recorded on the licence and consider whether the sponsor’s governance arrangements work in practice.

14. Reviewing key personnel arrangements

Sponsors should periodically review their key personnel and SMS arrangements.

A review can consider:

• whether the Authorising Officer remains appropriate;
• whether the Key Contact details remain current;
• whether sufficient Level 1 Users are available;
• whether former personnel still have access;
• whether external representative access remains appropriate; and
• whether internal responsibilities are clearly understood.

Changes should be dealt with in accordance with the applicable Home Office requirements.

15. Key personnel checklist

A practical governance check can be structured as:

Authorising Officer

Appropriate seniority → Current → Understands sponsor responsibilities

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Key Contact

Current → Contactable → Correct details recorded

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Level 1 Users

Eligible → Trained → Sufficient coverage → Access controlled

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Internal teams

Know what events must be escalated

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Review

Personnel and SMS access checked periodically

This helps prevent sponsor management from becoming dependent on outdated personnel arrangements.

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