Sponsor Licence Key Personnel: Roles & Requirements

Sponsor Licence Key Personnel: At a Glance

UK sponsor licence holders need named individuals to take responsibility for how sponsorship is overseen, communicated and administered. For most sponsors, that structure centres on the Authorising Officer, Key Contact and Level 1 User, with each role carrying a different function.

The appointments affect how effectively the licence operates in practice. Sponsors remain responsible for sponsorship activity carried out through their arrangements, including actions taken by authorised Sponsor Management System (SMS) users and, where permitted, external representatives. Employers therefore need key personnel who satisfy the Home Office requirements and who also have the authority, knowledge, availability and organisational access needed to perform their role properly.

Role allocation will vary between organisations. One eligible individual can hold more than one key personnel role, while larger sponsors may divide responsibility across senior management, HR, global mobility and immigration teams. Employers also need to maintain appropriate key personnel throughout the life of the licence, including when employees leave, change role, take prolonged absence or when the business restructures.

Current SMS changes add a further governance issue. Sponsors can no longer appoint new Level 2 Users from 9 September 2026. Existing Level 2 Users must be upgraded to Level 1 User status, where eligible and appropriate, or deactivated by 8 March 2027. Sponsors also need to keep SMS-user details accurate, comply with mandatory multi-factor authentication requirements and review whether users remain active, eligible and genuinely require access.

This guide explains the sponsor licence key personnel roles, who can be appointed, how the roles interact, who can access the SMS and the governance controls employers should maintain around their sponsor licence.

 

 

 

Section A: What are Sponsor Licence Key Personnel?

 

Sponsor licence key personnel are the individuals nominated by an organisation to take responsibility for specified aspects of managing its sponsor licence and its relationship with the Home Office.

The framework is built around three principal functions: senior accountability, communication with UK Visas and Immigration (UKVI) and operational administration through the Sponsor Management System (SMS).

The three principal roles are:

 

• Authorising Officer – the senior person responsible for overseeing the organisation’s sponsorship arrangements and the activities of those involved in operating the licence.
• Key Contact – the organisation’s principal point of contact with UKVI in relation to the sponsor licence.
• Level 1 User – an individual authorised to access the SMS and carry out sponsorship administration on behalf of the organisation.

 

A sponsor can have only one Authorising Officer and one Key Contact at any given time, but it can appoint more than one Level 1 User. The same individual can hold two or all three roles where they satisfy the requirements applying to each appointment.

The appropriate structure will depend on the size of the organisation, the number of sponsored workers, the volume of sponsorship activity and where responsibility for immigration compliance sits internally.

Holding a key personnel role is also separate from having SMS access. An Authorising Officer or Key Contact does not automatically receive system access because of their appointment. They need to hold an appropriate SMS-user role if they are expected to use the system.

1. Accountability, communication and system control

The key personnel structure can be viewed across three functions:

Accountability → Communication → System Control

The Authorising Officer provides senior organisational accountability and oversight.

The Key Contact provides the formal communication channel between the sponsor and UKVI.

The Level 1 User provides operational control through permitted actions carried out in the SMS.

These functions can sit with one individual, but they remain distinct. Someone who is well suited to day-to-day SMS administration may not have the seniority or authority required to oversee sponsorship at organisational level. Equally, a senior director acting as Authorising Officer may have no operational need to access the SMS personally.

Key personnel therefore form part of the governance structure through which the organisation manages sponsorship after the sponsor licence application has been approved.

2. Key personnel must remain eligible

Sponsors need to ensure that each individual is eligible for the role they hold, understands the responsibilities attached to it and remains able to perform those functions throughout the life of the licence.

Depending on the role, Home Office requirements can include:

 

• the individual’s relationship with the sponsoring organisation;
• whether they are a paid member of staff, office holder or otherwise fall within a permitted category;
• whether they are based in the UK for the purposes required by the sponsor guidance;
• their immigration status;
• National Insurance number requirements and any applicable exceptions;
• their previous involvement with sponsor licence holders;
• whether any suitability restrictions apply; and
• whether they continue to meet the relevant requirements after appointment.

 

An Authorising Officer must ordinarily be a paid member of staff or office holder within the sponsoring organisation, subject to limited exceptions. Sponsors must also maintain at least one eligible Level 1 User. Where there is only one Level 1 User, that individual cannot simply be an external representative acting in place of the sponsor’s required internal personnel.

Eligibility therefore needs to be monitored beyond the point of appointment. Changes in employment status, role, location, immigration position or suitability can affect whether an individual remains appropriate.

The sponsoring organisation remains responsible for how its licence is managed and for activity undertaken through its SMS account, including actions carried out by permitted users or representatives acting on its behalf.

3. What about Level 2 Users?

Level 2 Users remain part of the Home Office key personnel framework only on a transitional basis.

From 9 September 2026, sponsors can no longer appoint new Level 2 Users. Existing Level 2 Users can continue temporarily, but sponsors need to decide whether each user should be upgraded to Level 1 User status, where they are eligible and require that access, or deactivated by 8 March 2027.

The transition should be treated as part of the sponsor’s wider SMS-access review. Employers establishing or redesigning their sponsor management arrangements should now focus primarily on the Authorising Officer, Key Contact and Level 1 User roles, while ensuring that existing Level 2 accounts are resolved before the transitional deadline.

 

 

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Section B: Which Sponsor Licence Key Personnel Do Employers Need?

 

When applying for a sponsor licence, an organisation will generally need to nominate individuals to perform the three principal key personnel roles: Authorising Officer, Key Contact and Level 1 User.

These roles form the core management structure for the licence, but they perform different functions and do not all automatically carry access to the Sponsor Management System.

 

Role	Required?	Number	SMS Access	Main Function
Authorising Officer	Yes	One	Not automatically	Senior oversight and accountability for sponsorship
Key Contact	Yes	One	Not automatically	Main point of contact between the sponsor and UKVI
Level 1 User	Yes	One or more	Yes	Operational administration of the licence through the SMS
Level 2 User	Transitional only	No new appointments from 9 September 2026	Restricted SMS access for existing users	Historic limited SMS-user role being phased out

 

The same individual can potentially hold more than one of the principal roles. An employer does not therefore necessarily need three different people to satisfy the key personnel requirements.

For example, a smaller organisation could appoint a suitably senior director as its Authorising Officer and also nominate that individual as the Key Contact and Level 1 User, provided the person satisfies the requirements applicable to each role.

A larger organisation may prefer to separate the responsibilities. A senior HR director might act as Authorising Officer, while an immigration or global mobility manager acts as the Key Contact and one of several Level 1 Users.

The appropriate structure should reflect how sponsorship is actually managed within the organisation rather than simply allocating titles for the purposes of the licence application.

1. Authorising Officer

Every sponsor needs an Authorising Officer. This is the senior person responsible for the organisation’s sponsorship arrangements and for overseeing the activities of those involved in operating the sponsor licence.

There can only be one Authorising Officer at a time.

The Authorising Officer must ordinarily be a paid member of staff or an office holder within the sponsoring organisation, subject to limited exceptions provided for under the sponsor guidance. An external immigration adviser or other representative cannot ordinarily be appointed to perform this role.

The Authorising Officer does not automatically have access to the SMS. If the organisation wants the Authorising Officer to perform SMS functions personally, the individual will also need to be appointed to an appropriate SMS-user role.

2. Key Contact

Every sponsor also needs a Key Contact.

The Key Contact acts as the principal point of contact between the organisation and UKVI in relation to its sponsor licence.

There can only be one Key Contact at a time. The Key Contact does not automatically receive SMS access and will need an appropriate SMS-user appointment if they are also expected to carry out sponsorship administration through the system.

Subject to the Home Office requirements governing representatives, an appropriately appointed external representative can act as the sponsor’s Key Contact. The appointment of an external Key Contact does not, however, transfer responsibility for the sponsor licence to that representative.

3. Level 1 User

A sponsor must also maintain at least one eligible Level 1 User.

Level 1 Users are responsible for much of the practical administration undertaken through the Sponsor Management System. Depending on their permissions and the applicable sponsorship route, this can include maintaining licence information, managing sponsorship records and dealing with Certificates of Sponsorship.

Unlike the Authorising Officer and Key Contact roles, an organisation can have multiple Level 1 Users.

Current Home Office requirements place important restrictions on how Level 1 User arrangements can be structured. A sponsor must maintain appropriate internal Level 1 User capability. In particular, where the sponsor has only one Level 1 User, that individual cannot simply be an external representative acting in place of the sponsor’s own personnel.

For sponsors whose successful licence application was made on or after 1 January 2025, at least one Level 1 User must satisfy both the applicable requirement to be an employee, director or partner of the sponsor and the requirement to be a settled worker, unless a published exception applies.

A transitional arrangement applies to sponsors whose successful licence application was made before 1 January 2025 and who have held the licence continuously since then. For those sponsors, the requirement to have at least one Level 1 User who is an employee, director or partner and the requirement to have at least one Level 1 User who is a settled worker can currently be met by two different Level 1 Users.

An appropriately appointed representative may, subject to the applicable rules, be given Level 1 access as an additional user. This does not remove the sponsor’s obligation to maintain the Level 1 User arrangements that apply to its licence.

Having more than one Level 1 User can provide operational resilience where sponsorship activity is substantial or where the primary user is unavailable. Employers should, however, control SMS access carefully rather than appointing additional users unnecessarily.

4. What about Level 2 Users?

Historically, sponsors could appoint Level 2 Users with more restricted SMS permissions than Level 1 Users.

This position changed on 9 September 2026. Sponsors can no longer appoint new Level 2 Users.

Existing Level 2 Users remain recognised as key personnel during the transitional period. Their permissions are more limited than those of Level 1 Users and can include creating and assigning Certificates of Sponsorship and undertaking permitted reporting activity relating to Certificates of Sponsorship they have created or assigned, or which have been transferred to them by a Level 1 User.

Organisations with existing Level 2 Users must review those accounts and, where appropriate, upgrade eligible individuals to Level 1 User status or deactivate their accounts by 8 March 2027. Remaining Level 2 accounts will be deactivated by the Home Office after the transitional period ends.

Level 2 Users should therefore no longer be regarded as part of the normal personnel structure when an employer is deciding how to establish or reorganise management of its sponsor licence.

5. Current sponsor licence key personnel structure

For employers establishing their sponsor management arrangements, the core structure can therefore be understood as:

Authorising Officer → senior accountability

Key Contact → UKVI communication

Level 1 User → SMS administration

The critical issue is not merely that these roles have been allocated. The individuals appointed must satisfy the applicable Home Office requirements, understand their responsibilities and collectively provide an effective structure for managing the organisation’s sponsorship obligations.

 

 

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Section C: Authorising Officer

 

The Authorising Officer is the senior individual responsible for overseeing the organisation’s sponsor licence arrangements.

The Authorising Officer should be the most senior person in the organisation responsible for the recruitment of all sponsored workers and for ensuring that sponsor duties are met. Where the organisation does not recruit the workers it sponsors, the Authorising Officer should be the most senior person responsible for the organisation’s activity as a licensed sponsor. In most organisations, this will be a director, partner, senior manager or another appropriately senior office holder or member of staff with responsibility for recruitment, HR, immigration compliance or workforce management.

Under the Home Office sponsor guidance, the Authorising Officer must ordinarily be a paid member of staff or an office holder within the sponsoring organisation. The role cannot generally be outsourced to an immigration adviser, HR consultant or other external representative simply because that person assists with management of the sponsor licence.

Limited exceptions apply in specific circumstances. These include certain insolvency arrangements and separate provisions relevant to the UK Expansion Worker route. Employers seeking to rely on an exception should ensure that the particular Home Office requirements are satisfied.

The Authorising Officer is not expected to undertake every sponsorship task personally. Their function is primarily one of senior ownership, accountability and oversight.

This means the Authorising Officer should have sufficient visibility of the organisation’s sponsorship activities to understand how the licence is being used and whether appropriate systems and controls are in place.

1. What is the Authorising Officer responsible for?

The Authorising Officer should be able to satisfy themselves that the organisation has appropriate arrangements for managing its sponsor licence.

In practice, this means they should have sufficient oversight to understand whether:

 

• appropriate people have access to the Sponsor Management System;
• SMS access is removed or amended when users leave or change responsibilities;
• those operating the licence understand the sponsor’s compliance obligations;
• sponsorship activity is subject to appropriate internal controls;
• significant sponsorship or compliance issues are escalated appropriately;
• key personnel and SMS-user information remains current; and
• the organisation remains capable of meeting its sponsor duties.

 

The Authorising Officer is therefore different from an administrator who simply processes sponsorship activity through the SMS. An organisation may have several employees involved in sponsorship administration, but there remains one nominated Authorising Officer providing senior-level responsibility for the licence.

The Home Office recommends that the Authorising Officer reviews the Certificates of Sponsorship assigned to workers at least once a month as part of the sponsor’s system for checking SMS-user activity.

2. Does the Authorising Officer need access to the SMS?

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

If the Authorising Officer needs to use the SMS, they will also need to be appointed to an appropriate SMS-user role and satisfy the requirements applying to that appointment.

This is particularly relevant for smaller organisations. A managing director, for example, may be appointed as the Authorising Officer and also act as a Level 1 User, allowing them both to oversee the licence and carry out SMS functions.

In a larger organisation, the Authorising Officer may have little reason to access the SMS personally. Day-to-day system administration may instead be undertaken by HR, global mobility or immigration personnel appointed as Level 1 Users.

The important distinction is between accountability for the sponsorship arrangements and operational access to the SMS.

3. Choosing an Authorising Officer

Employers should avoid treating the Authorising Officer appointment as simply a question of choosing the most senior person in the organisation.

Seniority is important, but the individual should also be sufficiently involved in, or able to exercise appropriate oversight of, the organisation’s sponsorship activities.

For example, appointing a senior executive who has no practical involvement in recruitment, HR or immigration compliance may create a disconnect between formal responsibility for the licence and the people actually managing sponsorship.

A suitable Authorising Officer should therefore have:

 

• sufficient seniority and authority within the organisation;
• the required employment or office-holder relationship with the sponsor;
• an appropriate understanding of the organisation’s sponsorship activities;
• access to those responsible for HR, recruitment and immigration compliance;
• the ability to oversee those using the SMS;
• sufficient continuity within the organisation to provide effective oversight;
• the ability to respond where sponsorship or compliance problems are identified; and
• the ability to satisfy the relevant Home Office eligibility and suitability requirements.

 

4. What happens if the Authorising Officer leaves?

Employers should consider succession planning when appointing and managing the Authorising Officer.

If the Authorising Officer leaves the organisation, changes role or otherwise ceases to satisfy the applicable requirements, the sponsor needs to ensure that an eligible replacement is appointed and that the sponsor’s details are updated using the appropriate Home Office process.

This becomes particularly important where the Authorising Officer also acts as the Key Contact or a Level 1 User. A single departure can then affect several elements of the sponsor’s management structure simultaneously.

Employers should therefore identify potential replacement arrangements before a planned departure wherever possible rather than waiting until the existing Authorising Officer has left.

The detailed eligibility criteria, responsibilities and practical considerations applying specifically to this position are considered separately in our guide to the Authorising Officer: Sponsor Licence Duties & Requirements.

 

 

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Section D: Key Contact

 

The Key Contact is the individual nominated to act as the principal point of contact between the sponsoring organisation and UK Visas and Immigration (UKVI).

Every sponsor needs a Key Contact, and there can only be one Key Contact at any given time.

The role is primarily concerned with communication. Where UKVI needs to contact the sponsor about its licence, sponsorship arrangements or an issue arising from the organisation’s activities as a sponsor, the Key Contact provides the principal communication channel.

This makes the role distinct from that of the Authorising Officer. The Authorising Officer provides senior oversight and accountability for sponsorship, while the Key Contact is primarily responsible for facilitating effective communication between the sponsor and the Home Office.

1. What does the Key Contact do?

The Key Contact should be someone who can receive relevant communications from UKVI and ensure that they are dealt with appropriately within the organisation.

This does not mean the Key Contact must personally resolve every issue raised by the Home Office. Instead, the organisation should have arrangements that allow the Key Contact to identify the significance of a communication and ensure it reaches the appropriate person.

Depending on the issue, this could involve escalation to:

 

• the Authorising Officer;
• a Level 1 User;
• HR or global mobility personnel;
• recruitment teams;
• payroll;
• senior management;
• legal or compliance teams; or
• the sponsor’s external immigration advisers.

 

The practical effectiveness of the role therefore depends not simply on having a named Key Contact, but on ensuring that the individual is accessible and integrated into the organisation’s sponsorship arrangements.

2. Does the Key Contact have access to the SMS?

Appointment as Key Contact does not automatically provide access to the Sponsor Management System.

If the Key Contact also needs to carry out SMS functions, they must separately be appointed to an appropriate SMS-user role and satisfy the requirements applicable to that appointment.

For example, an internal immigration manager could act as both Key Contact and Level 1 User. In that arrangement, the individual would act as the principal UKVI contact while also carrying out operational sponsorship administration through the SMS.

Alternatively, the organisation could appoint one person as Key Contact while its SMS administration is handled by different employees acting as Level 1 Users.

3. Can an external immigration adviser be the Key Contact?

Unlike the Authorising Officer role, the Key Contact role can, subject to the applicable Home Office requirements, be performed by an appropriately appointed external representative.

This can allow an immigration adviser to act as a communication point between UKVI and the sponsoring organisation where the relevant representative requirements are satisfied.

Using an external representative as Key Contact does not, however, transfer responsibility for the sponsor licence to the adviser.

The sponsoring organisation remains responsible for complying with its sponsor duties and should retain effective internal arrangements for receiving information, making decisions and responding to matters raised by the Home Office.

Where an external representative acts as Key Contact, employers should therefore establish clear arrangements governing:

 

• how Home Office communications are passed to the organisation;
• which internal person receives those communications;
• which matters must be escalated to the Authorising Officer;
• who is responsible for providing information or instructions to the representative;
• who has authority to make decisions affecting sponsored workers or the sponsor licence; and
• how urgent Home Office correspondence will be handled if the usual internal contact is unavailable.

 

4. Choosing a Key Contact

Whether the Key Contact is internal or an appropriately appointed external representative, the sponsor should consider whether the arrangement provides a reliable communication channel with UKVI.

Where an employee is appointed, useful characteristics include:

 

• an understanding of the organisation’s sponsorship arrangements;
• access to the Authorising Officer and relevant decision-makers;
• regular availability;
• the ability to recognise potentially important immigration or compliance issues;
• access to relevant HR, recruitment and sponsorship information; and
• clear responsibility for escalating Home Office correspondence.

 

The organisation should also ensure that the Key Contact’s details remain accurate. A Key Contact who has left the organisation, changed responsibilities or no longer monitors the relevant communications can undermine the effectiveness of the sponsor’s contact arrangements.

5. Key Contact continuity

Although only one person can formally hold the Key Contact role at a time, employers should consider how Home Office communications will be handled if that individual is temporarily unavailable.

This may involve internal procedures for monitoring relevant communications, escalation arrangements and ensuring other members of the sponsorship team understand who needs to be informed if correspondence is received.

If the Key Contact permanently leaves the organisation or ceases to be suitable for the role, an eligible replacement should be appointed and the sponsor’s records updated through the appropriate Home Office process.

Where the Key Contact also acts as a Level 1 User, their departure should additionally trigger an immediate review of SMS access and whether the organisation continues to have sufficient eligible Level 1 User coverage.

Further detail on the eligibility requirements, appointment and operation of this role is provided in our guide to the Key Contact: Sponsor Licence Role & Responsibilities.

 

 

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Section E: Level 1 User

 

The Level 1 User is the principal operational user of the Sponsor Management System (SMS). While the Authorising Officer provides senior oversight and the Key Contact provides the main communication channel with UK Visas and Immigration (UKVI), Level 1 Users carry out many of the practical actions required to administer the sponsor licence.

Every sponsor must maintain at least one eligible Level 1 User. Unlike the Authorising Officer and Key Contact roles, a sponsor can have more than one Level 1 User.

The number required will depend on the organisation’s circumstances. A smaller employer with limited sponsorship activity may need only a small number of users, while a larger organisation sponsoring workers across multiple teams, locations or business units may require several Level 1 Users to provide effective administration and continuity.

Employers should nevertheless avoid giving SMS access to individuals who do not genuinely require it. Level 1 access carries significant permissions and should form part of the organisation’s wider access-control and sponsorship governance arrangements.

1. What does a Level 1 User do?

Level 1 Users can perform a wide range of functions through the SMS, subject to the permissions available within the system and the sponsorship routes held by the organisation.

These functions can include:

 

• managing aspects of the sponsor’s licence information;
• managing key personnel and SMS-user information where permitted;
• reporting relevant changes to the Home Office;
• requesting and managing Certificates of Sponsorship where applicable;
• assigning Certificates of Sponsorship to eligible workers;
• reporting specified changes relating to sponsored workers;
• maintaining sponsorship information held within the SMS; and
• carrying out other administrative functions made available to Level 1 Users.

 

The precise mechanics of using the SMS are considered separately in our Sponsor Management System (SMS): Employer Guide. For key personnel purposes, the important point is that Level 1 Users exercise substantial operational control over the sponsor’s licence.

2. Who should be a Level 1 User?

A Level 1 User should be someone who satisfies the relevant Home Office eligibility requirements and has a genuine organisational need to undertake sponsorship administration.

Depending on the organisation, appropriate internal users may include:

 

• HR managers;
• global mobility personnel;
• immigration or compliance managers;
• recruitment managers;
• senior managers responsible for sponsored workers;
• directors or partners; or
• other appropriately authorised employees involved in sponsorship administration.

 

The person does not necessarily have to be the most senior member of the organisation. What matters is that they satisfy the relevant Home Office requirements, understand how sponsorship operates and are appropriately authorised to perform the functions entrusted to them.

3. Internal Level 1 User requirement

An employer cannot simply outsource all Level 1 User responsibility to an external immigration adviser or other representative.

The Home Office requires the sponsor to maintain appropriate internal Level 1 User capability. The precise requirement depends on when the sponsor’s successful licence application was made and whether the licence has been held continuously since then.

For sponsors whose successful licence application was made on or after 1 January 2025, at least one Level 1 User must satisfy both the applicable internal relationship requirement and the settled-worker requirement, unless a published exception applies. For continuously licensed sponsors whose successful application was made before 1 January 2025, those two requirements can currently be met by two different Level 1 Users.

In particular, where a sponsor has only one Level 1 User, that person cannot be an external representative acting instead of the sponsor’s own internal personnel.

This distinction is important where employers use immigration solicitors, outsourced HR providers or other professional advisers to assist with sponsor licence administration.

An eligible representative may, where the Home Office rules permit, be appointed as an additional Level 1 User. The sponsor must nevertheless retain the required internal Level 1 User arrangements and remains responsible for activity carried out on its licence.

4. Can the Authorising Officer or Key Contact also be a Level 1 User?

Yes. Subject to satisfying the applicable eligibility requirements, the Authorising Officer or Key Contact can also be appointed as a Level 1 User.

This is common in smaller organisations where one senior employee may oversee sponsorship, communicate with UKVI and carry out SMS administration.

For example, an eligible HR director could potentially act as:

 

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

 

Combining roles can provide a simple structure, but employers should consider the operational consequences of concentrating all sponsor management functions in one individual.

If that person leaves, becomes unavailable or ceases to satisfy the applicable requirements, the organisation could simultaneously lose its Authorising Officer, Key Contact and only Level 1 User.

For this reason, even where one person formally holds several key personnel roles, employers should consider appropriate contingency arrangements.

5. Should an employer have more than one Level 1 User?

There is no universal requirement for every sponsor to maintain several Level 1 Users. The organisation should instead determine what level of access is necessary to administer its licence effectively while maintaining appropriate control.

Additional Level 1 Users may be useful where:

 

• the organisation sponsors a significant number of workers;
• Certificates of Sponsorship are assigned frequently;
• different teams are involved in sponsorship administration;
• the organisation operates across multiple sites or business divisions;
• the principal Level 1 User may be unavailable during holidays or sickness;
• there is a need for operational cover during staff changes; or
• the organisation’s sponsorship arrangements are sufficiently complex to require more than one administrator.

 

A practical model for some employers is to maintain a primary Level 1 User and an appropriately trained backup Level 1 User. This is a governance and resilience measure rather than a universal Home Office requirement.

Conversely, appointing large numbers of Level 1 Users simply for convenience can create unnecessary access risk. Each additional user represents another account through which significant sponsor licence functions may be performed.

6. Level 1 User accounts and security

SMS access should be treated as individual privileged access rather than as a general departmental resource.

Each authorised user should use their own account and authentication credentials. Login details should not be shared between employees, departments or external advisers.

Mandatory multi-factor authentication is being introduced across the SMS on a phased basis from 3 September 2026 and is expected to be in place for all sponsors by November 2026. Sponsors should therefore ensure that the personal and contact information associated with each SMS user is accurate and that users are able to complete the required authentication process.

Employers should also maintain oversight of who has SMS access, why access has been granted and whether that access remains necessary.

A useful internal SMS-access record can include:

 

• the user’s name;
• their job title and department;
• their key personnel or SMS-user role;
• the reason access is required;
• the date access was granted;
• the date access was last reviewed; and
• the date access was amended or removed.

 

7. Inactive Level 1 Users

SMS accounts should not simply be created and then forgotten.

Current Home Office guidance places increased emphasis on the management of inactive SMS users. Sponsors should check that their SMS-user details remain accurate and take action where users no longer require access or their circumstances have changed.

The Home Office recommends that a Level 1 User should access the SMS at least once a month. Regular access can help ensure that the sponsor retains functioning system access, that user accounts remain current and that relevant information within the SMS is being actively monitored.

An SMS account is treated as inactive where the user has not accessed the system for 12 months or more. Where this happens, the Home Office can contact the Authorising Officer and affected Level 1 User. A Level 1 User who needs to retain access should log in and check or update their details within 3 months of the Home Office notification. If the required action is not taken, the inactive account will be deactivated.

If deactivation leaves the sponsor with no active Level 1 User, the Home Office can suspend the sponsor licence. The sponsor will then normally have 28 days to nominate an eligible Level 1 User. Failure to do so will normally result in revocation.

This should form part of a wider periodic review of sponsor management arrangements rather than being treated as an isolated login exercise.

Where an employee no longer needs access, has changed responsibilities or has left the organisation, the sponsor should take appropriate action to amend or remove their SMS access.

8. What happens if the only Level 1 User leaves?

The loss of an organisation’s only Level 1 User can create an immediate operational problem because there may be nobody remaining with the necessary access to administer the sponsor licence through the SMS.

Where departure is planned, employers should wherever possible appoint and prepare an eligible replacement before the existing Level 1 User leaves.

If the organisation has already lost its only Level 1 User and nobody is able to access the SMS, the sponsor will need to use the appropriate Home Office process, including the relevant change of circumstances procedure, to request the addition of a new Level 1 User.

This is one reason employers should consider continuity when deciding how many Level 1 Users to maintain.

Level 1 User arrangements should also form part of the organisation’s employee offboarding procedures so that the sponsorship team is alerted before an SMS user leaves wherever possible.

9. Level 1 Users remain subject to sponsor controls

Giving an individual Level 1 access does not mean they should be free to make every sponsorship decision independently.

Employers should distinguish between system permission and organisational authority.

A Level 1 User may technically have permission within the SMS to perform a particular function, but the organisation can still require internal approval before that function is exercised.

For example, internal procedures may require management approval before a Certificate of Sponsorship is assigned, before certain sponsor details are changed or before significant information is reported to the Home Office.

This allows the sponsor to combine effective SMS administration with appropriate internal governance and oversight.

Further guidance on the eligibility requirements, permissions and practical responsibilities of this role is provided in our Level 1 User: Sponsor Licence Role & Responsibilities guide.

 

 

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Section F: What Happened to the Level 2 User Role?

 

The Level 2 User was historically an SMS-user role that allowed sponsors to give an individual more restricted access to the Sponsor Management System than a Level 1 User.

The Home Office is now phasing out the Level 2 User role. This represents an important change for existing sponsor licence holders because employers can no longer treat Level 2 access as a normal option when deciding how to structure their sponsor management arrangements.

1. Can sponsors still appoint Level 2 Users?

No new Level 2 Users can be appointed from 9 September 2026.

Employers establishing new sponsor management arrangements should therefore focus on the Authorising Officer, Key Contact and Level 1 User roles rather than planning to use Level 2 Users as part of their ongoing SMS-access structure.

Existing Level 2 Users have not, however, disappeared immediately. They remain recognised within the Home Office key personnel framework during a transitional period.

2. What can existing Level 2 Users do?

Existing Level 2 Users have more restricted SMS permissions than Level 1 Users.

Subject to the functions available within the SMS and the applicable sponsorship arrangements, an existing Level 2 User can carry out limited activities relating to Certificates of Sponsorship and sponsored workers.

This can include:

 

• creating Certificates of Sponsorship;
• assigning Certificates of Sponsorship;
• undertaking permitted reporting activity relating to Certificates of Sponsorship they have created or assigned; and
• undertaking relevant activity in relation to Certificates of Sponsorship transferred to them by a Level 1 User.

 

Level 2 Users do not have the broader administrative permissions available to Level 1 Users. Employers should therefore avoid treating an existing Level 2 User as a substitute for maintaining the required Level 1 User arrangements.

3. What must employers do with existing Level 2 Users?

Sponsors with existing Level 2 Users should now review each account and determine whether the individual should:

 

• be upgraded to Level 1 User status, where they satisfy the applicable eligibility requirements and genuinely require that level of access; or
• have their SMS access deactivated.

 

The transition should be completed by 8 March 2027. Remaining Level 2 accounts will be deactivated by the Home Office after the transitional period ends.

Employers should not automatically upgrade every Level 2 User to Level 1 simply because the Level 2 role is being removed.

From 9 September 2026, sponsors can no longer appoint as key personnel workers supplied to them by an employment business. An existing Level 2 User supplied in this way cannot be converted to Level 1 User status and should be deactivated by 8 March 2027 if not removed sooner.

Level 1 Users have substantially greater access to the sponsor’s SMS account. Before upgrading an existing Level 2 User, the organisation should therefore consider both whether the individual satisfies the relevant Home Office requirements and whether Level 1 access is operationally necessary.

4. Use the Level 2 transition to review SMS access

The withdrawal of Level 2 access provides employers with an opportunity to review their wider SMS-user structure.

For each existing Level 2 User, sponsors should consider:

 

• whether the individual still works for or remains appropriately connected with the organisation;
• whether they still perform sponsorship-related functions;
• whether they genuinely need SMS access;
• whether they satisfy the requirements to become a Level 1 User;
• whether their responsibilities justify the wider permissions available to a Level 1 User;
• whether another existing Level 1 User can perform the functions instead; and
• whether removing the account would improve access control without creating an operational gap.

 

This review should form part of the organisation’s broader approach to controlling privileged SMS access.

5. Avoid unnecessary Level 1 upgrades

The disappearance of Level 2 Users should not result in uncontrolled growth in the number of Level 1 Users.

If an individual previously needed only occasional or restricted SMS access, employers should consider whether that person now needs direct access at all.

Where the relevant functions can be undertaken effectively by an existing Level 1 User, deactivating the former Level 2 account may provide a more controlled arrangement than granting wider Level 1 permissions.

Conversely, where the individual has an ongoing operational role and requires regular access to administer sponsorship, upgrading them may be appropriate if they satisfy all applicable Level 1 User requirements.

The decision should therefore be based on eligibility, operational need and access control, rather than treating conversion to Level 1 status as an automatic administrative exercise.

6. Level 2 Users remain key personnel during the transition

Although the role is being phased out, existing Level 2 Users remain part of the Home Office’s key personnel framework during the transitional period.

Employers should therefore continue to manage existing Level 2 accounts appropriately until those accounts are either upgraded or deactivated.

This includes ensuring that user information remains accurate, that access is still required and that accounts belonging to individuals who have left the organisation or no longer need SMS access are dealt with promptly.

Once the transition has been completed, the practical sponsor licence management structure will centre on the Authorising Officer, Key Contact and Level 1 User, with Level 1 Users providing the operational SMS access required to administer the licence.

Further detail on the transitional arrangements and the remaining permissions of existing users is provided in our guide to Level 2 User: Sponsor Licence Role & Permissions.

 

 

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Section G: Can the Same Person Hold More Than One Key Personnel Role?

 

Yes. The same individual can hold more than one sponsor licence key personnel role, provided they satisfy the Home Office requirements that apply to each role they hold.

This means an eligible individual can potentially act as:

 

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

 

There is therefore no general requirement for an employer to appoint three different individuals simply because there are three principal key personnel roles.

This flexibility can be particularly useful for smaller organisations where responsibility for recruitment, HR and immigration compliance may be concentrated in a small management team.

1. Can one person be Authorising Officer, Key Contact and Level 1 User?

Yes. Subject to satisfying the applicable requirements for all three roles, one person can potentially act as the sponsor’s Authorising Officer, Key Contact and Level 1 User.

For example, the managing director of a smaller company may have overall responsibility for recruitment and sponsorship, communicate directly with UKVI and administer the sponsor licence through the SMS.

In these circumstances, combining the roles can provide a straightforward management structure.

The organisation should nevertheless distinguish between the functions being performed:

 

• as Authorising Officer, the individual provides senior accountability and oversight;
• as Key Contact, they act as the principal communication point with UKVI; and
• as Level 1 User, they carry out permitted operational functions through the SMS.

 

Holding all three roles does not remove the separate requirements associated with each appointment.

2. Should one person hold all three roles?

The more important question for employers is often not simply whether the roles can be combined, but whether combining them produces an effective and resilient sponsorship structure.

For some organisations, particularly smaller employers with limited sponsorship activity, a combined arrangement may be entirely appropriate.

For others, concentrating all sponsor management functions in one individual may create unnecessary operational risk.

If that individual:

 

• leaves the organisation;
• is absent for a prolonged period;
• changes role;
• loses access to the SMS;
• ceases to satisfy an applicable eligibility requirement; or
• is otherwise unable to perform their sponsorship functions,

 

the organisation may simultaneously lose its senior sponsorship oversight, principal UKVI contact and only operational SMS user.

This creates a single point of failure within the sponsor management structure.

3. Role separation in larger organisations

Larger sponsors may benefit from separating the roles according to organisational responsibility.

For example:

 

• HR Director → Authorising Officer
• Head of Global Mobility → Key Contact
• Immigration or HR Managers → Level 1 Users

 

This type of structure allows senior accountability to remain with an appropriate decision-maker while operational SMS administration is undertaken by personnel who deal with sponsorship activity more regularly.

It can also provide clearer internal escalation. Routine sponsorship administration can be handled by Level 1 Users, while material compliance concerns or significant sponsorship decisions can be escalated to the Authorising Officer.

4. Combining roles does not mean combining permissions

Employers should remember that holding several key personnel roles does not automatically give an individual all available SMS permissions.

In particular, appointment as Authorising Officer or Key Contact does not itself provide SMS access.

If someone holding either of those roles also needs to use the SMS, they must be appropriately appointed as an SMS user and satisfy the relevant requirements.

This distinction allows employers to separate organisational responsibility from system access.

For example, an Authorising Officer can retain senior responsibility for sponsorship without routinely accessing the SMS, while appropriately authorised Level 1 Users undertake the day-to-day system administration.

5. Consider continuity when combining key personnel roles

Where one person holds several key personnel roles, employers should consider what would happen if that individual became unavailable.

Continuity measures may include:

 

• maintaining an additional eligible Level 1 User where appropriate;
• ensuring another senior individual understands the sponsorship governance arrangements;
• documenting key sponsorship procedures;
• maintaining an up-to-date record of SMS users and their responsibilities;
• ensuring relevant sponsorship information is stored organisationally rather than solely by one individual;
• identifying potential successors for key roles; and
• including sponsor licence responsibilities within staff-leaver and internal-transfer procedures.

 

A practical structure should therefore balance simplicity against resilience.

6. Roles should reflect genuine responsibilities

Employers should avoid appointing individuals to key personnel roles purely to satisfy an application requirement where those individuals will have little or no genuine involvement in sponsorship.

The formal key personnel structure should broadly reflect how responsibility operates within the organisation.

If the Authorising Officer is described as having senior oversight, for example, there should be a credible internal process through which significant sponsorship issues can reach that individual. Similarly, a Level 1 User should understand the functions they are authorised to perform rather than merely holding an unused SMS account.

This becomes particularly relevant if the Home Office examines the sponsor’s systems during a compliance visit. The organisation should be capable of explaining who performs each sponsorship function, how responsibilities are allocated and how significant issues are escalated.

The objective is therefore not to maximise the number of key personnel or to separate every role automatically. It is to establish a structure in which responsibility, communication, system access and continuity are clear.

 

 

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Section H: Who Can Be Sponsor Licence Key Personnel?

 

The Home Office applies eligibility and suitability requirements to sponsor licence key personnel. Employers should therefore check that each proposed individual satisfies the requirements applicable to the particular role before making an appointment.

Eligibility is not identical across every key personnel role. The rules governing an Authorising Officer, Key Contact and Level 1 User differ in important respects, particularly in relation to the individual’s connection with the sponsoring organisation and whether an external representative can perform the role.

As a general framework, employers need to consider:

 

• the individual’s relationship with the sponsoring organisation;
• whether they are a paid member of staff, office holder or otherwise fall within a permitted category;
• whether they are based in the UK as required by the sponsor guidance;
• their immigration and settlement status where relevant to the role;
• National Insurance number requirements and any applicable exceptions;
• whether they are subject to any relevant suitability restrictions;
• their previous involvement with sponsor licence holders;
• whether any restrictions relating to contractors, consultants or representatives apply; and
• whether they continue to satisfy the requirements after appointment.

 

1. Relationship with the sponsoring organisation

Key personnel will usually need to have an appropriate relationship with the sponsor.

As a general rule, allocated staff should ordinarily be paid members of staff or office holders within the sponsoring organisation, although the sponsor guidance provides specific exceptions depending on the role and circumstances.

This distinction is particularly important when employers use external immigration advisers, outsourced HR providers or consultants.

The fact that an external adviser assists with sponsor licence management does not mean that adviser can automatically be appointed to any key personnel role.

For example, the Authorising Officer must ordinarily be a paid member of staff or office holder within the sponsoring organisation. By contrast, an appropriately appointed representative may be able to act as the Key Contact and, subject to the applicable requirements, as an additional Level 1 User.

Employers should therefore check eligibility by reference to the specific role rather than assuming that a person eligible for one key personnel position is automatically eligible for another.

2. UK-based requirements

Home Office requirements also address where key personnel are based.

Allocated staff must generally be based in the UK for the period they fill the role, subject to specific exceptions provided for within the sponsor guidance.

This means employers should be cautious about nominating an individual who principally works overseas merely because that person holds a senior position within an international group.

The issue is not simply nationality. An individual does not necessarily have to be a British citizen to act as key personnel. Instead, the sponsor needs to consider the specific eligibility requirements applying to the role, including the person’s location, immigration status and, where applicable, settlement requirements.

Special rules can apply under particular sponsorship routes. For example, the UK Expansion Worker route contains provisions allowing an overseas business establishing a UK presence to nominate an appropriate senior employee of the overseas business as Authorising Officer in circumstances where there is not yet a suitable UK-based person.

Where the Authorising Officer is overseas at the application stage under these provisions, that individual must also be the initial Level 1 User. They can remain outside the UK until they enter with permission as a UK Expansion Worker. While the licence remains provisionally rated, the sponsor cannot add or change Level 1 Users in the normal way; broader Level 1 User changes become available once the sponsor has obtained an A-rating.

Employers relying on a route-specific exception should check the applicable sponsor guidance rather than applying the ordinary key personnel rules in isolation.

3. Immigration status and settled worker requirements

Employers should distinguish between the general eligibility requirements applying to key personnel and the additional requirements applying to particular roles.

There is no general rule that every member of key personnel must be a British citizen.

However, immigration status can be relevant when determining whether an individual can perform a particular role. Of particular importance, the sponsor must maintain Level 1 User arrangements that satisfy the applicable Home Office requirements concerning the user’s relationship with the organisation and settled-worker status. For continuously licensed sponsors whose successful application was made before 1 January 2025, those two requirements can currently be met by two different Level 1 Users.

This is one reason an external representative cannot simply replace the sponsor’s required internal Level 1 User.

Employers should verify the current requirements applying to the proposed appointment rather than relying only on the individual’s right to work for the organisation.

4. National Insurance number requirements

National Insurance number requirements can also apply when key personnel and SMS users are appointed.

Where the Home Office requires a National Insurance number, the sponsor should provide the relevant information through the applicable process. Specific exceptions can apply where an individual does not have a National Insurance number and falls within circumstances recognised by the sponsor guidance.

The absence of a National Insurance number should therefore not simply be ignored or replaced with inaccurate information. Where an exception applies, the sponsor should follow the prescribed process and provide any information or explanation required by the Home Office.

5. Suitability requirements

Formal connection with the organisation is not the only consideration. Proposed key personnel must also satisfy the relevant Home Office suitability requirements.

The Home Office can consider matters including relevant immigration and sponsorship history, certain criminal convictions, previous compliance concerns and associations with organisations whose sponsor licences have been refused, revoked or otherwise subject to relevant action.

Relevant restrictions can also arise where an individual is subject to a bankruptcy restriction order or undertaking or a debt relief restriction order or undertaking.

The precise suitability rules should be checked against the current sponsor guidance because the effect of a particular issue can depend on its nature, timing and the role concerned.

Employers should therefore undertake appropriate checks before nominating key personnel rather than assuming that seniority or employment status alone makes an individual suitable.

6. Contractors and consultants

The sponsor guidance places restrictions on the use of contractors and consultants as allocated staff.

From 9 September 2026, a worker supplied to the sponsor by an employment business cannot be appointed as key personnel.

In addition, an individual who is a contractor or consultant contracted for a specific project should not simply be nominated as key personnel on that basis.

This is separate from the rules allowing appropriately appointed professional representatives to perform certain specified functions. Employers should not assume that every consultant, outsourced HR provider or immigration adviser falls within the representative provisions.

Where an external person is being considered, the sponsor should establish:

 

• the precise role the person is intended to hold;
• their contractual and professional relationship with the sponsor;
• whether the Home Office rules permit an external person to perform that role;
• whether any representative requirements apply; and
• whether the sponsor continues to satisfy its internal key personnel and Level 1 User requirements.

 

7. Eligibility must continue after appointment

Key personnel eligibility is not merely an application-stage test.

An individual who was eligible when appointed may later:

 

• leave the organisation;
• move into a different role;
• change their working location;
• cease to have the required relationship with the sponsor;
• experience a change relevant to their immigration status;
• become subject to a relevant suitability issue; or
• otherwise cease to meet the requirements applying to their appointment.

 

Sponsors should therefore review key personnel eligibility when relevant circumstances change rather than relying indefinitely on checks carried out when the licence was first obtained.

Particular attention should be given to the Authorising Officer and Level 1 User arrangements. Sponsors are expected to maintain an eligible Authorising Officer and appropriate eligible Level 1 User provision throughout the life of the licence. Failure to maintain the required key personnel structure can expose the organisation to Home Office compliance action.

 

 

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Section I: Who Cannot Act as Sponsor Licence Key Personnel?

 

Not every employee, director, consultant or adviser will be eligible to act as sponsor licence key personnel. The Home Office applies requirements concerning the individual’s relationship with the sponsor, location, immigration status where relevant, suitability and previous sponsorship history.

The precise restrictions depend on the particular role. Someone who cannot act as an Authorising Officer may, for example, potentially be eligible to act as a Key Contact or an additional Level 1 User where the relevant representative provisions are satisfied.

Employers should therefore avoid applying a single eligibility test to every key personnel position.

1. Individuals without the required relationship with the sponsor

Key personnel will ordinarily need to have the relationship with the sponsoring organisation required for the relevant role.

As a general rule, allocated staff are usually expected to be paid members of staff or office holders, subject to the specific exceptions contained in the sponsor guidance.

This means an employer cannot simply nominate any individual connected with the business because they are convenient or have immigration knowledge.

Particular care is required where the proposed individual is:

 

• an external consultant;
• an outsourced HR provider;
• an immigration adviser;
• an employee of another group company;
• a contractor;
• an accountant or other professional adviser; or
• another third party who is not directly part of the sponsoring organisation.

 

Whether such a person can perform a role depends on the specific Home Office rules governing that appointment.

2. External representatives cannot ordinarily be the Authorising Officer

The Authorising Officer must ordinarily be a paid member of staff or an office holder within the sponsoring organisation.

An external immigration solicitor, HR consultant or other professional representative cannot generally be appointed as Authorising Officer merely because they manage or advise on the organisation’s sponsorship arrangements.

This reflects the nature of the role. The Authorising Officer provides senior organisational accountability for sponsorship and should therefore ordinarily sit within the sponsoring organisation itself.

Specific exceptions exist in limited circumstances, including provisions relevant to certain insolvency situations and the UK Expansion Worker route. These exceptions should be considered by reference to the applicable Home Office guidance rather than treated as a general ability to outsource the Authorising Officer role.

3. Restrictions on contractors and consultants

A contractor or consultant who is contracted for a specific project should not simply be nominated as allocated staff for sponsor licence purposes.

Employers should distinguish this restriction from the separate provisions allowing appropriately appointed representatives to perform certain permitted sponsor management functions.

For example, an immigration solicitor acting as an authorised representative may potentially be appointed as Key Contact or, where the requirements are met, as an additional Level 1 User. That does not mean an unrelated project consultant or a worker supplied by an employment business can automatically be treated in the same way.

4. Individuals who are not appropriately based in the UK

Allocated staff are generally required to be based in the UK for the period they fill the role, subject to specific exceptions.

An individual who principally works overseas should therefore not automatically be appointed simply because they are a senior executive within the wider corporate group.

This issue commonly arises in multinational organisations where immigration or HR functions are managed regionally or globally.

A global HR director based outside the UK may exercise considerable authority over the organisation’s international workforce, but that does not in itself mean they satisfy the Home Office requirements to act as key personnel for the UK sponsor licence.

Route-specific exceptions can apply. The UK Expansion Worker route, for example, contains provisions relevant to overseas businesses that have not yet established the normal UK-based personnel structure.

5. Individuals who do not satisfy applicable immigration or settlement requirements

There is no general requirement for all key personnel to be British citizens, but immigration and settlement status can affect eligibility for particular roles.

This is especially important for Level 1 User arrangements, where the sponsor must maintain at least one Level 1 User who satisfies the applicable internal-user and settled-worker requirements.

An employer should therefore not assume that because an individual has permission to work for the organisation, they necessarily satisfy every requirement for the proposed sponsor management role.

6. Individuals affected by suitability concerns

The Home Office can take account of relevant suitability matters when considering key personnel.

Depending on the circumstances, relevant matters can include:

 

• certain unspent criminal convictions;
• relevant immigration offences;
• previous immigration penalties or compliance action;
• previous involvement with a sponsor whose licence was revoked;
• relevant involvement with unsuccessful or problematic sponsor licence applications;
• previous failures to comply with sponsorship requirements;
• other relevant immigration or sponsorship history;
• a bankruptcy restriction order or undertaking; or
• a debt relief restriction order or undertaking.

 

The existence of an historic issue should be considered against the precise wording of the current sponsor guidance. Employers should not assume either that every previous issue automatically prevents appointment or that an old compliance matter is irrelevant.

7. Individuals who later cease to meet the requirements

Eligibility must continue after the person has been appointed.

A key person may become unsuitable or ineligible because they:

 

• leave the sponsoring organisation;
• change employment status;
• move into a different role;
• relocate overseas;
• cease to satisfy a relevant immigration or settlement requirement;
• become subject to a relevant suitability restriction;
• no longer have the organisational relationship required for the role; or
• otherwise cease to satisfy the applicable Home Office requirements.

 

Employers should therefore connect sponsor licence governance with normal HR processes. Changes affecting key personnel should trigger consideration of whether the sponsor’s Home Office records, SMS access and internal responsibilities need to be updated.

8. Avoid nominal appointments

Even where an individual appears formally eligible, employers should avoid appointing someone who has no realistic ability to perform the role.

For example, an Authorising Officer who has no understanding of the organisation’s sponsorship activity and no contact with the people administering the licence may provide weak practical oversight even if they satisfy the basic appointment criteria.

Similarly, giving Level 1 access to an employee who has no training, no genuine sponsorship responsibilities and no understanding of the significance of SMS actions creates unnecessary compliance risk.

Employers should therefore distinguish between formal eligibility and practical suitability.

A strong key personnel appointment should satisfy both.

 

 

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Section J: Can an Immigration Lawyer or External Adviser Be Key Personnel?

 

External immigration lawyers and other professional advisers can perform certain sponsor management functions, but an employer cannot outsource all responsibility for its sponsor licence to an external adviser.

The extent to which an external adviser can act as key personnel depends on the particular role and whether the individual satisfies the Home Office requirements applying to representatives.

The distinction between the roles is important. An external adviser cannot ordinarily act as the sponsor’s Authorising Officer, but an appropriately appointed representative may be able to act as the Key Contact and, subject to the applicable requirements, as an additional Level 1 User.

In all cases, the sponsoring organisation remains responsible for compliance with its sponsor duties and for ensuring that appropriate internal sponsorship management arrangements are maintained.

1. Can an immigration lawyer be the Authorising Officer?

Ordinarily, no.

The Authorising Officer is intended to provide senior accountability from within the sponsoring organisation. The individual must ordinarily be a paid member of staff or an office holder of the sponsor, subject to limited exceptions provided for within the sponsor guidance.

An external immigration solicitor, immigration adviser, outsourced HR provider or consultant should therefore not generally be appointed as Authorising Officer merely because they advise the organisation or assist with management of the sponsor licence.

This distinction is important because professional advisers can support the Authorising Officer, but they do not replace the sponsor’s own senior responsibility for its licence.

2. Can an immigration lawyer be the Key Contact?

Yes, an appropriately appointed external representative can potentially act as the sponsor’s Key Contact, subject to satisfying the relevant Home Office requirements.

This arrangement can be useful where an employer wants its immigration adviser to act as the principal professional communication point with UKVI.

The sponsor should nevertheless maintain clear internal arrangements so that communications received by the representative reach the appropriate people within the organisation.

For example, the organisation should determine:

 

• who receives information passed on by the external Key Contact;
• which matters are escalated to the Authorising Officer;
• who provides instructions to the adviser;
• who is responsible for supplying factual information and supporting documents;
• who makes decisions affecting sponsored workers; and
• how urgent Home Office correspondence will be dealt with.

 

The external representative provides the communication function, but responsibility for sponsorship remains with the licensed organisation.

3. Can an immigration lawyer be a Level 1 User?

An appropriately appointed representative may, where the Home Office requirements are satisfied, be appointed as an additional Level 1 User.

This can allow an immigration adviser to assist directly with permitted SMS administration, for example where the adviser supports the employer with sponsorship matters.

There is, however, an important restriction: an external representative cannot simply replace the sponsor’s required internal Level 1 User arrangements.

Where a sponsor has only one Level 1 User, that individual cannot be an external representative acting instead of the sponsor’s own internal personnel.

The sponsor must maintain Level 1 User arrangements that satisfy the applicable Home Office requirements concerning the relationship with the organisation and settled-worker status, taking account of the transitional rules for continuously licensed sponsors whose successful application was made before 1 January 2025.

An external adviser with Level 1 access should therefore be viewed as additional professional support, rather than as a means of transferring control of the licence away from the sponsor.

4. What about outsourced HR providers?

The fact that an organisation has outsourced some or all of its HR administration does not automatically mean that personnel employed by the outsourced provider can be appointed to every key personnel role.

The Home Office rules distinguish between employees and office holders of the sponsor, appropriately appointed representatives and contractors or consultants.

There are also restrictions affecting contractors or consultants engaged for a specific project.

Employers using outsourced HR support should therefore consider the precise status of the proposed individual and the role they are expected to perform rather than assuming that an outsourced HR contract is sufficient for key personnel eligibility.

Where an external HR provider is eligible to act as a representative and the relevant requirements are satisfied, it may be possible for an appropriate individual to perform certain permitted functions, such as acting as Key Contact or an additional Level 1 User.

The sponsor must still maintain the internal personnel and governance arrangements required by the Home Office.

5. Sponsor responsibility cannot be outsourced

Using an immigration lawyer or other external adviser can provide additional expertise and administrative support, but it does not transfer the sponsor licence itself or the sponsor’s compliance responsibilities to the adviser.

The licensed organisation remains responsible for matters including:

 

• ensuring sponsored roles and workers satisfy the relevant requirements;
• maintaining appropriate records;
• monitoring sponsored workers where required;
• ensuring relevant changes are identified and reported;
• providing accurate information to the Home Office;
• maintaining appropriate key personnel;
• controlling access to the SMS; and
• ensuring its sponsorship systems operate effectively.

 

An employer should therefore remain capable of understanding and overseeing its sponsor licence even where substantial administrative support is provided externally.

6. Practical internal and external governance model

For some organisations, an effective arrangement may combine internal accountability with external immigration support.

For example:

 

• Managing Director or HR Director → Authorising Officer
• Immigration solicitor → Key Contact
• Internal HR Manager → Level 1 User
• Immigration solicitor → Additional Level 1 User, where eligible and required

 

Under this type of structure, the organisation retains senior responsibility and internal SMS capability while using its external adviser to support Home Office communications and permitted sponsorship administration.

The precise arrangement should reflect the organisation’s size, sponsorship activity and internal resources.

7. Control external SMS access

Where an external representative has SMS access, that access should be controlled in the same way as access granted to internal users.

The sponsor should know:

 

• which external individuals have access;
• what level of access they hold;
• why that access is required;
• which activities they are authorised to undertake;
• which activities require internal approval;
• how instructions are recorded;
• how multi-factor authentication and individual account security are maintained; and
• when access should be removed if the advisory relationship ends.

 

An adviser should use their own authorised account. SMS credentials should not be shared between the sponsor and its adviser or between different members of the adviser’s team.

If the organisation changes immigration advisers, the sponsor should review its key personnel information and SMS-user accounts promptly to determine whether the outgoing representative’s access or appointment needs to be removed or replaced.

8. External support should strengthen internal governance

The most effective use of external immigration support is generally to supplement the sponsor’s internal governance rather than replace it.

An adviser can provide specialist immigration knowledge, assist with complex sponsorship issues, support SMS administration and help the organisation interpret Home Office requirements. Internal personnel, however, remain essential because they control the employment relationship, recruitment decisions, HR records and much of the factual information on which sponsorship compliance depends.

The objective should therefore be an integrated arrangement in which the sponsor retains internal accountability and control while external advisers provide specialist support and permitted administrative assistance.

 

 

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Section K: Which Key Personnel Have Access to the Sponsor Management System?

 

Not every member of sponsor licence key personnel automatically has access to the Sponsor Management System (SMS).

This is an important distinction because the Home Office separates the organisational roles of Authorising Officer and Key Contact from the operational permissions given to SMS users.

Appointment as an Authorising Officer or Key Contact does not, by itself, provide SMS access. By contrast, the Level 1 User is specifically an SMS-user role and is responsible for carrying out many of the practical functions required to administer the licence.

 

Key Personnel Role	Automatic SMS Access?	Can Have SMS Access?	Principal Function
Authorising Officer	No	Yes, if separately appointed to an appropriate SMS-user role	Senior oversight and accountability
Key Contact	No	Yes, if separately appointed to an appropriate SMS-user role	Principal communication with UKVI
Level 1 User	Yes	Yes	Operational administration through the SMS
Level 2 User	Existing users only	Restricted transitional access	Limited SMS functions during the transition to removal of the role

 

1. Authorising Officer SMS access

The Authorising Officer does not need to use the SMS simply because they have senior responsibility for sponsorship.

In many larger organisations, the Authorising Officer may exercise oversight while operational administration is carried out by HR, immigration or global mobility personnel appointed as Level 1 Users.

If the Authorising Officer needs to carry out SMS functions personally, they must also be appropriately appointed as an SMS user and satisfy the requirements applying to that appointment.

This allows the sponsor to distinguish between senior accountability and system access.

2. Key Contact SMS access

The same principle applies to the Key Contact.

Being the sponsor’s principal point of contact with UKVI does not automatically provide access to the SMS.

A Key Contact who also needs to administer the licence through the system will need to hold an appropriate SMS-user role.

For example, an internal immigration manager could be both the Key Contact and a Level 1 User, allowing the individual to manage UKVI communications and undertake permitted SMS administration.

3. Level 1 User SMS access

Level 1 Users have the principal operational access to the SMS.

Depending on the functions available to the sponsor, a Level 1 User may be able to:

 

• maintain sponsor licence information;
• manage aspects of key personnel and SMS-user information;
• request Certificates of Sponsorship where applicable;
• create and assign Certificates of Sponsorship;
• report relevant organisational changes;
• report specified changes relating to sponsored workers; and
• perform other permitted sponsor management functions.

 

These permissions make Level 1 access particularly significant from a compliance and information-security perspective.

4. More SMS access is not necessarily better

Employers should avoid assuming that giving more employees SMS access will necessarily make sponsor licence management more effective.

Every additional SMS user increases the number of people able to perform functions affecting the sponsor licence.

A more controlled approach is to apply the principle of least necessary access: individuals should receive the level of system access genuinely required to perform their sponsorship responsibilities, rather than being given access simply because they may occasionally be involved in immigration matters.

Employers should balance two competing considerations:

 

• resilience – ensuring there are sufficient eligible users to administer the licence if somebody is unavailable; and
• access control – avoiding unnecessary or excessive access to the SMS.

 

The appropriate balance will depend on the organisation’s size, structure and volume of sponsorship activity.

5. SMS accounts are individual accounts

SMS access should be allocated to identifiable individuals rather than treated as a shared departmental resource.

Users should access the system through their own authorised accounts and should not share login credentials.

Employers should not operate arrangements such as:

 

• a shared HR SMS login;
• one employee allowing colleagues to use their account;
• an external adviser using an employee’s credentials;
• multiple members of an adviser’s team using one authorised account; or
• login details being retained by people who are no longer authorised to use the system.

 

Individual accounts provide clearer accountability for activity undertaken through the SMS and allow access to be removed when a user’s responsibilities change.

6. Multi-factor authentication for SMS users

SMS security requirements changed in September 2026 with the phased introduction of mandatory multi-factor authentication for SMS users from 3 September 2026. The Home Office expects the rollout to cover all sponsors by November 2026, and sponsor licences granted on or after 9 September 2026 have MFA enabled.

Sponsors should ensure that SMS users have accurate personal and contact information recorded and are able to complete the authentication requirements associated with their accounts. Level 1 Users will normally receive the one-time passcode by SMS where a valid mobile number is recorded; Level 1 Users without a valid mobile number and existing Level 2 Users receive the code by email. Level 1 Users should also ensure that the date-of-birth information required for MFA is recorded accurately where prompted.

Multi-factor authentication reinforces the need for each user to operate their own account rather than sharing access.

Employers should incorporate SMS authentication into their wider access-management arrangements, including procedures for:

 

• setting up new users;
• maintaining accurate user information;
• dealing with changes to contact details;
• responding to access problems;
• removing access when an individual leaves; and
• reviewing whether existing users still require access.

 

7. Inactive SMS accounts

Sponsors should actively manage SMS-user accounts rather than leaving historic or unused accounts in place indefinitely.

Current Home Office guidance places increased emphasis on inactive SMS users and the need for sponsors to check that user details remain accurate and that those with access continue to require it.

The Home Office recommends that a Level 1 User accesses the SMS at least once a month.

An SMS account is treated as inactive after 12 months without access. Where the Home Office notifies the sponsor and affected Level 1 User, a user who needs to retain access should log in and check or update their details within 3 months. Otherwise the account will be deactivated. If this leaves the sponsor with no active Level 1 User, the sponsor licence can be suspended and the sponsor will normally have 28 days to nominate an eligible Level 1 User, failing which the licence will normally be revoked.

This should not be viewed simply as a requirement to log into the system periodically. Regular access should form part of active sponsor licence management, allowing the organisation to check its information, identify matters requiring action and confirm that it retains effective access to the system.

Where an SMS user has become inactive because they no longer undertake sponsorship work, the organisation should consider whether the account should remain active at all.

8. Maintain an SMS access register

As a practical governance measure, sponsors should consider maintaining an internal register of individuals with SMS access.

The register could record:

 

• the user’s full name;
• their job title;
• their department or business function;
• whether they are an internal user or permitted external representative;
• their SMS-user level;
• any other key personnel role they hold;
• why SMS access is required;
• the date access was granted;
• the date access was last reviewed;
• whether the individual remains eligible;
• the date access was changed; and
• the date access was removed.

 

This can help employers demonstrate that SMS access is being actively controlled rather than accumulating over time.

9. Review access when circumstances change

An SMS-access review should be triggered where relevant circumstances change.

Examples include where a user:

 

• leaves the organisation;
• changes department;
• changes job role;
• no longer undertakes sponsorship work;
• takes a prolonged absence;
• ceases to satisfy an eligibility requirement;
• moves overseas;
• changes from an internal to an external relationship with the organisation; or
• is an external adviser whose engagement with the sponsor has ended.

 

Changes involving one user should also prompt consideration of the wider structure. Removing an account may, for example, leave the organisation with only one Level 1 User or no functioning Level 1 access.

10. System permission is different from organisational authority

Having technical permission to perform an action through the SMS does not mean an employee should necessarily have internal authority to make the underlying decision.

Employers can establish internal approval controls governing how SMS permissions are used.

For example, a Level 1 User may technically be able to assign a Certificate of Sponsorship, but the organisation may require approval from HR, finance, recruitment or senior management before assignment takes place.

Similarly, changes affecting the organisation’s sponsor licence may require internal legal or compliance review before they are reported through the SMS.

This distinction between system permission and organisational authority is an important element of effective sponsor licence governance.

11. SMS access should form part of wider sponsor governance

SMS access should not be managed independently from the organisation’s wider HR, IT security and compliance processes.

New starters, internal transfers and employee departures can all affect whether an individual should have access to the system.

Employers should therefore integrate SMS-user management with:

 

• HR onboarding;
• employee role changes;
• IT access management;
• staff offboarding;
• immigration compliance procedures;
• sponsor licence audits; and
• periodic access reviews.

 

The objective is to ensure that the sponsor can identify at any point who can access the SMS, why they have access, what they are authorised to do and whether that access remains appropriate.

Detailed guidance on operating the system itself is provided in our Sponsor Management System (SMS): Employer Guide.

 

 

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Section L: How Many Level 1 Users Should an Employer Have?

 

Every sponsor must maintain at least one eligible Level 1 User, but there is no single number of Level 1 Users that will be appropriate for every organisation.

The right number depends on the employer’s size, sponsorship activity, organisational structure and the extent to which different people need to carry out functions through the Sponsor Management System.

The objective should be to maintain sufficient Level 1 User coverage to administer the licence effectively without giving unnecessary people access to a system through which significant sponsorship functions can be performed.

1. Is one Level 1 User enough?

For some smaller sponsors, one Level 1 User may be sufficient from an operational perspective.

For example, an organisation that sponsors only a small number of workers and has relatively limited sponsorship activity may have one appropriately trained HR manager or director responsible for administering the licence.

There is, however, an obvious continuity risk where the organisation depends entirely on one individual.

If the sole Level 1 User:

 

• leaves the organisation;
• is absent unexpectedly;
• takes extended leave;
• changes role;
• loses access to their SMS account;
• ceases to satisfy the relevant eligibility requirements; or
• is otherwise unavailable when urgent action is required,

 

the organisation may temporarily lose its practical ability to administer the sponsor licence through the SMS.

Where the sponsor has lost its only Level 1 User and nobody remains able to access the SMS, the organisation will need to use the appropriate Home Office process, including the relevant change of circumstances procedure, to request the addition of a replacement Level 1 User.

2. When can additional Level 1 Users be useful?

Having more than one Level 1 User may be appropriate where the organisation has greater sponsorship activity or needs operational cover.

Factors that may support having additional Level 1 Users include:

 

• a significant sponsored workforce;
• frequent Certificate of Sponsorship activity;
• multiple recruitment teams;
• separate HR or global mobility teams;
• multiple UK sites or business divisions;
• different teams managing different categories of sponsored worker;
• the need for holiday or sickness cover;
• business continuity requirements;
• high volumes of reportable worker changes; or
• complex sponsorship arrangements requiring regular SMS administration.

 

Additional users can provide resilience and reduce dependency on a single administrator.

3. Primary and backup Level 1 Users

For some employers, a practical structure is to maintain a primary Level 1 User and an appropriately trained backup Level 1 User.

The primary user may carry out most day-to-day sponsorship administration, while the backup user remains sufficiently familiar with the organisation’s procedures and SMS arrangements to provide cover where necessary.

This is a practical governance model rather than a universal Home Office requirement.

If an employer adopts this approach, the backup user should not merely exist as a name on the system. They should remain appropriately trained, eligible and capable of accessing the SMS if required.

The sponsor should also ensure that the user’s account remains current and is managed in accordance with Home Office requirements concerning SMS access, authentication and inactive users.

4. Larger sponsors may need a wider Level 1 structure

Larger organisations may require several Level 1 Users.

For example, a national employer could have sponsorship activity divided between:

 

• a central immigration team;
• HR operations;
• global mobility;
• specialist recruitment teams; and
• different business divisions or locations.

 

In these circumstances, restricting SMS administration to one individual may create delays and excessive dependency.

Multiple Level 1 Users can allow responsibilities to be distributed, but the organisation should still maintain central oversight of who has access and how that access is used.

5. Avoid excessive Level 1 access

The opposite problem can arise where an organisation appoints too many Level 1 Users.

SMS access should not be given simply because an employee works in HR, recruitment or another function that occasionally interacts with sponsored workers.

Each additional user increases the number of accounts capable of carrying out potentially significant actions affecting the sponsor licence.

Excessive access can make it harder to:

 

• maintain clear accountability;
• control sponsorship activity;
• ensure users remain appropriately trained;
• monitor who has performed particular actions;
• remove access when responsibilities change; and
• maintain effective SMS security.

 

Employers should therefore apply a least necessary access approach rather than maximising the number of users.

6. External advisers should not replace internal Level 1 capability

Where an employer uses an immigration lawyer or another permitted representative as an additional Level 1 User, this should not be treated as a substitute for maintaining the required internal Level 1 User arrangements.

In particular, where the sponsor has only one Level 1 User, that person cannot simply be an external representative.

The organisation must retain the Level 1 User capability required by the Home Office, with its users collectively satisfying the applicable relationship and settled-worker requirements, taking account of the transitional rules for continuously licensed sponsors whose successful application was made before 1 January 2025.

External Level 1 access can therefore provide additional expertise or operational support, but it should sit alongside rather than replace the sponsor’s required internal arrangements.

7. Level 1 Users should not operate in isolation

Even where only one or two people use the SMS, Level 1 Users should operate within a wider governance structure.

They should know when an issue requires escalation to:

 

• the Authorising Officer;
• the Key Contact;
• HR leadership;
• senior management;
• legal or compliance teams; or
• external immigration advisers.

 

For example, a Level 1 User may have the technical ability to make a report through the SMS, but the organisation may require legal or senior management input before reporting a complex corporate restructuring or a potentially serious compliance issue.

The number of Level 1 Users should therefore be considered alongside the organisation’s decision-making and escalation processes.

8. Review Level 1 User numbers periodically

The appropriate number of Level 1 Users can change over time.

A business that initially sponsors one or two employees may later develop a substantial international recruitment programme. Conversely, an organisation that previously required several users may reduce its sponsorship activity or centralise administration.

Employers should therefore periodically review:

 

• how many Level 1 Users are currently appointed;
• whether each user still requires access;
• whether each user remains eligible;
• whether there is excessive dependence on one individual;
• whether sufficient operational cover exists;
• whether inactive accounts should be removed;
• whether SMS-user information remains accurate; and
• whether the existing structure still reflects how sponsorship is actually managed.

 

Current Home Office guidance also recommends that a Level 1 User accesses the SMS at least once a month. Employers should incorporate this into their wider arrangements for maintaining active and effective SMS access.

9. Finding the right balance

The aim is not to identify a fixed numerical target for Level 1 Users.

Instead, employers should maintain the smallest number of suitably trained and eligible Level 1 Users that provides effective administration, appropriate access control and reasonable operational resilience.

For a small sponsor this may mean a primary and backup arrangement. For a larger sponsor it may mean several users operating within a centrally controlled sponsorship function.

Whatever model is adopted, the sponsor should be able to explain who has Level 1 access, why they need it, how their activity is controlled and what arrangements exist if a principal user becomes unavailable.

 

 

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Section M: Choosing the Right People for Sponsor Licence Key Personnel Roles

 

Meeting the Home Office’s formal eligibility requirements is only the starting point when selecting sponsor licence key personnel.

An individual may technically be eligible for appointment but still be a poor practical choice if they lack sufficient authority, have little involvement in sponsorship, cannot access the information needed to perform the role or are unlikely to provide continuity.

Employers should therefore consider both formal eligibility and operational suitability when deciding who should act as Authorising Officer, Key Contact and Level 1 User.

A useful framework is to assess proposed key personnel against five factors:

Authority → Involvement → Knowledge → Access → Continuity

1. Authority

The individual should have sufficient organisational authority for the responsibilities they are expected to perform.

This is particularly important for the Authorising Officer. The role involves senior oversight of the organisation’s sponsorship arrangements, so the person appointed should be capable of exercising meaningful authority where compliance problems or sponsorship issues arise.

Questions to consider include:

 

• Can the individual require changes to sponsorship procedures?
• Can they obtain information from HR, recruitment and management?
• Can they escalate significant compliance concerns?
• Can they ensure corrective action is taken where weaknesses are identified?
• Do relevant teams recognise their responsibility for sponsorship oversight?

 

Authority is less critical for some routine administrative functions, but every person given SMS access should still have clear organisational authorisation to perform the functions assigned to them.

2. Involvement

The person should have an appropriate level of involvement in the organisation’s sponsorship activities.

An Authorising Officer does not need to perform daily SMS administration, but they should have sufficient visibility of sponsorship to provide genuine oversight.

A Level 1 User, by contrast, is likely to require much more regular involvement because the role centres on practical administration through the SMS.

The Key Contact should be sufficiently connected with the organisation’s sponsorship arrangements to ensure Home Office communications reach the correct people and are acted on appropriately.

 

Consideration	Authorising Officer	Key Contact	Level 1 User
Senior organisational authority	High importance	Helpful depending on structure	Not necessarily required
Regular sponsorship involvement	Oversight required	Useful	High importance
Direct SMS access	Not automatically required	Not automatically required	Required
UKVI communication	Oversight as appropriate	Core function	May be relevant operationally
Detailed SMS knowledge	Useful but not necessarily operational	Useful where relevant	High importance
Ability to escalate issues	High importance	High importance	High importance

 

3. Knowledge

Key personnel should have sufficient knowledge to perform their respective functions effectively.

This does not mean every individual needs to be an immigration specialist.

The Authorising Officer should understand the significance of holding a sponsor licence, the organisation’s principal sponsor duties and the systems used to manage sponsorship.

The Key Contact should understand enough about the sponsor’s arrangements to identify relevant Home Office communications and ensure they reach the appropriate person.

Level 1 Users require more detailed operational knowledge because they perform actions directly through the SMS.

Relevant knowledge may include:

 

• how the sponsor licence is structured;
• the organisation’s sponsored worker population;
• the principal sponsor duties;
• internal sponsorship procedures;
• the organisation’s Certificate of Sponsorship approval process;
• reporting and record-keeping arrangements;
• internal escalation procedures;
• SMS security requirements;
• the limits of the individual’s own authority; and
• when specialist advice should be obtained.

 

4. Access

Key personnel need access to the information and systems required to perform their roles.

For Level 1 Users, this includes authorised access to the SMS.

For the wider key personnel structure, access can also mean access to relevant organisational information.

Depending on the role, this may include information relating to:

 

• recruitment;
• employee start and end dates;
• job roles and duties;
• salary and payroll;
• working locations;
• absence;
• changes in employment;
• corporate restructuring;
• business ownership; and
• other matters potentially affecting sponsorship.

 

A Level 1 User cannot report information they do not know about. Effective sponsorship therefore depends on information flowing from the wider organisation to those responsible for the licence.

Employers should ask not only whether a Level 1 User can access the SMS, but whether they receive the information necessary to use it correctly.

5. Does the person actually need SMS access?

Appointment to a key personnel role should not automatically result in SMS access.

The Authorising Officer and Key Contact do not receive SMS access merely because they hold those roles.

Before appointing an additional Level 1 User, employers should ask:

 

• What SMS functions does this person need to perform?
• How frequently will they perform those functions?
• Could an existing Level 1 User perform them instead?
• Does the individual understand the consequences of SMS actions?
• Have they received appropriate training?
• Is granting access necessary for resilience or merely convenient?

 

SMS access should be granted because there is an identifiable operational requirement, not simply because an individual is senior or involved in HR.

6. Continuity

Employers should consider how stable the proposed appointment is likely to be.

This does not mean key personnel must remain in their roles indefinitely. Personnel changes are a normal part of running an organisation.

The issue is whether the sponsorship structure can continue to function when changes occur.

Employers should consider:

 

• what happens if the Authorising Officer leaves;
• who will deal with UKVI communications if the Key Contact is unavailable;
• whether another eligible person can operate the SMS if the principal Level 1 User leaves;
• whether sponsorship knowledge is documented or concentrated in one employee;
• whether handover procedures exist;
• whether HR will notify the sponsorship team before key personnel leave; and
• whether potential replacement personnel have been identified.

 

Continuity becomes particularly important where one person holds several key personnel roles.

7. Practical key personnel selection framework

Employers can therefore assess potential appointments using the following five questions:

 

1. Authority: Does this person have sufficient organisational authority for the role?
2. Involvement: Are they sufficiently involved in sponsorship or connected with those who are?
3. Knowledge: Do they understand the responsibilities and processes relevant to the role?
4. Access: Can they access the systems and organisational information they need?
5. Continuity: What happens if they leave or become unavailable?

 

This framework goes beyond simply identifying someone who satisfies the minimum eligibility requirements.

8. Match roles to genuine organisational responsibility

The strongest key personnel structures generally reflect how the organisation actually operates.

For example, where an HR Director has senior responsibility for recruitment and workforce compliance, appointing that individual as Authorising Officer may provide a logical alignment between formal sponsor responsibility and internal authority.

If an immigration manager handles day-to-day sponsorship administration, that individual may be an appropriate Level 1 User.

Where an external immigration solicitor manages communications with UKVI, appointing the adviser as Key Contact may be appropriate where the representative requirements are satisfied, while internal responsibility remains with the sponsor.

By contrast, appointing individuals solely because their names were available when the licence application was completed can create a structure that bears little relationship to the organisation’s actual sponsorship processes.

9. The objective: effective sponsor governance

There is no single key personnel structure that will suit every sponsor.

A small business sponsoring two workers may legitimately have a much simpler structure than a multinational employer sponsoring hundreds of workers across multiple locations.

The objective is to establish arrangements that combine:

 

• clear senior accountability;
• reliable UKVI communication;
• controlled SMS access;
• appropriate sponsorship knowledge;
• effective information flows; and
• reasonable operational continuity.

 

Employers that assess proposed key personnel against Authority, Involvement, Knowledge, Access and Continuity are better placed to create a sponsor management structure that works in practice as well as satisfying the formal appointment requirements.

 

 

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Section N: Key Personnel Governance & Internal Controls

 

Appointing eligible sponsor licence key personnel is only the starting point. Employers also need internal controls that allow the Authorising Officer, Key Contact and Level 1 Users to perform their respective functions effectively.

A sponsor can have correctly appointed key personnel and still experience compliance problems if responsibilities are unclear, information does not reach the sponsorship team, SMS access is poorly controlled or important decisions are made without appropriate oversight.

Key personnel should therefore form part of a wider sponsor licence governance framework.

1. Define ownership of sponsorship responsibilities

Employers should identify who is responsible for the different activities involved in operating the sponsor licence.

This should include responsibility for:

 

• senior oversight of the sponsor licence;
• communications with UKVI;
• day-to-day SMS administration;
• Certificate of Sponsorship requests and assignments;
• checking that proposed sponsored roles meet the relevant requirements;
• identifying reportable organisational changes;
• identifying reportable changes relating to sponsored workers;
• maintaining sponsorship records;
• monitoring relevant worker information;
• managing key personnel changes;
• managing SMS-user access;
• escalating potential compliance breaches; and
• responding to Home Office enquiries or compliance activity.

 

Responsibility for these functions does not necessarily have to sit with one person or team. The important point is that the organisation knows who owns each process and how information moves between the people involved.

2. Distinguish system permission from organisational authority

One of the most important governance distinctions is between what an SMS user is technically able to do and what the organisation has authorised them to do.

A Level 1 User may have system permission to perform a particular function, but the employer can require internal approval before that function is exercised.

For example, an organisation might require:

 

• recruitment approval before a Certificate of Sponsorship is assigned;
• salary verification before sponsored employment details are confirmed;
• HR approval before certain worker changes are reported;
• legal review where the reporting position is uncertain;
• senior management approval for significant corporate changes; or
• Authorising Officer escalation where a potential compliance breach is identified.

 

This allows employers to retain appropriate control without preventing Level 1 Users from performing the practical SMS functions required to administer the licence.

3. Apply least necessary SMS access

SMS access should be limited to individuals who genuinely need it.

Employers should avoid giving Level 1 access to every employee who has some involvement with international recruitment or sponsored workers.

Instead, access should reflect an identifiable operational requirement.

For each SMS user, the organisation should be able to answer:

 

• Why does this person need SMS access?
• Which sponsorship functions do they perform?
• How frequently do they use the system?
• Do they remain eligible for their role?
• Have they received appropriate training?
• Do they understand the limits of their authority?
• Does the organisation still need them to retain access?

 

This approach can reduce unnecessary system exposure while retaining sufficient Level 1 User coverage for effective administration and continuity.

4. Maintain a key personnel and SMS-user register

As a practical governance measure, employers should consider maintaining a central record of their key personnel and SMS users.

This can provide a clear internal picture of who currently holds responsibility for the sponsor licence.

The record could include:

 

• the individual’s full name;
• their job title and department;
• whether they are internal personnel or an external representative;
• their key personnel role or roles;
• their SMS-user level;
• the reason SMS access is required;
• the date they were appointed;
• the date eligibility was last reviewed;
• the date SMS access was last reviewed;
• relevant training dates;
• any planned departure or role change; and
• the date access or appointment was removed.

 

This record should complement the information held within the SMS rather than replace the sponsor’s obligation to keep Home Office records current.

5. Integrate key personnel with HR processes

Key personnel management should be connected to normal HR procedures.

A common risk arises where HR knows that an employee is leaving or changing role but nobody considers whether that employee is also an Authorising Officer, Key Contact or SMS user.

Employers should therefore build sponsorship checks into:

 

• employee resignation procedures;
• termination processes;
• internal transfers;
• promotions and changes in responsibility;
• long-term absence procedures;
• international relocations;
• IT access changes; and
• employee offboarding.

 

Where the affected employee holds a sponsor management role, the relevant HR process should alert the sponsorship team before the change takes effect wherever possible.

6. Manage leavers before they leave

Planned departures provide an opportunity to manage key personnel changes in an orderly way.

Before a key person or SMS user leaves, the sponsor should consider:

 

• whether a replacement is required;
• whether the replacement satisfies the applicable eligibility requirements;
• whether Home Office records need to be updated;
• whether SMS access needs to be created, amended or removed;
• whether a handover is required;
• whether outstanding sponsorship actions need to be completed;
• whether responsibility for UKVI communications needs to change; and
• whether the departure affects the organisation’s wider sponsorship governance.

 

Particular attention should be given where the departing individual is the only Level 1 User or holds several key personnel roles simultaneously.

7. Control SMS authentication and account security

SMS-user security should form part of the organisation’s wider access-control arrangements.

Each SMS user should operate through their own authorised account. Credentials should not be shared between employees, between departments or with external advisers.

Mandatory multi-factor authentication is being introduced across the SMS on a phased basis from 3 September 2026, with the Home Office expecting the rollout to cover all sponsors by November 2026. Employers should ensure that users’ personal and contact information remains accurate and that users can complete the applicable authentication process.

Organisations should also have procedures for responding where:

 

• a user changes their contact details;
• a user cannot access their account;
• an account is no longer required;
• an employee leaves;
• an external representative’s engagement ends; or
• there is concern that SMS access or credentials may have been compromised.

 

8. Manage inactive SMS users

Inactive accounts should not remain indefinitely without review.

Current Home Office guidance places increased emphasis on keeping SMS-user details current and managing accounts that are no longer actively used.

The Home Office recommends that a Level 1 User accesses the SMS at least once a month.

Employers should incorporate this into a wider active-management process rather than treating periodic login as an end in itself.

A periodic review should consider:

 

• whether the individual still needs access;
• whether they remain eligible;
• whether their contact information is current;
• whether their role within the organisation has changed;
• whether they remain sufficiently trained;
• whether they are actually performing sponsorship functions; and
• whether the account should instead be removed.

 

9. Integrate sponsorship with wider business functions

Key personnel cannot manage the sponsor licence effectively if relevant information remains elsewhere in the organisation.

Sponsorship can be affected by decisions made by:

 

• recruitment;
• HR;
• payroll;
• line management;
• finance;
• legal and compliance teams;
• corporate secretarial teams;
• senior management; and
• teams responsible for mergers, acquisitions or restructuring.

 

Employers should establish information flows so that matters potentially affecting sponsorship reach the appropriate key personnel.

For example, payroll may identify a salary change, HR may process a change in job role, management may approve a new work location or the corporate team may begin a restructuring exercise. Depending on the circumstances, these developments may have sponsorship implications.

The key personnel structure therefore needs to be connected with the organisation’s wider operating processes.

10. Establish escalation procedures

Key personnel should know which matters can be handled routinely and which require escalation.

Events that may justify immediate or senior review can include:

 

• suspected illegal working;
• a potential breach of sponsor duties;
• uncertainty about whether an event is reportable;
• significant changes to a sponsored worker’s employment;
• changes in salary, duties or work location that may affect sponsorship;
• corporate restructuring;
• mergers, acquisitions or changes of ownership;
• receipt of significant Home Office correspondence;
• notification of a Home Office compliance visit;
• suspected misuse of the SMS;
• discovery that inaccurate information may have been provided to the Home Office;
• loss of the organisation’s only Level 1 User; or
• concerns about whether a member of key personnel remains eligible.

 

The escalation route should identify who needs to be informed and who has authority to determine the organisation’s response.

11. Periodically review key personnel governance

Sponsor management arrangements should be reviewed periodically and when material organisational changes occur.

A governance review can consider:

 

• whether the Authorising Officer remains appropriate and eligible;
• whether the Key Contact’s details remain accurate;
• whether the organisation has sufficient eligible Level 1 User coverage;
• whether any unnecessary SMS users remain active;
• whether existing Level 2 Users have been addressed under the transitional arrangements;
• whether SMS users remain trained and active;
• whether multi-factor authentication arrangements are functioning;
• whether responsibilities remain clearly documented;
• whether sponsorship information flows operate effectively;
• whether escalation arrangements remain appropriate; and
• whether business changes have affected the existing structure.

 

Reviews may be particularly useful following significant recruitment growth, restructuring, acquisitions, changes in senior management or expansion of the organisation’s sponsored workforce.

12. Test governance before the Home Office does

A useful approach is to consider whether the organisation could explain its sponsor management arrangements clearly if the Home Office examined them today.

The sponsor should be capable of answering questions such as:

 

• Who is the Authorising Officer and what oversight do they exercise?
• Who is the Key Contact and how are UKVI communications handled?
• Who has Level 1 access to the SMS?
• Why does each SMS user need access?
• When was that access last reviewed?
• How are Certificate of Sponsorship decisions approved?
• How does the sponsorship team learn about changes affecting sponsored workers?
• How are significant compliance concerns escalated?
• What happens if the principal Level 1 User leaves tomorrow?
• How are SMS accounts removed when staff or advisers leave?
• How are key personnel eligibility and training reviewed?
• How does senior management obtain assurance that sponsorship controls are working?

 

If these questions cannot be answered readily, the issue may not simply be one of documentation. It can indicate that responsibility for the sponsor licence is insufficiently defined.

Effective key personnel governance should enable the organisation to demonstrate who is responsible, who has access, how decisions are controlled, how relevant information is communicated and how senior oversight is maintained.

 

 

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Section O: What Happens if Sponsor Licence Key Personnel Leave or Change Role?

 

Changes to sponsor licence key personnel are a normal part of managing a sponsor licence. Employees resign, move between roles, take long-term leave or cease to satisfy the requirements applying to their appointment.

The compliance risk arises where these changes are not identified and managed promptly.

Sponsors should therefore have procedures for identifying changes affecting the Authorising Officer, Key Contact and SMS users and determining what action is required.

Where possible, planned changes should be dealt with before the existing individual leaves or moves role. This can allow the sponsor to check the eligibility of a replacement, complete an effective handover and maintain uninterrupted access to the Sponsor Management System.

1. What happens if the Authorising Officer leaves?

If the Authorising Officer leaves the organisation or otherwise ceases to satisfy the requirements for the role, the sponsor will need to appoint an eligible replacement and update its sponsor licence records using the appropriate Home Office process.

Before the existing Authorising Officer leaves, the organisation should consider:

 

• who will become the replacement Authorising Officer;
• whether the proposed replacement satisfies the applicable eligibility and suitability requirements;
• whether the replacement has sufficient seniority and authority;
• whether an effective handover is required;
• whether the outgoing Authorising Officer also holds another key personnel role;
• whether the outgoing individual has SMS access; and
• whether any wider changes to sponsorship governance are required.

 

Where the Authorising Officer is also the Key Contact or a Level 1 User, the departure can affect several elements of the sponsor management structure simultaneously.

The employer should therefore review all roles held by the individual rather than simply replacing them as Authorising Officer.

2. What happens if the Key Contact leaves?

If the Key Contact leaves or ceases to perform the role, an eligible replacement should be appointed and the sponsor’s records updated through the appropriate Home Office process.

The organisation should also consider the practical communication handover.

This can include:

 

• identifying outstanding Home Office correspondence;
• checking whether any responses are due;
• ensuring relevant communications have been retained;
• updating internal contact arrangements;
• ensuring the replacement knows how matters are escalated; and
• reviewing any SMS access held by the outgoing Key Contact.

 

If an external immigration adviser acts as Key Contact and the organisation changes adviser, the sponsor should similarly review whether the outgoing representative needs to be replaced as Key Contact and whether any SMS access held by that representative should be removed.

3. What happens if a Level 1 User leaves?

The departure of a Level 1 User requires an immediate review of the sponsor’s remaining SMS access.

If other eligible Level 1 Users remain, the organisation may still have sufficient operational access. The outgoing user’s account should nevertheless be reviewed and removed or amended as appropriate.

If the departing employee is the organisation’s only Level 1 User, the position is more serious because the sponsor may lose its ability to administer the licence through the SMS.

Where the departure is planned, the employer should wherever possible identify and appoint an eligible replacement before the existing Level 1 User leaves.

This allows time for:

 

• eligibility checks;
• appropriate SMS access to be established;
• multi-factor authentication arrangements to be completed;
• training;
• handover of outstanding sponsorship matters;
• review of upcoming Certificate of Sponsorship requirements; and
• transfer of relevant internal responsibilities.

 

4. What if the sponsor has already lost its only Level 1 User?

If the organisation has already lost its only Level 1 User and nobody remains able to access the SMS, the sponsor cannot simply log into the former user’s account or share that person’s credentials.

Instead, the sponsor will need to use the appropriate Home Office procedure to obtain access for an eligible replacement.

This can involve using the relevant change of circumstances form to request the addition of a new Level 1 User where there is no existing Level 1 User able to make the change through the SMS.

The replacement should satisfy the applicable Level 1 User requirements, including the rules governing the sponsor’s required internal Level 1 User arrangements.

This scenario demonstrates why employers should consider Level 1 User continuity before a problem arises.

5. What if key personnel change role internally?

An employee does not have to leave the organisation for their key personnel appointment to require review.

An internal transfer, promotion, change in responsibilities or relocation may affect whether the individual remains appropriate or eligible for the role.

For example, an employee may:

 

• move out of HR or global mobility;
• cease to have responsibility for sponsorship;
• move to another group company;
• relocate outside the UK;
• move into a role where SMS access is no longer required;
• lose the senior authority that previously made them appropriate as Authorising Officer; or
• otherwise experience a change affecting the requirements for their appointment.

 

Internal role changes should therefore trigger consideration of both formal Home Office requirements and practical suitability.

6. What about temporary absence?

A short period of annual leave or ordinary temporary absence does not necessarily mean that a member of key personnel has to be replaced.

The organisation should, however, consider whether sufficient cover exists to manage sponsorship while the individual is unavailable.

This is particularly important where the absent person is:

 

• the only Level 1 User;
• the principal person dealing with UKVI correspondence;
• the only employee with detailed knowledge of sponsorship administration; or
• simultaneously the Authorising Officer, Key Contact and Level 1 User.

 

Long-term absence may justify a more detailed review of whether the existing arrangements remain effective.

7. Personnel changes should trigger an SMS-access review

Whenever key personnel leave or change responsibilities, the sponsor should consider their SMS access separately.

The fact that someone no longer holds a particular organisational role does not necessarily remove their SMS account automatically.

The employer should therefore check:

 

• whether the individual has SMS access;
• whether that access is still required;
• whether the account should be amended or removed;
• whether the individual holds more than one sponsor management role;
• whether another user needs to be appointed;
• whether sufficient Level 1 coverage remains; and
• whether any external representative access is affected.

 

This review should also extend to IT and information-security arrangements where appropriate.

8. Build sponsor roles into employee offboarding

A practical way to reduce risk is to include sponsor licence responsibilities within the organisation’s normal leaver process.

Before an employee leaves, HR can ask whether the individual is:

 

• the Authorising Officer;
• the Key Contact;
• a Level 1 User;
• an existing transitional Level 2 User;
• responsible for Certificate of Sponsorship administration;
• responsible for sponsored worker reporting; or
• responsible for retaining sponsorship records.

 

If the answer to any of these questions is yes, the sponsorship team can be notified before the employee’s departure date.

This allows replacement, access removal and handover arrangements to be managed alongside the normal offboarding process.

9. Do not assume the general reporting timeframe applies to every key personnel change

Sponsors should follow the specific Home Office procedure and timeframe applying to the particular change.

The sponsor guidance contains a general requirement to report specified organisational changes within the applicable reporting period, but the provisions dealing with replacement of the Authorising Officer and Key Contact need to be considered separately rather than assuming that the general reporting rule automatically applies in exactly the same way.

Employers should therefore check the current Home Office procedure when replacing key personnel, particularly where access to the SMS has been lost or the organisation needs to use an alternative change of circumstances process.

10. Maintain continuity throughout personnel changes

The practical objective when key personnel change is to ensure that the sponsor continues to have:

 

• senior accountability through an eligible Authorising Officer;
• a functioning communication channel through the Key Contact;
• appropriate operational access through eligible Level 1 Users;
• controlled and current SMS-user accounts;
• effective transfer of sponsorship knowledge; and
• clear responsibility for outstanding sponsorship matters.

 

Personnel changes are therefore not simply an SMS administration issue. They should be managed as part of the organisation’s wider sponsor licence governance and business continuity arrangements.

Detailed guidance on the procedure for replacing or updating sponsor management roles is provided in our guide to How to Change Sponsor Licence Key Personnel.

 

 

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Section P: Key Personnel Mistakes That Put Sponsor Licences at Risk

 

Many sponsor licence key personnel problems arise not because an employer has deliberately ignored the sponsorship rules, but because responsibility becomes unclear, personnel changes are not communicated or SMS access is allowed to develop without adequate control.

Employers should therefore consider both the formal Home Office requirements and the practical weaknesses that can develop within their sponsor management arrangements.

Common key personnel mistakes include the following.

1. Appointing an Authorising Officer in name only

The Authorising Officer should provide meaningful senior oversight of the organisation’s sponsorship arrangements.

A weak structure can arise where a senior executive is nominated simply because they appear suitable for the application but has little understanding of the sponsor licence after it has been granted.

The Authorising Officer does not need to perform routine SMS administration, but they should understand the significance of the licence, know who is responsible for its day-to-day management and be capable of exercising oversight where sponsorship or compliance issues arise.

2. Depending entirely on one Level 1 User

Maintaining only one Level 1 User may be sufficient for some organisations, but it can create a significant operational dependency.

If that individual leaves unexpectedly, becomes unavailable or loses access to the SMS, the sponsor may temporarily lose its ability to administer the licence.

Employers should consider whether their level of sponsorship activity justifies maintaining an appropriately trained backup Level 1 User.

This is a resilience measure rather than a universal requirement to appoint multiple Level 1 Users.

3. Giving too many people Level 1 access

The opposite problem arises where SMS access is granted too widely.

Employees should not automatically become Level 1 Users simply because they work in HR, recruitment or global mobility.

Each additional Level 1 User increases the number of people able to perform significant sponsor management functions.

Employers should therefore be able to explain why each individual requires SMS access and should remove access where the operational need no longer exists.

4. Failing to remove access when somebody leaves

SMS access should form part of the organisation’s employee and adviser offboarding procedures.

Where an SMS user leaves the organisation, changes role or an external adviser’s engagement ends, the sponsor should consider immediately whether that person’s system access needs to be removed or amended.

Historic accounts should not simply remain active because nobody remembered that the individual had SMS access.

5. Assuming the Authorising Officer or Key Contact automatically has SMS access

Appointment as Authorising Officer or Key Contact does not automatically make the individual an SMS user.

If either person needs to carry out SMS functions, they must also hold an appropriate SMS-user role and satisfy the requirements applying to that appointment.

Employers should therefore avoid designing procedures that assume the Authorising Officer or Key Contact can access the system unless their actual SMS permissions have been confirmed.

6. Sharing SMS credentials

SMS accounts are individual accounts and should not be treated as shared organisational logins.

Employers should not allow:

 

• several HR employees to use the same SMS account;
• one employee to give their login credentials to another;
• an external adviser to use an employee’s account;
• multiple employees of an external adviser to share one authorised account; or
• former employees to retain access credentials.

 

Mandatory multi-factor authentication reinforces the requirement for SMS access to be associated with the individual authorised user.

7. Ignoring inactive SMS users

Employers should not assume that an SMS account can remain indefinitely simply because the individual has not formally left the organisation.

Current Home Office guidance places increased emphasis on maintaining accurate SMS-user information and managing inactive accounts.

The Home Office recommends that a Level 1 User accesses the SMS at least once a month.

If a user has stopped accessing the system because they no longer undertake sponsorship work, the sponsor should consider whether they still need an account.

Periodic access reviews should identify inactive users, confirm continuing eligibility and remove access that is no longer required.

8. Failing to maintain accurate user details for multi-factor authentication

Mandatory multi-factor authentication means SMS users need accurate personal and contact information associated with their accounts.

Employers should ensure changes affecting relevant contact details are addressed and should not wait until urgent SMS access is required before discovering that a user’s authentication arrangements no longer work.

Authentication and SMS-user information should therefore form part of routine sponsor management rather than being treated purely as an IT issue.

9. Failing to review continuing eligibility

Eligibility should not be checked only when the sponsor licence application is submitted.

Key personnel circumstances can change.

An individual may:

 

• leave the organisation;
• move to another group company;
• change their employment relationship;
• relocate outside the UK;
• cease to satisfy a relevant immigration or settlement requirement;
• become subject to a relevant suitability issue; or
• otherwise cease to satisfy the requirements for their role.

 

Employers should therefore reconsider eligibility when relevant changes occur.

10. Allowing Key Contact information to become stale

The Key Contact exists to provide an effective communication channel between the sponsor and UKVI.

That function is undermined if the named individual has left, changed responsibilities or no longer monitors the relevant communications.

Employers should ensure Key Contact information remains current and that Home Office correspondence can reach someone capable of escalating it appropriately.

11. Over-relying on an external immigration adviser

External advisers can provide valuable specialist support, but the sponsor cannot transfer responsibility for its licence to an adviser.

The Authorising Officer must ordinarily remain an appropriate internal person, and the sponsor must maintain the required internal Level 1 User arrangements.

An adviser may potentially act as Key Contact or as an additional Level 1 User where the relevant requirements are satisfied, but this should support rather than replace internal sponsor governance.

Employers should retain sufficient internal knowledge to understand how their licence is being used and what information their advisers require.

12. Failing to integrate sponsorship with HR and business processes

Key personnel cannot manage matters they do not know about.

Problems can arise where recruitment, HR, payroll or management make changes affecting sponsored workers without informing those responsible for the sponsor licence.

Relevant information can include changes to:

 

• job duties;
• salary;
• working hours;
• work location;
• employment status;
• absence;
• termination of employment; or
• the structure or ownership of the organisation.

 

Sponsor governance should therefore include clear information flows between the sponsorship team and other relevant business functions.

13. Failing to train key personnel and SMS users

Appointment to a key personnel role does not mean the individual automatically understands the sponsorship regime.

Training should reflect the person’s responsibilities.

The Authorising Officer may require sufficient knowledge to provide effective oversight, while Level 1 Users are likely to need more detailed training on SMS administration, reporting, Certificate of Sponsorship processes, access security and internal approval procedures.

Training should also be refreshed where Home Office requirements or the organisation’s own sponsorship arrangements materially change.

14. Missing the Level 2 User transition

Employers with historic Level 2 Users need to take specific action following the withdrawal of the role.

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 they are eligible and genuinely require that access; or
• deactivated.

 

This should be completed by 8 March 2027. Remaining Level 2 accounts will be deactivated by the Home Office after the transitional period.

Employers should not automatically convert every Level 2 User into a Level 1 User. The transition provides an opportunity to determine whether each individual still requires SMS access.

15. Failing to distinguish system permission from decision-making authority

A Level 1 User may technically be able to perform an action through the SMS without having organisational authority to make the underlying decision.

Employers should establish internal approval processes where appropriate.

For example, the organisation may require approval before:

 

• a Certificate of Sponsorship is assigned;
• a significant worker change is reported;
• certain sponsor details are amended;
• a new SMS user is added; or
• a complex compliance issue is reported to the Home Office.

 

This reduces the risk of important sponsorship decisions being made solely because an individual has the technical system permission to implement them.

16. Failing to maintain clear responsibility

Where several employees are involved in sponsorship, responsibility can become fragmented.

HR may assume the immigration adviser is responsible. The immigration adviser may assume HR has verified the factual information. Recruitment may assume the Level 1 User has checked the role. The Level 1 User may assume senior management has approved the sponsorship decision.

Employers should define who is responsible for each stage of the sponsorship process and where responsibility transfers between teams.

Clear ownership is particularly important for activities such as Certificate of Sponsorship assignment, worker reporting, record keeping, right to work processes and escalation of potential compliance breaches.

17. Treating key personnel as an application-stage requirement

One of the most fundamental mistakes is treating key personnel as names that are required only to obtain the sponsor licence.

The roles continue throughout the life of the licence.

The organisation therefore needs to maintain:

 

• an eligible Authorising Officer;
• an effective Key Contact;
• appropriate eligible Level 1 User arrangements;
• accurate SMS-user information;
• controlled system access;
• appropriate continuity arrangements; and
• effective sponsorship governance.

 

18. The practical key personnel risk test

A useful way to test the organisation’s arrangements is to ask whether it can answer four questions immediately:

 

1. Who owns senior responsibility for the sponsor licence?
2. Who receives and manages UKVI communications?
3. Who can access the SMS and why?
4. What happens if any of those people become unavailable tomorrow?

 

If the answers are unclear, outdated or dependent entirely on one individual, the sponsor should review its key personnel arrangements.

The objective is not simply to have the correct names recorded with the Home Office. It is to maintain an active governance structure capable of managing the sponsor licence effectively throughout its duration.

 

 

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Section Q: Employer Sponsor Licence Key Personnel Checklist

 

Employers should review their sponsor licence key personnel periodically rather than waiting for a Home Office compliance visit or a personnel problem to expose weaknesses in their arrangements.

The following checklist can be used as a practical review of the organisation’s Authorising Officer, Key Contact, Level 1 Users, SMS access and wider governance controls.

1. Authorising Officer

 

• Is an eligible Authorising Officer currently appointed?
• Is the individual ordinarily a paid member of staff or office holder of the sponsor, unless a specific permitted exception applies?
• Does the individual continue to satisfy the applicable eligibility and suitability requirements?
• Is the Authorising Officer appropriately based in the UK under the applicable requirements?
• Does the individual have sufficient seniority and authority within the organisation?
• Do they understand their responsibility for oversight of the sponsor licence?
• Do they know who manages day-to-day sponsorship activity?
• Are significant sponsorship and compliance issues escalated to them?
• If they also need SMS access, have they been separately appointed to an appropriate SMS-user role?
• Is there a process for replacing the Authorising Officer if they leave or cease to be eligible?

 

2. Key Contact

 

• Is an eligible Key Contact currently appointed?
• Are the Key Contact’s details accurate and current?
• Does the individual continue to satisfy the applicable requirements?
• Is the individual capable of acting as an effective communication point between the sponsor and UKVI?
• Are Home Office communications monitored appropriately?
• Is there a clear process for escalating important communications?
• If an external representative acts as Key Contact, are communications passed effectively to the organisation?
• If the Key Contact also needs SMS access, have they been separately appointed to the appropriate SMS-user role?
• Is there adequate communication cover if the Key Contact is unavailable?

 

3. Level 1 Users

 

• Does the organisation have at least one eligible Level 1 User?
• Does it maintain the required internal Level 1 User arrangement?
• Do the organisation’s Level 1 User arrangements satisfy the applicable requirements concerning relationship with the sponsor and settled-worker status, including the transitional rules for continuously licensed pre-1 January 2025 sponsors?
• If the sponsor has only one Level 1 User, have you confirmed that this person is not an external representative acting in place of the required internal user?
• Does each Level 1 User genuinely need SMS access?
• Does each user understand the SMS functions they are authorised to perform?
• Have Level 1 Users received appropriate training?
• Is there excessive dependency on a single Level 1 User?
• Would additional Level 1 coverage improve operational resilience?
• Conversely, are there Level 1 Users who no longer need access?
• Does the organisation retain effective access if its principal Level 1 User is absent?

 

4. Existing Level 2 Users

Employers should identify whether any existing Level 2 Users remain on the licence following the September 2026 changes.

 

• Have all existing Level 2 User accounts been identified?
• Has the organisation confirmed that no new Level 2 Users are being appointed?
• Does each existing Level 2 User still require SMS access?
• If continued access is required, is the individual eligible and suitable to become a Level 1 User, including confirming that they are not a worker supplied by an employment business?
• If Level 1 access is unnecessary, has the organisation planned to deactivate the Level 2 account?
• Is action scheduled to be completed by 8 March 2027?

 

The transition should not be used simply to convert every historic Level 2 User into a Level 1 User. Employers should use it as an opportunity to review whether the individual requires SMS access at all.

5. Key personnel eligibility and suitability

For every member of key personnel, consider whether the individual continues to satisfy the requirements applying to their role.

 

• Is their relationship with the sponsor appropriate for the role?
• Are they appropriately based in the UK where required?
• Do they satisfy any applicable immigration or settled-worker requirements?
• Are the necessary personal details available and accurate?
• Have any relevant circumstances changed since appointment?
• Are there any sponsorship or immigration compliance issues that require consideration?
• Are there any relevant unspent criminal convictions or other suitability concerns within the scope of the current sponsor guidance?
• Are there any applicable bankruptcy restriction orders or undertakings?
• Are there any applicable debt relief restriction orders or undertakings?
• If the individual is a contractor, consultant or representative, does the proposed appointment comply with the specific rules applying to that relationship?

 

Employers should check the current Home Office sponsor guidance when assessing eligibility rather than relying solely on the position that applied when the person was first appointed.

6. SMS access and security

 

• Do you know every individual who currently has SMS access?
• Can you explain why each user requires access?
• Does each user operate their own individual account?
• Are shared SMS credentials prohibited?
• Are current multi-factor authentication requirements being followed?
• Are users’ personal and contact details accurate?
• Are inactive accounts identified and reviewed?
• Does a Level 1 User access the SMS regularly, taking account of the Home Office recommendation that a Level 1 User should access the system at least once a month?
• Is access removed when employees or external advisers no longer require it?
• Is SMS access included within the organisation’s wider IT and information-security controls?

 

7. Role allocation and internal authority

Employers should be able to distinguish clearly between Home Office system permissions and internal organisational authority.

 

• Who has senior responsibility for the sponsor licence?
• Who manages communications with UKVI?
• Who performs day-to-day SMS administration?
• Who can approve the sponsorship of a worker?
• Who approves Certificate of Sponsorship assignment?
• Who checks the factual information used for sponsorship?
• Who identifies reportable changes?
• Who decides how complex or uncertain matters should be reported?
• Who reviews significant compliance concerns?
• Which matters require escalation to the Authorising Officer or senior management?

 

These responsibilities should be understood by the relevant teams rather than existing only within a policy document.

8. HR and business integration

 

• Does HR know who the sponsor licence key personnel are?
• Does recruitment know when the sponsorship team needs to be involved?
• Does payroll understand which changes may need to be communicated to the sponsorship team?
• Do line managers know how to escalate changes affecting sponsored workers?
• Are key personnel informed about relevant changes to duties, salary, hours or work location?
• Are they informed when sponsored employment ends?
• Are they notified about significant organisational or corporate changes?
• Are sponsorship considerations built into relevant recruitment and HR procedures?

 

The effectiveness of key personnel depends heavily on whether relevant information reaches them.

9. Leavers and internal transfers

 

• Does the leaver process identify whether an employee is key personnel or an SMS user?
• Is the sponsorship team notified before a relevant employee leaves where possible?
• Are replacement requirements considered before departure?
• Is an appropriate handover completed?
• Is SMS access removed where required?
• Are outstanding sponsorship matters transferred to another responsible person?
• Do internal transfers trigger a review of whether key personnel appointments remain appropriate?
• Are international relocations considered where they may affect eligibility?
• Are external adviser appointments and SMS accounts reviewed when professional advisers change?

 

10. Continuity planning

The sponsor should consider what would happen if a key person became unavailable without warning.

 

• What happens if the Authorising Officer leaves tomorrow?
• Who manages UKVI communications if the Key Contact is unavailable?
• What happens if the principal Level 1 User cannot access the SMS?
• Is there another eligible person who can provide operational cover?
• Is important sponsorship knowledge documented?
• Are outstanding cases and deadlines visible to more than one appropriate person?
• Would one employee’s departure remove several key personnel roles simultaneously?
• Does the organisation know how to use the appropriate Home Office process if it loses its only Level 1 User and nobody can access the SMS?

 

Continuity planning should be proportionate to the organisation’s sponsorship activity, but the sponsor should avoid unnecessary single-person dependency.

11. Training and knowledge

 

• Do key personnel understand the purpose of their respective roles?
• Does the Authorising Officer understand the organisation’s principal sponsorship risks?
• Does the Key Contact know how Home Office communications are handled and escalated?
• Are Level 1 Users trained in the SMS functions they perform?
• Do SMS users understand the organisation’s internal approval requirements?
• Do relevant employees understand when specialist immigration advice should be obtained?
• Is training refreshed when responsibilities or Home Office requirements change?

 

12. Periodic key personnel review

Employers should not treat this checklist as a one-off exercise.

Key personnel arrangements should be reviewed periodically and following trigger events such as:

 

• departure of a member of key personnel;
• significant internal restructuring;
• changes in senior management;
• rapid growth in sponsored recruitment;
• mergers or acquisitions;
• changes to the organisation’s immigration adviser;
• significant changes to Home Office sponsor guidance;
• identification of a sponsorship compliance problem;
• preparation for a Home Office compliance visit; or
• an internal sponsor licence audit.

 

13. Final key personnel audit question

At the end of the review, employers should ask one overarching question:

If the Home Office reviewed our sponsor licence today, could we clearly explain who is responsible for sponsorship, demonstrate that those individuals are eligible, show who has SMS access and evidence the controls we use to manage the licence?

If the answer is uncertain, the organisation should review its key personnel structure before a Home Office compliance issue exposes the weakness.

 

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Section R: How DavidsonMorris Supports Sponsor Licence Management

 

Effective sponsor licence management requires more than appointing an Authorising Officer, Key Contact and Level 1 User. Employers need to ensure that the individuals holding these roles remain eligible, understand their responsibilities and operate within a governance structure capable of meeting the organisation’s ongoing sponsor duties.

DavidsonMorris advises employers on the full lifecycle of sponsor licence management, from establishing the initial key personnel structure through to reviewing existing arrangements, managing personnel changes and responding to compliance concerns.

1. Key personnel eligibility reviews

We can review proposed or existing sponsor licence key personnel to assess whether appointments satisfy the relevant Home Office requirements.

This can include reviewing:

 

• the proposed Authorising Officer;
• the proposed Key Contact;
• Level 1 User arrangements;
• the use of external representatives;
• the relationship between proposed personnel and the sponsoring organisation;
• UK-based requirements;
• applicable immigration or settled-worker requirements;
• relevant suitability considerations; and
• whether particular individuals should have SMS access.

 

Where one individual is intended to hold several roles, we can also consider whether the proposed structure provides sufficient operational resilience and appropriate separation between senior oversight and day-to-day administration.

2. Structuring the Authorising Officer, Key Contact and Level 1 User roles

Employers frequently need to decide not only who is technically eligible for appointment, but how the roles should be allocated within the organisation.

We can advise on a structure that reflects the employer’s:

 

• size;
• management structure;
• HR and recruitment functions;
• volume of sponsored recruitment;
• number of sponsored workers;
• use of external immigration support;
• SMS administration requirements; and
• business continuity needs.

 

This can include considering whether the same individual should hold multiple roles, whether additional Level 1 Users are appropriate and how external immigration advisers should fit within the sponsor management structure.

3. Reviewing Level 1 User and SMS access

SMS access can become difficult to control where users accumulate over time or employees change responsibilities without their sponsor management permissions being reviewed.

We can assist employers with reviewing:

 

• current Level 1 Users;
• the eligibility of existing users;
• whether each user continues to require access;
• whether the organisation has sufficient internal Level 1 User capability;
• whether there is excessive dependence on one user;
• whether unnecessary or inactive accounts remain;
• external representative access;
• SMS-user governance and approval processes; and
• procedures for removing access when users leave.

 

The objective is to maintain sufficient access for effective sponsor administration while avoiding unnecessary SMS permissions.

4. Level 2 User transition support

The withdrawal of the Level 2 User role requires sponsors with existing Level 2 Users to review their current SMS-user arrangements.

We can assist employers in identifying existing Level 2 Users and determining whether each individual should:

 

• be upgraded to Level 1 User status, where eligible and operationally necessary; or
• have their access deactivated.

 

No new Level 2 Users can be appointed from 9 September 2026, and sponsors should address existing Level 2 accounts by 8 March 2027.

The transition also provides an opportunity to conduct a wider review of SMS access rather than automatically converting historic Level 2 Users into Level 1 Users.

5. Support when key personnel leave or change role

Changes involving the Authorising Officer, Key Contact or Level 1 Users can require prompt action.

We can advise on the steps required where:

 

• the Authorising Officer is leaving;
• the Key Contact needs to be replaced;
• a Level 1 User leaves the organisation;
• the sponsor loses its only Level 1 User;
• an employee changes role internally;
• a key person relocates overseas;
• an external representative is being replaced;
• SMS access needs to be removed or amended; or
• there is uncertainty about the correct Home Office procedure.

 

Where possible, planned changes should be managed before the outgoing individual leaves to protect continuity of SMS access and sponsorship administration.

6. Sponsor licence governance procedures

We can work with employers to develop or review internal procedures governing how the sponsor licence is managed.

This can include controls relating to:

 

• key personnel responsibilities;
• SMS-user access;
• Certificate of Sponsorship approvals;
• internal reporting and escalation;
• changes affecting sponsored workers;
• corporate changes;
• HR and sponsorship information flows;
• key personnel leavers;
• SMS-user offboarding;
• business continuity; and
• periodic sponsor management reviews.

 

These procedures can help distinguish who has technical SMS permission from who has organisational authority to approve sponsorship decisions.

7. Key personnel and sponsor compliance training

Training can be tailored to the responsibilities of different personnel rather than applying the same level of detail to everybody involved in sponsorship.

For example, training can address:

 

• Authorising Officer oversight responsibilities;
• Key Contact responsibilities;
• Level 1 User functions;
• SMS security and account management;
• Certificate of Sponsorship controls;
• sponsor reporting duties;
• record-keeping requirements;
• changes affecting sponsored workers;
• internal escalation procedures; and
• preparation for Home Office compliance activity.

 

Training can also extend beyond formal key personnel to HR, recruitment, payroll, line managers and other teams whose actions may affect sponsor compliance.

8. Sponsor licence compliance audits

A sponsor licence audit can test whether the organisation’s key personnel arrangements operate effectively in practice.

An audit can consider matters such as:

 

• whether current key personnel remain eligible;
• whether Home Office records are accurate;
• whether SMS access is appropriately controlled;
• whether users remain active and appropriately trained;
• whether sponsored worker records are complete;
• whether reportable events have been identified and handled correctly;
• whether Certificate of Sponsorship processes are controlled;
• whether HR systems support the sponsor’s duties;
• whether internal escalation procedures operate effectively; and
• whether weaknesses require remedial action.

 

This can allow compliance weaknesses to be identified before they become an issue during Home Office scrutiny.

9. Home Office compliance visits and investigations

Key personnel may play an important role if the Home Office conducts a compliance visit or raises concerns about the sponsor’s arrangements.

DavidsonMorris can support employers with:

 

• preparing for a compliance visit;
• reviewing sponsor records and systems;
• preparing key personnel and relevant employees;
• identifying and addressing compliance weaknesses;
• responding to Home Office enquiries;
• managing remedial action; and
• advising where the sponsor licence is at risk of enforcement action.

 

10. Key personnel as part of wider sponsor management

Key personnel should not be considered in isolation from the employer’s wider sponsorship arrangements.

The Authorising Officer, Key Contact and Level 1 Users sit within a broader compliance framework involving recruitment, right to work, Certificates of Sponsorship, sponsored worker management, record keeping, reporting and organisational change.

DavidsonMorris works with employers to align these different elements so that responsibility for sponsorship is clear and the organisation can demonstrate effective control of its licence.

If you are applying for a sponsor licence, reviewing existing key personnel arrangements or dealing with a change affecting your Authorising Officer, Key Contact or Level 1 Users, contact DavidsonMorris for advice on the applicable Home Office requirements and the practical steps needed to maintain compliant sponsor management arrangements.

 

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Section S: Sponsor Licence Key Personnel FAQs

 

Do sponsor licence key personnel have to be British citizens?

No. Sponsor licence key personnel do not generally have to be British citizens.

However, the individual must satisfy the specific eligibility requirements applying to their role. These can include requirements relating to their relationship with the sponsoring organisation, where they are based, their immigration status or settled-worker status and their suitability.

Level 1 User arrangements require particular attention because the sponsor must maintain the required internal Level 1 User who satisfies the applicable Home Office requirements.

Employers should therefore assess eligibility by reference to the particular role rather than assuming that British citizenship is either universally required or sufficient.

Can the Authorising Officer also be a Level 1 User?

Yes. The same person can act as both Authorising Officer and Level 1 User, provided they satisfy the requirements for both roles.

The appointments remain distinct. Being the Authorising Officer does not automatically provide SMS access. The individual must also be appropriately appointed as a Level 1 User if they are to use the Sponsor Management System.

Can the same person be Authorising Officer, Key Contact and Level 1 User?

Yes. One eligible individual can potentially hold all three roles.

This can be a practical arrangement for smaller organisations, but employers should consider the resulting concentration of responsibility.

If that individual leaves or becomes unavailable, the organisation could simultaneously lose its Authorising Officer, Key Contact and principal SMS user.

The sponsor should therefore consider continuity as well as technical eligibility when combining roles.

Can an immigration solicitor be a Level 1 User?

An appropriately appointed immigration representative can potentially act as an additional Level 1 User where the relevant requirements are satisfied.

An external representative should not, however, be used to replace the sponsor’s required internal Level 1 User arrangements.

In particular, where the sponsor has only one Level 1 User, that individual cannot simply be an external representative acting instead of the required internal user.

External SMS access should therefore supplement rather than replace appropriate internal sponsor management capability.

Can a sponsor have two Authorising Officers?

No. A sponsor has one Authorising Officer at a time.

The organisation can have multiple Level 1 Users where appropriate, but the Authorising Officer provides the principal senior accountability for sponsorship.

Employers should nevertheless have continuity arrangements so that an eligible replacement can be identified if the existing Authorising Officer leaves or ceases to satisfy the requirements.

What happens if our only Level 1 User leaves?

The sponsor should ideally appoint an eligible replacement before the existing Level 1 User leaves.

If the organisation has already lost its only Level 1 User and nobody can access the SMS, it should not use the former user’s credentials.

The sponsor will instead need to use the appropriate Home Office process, including the relevant change of circumstances procedure, to request the addition of an eligible replacement Level 1 User.

This is one reason employers should consider Level 1 User continuity as part of their sponsor governance arrangements.

Can sponsors still appoint Level 2 Users?

No new Level 2 Users can be appointed from 9 September 2026.

Existing Level 2 Users remain subject to transitional arrangements. Sponsors should review those users and either upgrade them to Level 1 User status, where they are eligible and require the access, or deactivate them.

Action should be completed by 8 March 2027. Remaining Level 2 accounts will be deactivated by the Home Office after the transition.

Does the Authorising Officer automatically have access to the SMS?

No. Appointment as Authorising Officer does not automatically provide access to the Sponsor Management System.

If the Authorising Officer needs to use the SMS, they must also be appropriately appointed to an SMS-user role.

The same principle applies to the Key Contact.

How many Level 1 Users should a sponsor have?

A sponsor must maintain at least one eligible Level 1 User, but there is no single number that is appropriate for every employer.

The number should reflect the organisation’s size, sponsorship activity and need for operational resilience while avoiding unnecessary SMS access.

For some employers, a primary Level 1 User supported by an appropriately trained backup provides a practical model. Larger sponsors may require several users across their immigration, HR or global mobility functions.

Can an external HR consultant be key personnel?

It depends on the role, the individual’s relationship with the sponsor and the requirements applying to that appointment.

An external consultant cannot simply be appointed to any key personnel role because they provide HR services to the business. There are specific rules governing employees, office holders, representatives, contractors and consultants, including restrictions affecting contractors or consultants engaged for a specific project.

The Authorising Officer must ordinarily be an appropriate paid member of staff or office holder, subject to limited exceptions. An appropriately appointed representative may potentially act as Key Contact or an additional Level 1 User where the relevant requirements are satisfied.

Do sponsor licence key personnel have to be based in the UK?

Key personnel are generally expected to be based in the UK for most of the time, subject to the exceptions and specific provisions contained in the sponsor guidance.

Employers should therefore review the position where proposed or existing key personnel are permanently or substantially based overseas.

Route-specific provisions can also apply. For example, the UK Expansion Worker route contains particular arrangements relevant to overseas businesses establishing a UK presence.

What checks should employers carry out before appointing key personnel?

Employers should check both formal eligibility and practical suitability.

Formal checks can include the individual’s relationship with the sponsor, UK-based requirements, relevant immigration or settled-worker requirements and the suitability provisions in the current Home Office guidance.

Practical considerations should include whether the individual has sufficient authority, involvement, knowledge, access to relevant information and the ability to provide continuity.

For Level 1 Users, employers should also consider whether SMS access is genuinely required and whether the individual has been appropriately trained.

How often should sponsor licence key personnel be reviewed?

There is no reason to wait for a Home Office compliance visit before reviewing key personnel.

Employers should review their arrangements periodically and whenever a relevant trigger event occurs, such as:

 

• a member of key personnel leaving;
• an internal transfer or promotion;
• a significant period of absence;
• an overseas relocation;
• a change of immigration adviser;
• business restructuring;
• rapid growth in sponsored recruitment;
• a change in Home Office requirements; or
• identification of a sponsor compliance concern.

 

The review should consider eligibility, role allocation, SMS access, training, continuity and whether the organisation’s current structure still reflects how sponsorship is actually managed.

 

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Section T: Primary Home Office Sources

 

Sponsor licence key personnel requirements are primarily set out in the Home Office guidance for organisations licensed to sponsor workers.

Employers should use the current version of the relevant Home Office guidance when making or reviewing key personnel appointments. Sponsor guidance and Sponsor Management System procedures are updated periodically, and operational requirements can change even where the underlying key personnel structure remains broadly the same.

1. Workers and Temporary Workers: Guidance for Sponsors

The principal source is the Home Office Workers and Temporary Workers: Guidance for Sponsors.

The guidance is divided into a number of parts dealing with different aspects of sponsorship. The provisions concerning key personnel explain matters including:

 

• the key personnel roles a sponsor must have;
• the Authorising Officer;
• the Key Contact;
• Level 1 Users;
• the eligibility requirements applying to key personnel;
• restrictions affecting particular individuals;
• the use of representatives;
• SMS-user arrangements; and
• the sponsor’s responsibility for maintaining appropriate key personnel.

 

Employers should read the key personnel provisions alongside the wider sponsor guidance rather than treating them as standalone administrative rules.

2. Sponsor guidance on key personnel

The Home Office guidance dealing specifically with sponsor licence key personnel should be the starting point when assessing whether a proposed Authorising Officer, Key Contact or Level 1 User is eligible.

This is particularly important when considering matters such as:

 

• the individual’s relationship with the sponsor;
• whether the individual must be a paid member of staff or office holder;
• requirements concerning where the individual is based;
• immigration and settled-worker requirements;
• the appointment of representatives;
• restrictions affecting contractors and consultants;
• suitability requirements;
• National Insurance number requirements;
• role-specific exceptions; and
• the circumstances in which one person can hold several key personnel roles.

 

Employers should check the wording applying to the particular role rather than assuming that every eligibility requirement applies identically to the Authorising Officer, Key Contact and Level 1 User.

3. Sponsor Management System guidance and manuals

The Home Office publishes separate guidance and manuals covering operation of the Sponsor Management System.

These materials are particularly relevant to Level 1 Users because they explain the practical operation of the system and the functions available to different users.

Depending on the sponsor and the action being undertaken, the SMS guidance can be relevant to matters including:

 

• SMS-user administration;
• maintaining sponsor information;
• reporting changes;
• Certificate of Sponsorship administration;
• changes involving key personnel;
• user access;
• account management;
• authentication requirements; and
• other operational sponsor management functions.

 

Sponsors should ensure that Level 1 Users understand both the immigration compliance implications of their actions and the current practical procedures for carrying those actions out through the SMS.

4. Home Office guidance on sponsorship management roles

GOV.UK also provides guidance explaining the principal sponsorship management roles and who can perform them.

This can provide a useful overview of:

 

• the Authorising Officer;
• the Key Contact;
• Level 1 Users;
• the possibility of one individual holding more than one role;
• requirements affecting Level 1 Users; and
• the use of representatives.

 

Where a simplified GOV.UK overview and the detailed sponsor guidance need to be considered together, employers should check the detailed current guidance applicable to their circumstances.

5. Sponsor duties and compliance guidance

Key personnel requirements should also be read alongside the Home Office guidance dealing with sponsor duties and compliance.

This wider guidance explains the obligations that the sponsor’s governance structure ultimately needs to support, including requirements relating to:

 

• record keeping;
• reporting;
• monitoring sponsored workers;
• compliance with immigration requirements;
• co-operation with the Home Office;
• changes affecting the sponsoring organisation; and
• Home Office compliance action.

 

The Authorising Officer, Key Contact and Level 1 Users should therefore be understood within the context of the sponsor’s wider compliance responsibilities.

6. Route-specific sponsor guidance

Employers should also check whether the immigration route under which they sponsor workers contains additional or modified requirements.

This is particularly relevant where the general key personnel rules contain route-specific exceptions.

For example, the UK Expansion Worker route contains specific provisions relevant to overseas businesses establishing a UK presence, including circumstances affecting the appointment of the Authorising Officer where there is not yet a suitable person based in the UK.

Employers should not assume that an exception applying to one sponsored work route applies across the sponsor licensing system generally.

7. Check the current guidance before acting

Sponsor management requirements are not static.

The 2026 changes affecting Level 2 Users provide a clear example. From 9 September 2026, sponsors can no longer appoint new Level 2 Users, while existing Level 2 Users are subject to transitional arrangements requiring sponsors to upgrade eligible users to Level 1 where appropriate or deactivate their accounts by 8 March 2027.

Mandatory multi-factor authentication and the increased focus on inactive SMS users also illustrate why employers should not rely indefinitely on procedures developed under earlier versions of the sponsor management regime.

Before appointing or replacing key personnel, changing SMS access or responding to an unusual sponsorship issue, employers should therefore check:

 

1. the current Workers and Temporary Workers sponsor guidance;
2. the current provisions dealing with key personnel;
3. the relevant SMS guidance or manual;
4. any route-specific sponsor guidance; and
5. any current Home Office operational requirements affecting the proposed action.

 

This is particularly important where the organisation is relying on an exception to the general key personnel rules or where the sponsor has lost access to the SMS.

 

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Section U: Conclusion

 

Sponsor licence key personnel provide the organisational framework through which an employer maintains responsibility for its sponsor licence.

The three principal roles perform different but complementary functions:

 

• Authorising Officer – Accountability: senior responsibility and oversight of the organisation’s sponsorship arrangements.
• Key Contact – Communication: the principal point of contact between the sponsor and UKVI.
• Level 1 User – System Control: operational administration of the sponsor licence through the Sponsor Management System.

 

One eligible individual can potentially hold more than one of these roles, including all three. Whether that is appropriate will depend on the organisation’s size, structure, sponsorship activity and ability to maintain effective continuity if that individual becomes unavailable.

1. Eligibility is only the starting point

Employers should not select key personnel solely by asking whether an individual satisfies the minimum Home Office requirements.

Effective appointments also depend on whether the individual has the authority, involvement, knowledge and access required to perform the role properly.

The practical selection framework considered throughout this guide can be summarised as:

Authority → Involvement → Knowledge → Access → Continuity

These factors help distinguish an appointment that is technically possible from one that is likely to support effective sponsor licence management in practice.

2. Key personnel should reflect how the organisation actually operates

The strongest sponsor management structures generally align formal Home Office roles with genuine organisational responsibility.

The Authorising Officer should provide meaningful senior oversight. The Key Contact should provide an effective communication channel with UKVI. Level 1 Users should be appropriately trained individuals who genuinely need access to the SMS and understand the responsibilities associated with using it.

Where external immigration advisers are involved, their role should complement rather than replace the sponsor’s internal governance.

The organisation remains responsible for its sponsor licence and should retain the internal personnel, knowledge and control required by the Home Office.

3. SMS access requires active control

Employers should know exactly who can access the Sponsor Management System and why.

SMS access should be:

 

• limited to individuals who genuinely require it;
• allocated through individual user accounts;
• protected by the applicable multi-factor authentication requirements;
• reviewed when employees change role;
• removed when employees or external representatives leave;
• reviewed where accounts become inactive; and
• supported by appropriate internal approval and escalation procedures.

 

Employers should aim for sufficient Level 1 User coverage to provide effective administration and reasonable resilience without creating unnecessary system access.

4. Employers need to address the Level 2 User transition

Level 2 Users are now a transitional part of the sponsor management system rather than a role available for new appointments.

No new Level 2 Users can be appointed from 9 September 2026.

Sponsors with existing Level 2 Users should review those accounts and determine whether the individual should be upgraded to Level 1 User status, where eligible and genuinely required, or have their access deactivated.

This action should be completed by 8 March 2027.

The transition provides an opportunity for employers to review their wider SMS-user structure rather than automatically converting historic Level 2 Users into Level 1 Users.

5. Key personnel require ongoing management

Key personnel should not be treated as an administrative requirement that ends when the sponsor licence is granted.

Employers should continue to review:

 

• whether key personnel remain eligible;
• whether the individuals remain appropriate for their roles;
• whether contact information remains accurate;
• whether SMS users still require access;
• whether users remain appropriately trained;
• whether sufficient Level 1 User continuity exists;
• whether personnel changes have been reflected in sponsor management arrangements; and
• whether the organisation’s wider governance structure remains effective.

 

Changes involving key personnel should also be integrated with HR, IT access management and employee offboarding so that sponsorship responsibilities are considered when employees leave, transfer internally or change responsibilities.

6. The ultimate key personnel governance test

An employer should be able to identify, without uncertainty:

 

1. who holds senior responsibility for the sponsor licence;
2. who manages communications with UKVI;
3. who can access the SMS and why;
4. who has authority to approve sponsorship decisions;
5. how relevant information reaches the sponsorship team;
6. how compliance concerns are escalated;
7. what happens when key personnel leave or become unavailable; and
8. how the organisation checks that its sponsor management arrangements continue to operate effectively.

 

If those questions can be answered clearly and supported by effective internal processes, the employer is better placed to demonstrate that its sponsor licence is being actively managed rather than simply administered through the SMS.

For employers, the central principle is therefore straightforward: key personnel should provide clear accountability, reliable communication, controlled system access and continuity throughout the life of the sponsor licence.

 

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Section V: Sponsor Licence Key Personnel Glossary

 

The following terms are commonly used when dealing with sponsor licence key personnel and the management of a UK sponsor licence.

 

Term	Meaning
Authorising Officer (AO)	The Authorising Officer is the senior person responsible for oversight of the organisation’s sponsor licence and the activities of those who use the Sponsor Management System. The Authorising Officer must ordinarily be an appropriately senior paid member of staff or office holder of the sponsoring organisation, subject to the specific exceptions contained in the Home Office sponsor guidance. Appointment as Authorising Officer does not automatically provide access to the SMS. If the individual also needs to use the system, they must hold an appropriate SMS-user role.
Certificate of Sponsorship (CoS)	A Certificate of Sponsorship is an electronic sponsorship record assigned by a licensed sponsor to an eligible worker for use in connection with a sponsored work visa application. Certificates of Sponsorship are managed through the Sponsor Management System. Their allocation, creation and assignment should be subject to appropriate internal controls because incorrect use can create sponsor compliance risks.
Key Contact	The Key Contact is the sponsor’s principal point of contact with UKVI. The role concerns communication rather than automatic system access. A Key Contact does not automatically receive access to the SMS and must separately hold an appropriate SMS-user role if system access is required. An appropriately appointed external representative can potentially act as Key Contact where the relevant Home Office requirements are satisfied.
Key Personnel	Key personnel are the individuals appointed to the principal sponsor management roles required by the Home Office. The core roles are:   Authorising Officer; Key Contact; and Level 1 User.   Existing Level 2 Users remain relevant as key personnel during the current transitional arrangements, but new Level 2 Users can no longer be appointed. One eligible individual can potentially hold more than one key personnel role.
Level 1 User	A Level 1 User is an authorised user of the Sponsor Management System with access to the principal operational functions required to administer the sponsor licence. Depending on the relevant permissions and sponsor circumstances, Level 1 Users can undertake functions relating to Certificates of Sponsorship, sponsor information, worker reporting and other sponsor management activities. The sponsor must maintain appropriate eligible Level 1 User arrangements throughout the life of the licence.
Level 2 User	A Level 2 User is a historic SMS-user role with more restricted permissions than a Level 1 User. The role is being withdrawn. Sponsors have been unable to appoint new Level 2 Users since 9 September 2026. Existing Level 2 Users remain subject to transitional arrangements and should be either upgraded to Level 1 User status, where eligible and operationally necessary, or deactivated by 8 March 2027. Remaining Level 2 accounts will be deactivated by the Home Office following the end of the transitional period.
Sponsor	A sponsor is an organisation authorised by the Home Office to sponsor eligible workers under one or more sponsored immigration routes. The organisation remains responsible for complying with its sponsor duties even where immigration lawyers, HR providers or other external representatives assist with sponsor licence management.
Sponsor Duties	Sponsor duties are the ongoing compliance obligations imposed on licensed sponsors. They include requirements relating to matters such as record keeping, reporting, monitoring sponsored workers, maintaining appropriate systems and personnel, complying with immigration requirements and co-operating with the Home Office. Key personnel form part of the governance structure through which an employer manages these obligations.
Sponsor Licence	A sponsor licence is the Home Office authorisation that allows an eligible organisation to sponsor qualifying workers under relevant UK immigration routes. Holding a sponsor licence brings continuing compliance responsibilities. It is not simply an authorisation to issue Certificates of Sponsorship.
Sponsor Management System (SMS)	The Sponsor Management System is the Home Office online system used by licensed sponsors to administer their sponsor licence. Depending on the user’s permissions and the relevant sponsor route, the SMS is used for functions including managing Certificates of Sponsorship, reporting changes and maintaining sponsor information. Access is restricted to authorised individual users and is subject to Home Office security and authentication requirements.
SMS User	An SMS User is an individual authorised to access the Sponsor Management System. Level 1 Users are SMS users. Existing Level 2 Users may continue to have restricted SMS access during the transitional period. The Authorising Officer and Key Contact do not automatically become SMS users merely because they hold those roles.
UK Visas and Immigration (UKVI)	UK Visas and Immigration (UKVI) is the part of the Home Office responsible for administering the UK’s visa and immigration system, including the sponsorship regime. UKVI administers sponsor licences, publishes sponsor guidance, operates the Sponsor Management System and undertakes sponsor compliance activity.
Settled Worker	A settled worker, for sponsor management purposes, is an individual who falls within the definition used in the current Home Office sponsor guidance. The concept is particularly relevant to the requirements governing the sponsor’s internal Level 1 User arrangements. Employers should apply the current Home Office definition rather than assuming that the term is synonymous only with British citizenship or indefinite leave to remain.
Representative	A representative is an appropriately appointed external person or organisation providing immigration or related professional services to the sponsor. Subject to the Home Office requirements, a representative may potentially act as Key Contact and may in permitted circumstances act as an additional Level 1 User. An external representative cannot ordinarily replace the sponsor’s internal Authorising Officer or required internal Level 1 User arrangements.
Multi-Factor Authentication (MFA)	Multi-factor authentication is the additional identity-verification process required for SMS access. Mandatory MFA reinforces the requirement for SMS accounts to be associated with individual authorised users rather than shared between colleagues or advisers. Sponsors should ensure that user details remain accurate and that SMS access and authentication arrangements are reviewed when personnel change.

 

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Section W: Useful Links

 

Resource	URL
Managing a Sponsor Licence: Complete Employer Guide an overview of the systems, personnel and processes employers need to maintain their sponsor licence.	https://www.davidsonmorris.com/managing-a-sponsor-licence/
Sponsor Licence Management: Employer Guide practical guidance on the ongoing administration and governance of a sponsor licence.	https://www.davidsonmorris.com/sponsor-licence-management/
Sponsor Management System (SMS): Employer Guide guidance on the Home Office system used to administer sponsor licences, manage sponsorship activity and report relevant changes.	https://www.davidsonmorris.com/sponsor-management-system/
Authorising Officer: Sponsor Licence Duties & Requirements detailed guidance on the Authorising Officer role, eligibility requirements and senior responsibility for sponsorship.	https://www.davidsonmorris.com/sponsor-licence-authorising-officer/
Key Contact: Sponsor Licence Role & Responsibilities guidance on the sponsor’s principal point of contact with UKVI.	https://www.davidsonmorris.com/sponsor-licence-key-contact/
Level 1 User: Sponsor Licence Role & Responsibilities detailed guidance on Level 1 User eligibility, SMS access and operational responsibilities.	https://www.davidsonmorris.com/sponsor-licence-level-1-user/
Level 2 User: Sponsor Licence Role & Permissions guidance on the transitional position for existing Level 2 Users following the withdrawal of the role for new appointments from 9 September 2026.	https://www.davidsonmorris.com/sponsor-licence-level-2-user/
How to Change Sponsor Licence Key Personnel guidance on replacing or updating the Authorising Officer, Key Contact and SMS users when personnel leave or circumstances change.	https://www.davidsonmorris.com/change-sponsor-licence-key-personnel/
Sponsor Licence Duties guidance on the principal duties employers assume when they become licensed sponsors.	https://www.davidsonmorris.com/sponsor-licence-duties/
Sponsor Licence Reporting Duties guidance on changes and events that sponsors may need to report to the Home Office.	https://www.davidsonmorris.com/sponsor-licence-reporting-duties/
Sponsor Licence Compliance Audit guidance on reviewing sponsorship systems, records, personnel and processes before weaknesses result in Home Office action.	https://www.davidsonmorris.com/sponsor-licence-compliance-audit/
Sponsor Compliance employer guidance on maintaining effective systems and controls throughout the life of the sponsor licence.	https://www.davidsonmorris.com/sponsor-licence-compliance/
Home Office Compliance Visits guidance on preparing for and responding to Home Office scrutiny of sponsor licence arrangements.	https://www.davidsonmorris.com/ukvi-compliance-visit/
Workers and Temporary Workers: Guidance for Sponsors the principal Home Office sponsor guidance covering sponsor licensing, key personnel and ongoing sponsor responsibilities.	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Home Office Guidance on Sponsorship Management Roles GOV.UK guidance on the Authorising Officer, Key Contact, Level 1 Users and representatives.	https://www.gov.uk/uk-visa-sponsorship-employers/sponsorship-management-roles
Sponsor Management System Guidance and Manuals operational Home Office guidance on using the SMS and carrying out sponsor management functions.	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators
Home Office Sponsor Duties and Compliance Guidance guidance on the duties licensed sponsors must meet and the consequences of non-compliance.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-3-sponsor-duties-and-compliance

 

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