Level 2 User: Sponsor Licence Role & Permissions

SMS Level 2 User: At a Glance

The Level 2 User role is being withdrawn from the Sponsor Management System. No new Level 2 Users can be appointed, and employers with existing accounts have until 8 March 2027 to decide whether each user should be converted to Level 1 or have their SMS access deactivated.

Existing Level 2 Users can continue to operate during the transitional period, but only within the restricted permissions attached to the role. Their access is principally focused on specified Certificate of Sponsorship and sponsored worker functions, with important limits around CoS ownership and wider licence management.

For employers, the transition requires more than changing user status. Sponsors need to identify what work currently depends on each Level 2 User, whether the individual is eligible and suitable for broader Level 1 access, and how CoS and worker responsibilities will be reassigned where access ends.

The objective is to reach the transition deadline with a deliberate and workable SMS structure, sufficient Level 1 capacity and clear ownership of sponsorship activity.

 

Section A: What Is a Sponsor Licence Level 2 User?

 

A Level 2 User is an existing Sponsor Management System (SMS) user with restricted permissions to carry out specified sponsorship activities on behalf of a licensed employer.

Historically, the role allowed sponsors to delegate operational sponsorship tasks without giving the individual the broader SMS permissions available to a Level 1 User. This could be useful where an employee, representative or other eligible person needed direct system access for defined functions without wider authority over the sponsor licence.

Level 2 Users have therefore generally operated below Level 1 Users within the sponsor’s SMS access structure.

The role is now being phased out. Since 9 September 2026, sponsors have not been able to appoint new Level 2 Users. Existing users can continue to operate during the transitional period, but employers need to deal with those accounts by 8 March 2027. Eligible users requiring continued SMS access can be converted to Level 1, while accounts that are no longer required or appropriate should be deactivated. The Home Office has stated that remaining Level 2 User accounts will be deactivated after the deadline.

The restricted nature of the role is important because SMS access does not give every user authority to perform every sponsorship function. The Home Office determines the functions available to each user type.

For an existing Level 2 User, the principal permitted functions include:

 

• creating and assigning Certificates of Sponsorship (CoS), subject to the functions available to the Level 2 User and the status and routes on the sponsor’s licence;
• reporting worker activity relating to CoS they have personally created and assigned; and
• reporting worker activity relating to CoS that have been transferred to them by a Level 1 User, subject to the applicable SMS functionality.

 

A Level 2 User does not have unrestricted access to every sponsored worker or every CoS connected with the organisation’s licence. Their ability to view, manage and report against a CoS is restricted by CoS ownership.

Where a Certificate of Sponsorship is owned by another SMS User, the Level 2 User cannot access and manage that CoS simply because both users operate under the same sponsor licence. The relevant CoS needs to fall within the Level 2 User’s permitted ownership and access before the available SMS functions can be used in relation to it.

Level 2 Users also do not have the broader licence-management capabilities associated with Level 1 access. In particular, they cannot access the general Licence summary, applications and services area of the SMS in the same way as a Level 1 User.

They also cannot access the Defined CoS submenu within the Workers section of the SMS. Because Level 2 Users cannot access the Defined CoS submenu, they cannot apply for, create or assign a Defined Certificate of Sponsorship. Their separate ability to report worker activity remains subject to the ordinary Level 2 ownership rules for CoS transferred to them by a Level 1 User.

The sponsor remains responsible to the Home Office for actions carried out through its SMS Users. The Authorising Officer is responsible for overseeing the sponsor’s SMS Users and for ensuring that appropriate access and controls are maintained.

For employers, the practical issue is now transition planning. Remaining Level 2 accounts should be treated as legacy SMS access requiring active review, with a clear decision on whether the user will move to Level 1, lose direct access or have their sponsorship responsibilities reassigned elsewhere.

 

 

Back to top

 

Section B: Can Sponsors Still Appoint Level 2 Users?

 

No. Sponsors can no longer appoint new Level 2 Users.

The Home Office changed the Sponsor Management System arrangements on 9 September 2026. From that date, sponsors ceased to be able to appoint new Level 2 Users.

This represents a significant change to the previous sponsor management structure. Historically, an organisation could appoint a Level 2 User where it wanted to give someone limited operational access to the SMS without providing the broader permissions available to a Level 1 User.

That option is no longer available.

The change does not, however, mean that all existing Level 2 User accounts ceased to operate on 9 September 2026. The Home Office introduced a transitional period for users who already held Level 2 access.

Existing Level 2 Users can continue to use their accounts within the permissions and restrictions applying to the role while the sponsor decides what should happen to their access.

Sponsors have until 8 March 2027 to deal with those accounts.

By that deadline, the sponsor should either:

 

• convert the Level 2 User to a Level 1 User, where the individual satisfies the applicable Level 1 User requirements and continued SMS access is required; or
• deactivate the Level 2 User account where access is no longer required or the individual is not eligible or appropriate for Level 1 access.

 

Any remaining Level 2 User accounts will be deactivated by the Home Office after the transition deadline.

The change means employers should not treat the March 2027 deadline simply as an administrative exercise. It provides an opportunity to review who has access to the organisation’s sponsor licence and whether that access remains appropriate.

For example, an employer may have Level 2 Users who were originally appointed to assign Certificates of Sponsorship but who no longer perform sponsorship duties. Other Level 2 Users may remain heavily involved in sponsorship administration and require continued SMS access after the Level 2 role disappears.

Those situations require different action.

Where continued access is genuinely required, the employer will need to consider whether the individual is eligible to become a Level 1 User and whether granting broader Level 1 permissions is appropriate for their role.

This matters because conversion does not simply change the user’s title. Level 1 access carries substantially wider SMS permissions than Level 2 access.

Employers should therefore avoid automatically converting every existing Level 2 User without considering the consequences for SMS governance and access control.

A sensible review should establish:

 

• which Level 2 User accounts currently exist;
• whether each user still requires SMS access;
• what sponsorship activities each person currently performs;
• whether those activities need to continue after 8 March 2027;
• whether the individual satisfies the applicable general Key Personnel requirements and the specific requirements for Level 1 access;
• whether broader Level 1 permissions are appropriate for their role; and
• which accounts should instead be deactivated.

 

This is particularly important for organisations that historically used Level 2 access as a way of restricting operational staff to narrower sponsorship functions. Once the Level 2 role disappears, employers will need to reconsider how responsibility for those functions is allocated within their remaining SMS user structure.

Sponsors should also avoid leaving the review until the deadline. If a Level 2 account remains in place after 8 March 2027, the Home Office will deactivate it.

The immediate position for employers is therefore straightforward: no new Level 2 Users can be appointed, existing Level 2 Users can continue operating during the transitional period, and every remaining Level 2 account needs to be converted or deactivated by 8 March 2027.

 

 

Back to top

 

 

Section C: What Happens to Existing Level 2 Users?

 

Existing Level 2 Users are not being removed immediately. They can continue to use their existing Sponsor Management System accounts during the transitional period, subject to the permissions and restrictions that apply to Level 2 access.

However, all existing Level 2 User accounts must be dealt with by 8 March 2027.

For each existing Level 2 User, the sponsor will effectively need to choose between two outcomes:

 

1. Convert the Level 2 User to a Level 1 User, where the individual satisfies the applicable Level 1 User requirements, continued SMS access is required and the broader level of access is appropriate; or
2. Deactivate the Level 2 User account, where the individual no longer needs access, is not eligible to become a Level 1 User or should not be given the wider permissions associated with Level 1 access.

 

If the sponsor takes neither action by the deadline, the Home Office has stated that remaining Level 2 User accounts will be deactivated after 8 March 2027.

 

1. Converting an Existing Level 2 User

 

Where a Level 2 User continues to perform sponsorship functions, conversion to Level 1 may be appropriate.

The sponsor should first consider whether the individual meets the requirements applicable to Level 1 Users. Existing Level 2 User status does not automatically establish eligibility for Level 1 access.

Eligibility will depend on the individual meeting the applicable general requirements for Key Personnel as well as the specific requirements governing Level 1 Users.

The employer should also consider whether the individual actually needs the additional access that comes with the Level 1 role.

This is important because conversion should not be treated as an automatic administrative replacement for Level 2 access. Level 1 Users have substantially broader access to applicable SMS functions, subject to the sponsor’s licence type, routes, status and the particular functions available within the system.

For example, an employee may historically have been given Level 2 access solely so they could assign Certificates of Sponsorship and administer specified sponsored workers. Converting that person to Level 1 could provide access to functions beyond those originally required for their role.

The employer should therefore consider both eligibility and operational need before changing the account.

Detailed requirements relating to who can act as a Level 1 User are considered separately in our guide to Sponsor Licence Level 1 Users.

 

2. Deactivating an Existing Level 2 User

 

Where continued SMS access is unnecessary or inappropriate, the Level 2 User account should be deactivated.

This could apply where the individual:

 

• has changed role within the organisation;
• no longer carries out sponsorship work;
• was given Level 2 access for a temporary or limited purpose;
• has left the organisation;
• does not need the broader permissions associated with Level 1 access;
• does not satisfy the applicable requirements for Level 1 access; or
• can have their existing sponsorship responsibilities allocated to another authorised Level 1 User.

 

Employers should not retain or expand SMS access merely because an account already exists.

Sponsor Management System access should reflect the individual’s current responsibilities and the organisation’s operational requirements. Removing unnecessary access can also reduce the risk of unauthorised, accidental or inappropriate activity within the sponsor’s account.

 

3. What Happens If the Sponsor Does Nothing?

 

A sponsor that leaves an existing Level 2 User account unchanged beyond the transitional deadline risks losing that user’s access without having made alternative arrangements.

The Home Office has stated that after 8 March 2027 it will deactivate any remaining Level 2 User accounts.

This could create an operational problem where an organisation relies on a Level 2 User for day-to-day sponsorship activity.

For example, if that person is responsible for assigning Certificates of Sponsorship or making permitted worker reports and the employer has not reorganised its SMS access before the deadline, the individual will no longer be able to perform those functions once their Level 2 account is deactivated.

The issue is therefore not simply whether the employer deals with the account before the deadline. Sponsors also need to ensure that responsibility for essential SMS functions continues without interruption.

 

4. Review CoS Ownership Before Changing Access

 

Employers should also review the Certificates of Sponsorship associated with each Level 2 User before converting or deactivating the account.

Level 2 User access is restricted by CoS ownership. A Level 2 User can view CoS within the scope of their permitted ownership and report worker activity relating to CoS they have created and assigned or which have been transferred to them by a Level 1 User through the appropriate SMS functionality.

The employer should therefore establish which sponsored workers and CoS are currently associated with the Level 2 User and decide who will be responsible for them after the account changes.

This is particularly important where the Level 2 User is going to be deactivated rather than converted.

Any outstanding sponsorship actions should also be identified so that responsibility does not become unclear during the transition.

 

5. Review Level 2 Access Before the Deadline

 

Employers with existing Level 2 Users should carry out an account review well before 8 March 2027.

The review should identify each Level 2 User, establish what they currently use the SMS for and determine who will perform those functions once Level 2 access disappears.

For some users, conversion to Level 1 may be appropriate. For others, deactivation may be the better option. In larger organisations, the removal of Level 2 access may require a wider reconsideration of how sponsorship responsibilities are distributed between HR, global mobility, recruitment, compliance teams and external representatives.

The objective should be to reach the deadline with a deliberate SMS access structure rather than simply converting every Level 2 User by default.

This is particularly important because the disappearance of Level 2 access removes the intermediate permission level that sponsors previously used to delegate certain operational sponsorship tasks while restricting wider access to the licence.

Employers should therefore use the transition period to decide who genuinely needs SMS access, what level of authority they should have and how sponsorship responsibilities will be controlled once the Level 2 User role has been withdrawn.

The sponsor should also ensure that an eligible Authorising Officer and at least one eligible Level 1 User remain in place. The Home Office requires these roles to be maintained throughout the life of the sponsor licence, making continuity of Level 1 access an important part of the Level 2 transition exercise.

 

 

Back to top

 

 

Section D: What Can a Level 2 User Do?

 

An existing Level 2 User can continue to carry out a limited range of sponsorship activities through the Sponsor Management System during the transitional period.

Their principal functions relate to Certificates of Sponsorship and activity concerning CoS they are permitted to access and manage.

Under current Home Office sponsor guidance, a Level 2 User can:

 

• create and assign Certificates of Sponsorship to workers, subject to the functions available to the Level 2 User and the status and routes on the sponsor’s licence;
• report worker activity relating to a CoS they personally created and assigned; and
• report worker activity relating to a CoS that has been transferred to them by a Level 1 User through the appropriate SMS functionality.

 

The scope of Level 2 access is therefore considerably narrower than Level 1 access.

 

1. Level 2 User Permissions

 

The following table summarises the practical scope of the Level 2 User role:

 

SMS Activity	Level 2 User Permission
Create and assign a Certificate of Sponsorship	Yes, subject to the applicable SMS functionality, licence status and sponsored route
View and manage a CoS they own	Yes, subject to the functions available to Level 2 Users
Report worker activity for a CoS they created and assigned	Yes
Report worker activity for a CoS transferred to them	Yes, subject to the applicable SMS functionality
View or report against any CoS on the sponsor licence automatically	No
Access the Defined CoS submenu	No
Access general licence management functions	No
Exercise the full permissions available to a Level 1 User	No

 

The distinction between being an SMS User and having authority over the whole sponsor licence is important. A Level 2 User’s access should not be understood simply as a reduced version of unrestricted licence administration. It is a specifically limited user role with defined SMS permissions.

 

2. Creating Certificates of Sponsorship

 

An existing Level 2 User can create and assign Certificates of Sponsorship within the functions available to them.

A Certificate of Sponsorship is an electronic sponsorship record rather than a paper certificate. It provides information about the worker, their proposed employment and the basis on which the employer is sponsoring them. The worker uses the CoS reference when making the relevant sponsored immigration application.

The Level 2 User’s ability to work with CoS does not, however, provide unrestricted access to every sponsorship function.

In particular, current Home Office SMS guidance provides that Level 2 Users cannot access the Defined CoS submenu within the Workers section of the SMS.

This distinction is important. Because Level 2 Users cannot access the Defined CoS submenu, they cannot apply for, create or assign Defined Certificates of Sponsorship. Their separate ability to report worker activity remains subject to the ordinary Level 2 ownership rules for CoS transferred to them by a Level 1 User.

Employers should therefore distinguish between the general ability of an existing Level 2 User to create and assign CoS within their permitted functionality and those CoS functions that require the appropriate Level 1 access.

The detailed rules and process for assigning sponsorship are considered separately in our guide to How to Assign a Certificate of Sponsorship.

 

3. Assigning Certificates of Sponsorship

 

Existing Level 2 Users can assign Certificates of Sponsorship within the scope of the functions available to them.

This has historically been one of the principal reasons for using Level 2 access. An employer could delegate operational CoS work without giving the individual the wider licence-management permissions associated with a Level 1 User.

Assigning a CoS is nevertheless an important sponsor action.

The information recorded on a CoS can affect both the worker’s immigration application and the sponsor’s compliance position. The fact that an individual has technical permission within the SMS to assign a CoS does not establish that the proposed sponsorship is lawful or that the CoS should be assigned.

Before a CoS is assigned, the sponsor should ensure that the relevant immigration and sponsorship requirements have been considered and that the information entered is accurate.

Employers should therefore maintain appropriate internal controls over who prepares, checks, approves and assigns Certificates of Sponsorship, even where the SMS itself allows a particular user to carry out the assignment.

These internal controls are a matter of sponsor governance. The precise internal approval process will depend on the organisation, but the sponsor remains responsible to the Home Office for actions carried out through its authorised SMS Users.

 

4. Viewing and Managing Certificates of Sponsorship

 

A significant restriction on Level 2 access concerns which Certificates of Sponsorship the user can view and manage.

A Level 2 User does not automatically have access to every CoS connected with the sponsor licence.

Current SMS guidance restricts Level 2 Users to CoS they own. This generally includes CoS they have created themselves and CoS that have been transferred to them through the appropriate SMS functionality.

Where a Level 2 User does not own the relevant CoS, they cannot simply view or edit it because they happen to be an authorised user on the same sponsor licence.

This makes CoS ownership an important practical limitation on Level 2 access.

For employers with several SMS Users, it is therefore important to know not only who has access to the system, but which user is responsible for the relevant CoS and sponsored worker.

 

5. Reporting Sponsored Worker Activity

 

A Level 2 User can also use the SMS to report certain activity relating to sponsored workers, but this permission is subject to the same important ownership restriction.

The Level 2 User can report activity in relation to:

 

• a CoS they personally created and assigned; or
• a CoS that has been transferred to them through the appropriate SMS functionality.

 

This means Level 2 access does not give the user authority to report against every sponsored worker associated with the organisation’s licence.

For example, if a sponsored worker’s CoS is owned by another SMS User, the Level 2 User cannot simply access that record and make a report because they work for the same sponsor.

Where responsibility for the worker needs to pass to the Level 2 User during the remaining transitional period, the relevant CoS can be transferred through the appropriate SMS functionality so that the Level 2 User has the necessary ownership and access.

This ownership restriction is one of the most important practical differences between Level 1 and Level 2 access. It can be particularly relevant where responsibility for sponsored workers is divided between different HR personnel, business units, sites or locations.

 

6. SMS Permission Does Not Determine Whether an Action Is Correct

 

Employers should distinguish between technical SMS permission and sponsor compliance.

The fact that a Level 2 User is technically able to perform an action within the SMS does not establish that the action should be taken.

Before assigning a CoS or reporting a worker event, the sponsor may need to determine:

 

• whether the relevant sponsorship requirements are met;
• whether the worker is eligible to be sponsored in the proposed role;
• whether the information being entered or reported is accurate;
• whether the event is one that must be reported to the Home Office;
• whether the correct information and effective date are being entered;
• whether an applicable reporting deadline must be met; and
• whether any wider action is required in relation to the worker or sponsor licence.

 

The sponsor remains responsible to the Home Office for actions carried out through its SMS Users, while the Authorising Officer is responsible for overseeing SMS Users and their activities.

Employers may therefore choose to operate internal controls that are more restrictive than the technical permissions available through the SMS.

For example, a Level 2 User may technically be able to assign a CoS, while the employer’s internal procedure requires the proposed sponsorship to be reviewed or approved by another person before assignment.

For employers retaining Level 2 Users during the transition period, the practical question should therefore be not only “What can this user do in the SMS?”, but also “What should this user be authorised to do within our sponsorship governance arrangements?”

That distinction becomes particularly important when deciding whether an existing Level 2 User should subsequently receive the considerably broader access associated with a Level 1 account.

 

 

Back to top

 

 

Section E: Which Sponsored Workers Can a Level 2 User Manage?

 

A Level 2 User cannot automatically view or manage every sponsored worker attached to the organisation’s sponsor licence.

Their ability to access a worker’s sponsorship record and carry out permitted activity is linked to the Certificate of Sponsorship they own within the Sponsor Management System.

An existing Level 2 User can view, manage and report activity relating to a CoS where:

 

• they created and assigned the worker’s CoS themselves; or
• the relevant CoS has been transferred to them through the appropriate SMS functionality.

 

This restriction can be particularly important for employers with several SMS Users or where responsibility for sponsored workers is divided between different teams, departments, sites or locations.

 

1. CoS Ownership Determines Level 2 Access

 

For Level 2 Users, access to a sponsor’s SMS does not mean unrestricted access to all sponsored worker records.

Instead, the relevant question is whether the Level 2 User owns the worker’s CoS for SMS purposes.

Current Home Office SMS guidance restricts Level 2 Users to viewing and reporting against CoS they own. They cannot simply view or edit a CoS they did not create or which has not been transferred to them through the appropriate SMS functionality.

For example, an employer may have a Level 1 User responsible for overall sponsor licence administration and an existing Level 2 User responsible for a particular group of sponsored employees.

If the Level 2 User creates and assigns the CoS for those workers, they can subsequently use the SMS functions available to them in relation to those CoS.

However, if another SMS User owns the relevant CoS, the Level 2 User does not automatically acquire access merely because both users operate under the same sponsor licence.

Where the Level 2 User needs to assume responsibility for that worker during the transitional period, the relevant CoS will need to be transferred to them through the appropriate SMS functionality.

 

2. What Does CoS Ownership Mean?

 

CoS ownership is an SMS concept that determines which user has access to particular Certificate of Sponsorship functions.

For Level 2 User purposes, a user will generally own a CoS where they created it themselves or where the CoS has been transferred to them by a Level 1 User, subject to the relevant SMS functionality.

This is important because the Level 2 User’s restricted access follows the CoS.

Ownership can affect whether the Level 2 User can:

 

• view the relevant CoS;
• access the worker’s sponsorship record through the functions available to them;
• make permitted changes relating to the CoS; and
• report relevant sponsored worker activity.

 

Employers should therefore avoid treating CoS ownership as merely an administrative label. For a Level 2 User, it directly affects what the user can see and do within the SMS.

 

3. Transferring a CoS to a Level 2 User

 

During the transitional period, responsibility for a Certificate of Sponsorship can be transferred to an existing Level 2 User through the appropriate SMS functionality.

Once the relevant CoS is transferred, the Level 2 User can use the functions available to them in relation to that CoS, including permitted worker reporting activity.

This mechanism has historically allowed sponsors to allocate responsibility for sponsored workers between different SMS Users.

For example, a business with several operating divisions may have used Level 2 Users to administer sponsored workers within individual divisions while Level 1 Users retained wider responsibility for management of the sponsor licence.

Similarly, a central HR or global mobility function may have allocated responsibility for particular sponsored workers to an existing Level 2 User responsible for their day-to-day sponsorship administration.

The important point is that transferring a CoS changes the Level 2 User’s access to that CoS; it does not expand their wider SMS permissions.

The individual remains a Level 2 User and continues to be subject to all restrictions applying to that role.

 

4. What If Another SMS User Owns the CoS?

 

Where another SMS User owns the relevant CoS, an existing Level 2 User cannot simply take over responsibility for that worker.

The sponsor should first establish who currently owns the CoS and whether responsibility needs to be transferred through the SMS.

This can become particularly important when there are changes within the organisation, such as:

 

• an SMS User leaving the business;
• an employee changing role;
• responsibility for immigration compliance moving between teams;
• restructuring of an HR or global mobility function;
• changes to responsibility between different offices, sites or business units;
• absence of the individual who normally administers particular sponsored workers; or
• preparation for the withdrawal of Level 2 User access.

 

Sponsors should ensure that responsibility for sponsored workers remains clear whenever SMS access arrangements change.

Where responsibility is being transferred, the organisation should also consider whether there are outstanding sponsorship actions or reportable events that need to be addressed as part of the handover.

 

5. CoS Ownership and the Withdrawal of Level 2 Access

 

The phasing out of the Level 2 User role makes CoS ownership particularly relevant during the transition to 8 March 2027.

Where an organisation has existing Level 2 Users responsible for sponsored workers, it should identify which CoS those users currently own and decide who will be responsible for the workers after the Level 2 account is converted or deactivated.

This should form part of the employer’s wider Level 2 User transition review.

For each existing Level 2 User, the sponsor should consider:

 

• which live sponsored workers they currently administer;
• which CoS they currently own;
• whether any sponsorship actions are outstanding;
• whether any reportable worker events are awaiting action;
• whether the user will be converted to Level 1;
• whether responsibility will instead pass to another authorised SMS User; and
• whether any CoS ownership changes are required to maintain effective sponsorship administration.

 

This is particularly important where the Level 2 User is going to be deactivated rather than converted.

Sponsors should avoid a situation where an account is removed without first considering how responsibility for the sponsored workers and CoS associated with that user will be managed afterwards.

 

6. SMS Access Should Match Operational Responsibility

 

For larger sponsors, the allocation of CoS ownership can form part of the organisation’s wider sponsorship control framework.

Where multiple people have access to the SMS, employers should be able to identify who is responsible for assigning sponsorship and dealing with relevant changes for particular workers.

Clear allocation of responsibility can help reduce the risk of reporting obligations being overlooked because one user assumes another person is dealing with the worker.

Employers may therefore choose to maintain internal records showing which SMS User or team is responsible for particular sponsored workers, even where this goes beyond the technical information recorded within the SMS.

This is a governance measure rather than a separate Home Office reporting requirement, but it can help sponsors demonstrate clear internal ownership of sponsorship activity.

The removal of Level 2 Users provides an opportunity for employers to review these arrangements more broadly.

Rather than simply replacing Level 2 accounts with Level 1 accounts, sponsors should consider how sponsored worker administration will operate after March 2027, who genuinely requires SMS access and how responsibility for individual workers will be allocated, supervised and covered when personnel change.

 

 

Back to top

 

 

Section F: What Can’t a Level 2 User Do?

 

A Level 2 User does not have the wider sponsor licence management permissions available to a Level 1 User.

Although existing Level 2 Users can continue to create and assign Certificates of Sponsorship and carry out permitted activity relating to CoS they own, their SMS access remains deliberately restricted.

In practical terms, a Level 2 User cannot use the Sponsor Management System as though they were responsible for the sponsor licence as a whole.

 

1. Level 2 Users Cannot Access General Licence Management Functions

 

Level 2 Users do not have access to the Licence summary, applications and services functions available to Level 1 Users.

These areas of the SMS are used for broader sponsor licence administration rather than the narrower worker and CoS functions available through Level 2 access.

As a result, an existing Level 2 User cannot independently carry out many of the actions required to administer or make changes to the organisation’s sponsor licence.

Where an action requires Level 1 access, it will need to be dealt with by an appropriately authorised Level 1 User.

 

2. Level 2 Users Cannot Access the Defined CoS Submenu

 

Current Home Office SMS guidance restricts Level 2 Users from accessing the Defined CoS submenu within the Workers section of the SMS.

This is an important distinction for sponsors using the Skilled Worker route.

Defined Certificates of Sponsorship are generally relevant where a Skilled Worker is applying for entry clearance from outside the UK. The process for requesting and managing Defined CoS therefore involves SMS functionality that is not available through Level 2 access.

The restriction should be described precisely. A Level 2 User cannot access the Defined CoS submenu and therefore cannot apply for, create or assign a Defined CoS. Their separate ability to report worker activity remains subject to the ordinary Level 2 ownership rules for CoS transferred to them by a Level 1 User.

Employers should therefore not assume that because a Level 2 User can create and assign CoS within their permitted functions, they can carry out every CoS-related function available within the SMS.

 

3. Level 2 Users Cannot View or Manage Every CoS

 

Level 2 Users cannot access every Certificate of Sponsorship simply because it sits under the same sponsor licence.

Their access is restricted by CoS ownership.

A Level 2 User can view and carry out permitted activity in relation to CoS they own, including CoS they created themselves or which have been transferred to them through the appropriate SMS functionality.

Where the Level 2 User does not own the relevant CoS, they cannot simply view or edit it because they are an authorised SMS User for the organisation.

This restriction is particularly important for employers with multiple SMS Users because access to the same sponsor licence does not mean that every user has access to the same worker and CoS records.

 

4. Level 2 Users Cannot Report Against Every Sponsored Worker

 

A Level 2 User does not have unrestricted authority to report activity relating to every sponsored worker under the organisation’s licence.

Their worker reporting permissions are restricted to CoS they own.

This includes CoS that:

 

• they created and assigned themselves; or
• have been transferred to them through the appropriate SMS functionality.

 

If the relevant CoS is owned by another user, the Level 2 User does not automatically have authority to view the CoS or make reports relating to that worker.

This makes CoS ownership an important part of managing existing Level 2 accounts during the transition period.

 

5. Level 2 Users Cannot Manage the Sponsor Licence Generally

 

The Level 2 role should not be treated as authority to make general changes to the sponsor licence.

Broader sponsor administration can involve matters such as changes to the organisation’s details, its licence arrangements, key personnel and other information held by the Home Office.

These wider licence-management functions fall outside the core permissions of the Level 2 role.

Employers should therefore ensure that a Level 2 User does not become the de facto person responsible for the sponsor licence where they do not have the system access required to perform that function.

The organisation should maintain appropriate Level 1 User access to deal with matters requiring wider SMS authority.

 

6. Level 2 Users Cannot Manage SMS Users in the Same Way as Level 1 Users

 

Level 2 access does not include the wider user-management functionality available to Level 1 Users.

Level 1 Users can carry out specified SMS user-management functions, subject to the particular permissions available within the system. These can include managing relevant user details and deactivating other users, although a Level 1 User cannot simply exercise unrestricted control over every aspect of their own or another user’s account.

A Level 2 User does not have equivalent user-management authority.

This distinction is particularly relevant during the current transition.

An existing Level 2 User cannot resolve the withdrawal of their own role simply by changing their own permissions. The appropriate Level 1 User will need to take the necessary action to convert an eligible Level 2 User to Level 1 or deactivate the Level 2 account.

Sponsors should therefore ensure that they have functioning Level 1 access well before the 8 March 2027 deadline.

Where a sponsor has no active Level 1 User with access to the SMS, the normal user-management process cannot simply be followed. The sponsor will need to use the applicable Home Office change of circumstances process to put an eligible Level 1 User in place.

This is a significant compliance issue. The Home Office requires an eligible Authorising Officer and at least one eligible Level 1 User to remain in place throughout the life of the sponsor licence.

 

7. Level 2 Users Do Not Have Unrestricted Access to SMS Information

 

The restrictions on Level 2 Users are not limited to the actions they can perform. They also affect the information and functionality they can access through the SMS.

For example, Home Office SMS guidance confirms that Level 2 Users do not see the same message screen presented to Level 1 Users when they log into the system.

They also cannot access the Licence summary, applications and services area or the Defined CoS submenu available through the appropriate Level 1 functionality.

This reinforces the broader distinction between the roles: Level 2 access was designed for limited operational sponsorship activity, while Level 1 access provides the broader applicable functionality required for day-to-day administration of the sponsor licence.

 

8. Level 2 Users Cannot Share or Use Another User’s SMS Credentials

 

The restricted nature of Level 2 access cannot be circumvented by allowing a Level 2 User to access the SMS through another person’s account.

SMS user credentials are personal to the authorised user. Users should access the system through their own authorised account and should not disclose or share their password or other authentication information.

This will become particularly important when Level 2 accounts are deactivated.

A former Level 2 User who continues to assist with sponsorship administration may still gather information, maintain internal records or prepare information for an authorised Level 1 User, but they should not carry out SMS activity using somebody else’s credentials.

If direct SMS access remains necessary after the Level 2 role disappears, the employer should determine whether the individual is eligible and appropriate to hold Level 1 access.

 

9. Restricted Access Does Not Reduce the Sponsor’s Responsibility

 

Using a Level 2 User does not transfer responsibility for sponsor compliance away from the licensed organisation.

The sponsor remains responsible to the Home Office for actions carried out through its SMS Users. The Authorising Officer is responsible for overseeing SMS Users and their activities.

Employers should therefore maintain appropriate controls over Level 2 Users during the remaining transitional period.

Depending on the organisation’s circumstances, internal controls can include determining:

 

• which sponsorship activities the individual is authorised to perform;
• which workers and CoS they are responsible for;
• who checks or approves CoS assignments where appropriate;
• who is responsible for identifying and making worker reports;
• who supervises the user’s SMS activity;
• how sponsorship responsibilities are covered during absence;
• how access is reviewed when an individual’s role changes; and
• what will happen to their responsibilities when Level 2 access ends.

 

These internal governance measures should be distinguished from specific Home Office requirements. Employers can choose to operate controls that are more restrictive than the technical permissions available within the SMS where this supports effective sponsor licence management.

The distinction between Level 1 and Level 2 access is particularly important now because employers should not assume that converting a Level 2 User to Level 1 simply preserves the existing arrangement.

Conversion can materially increase that person’s access to the sponsor’s SMS.

Before making that change, the employer should understand the difference between the two roles and decide whether broader Level 1 access is both legally available and operationally appropriate.

 

 

Back to top

 

 

Section G: Level 1 User vs Level 2 User

 

The principal difference between a Level 1 User and a Level 2 User is the scope of their Sponsor Management System permissions.

Level 1 Users have access to the broader SMS functionality required to administer the sponsor licence, subject to the sponsor’s licence type, sponsored routes, licence status and the specific functions available within the system.

Level 2 Users have substantially more restricted access. Their role is principally concerned with specified Certificate of Sponsorship and sponsored worker functions relating to CoS they own.

This distinction is particularly important for employers deciding whether an existing Level 2 User should be converted to Level 1 before the Level 2 role is withdrawn.

 

1. Level 1 and Level 2 User Comparison

 

SMS Function or Responsibility	Level 1 User	Level 2 User
Broader day-to-day administration of the sponsor licence	Yes, subject to the applicable SMS permissions, licence type, routes and licence status	No
Create and assign Certificates of Sponsorship	Yes, subject to the applicable SMS functionality and licence arrangements	Yes, subject to the functions available to the Level 2 User and the status and routes on the sponsor’s licence
View CoS they personally created	Yes, subject to applicable SMS functionality	Yes
View CoS transferred to them	Yes, subject to applicable SMS functionality	Yes
View or edit CoS they do not own	Broader access may be available, subject to the applicable SMS functionality	No
Report sponsored worker activity	Yes, subject to applicable SMS functionality	Yes, but restricted to CoS they own
Access Licence summary, applications and services	Yes, subject to applicable SMS permissions	No
Access the Defined CoS submenu within the Workers section	Yes, where applicable	No
Manage SMS users	Yes, subject to the specific SMS user-management permissions	No equivalent Level 1 user-management access
Use the broader licence-management functions available through the SMS	Yes, subject to applicable restrictions	No
Can be newly appointed after 9 September 2026	Yes, where the applicable requirements are met	No
Role continues after 8 March 2027	Yes	No

 

2. Level 1 Users Have Broader SMS Access

 

A Level 1 User is one of the principal operational users of the Sponsor Management System.

Level 1 access enables the individual to carry out the wider range of SMS activities available to the sponsor, subject to the particular sponsor licence, sponsored routes, licence status and any restrictions applying within the system.

This can include activities relating to:

 

• managing Certificates of Sponsorship;
• reporting relevant sponsored worker changes;
• accessing broader sponsor licence information;
• making certain changes to sponsor details;
• using applicable licence-management services;
• accessing relevant Defined CoS functionality;
• managing SMS users, subject to the specific user-management permissions; and
• carrying out other sponsorship administration available through Level 1 access.

 

Level 1 access should not, however, be described as completely unrestricted access to every possible SMS function.

The functionality available can depend on factors including the type and status of the sponsor licence, the routes for which the organisation is licensed and the particular action being undertaken.

For example, the functionality available to a sponsor can be affected where the licence is suspended, downgraded or otherwise subject to Home Office action.

Employers should therefore understand Level 1 as the broader operational SMS role rather than as an unlimited permission to carry out every sponsorship action.

 

3. Level 2 Users Have Restricted Operational Access

 

The Level 2 role was designed to provide narrower operational access.

Rather than giving the user broad authority over the sponsor licence, it allowed specified sponsorship tasks to be delegated while restricting the individual’s access to wider licence-management functions.

A Level 2 User’s ability to view, manage and report against CoS is restricted by CoS ownership.

They can generally carry out permitted activity relating to CoS they created and assigned themselves or which have been transferred to them through the appropriate SMS functionality.

They cannot simply access every CoS or sponsored worker record connected with the organisation.

They also cannot access the Licence summary, applications and services functions available through appropriate Level 1 access and cannot access the Defined CoS submenu within the Workers section of the SMS.

This narrower permission structure explains why some employers historically used Level 2 Users for staff responsible for operational sponsorship administration without wanting to provide them with broader control over the sponsor licence.

 

4. Conversion to Level 1 Is Not a Like-for-Like Replacement

 

The withdrawal of the Level 2 User role creates an important governance issue for sponsors.

Converting an existing Level 2 User to Level 1 should not be treated as a simple like-for-like replacement of one account type with another.

Level 1 access can provide materially broader SMS permissions.

An employee who historically needed Level 2 access only to assign CoS or deal with a particular group of sponsored workers may receive access to substantially more sponsor licence functionality if converted to Level 1.

The employer should therefore ask two separate questions:

 

1. Is the existing Level 2 User eligible to become a Level 1 User?
2. Does the individual genuinely need and should they be given the broader access associated with Level 1?

 

Eligibility alone does not mean that conversion is necessarily the appropriate operational decision.

The sponsor should consider the individual’s responsibilities, experience, training and need for access, together with the organisation’s wider sponsorship governance arrangements.

 

5. Level 1 Eligibility Must Be Considered Separately

 

An existing Level 2 User does not automatically qualify to become a Level 1 User simply because they already have authorised access to the SMS.

Eligibility depends on the individual meeting the applicable general requirements for Key Personnel and the specific requirements for Level 1 Users.

This can be particularly important where the existing Level 2 User is not an employee of the sponsor.

Certain UK-based representatives and employees of outsourced HR providers may be able to act as additional Level 1 Users where the relevant Home Office requirements are met. This should not be interpreted as meaning that an external representative can necessarily act as the sponsor’s sole or primary Level 1 User where the sponsor guidance requires an eligible employee or office holder to hold that role.

Employers should therefore check the individual’s precise status and the applicable Level 1 requirements before attempting conversion.

The detailed eligibility rules belong within the separate Level 1 User: Sponsor Licence Role & Responsibilities guidance rather than being duplicated here.

 

6. Temporary Staff Require Particular Attention

 

Employers should pay particular attention to existing Level 2 Users who are temporary staff supplied to the sponsor by an employment business.

Under the transitional arrangements, an individual in this position who was already an authorised Level 2 User may continue to operate within the remaining Level 2 transitional period.

However, temporary staff supplied by an employment business and not employed by the sponsor cannot be converted to Level 1 Users.

Where an organisation currently relies on such an individual for sponsorship administration, it will therefore need to make alternative arrangements before the Level 2 role disappears.

This may require the sponsor to:

 

• identify which sponsorship functions the Level 2 User currently performs;
• identify the workers and CoS for which they are responsible;
• allocate those responsibilities to an eligible Level 1 User;
• ensure sufficient Level 1 capacity exists within the organisation;
• transfer relevant knowledge and internal records;
• address any outstanding sponsorship actions; and
• deactivate the Level 2 account within the transition period.

 

The individual may potentially continue supporting the organisation with administrative work outside the SMS where appropriate, but they must not continue accessing the system through another person’s credentials once their own authorised access ends.

 

7. Employers Should Review Access Rather Than Automatically Upgrade Users

 

The removal of Level 2 access gives sponsors an opportunity to review their wider SMS user structure.

Employers should consider whether existing access arrangements developed over time rather than through a deliberate sponsorship governance process.

For example, an organisation may have Level 2 accounts belonging to individuals who:

 

• rarely use the SMS;
• no longer perform sponsorship functions;
• have moved into different roles;
• only require administrative involvement outside the SMS;
• are responsible for functions that could be consolidated under existing Level 1 Users; or
• would receive unnecessarily broad access if converted to Level 1.

 

Conversely, an organisation may discover that a Level 2 User carries out important day-to-day sponsorship work and that removing their access without replacement would create a significant operational gap.

The correct response will depend on the individual user’s circumstances and the sponsor’s operating model.

The objective should be to maintain sufficient authorised SMS access to meet the organisation’s sponsorship responsibilities while avoiding unnecessary access to sensitive sponsor licence functionality.

For this reason, the Level 1 versus Level 2 distinction is not simply a question of which user has more permissions. It is also a question of how the sponsor allocates authority, responsibility and oversight within its immigration compliance framework.

 

 

Back to top

 

 

Section H: How to Convert a Level 2 User to Level 1

 

Where an existing Level 2 User needs to retain access to the Sponsor Management System after the Level 2 role is withdrawn, the sponsor will need to consider converting that individual to a Level 1 User.

Conversion should only take place where the individual is eligible to become a Level 1 User, continued SMS access is genuinely required and the sponsor is satisfied that the broader permissions associated with Level 1 access are appropriate.

Existing Level 2 Users who require continued access should be dealt with before 8 March 2027. Where conversion is not appropriate, the Level 2 account should instead be deactivated and the individual’s sponsorship responsibilities reallocated.

 

1. Check Whether Continued SMS Access Is Required

 

The first step is to determine whether the existing Level 2 User actually needs continued direct access to the SMS.

Employers should not assume that every Level 2 User needs to become a Level 1 User simply because their existing account is being withdrawn.

The sponsor should consider what the individual currently does within the SMS, including whether they:

 

• create Certificates of Sponsorship;
• assign Certificates of Sponsorship;
• manage particular sponsored workers;
• make sponsored worker reports;
• regularly access the SMS as part of their role; or
• only use their Level 2 account occasionally.

 

If the individual no longer needs direct SMS access, conversion may be unnecessary. Their account can instead be deactivated and any remaining sponsorship responsibilities allocated elsewhere.

Where the individual performs important operational sponsorship functions, the employer should consider who will perform those functions after the Level 2 role disappears.

 

2. Check Whether the Level 2 User Is Eligible for Level 1 Access

 

Continued operational need is not enough on its own. The individual must also satisfy the applicable requirements for appointment as a Level 1 User.

An existing Level 2 User does not automatically become eligible for Level 1 access because they already have an authorised SMS account.

Eligibility also depends on the individual meeting the applicable general requirements for Key Personnel and the specific requirements for Level 1 Users.

The employer should therefore check the individual’s status against the current Home Office requirements before proceeding with conversion.

Detailed consideration of those requirements falls within the separate guidance on Level 1 Users, but the distinction is important when managing the Level 2 transition.

 

3. Temporary Agency Staff Cannot Be Converted to Level 1

 

A particularly important restriction applies where the existing Level 2 User is a temporary member of staff supplied to the sponsor by an employment business.

Where such an individual was already a Level 2 User before the Home Office stopped new Level 2 appointments, they may continue using their existing Level 2 access during the transitional period, subject to the applicable restrictions.

However, where the individual is temporary staff supplied by an employment business and is not employed by the sponsor, they cannot be converted to a Level 1 User.

This means an employer currently relying on such a Level 2 User will need to make alternative arrangements.

The sponsor should identify:

 

• which sponsorship functions the individual currently performs;
• which CoS and sponsored workers they currently manage;
• whether any worker reports or other sponsorship actions are outstanding;
• which eligible Level 1 User will assume those responsibilities;
• whether any CoS ownership or operational changes are required; and
• when the existing Level 2 account will be deactivated.

 

This should be dealt with before the end of the transitional period rather than waiting for the Home Office to deactivate the account.

 

4. External Representatives and Outsourced HR Providers

 

Employers should also take care where an existing Level 2 User is an external representative or works for an outsourced HR provider.

Home Office rules can allow certain eligible UK-based representatives and employees of outsourced HR providers to act as additional Level 1 Users, provided the relevant requirements are met.

However, this should not be interpreted as meaning that an external representative can automatically become the sponsor’s sole or primary Level 1 User.

The sponsor must continue to satisfy the Home Office requirements governing its primary Level 1 User and the circumstances in which additional Level 1 Users can be appointed.

Employers using external support should therefore check both the individual’s eligibility and the capacity in which they can hold Level 1 access before attempting to replace an existing Level 2 arrangement.

 

5. Consider Whether Broader Level 1 Access Is Appropriate

 

Eligibility does not necessarily mean that conversion is the correct governance decision.

A Level 2 User may historically have been given restricted access precisely because the organisation did not want that person to have broader control over the sponsor licence.

Moving the individual to Level 1 can provide access to significantly wider SMS functionality.

The sponsor should therefore consider:

 

• why the individual originally received Level 2 rather than Level 1 access;
• whether their responsibilities have changed since their appointment;
• which additional SMS functions would become available through Level 1 access;
• whether the individual has sufficient knowledge and training to exercise those permissions;
• whether the individual requires access to those additional functions;
• whether appropriate supervision and internal controls are in place; and
• whether sponsorship responsibilities could instead be handled by an existing Level 1 User.

 

This is particularly relevant for larger sponsors that have historically used Level 2 access to separate operational CoS administration from wider sponsor licence management.

 

6. Review the Level 2 User’s Existing CoS and Worker Responsibilities

 

Before changing the account, the sponsor should establish which Certificates of Sponsorship and sponsored workers are currently associated with the Level 2 User.

This is important because Level 2 access is restricted by CoS ownership.

The review should identify:

 

• which CoS the user created and assigned;
• which CoS have been transferred to the user;
• which sponsored workers the individual currently administers;
• whether any reportable worker events are outstanding;
• whether any sponsorship actions are awaiting completion; and
• whether responsibility needs to be transferred to another user.

 

This review can help prevent sponsorship responsibilities from being overlooked during the change in user access.

If the Level 2 User is being deactivated rather than converted, this step is particularly important because another authorised user will need to assume responsibility for relevant sponsorship activity.

 

7. An Existing Level 1 User Must Make the Change

 

The change from Level 2 to Level 1 requires appropriate action through the sponsor’s user-management arrangements.

A Level 2 User cannot simply give themselves Level 1 permissions.

A Level 1 User must take the relevant action within the SMS to convert an eligible Level 2 User to Level 1 or deactivate the Level 2 account, subject to the particular user-management functionality available.

Sponsors should therefore check that they have functioning Level 1 access before attempting to deal with their remaining Level 2 accounts.

Employers should also allow sufficient time for the process. They should not assume that every user-management change will necessarily take effect immediately, as some changes or circumstances may require Home Office consideration or further action.

 

8. What If the Sponsor Has No Active Level 1 User?

 

A more serious issue arises where the sponsor discovers that it has no active Level 1 User with access to the SMS.

The Home Office requires sponsors to maintain an eligible Authorising Officer and at least one eligible Level 1 User throughout the life of the sponsor licence.

If there is no Level 1 User with working SMS access, the sponsor cannot simply rely on an existing Level 2 User to administer the licence indefinitely or promote themselves to Level 1.

The sponsor will need to use the applicable change of circumstances process to request the necessary Level 1 User arrangements.

This should be addressed promptly. Failure to maintain the required Key Personnel and SMS access arrangements can expose the sponsor licence to compliance action and, in applicable circumstances, revocation.

Employers reviewing Level 2 accounts should therefore use the exercise to confirm that their wider Key Personnel arrangements remain compliant and operational.

 

9. Review Security and Authentication Arrangements

 

Where a user is given continuing SMS access, the employer should ensure that the individual’s account and authentication arrangements remain properly controlled.

The Home Office is rolling out mandatory multi-factor authentication across SMS accounts. It is already mandatory for organisations granted a sponsor licence on or after 9 September 2026 and is being introduced to existing sponsors on a phased basis, expected to be completed by November 2026. Each authorised user should use their own account and authentication details.

Credentials and authentication information should not be shared between employees or used as a workaround where another individual does not have authorised SMS access.

This is particularly important during the Level 2 transition. If a Level 2 account is deactivated, the former user should not continue accessing the SMS through a colleague’s Level 1 account.

 

10. Update Internal Sponsorship Controls After Conversion

 

Converting the account should not be the final step.

Where an existing Level 2 User becomes a Level 1 User, the sponsor should consider whether its internal sponsorship procedures need to be updated to reflect the individual’s broader access.

This may include reviewing:

 

• the individual’s documented responsibilities;
• internal authority to assign CoS;
• approval procedures for sponsorship decisions;
• worker reporting responsibilities;
• access to wider sponsor licence functions;
• escalation procedures for unusual or high-risk cases;
• training requirements;
• absence and contingency arrangements; and
• oversight by the Authorising Officer.

 

These are governance considerations rather than a suggestion that every sponsor is subject to an identical prescribed internal approval structure.

The objective is to ensure that the individual’s practical authority within the organisation reflects the wider technical access they now hold within the SMS.

 

11. Do Not Leave Conversion Until the Deadline

 

Sponsors should complete their Level 2 User review and any necessary conversion or deactivation work in advance of the Home Office deadline.

Waiting until the final days of the transitional period creates unnecessary risk, particularly where the employer discovers an eligibility issue, lacks sufficient Level 1 coverage or needs to reorganise responsibility for a significant number of sponsored workers.

The transition should therefore be treated as a planned sponsor governance exercise rather than a last-minute account administration task.

By the end of the process, the employer should know:

 

• which former Level 2 Users will hold Level 1 access;
• which Level 2 accounts will be deactivated;
• who is responsible for each affected group of sponsored workers;
• who will perform the sponsorship functions previously undertaken by Level 2 Users;
• whether sufficient Level 1 coverage exists; and
• whether internal procedures, training and oversight have been updated to reflect the new access structure.

 

This approach can help the organisation reach the end of the Level 2 transition with a deliberate and workable SMS structure rather than simply replacing restricted accounts with broader Level 1 access.

 

 

Back to top

 

 

Section I: Who Can Become a Level 1 User?

 

Not every existing Level 2 User can be converted to a Level 1 User.

Before changing an existing Level 2 account, the sponsor must establish that the individual satisfies the applicable Home Office requirements for Level 1 Users.

Eligibility depends on both the general requirements applying to sponsor licence Key Personnel and the specific requirements applying to Level 1 Users.

This is important because existing Level 2 status does not provide an automatic route to Level 1 access. The sponsor should assess the individual against the requirements that apply at the time the change is made.

 

1. Employees of the Sponsor

 

Employees of the sponsoring organisation can potentially act as Level 1 Users where they meet the applicable requirements.

For many sponsors, employees involved in HR, recruitment, global mobility or immigration compliance will form the core of the organisation’s Level 1 User arrangements.

However, being employed by the sponsor does not by itself mean that the individual should be given Level 1 access.

The sponsor should also consider whether the person:

 

• meets the applicable Home Office eligibility requirements;
• has an appropriate role within the organisation;
• understands the sponsor’s immigration compliance responsibilities;
• requires direct SMS access to perform their duties;
• has received appropriate training for the functions they will perform; and
• can be appropriately supervised within the sponsor’s governance arrangements.

 

The Level 2 transition should therefore involve both an eligibility assessment and an operational access decision.

 

2. External Representatives

 

In certain circumstances, an eligible UK-based representative can be appointed as an additional Level 1 User.

This can include an appropriate representative providing immigration-related services to the sponsor, where the relevant Home Office requirements are satisfied.

However, employers should not interpret this as allowing an external representative automatically to replace the sponsor’s required internal Level 1 arrangements.

The Home Office rules distinguish between the Level 1 User arrangements that the sponsor is required to maintain and circumstances in which additional Level 1 Users can be appointed.

Where an existing Level 2 User is an external representative, the sponsor should therefore check the individual’s precise status and the current requirements before seeking to convert their account.

 

3. Employees of an Outsourced HR Provider

 

The sponsor rules can also allow an employee of an organisation providing outsourced HR services to the sponsor to act as an additional Level 1 User where the applicable requirements are met.

This can be relevant where a business uses an external HR provider to support its sponsorship administration.

Again, the important distinction is that eligibility to act as an additional Level 1 User should not be confused with eligibility to satisfy the sponsor’s required primary Level 1 User arrangements.

Sponsors using outsourced HR support should ensure that they continue to maintain the required internal Key Personnel and Level 1 arrangements while determining whether external personnel can also hold authorised SMS access.

 

4. Temporary Staff Supplied by an Employment Business

 

A specific issue arises for existing Level 2 Users who are temporary staff supplied to the sponsor by an employment business.

Where such an individual already held Level 2 access before the Home Office stopped new Level 2 appointments, they may continue to operate under the transitional arrangements while their existing Level 2 account remains active.

However, temporary staff supplied by an employment business and not employed by the sponsor cannot be converted to Level 1 Users.

This means that affected sponsors cannot simply preserve the existing arrangement by upgrading the individual’s SMS permissions.

Instead, the employer will need to identify an eligible person to take responsibility for the SMS functions currently performed by the Level 2 User.

This may require the sponsor to:

 

• identify all sponsorship activities currently performed by the temporary worker;
• identify the CoS and sponsored workers currently associated with that user;
• allocate responsibility to an eligible Level 1 User;
• deal with any outstanding sponsorship actions;
• ensure sufficient knowledge is transferred to the replacement user; and
• deactivate the Level 2 account before the transitional arrangements end.

 

The individual may still be able to provide administrative assistance outside the SMS where appropriate, but they cannot continue direct SMS activity by using another person’s credentials.

 

5. Existing Level 2 Status Does Not Guarantee Level 1 Eligibility

 

Sponsors should avoid assuming that the Home Office has already established an individual’s suitability for Level 1 access merely because that person is an existing Level 2 User.

The two roles have different permissions and the applicable appointment requirements are not identical.

The employer should therefore carry out a fresh assessment before conversion.

This is particularly important where the Level 2 User was appointed some time ago and the individual’s circumstances have subsequently changed.

For example, the sponsor should consider whether the person:

 

• still works for or provides services to the organisation in the capacity originally relied upon;
• continues to satisfy the applicable Key Personnel requirements;
• falls within a category permitted to hold Level 1 access;
• has changed employment status;
• has moved to a different role or organisation; or
• remains an appropriate person to have broader access to the sponsor licence.

 

A historic Level 2 appointment should therefore not be treated as sufficient evidence that conversion is permitted.

 

6. Eligibility and Appropriateness Are Different Questions

 

Even where an existing Level 2 User is legally eligible to become a Level 1 User, the sponsor should separately decide whether granting Level 1 access is appropriate.

This distinction is particularly important because Level 1 access can provide materially broader SMS functionality than the individual previously held.

The employer should consider the principle of limiting access to those who genuinely require it to perform their sponsorship responsibilities.

For example, an existing Level 2 User may only assign a small number of CoS each year. If those assignments can reasonably be handled by an existing Level 1 User, the organisation may decide that granting another person broader SMS access is unnecessary.

Conversely, where a Level 2 User manages a substantial volume of sponsorship activity, conversion may be operationally important to maintain effective administration after the Level 2 role disappears.

The decision should therefore take account of:

 

• the volume and nature of the individual’s sponsorship work;
• the functions they need to perform;
• the sensitivity of the additional SMS functionality they would receive;
• the organisation’s existing number of Level 1 Users;
• business continuity and absence cover;
• the individual’s sponsorship knowledge and training;
• internal approval and supervision arrangements; and
• the sponsor’s wider compliance governance.

 

7. The Sponsor Must Maintain Appropriate Level 1 Coverage

 

The Level 2 transition should also be considered in the context of the sponsor’s wider obligation to maintain appropriate Key Personnel and SMS access.

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

This means employers should not assess individual Level 2 accounts in isolation.

They should consider whether the organisation will have sufficient Level 1 coverage once all Level 2 accounts have been converted or deactivated.

For example, a sponsor may technically have one Level 1 User but rely heavily on several Level 2 Users for operational activity. Removing those Level 2 accounts without reviewing capacity could leave the organisation dependent on a single person for substantial volumes of sponsorship administration.

That may create practical risks during periods of annual leave, sickness, staff turnover or other absence.

Home Office guidance recommends that a Level 1 User accesses the SMS regularly, including at least once a month, and sponsors should ensure that their Level 1 arrangements remain active and workable rather than existing only nominally.

 

8. Check the Current Level 1 Requirements Before Conversion

 

The Level 1 User eligibility rules are more detailed than is necessary to reproduce within this Level 2 User guide.

Employers should therefore check the current requirements when deciding whether a particular Level 2 User can be converted.

The separate Level 1 User: Sponsor Licence Role & Responsibilities guide considers those requirements in detail, including who can hold Level 1 access and the restrictions that apply.

For the purposes of the Level 2 transition, the key principle is that conversion is neither automatic nor available to every existing Level 2 User.

The employer should establish eligibility first, decide whether continued direct SMS access is genuinely necessary and then consider whether the broader permissions associated with Level 1 access are appropriate for that individual.

Where any of those conditions are not satisfied, the sponsor should make alternative arrangements for the person’s existing sponsorship responsibilities and deactivate the Level 2 account within the transitional period.

 

 

Back to top

 

 

Section J: What If a Level 2 User Cannot Become a Level 1 User?

 

If an existing Level 2 User cannot meet the requirements for Level 1 access, the sponsor cannot preserve their SMS access simply because the individual currently performs important sponsorship work.

The employer will need to deactivate the Level 2 User account and reallocate the individual’s SMS responsibilities to an eligible authorised user before the Level 2 arrangements end.

This makes early planning particularly important where an organisation relies heavily on an existing Level 2 User who cannot be converted.

The practical objective should be to identify everything the individual currently does within the Sponsor Management System and ensure that another authorised user can take responsibility without disrupting the organisation’s sponsorship administration.

 

1. Identify Why the Level 2 User Cannot Be Converted

 

The sponsor should first establish why the individual cannot become a Level 1 User.

The reason may affect how the organisation restructures its sponsorship arrangements.

For example, the individual may:

 

• not satisfy the applicable general requirements for Key Personnel;
• not satisfy the specific requirements applying to Level 1 Users;
• fall within a category that cannot hold the required Level 1 access;
• be temporary staff supplied by an employment business and not employed by the sponsor;
• no longer have the employment or contractual relationship on which their existing access was based;
• no longer require direct SMS access because their responsibilities have changed; or
• be eligible in principle, but the sponsor may decide that granting broader Level 1 permissions would not be appropriate.

 

The last point is important. A Level 2 User does not necessarily need to be legally ineligible for the sponsor to decide against conversion.

Employers may conclude that the person should not receive Level 1 access because their role does not justify the broader SMS permissions involved.

 

2. Identify Everything the Level 2 User Currently Does

 

Before deactivating the account, the sponsor should identify the sponsorship functions currently performed by the Level 2 User.

This review should be practical rather than limited to the individual’s job title.

The employer should establish whether the user currently:

 

• creates Certificates of Sponsorship;
• assigns Certificates of Sponsorship;
• administers particular groups of sponsored workers;
• makes worker reports through the SMS;
• maintains information needed for sponsorship reporting;
• coordinates sponsorship activity with recruitment or HR teams;
• monitors changes affecting sponsored workers; or
• provides operational cover for another SMS User.

 

The sponsor can then determine which of those functions require direct SMS access and which can continue to be performed as administrative support outside the system.

 

3. Review the CoS Owned by the Level 2 User

 

The sponsor should also identify the Certificates of Sponsorship currently owned by the Level 2 User.

This is particularly important because a Level 2 User’s ability to view, manage and report against CoS is restricted by CoS ownership.

The review should identify:

 

• CoS created by the Level 2 User;
• CoS previously transferred to the Level 2 User;
• the sponsored workers associated with those CoS;
• any current sponsorship issues affecting those workers;
• any outstanding reporting obligations; and
• who will assume responsibility when the Level 2 account is deactivated.

 

Where necessary, the sponsor should use the appropriate SMS functionality to ensure that responsibility for relevant CoS and workers is placed with an authorised user who can continue to administer them.

The employer should avoid deactivating an account first and only afterwards attempting to determine which workers the individual was responsible for.

 

4. Reallocate SMS Responsibilities

 

Any SMS functions that still need to be performed must be allocated to an appropriately authorised user.

Depending on the sponsor’s existing structure, this could involve:

 

• an existing Level 1 User assuming the responsibilities;
• converting another eligible Level 2 User to Level 1;
• appointing an additional eligible Level 1 User;
• reorganising responsibility between members of the HR or global mobility team; or
• using an eligible external representative or outsourced HR provider as an additional Level 1 User where the applicable requirements are satisfied.

 

The sponsor should ensure that the replacement arrangement is operational before the existing Level 2 access disappears.

This includes ensuring that the replacement user understands the responsibilities they are taking over and has access to the information required to perform them.

 

5. Temporary Agency Staff Need Alternative Arrangements

 

Temporary staff supplied by an employment business require particular attention because they cannot simply be converted from Level 2 to Level 1 where they are not employed by the sponsor.

If an organisation has historically relied on such a person for significant sponsorship administration, the removal of Level 2 access can create an immediate operational gap.

The sponsor should therefore identify an eligible replacement and complete an orderly handover before the existing account is deactivated.

The handover may need to cover:

 

• current sponsored worker cases;
• CoS that have already been assigned;
• planned future sponsorship;
• outstanding worker changes;
• reporting deadlines;
• internal sponsorship records;
• communications with sponsored workers and managers; and
• any cases requiring escalation or further review.

 

Where the individual continues providing services to the organisation after their SMS access ends, the employer should clearly distinguish between administrative support and actions that require an authorised SMS User.

 

6. A Former Level 2 User Can Still Provide Administrative Support

 

Loss of direct SMS access does not necessarily mean that the individual must cease all involvement in sponsorship administration.

Depending on their role and the organisation’s arrangements, a former Level 2 User may still be able to assist with work outside the SMS.

For example, they may:

 

• collect information required for a CoS;
• prepare sponsorship information for review;
• maintain internal immigration records;
• monitor internal dates and deadlines;
• liaise with sponsored workers and managers;
• prepare information concerning potential reportable events;
• support right to work and onboarding processes; or
• assist an authorised Level 1 User with sponsorship administration.

 

However, where an action must be carried out within the SMS, it must be completed by an appropriately authorised user through their own account.

The former Level 2 User should not be given another person’s login or authentication details as a workaround.

 

7. Do Not Share SMS Credentials

 

Employers should not respond to the withdrawal of Level 2 access by informally allowing former users to access the SMS through another person’s account.

SMS credentials and authentication arrangements are individual to the authorised user.

Allowing several employees to operate through a single Level 1 account undermines the sponsor’s access controls and makes it more difficult to establish who carried out particular sponsorship activity.

If an individual requires direct access to perform SMS functions, the correct approach is to determine whether they can be properly authorised for the relevant user role.

If they cannot hold authorised access, the SMS activity should be performed by somebody who can.

 

8. Check Whether the Sponsor Has Sufficient Level 1 Capacity

 

Where Level 2 Users cannot be converted, the sponsor should consider whether its remaining Level 1 Users have sufficient capacity to absorb their work.

This can be particularly important for employers that have historically used multiple Level 2 Users to distribute sponsorship administration across different sites, departments or business units.

Moving all of those responsibilities to a small number of Level 1 Users could create operational bottlenecks.

The sponsor should consider:

 

• how many sponsored workers it manages;
• how frequently CoS are assigned;
• how often worker reports need to be made;
• how sponsorship work is divided between teams;
• whether there is sufficient cover for absence;
• whether existing Level 1 Users have appropriate training;
• whether additional eligible Level 1 Users are required; and
• whether internal processes need to change.

 

The Home Office requires the sponsor to maintain at least one eligible Level 1 User, but maintaining the minimum required access does not necessarily mean that the organisation has sufficient operational capacity for its particular sponsorship activity.

Employers should therefore distinguish between the minimum Home Office requirement and their own governance and business continuity needs.

 

9. Complete the Handover Before Deactivating the Account

 

Where a Level 2 User cannot be converted, the sponsor should complete the handover of their responsibilities before deactivating the account wherever practicable.

A structured handover can include:

 

1. identifying the user’s existing SMS responsibilities;
2. identifying the CoS and workers associated with the user;
3. checking for outstanding sponsorship actions;
4. identifying an eligible replacement user;
5. transferring relevant information and operational knowledge;
6. reallocating CoS or worker responsibility where necessary;
7. confirming that the replacement user has the required SMS access;
8. updating internal procedures and responsibility records; and
9. deactivating the Level 2 account when the transition is complete.

 

This sequencing can help reduce the risk of reporting responsibilities, CoS activity or worker issues being missed during the transition.

 

10. Do Not Wait for Automatic Home Office Deactivation

 

Where the sponsor already knows that a Level 2 User cannot or should not become a Level 1 User, it should make its alternative arrangements during the transitional period.

Relying on the Home Office eventually deactivating the account does not address the underlying operational issue.

The organisation should know who will assume the individual’s responsibilities, how relevant sponsored workers will be managed and whether sufficient authorised SMS access remains in place.

The sponsor remains responsible to the Home Office for actions carried out through its SMS Users, while the Authorising Officer remains responsible for overseeing SMS Users and their activities.

The removal of a Level 2 User should therefore be managed as part of the sponsor’s wider compliance governance rather than treated solely as deletion of an obsolete account.

 

 

Back to top

 

 

Section K: Employer Risks When Changing SMS Access

 

The withdrawal of the Level 2 User role creates more than an administrative deadline for sponsors. It can also create compliance, governance and operational risks if existing SMS access arrangements are changed without sufficient planning.

For some employers, Level 2 Users have been responsible for substantial parts of day-to-day sponsorship administration. For others, the role has deliberately been used to give employees restricted SMS access without granting the broader permissions available to Level 1 Users.

Simply converting every Level 2 User to Level 1, or alternatively deactivating accounts without reviewing the work attached to them, can therefore create different types of risk.

The sponsor should use the transition to review who has SMS access, why they have it, what they are authorised to do and how their activity is supervised.

 

1. Granting Unnecessary Level 1 Access

 

One of the clearest risks is automatically converting existing Level 2 Users to Level 1 without considering whether they require the additional access.

Level 2 Users historically operated with restricted permissions. Level 1 Users can access considerably broader sponsor licence functionality, subject to the particular licence, sponsored routes, licence status and functions available within the SMS.

Conversion can therefore materially change what an individual is able to see and do.

Before conversion, employers should consider:

 

• why the individual was originally given Level 2 rather than Level 1 access;
• which SMS functions they currently use;
• whether they need broader licence-management functionality;
• whether their role justifies that additional access;
• whether they have sufficient knowledge and training;
• whether existing Level 1 Users could perform the relevant functions instead; and
• whether the organisation’s internal controls remain appropriate once broader access is granted.

 

The fact that an individual is eligible to become a Level 1 User does not necessarily mean that the sponsor should grant them Level 1 access.

 

2. Losing Operational Capacity

 

The opposite risk arises where a sponsor deactivates Level 2 accounts without understanding how much sponsorship work those users perform.

An organisation may technically retain an eligible Level 1 User while still losing significant operational capacity when its Level 2 Users disappear.

For example, existing Level 2 Users may currently be responsible for:

 

• creating and assigning CoS;
• administering sponsored workers;
• making permitted worker reports;
• monitoring sponsorship changes;
• supporting recruitment activity involving sponsored workers; or
• providing cover when other SMS Users are unavailable.

 

If these responsibilities are moved to a small number of remaining Level 1 Users, the organisation may create bottlenecks or excessive reliance on individual employees.

Sponsors should therefore consider operational capacity as well as technical compliance when designing their post-Level 2 SMS structure.

 

3. Missing Sponsor Reporting Deadlines

 

Changes to SMS responsibility can increase the risk of reportable events being overlooked.

This can happen where a Level 2 User previously monitored particular sponsored workers but their account is deactivated without clearly reallocating responsibility.

For example, one team may assume that another employee is responsible for reporting a change when responsibility has never formally been reassigned.

Employers should therefore identify any live or anticipated reporting issues as part of the Level 2 transition.

Where a user is being converted, replaced or removed, the sponsor should establish:

 

• which sponsored workers the user currently administers;
• whether any reportable events have already occurred;
• whether any reporting deadlines are running;
• whether relevant information is still being gathered;
• who will make the report where one is required; and
• who will monitor those workers after the change.

 

Changing an SMS account does not pause or extend the sponsor’s underlying reporting responsibilities.

 

4. Losing Visibility of CoS Ownership

 

CoS ownership is particularly important when dealing with Level 2 Users because their ability to view, manage and report against Certificates of Sponsorship is restricted by ownership.

If the sponsor deactivates a Level 2 account without first identifying the CoS and workers associated with that user, it can create confusion over who is responsible for ongoing sponsorship administration.

Employers should therefore map relevant CoS ownership before changing access.

The review should identify:

 

• CoS created by the Level 2 User;
• CoS transferred to the Level 2 User;
• workers associated with those CoS;
• outstanding sponsorship activity; and
• the authorised user who will assume responsibility.

 

For organisations with significant sponsored worker populations, this may require a structured handover rather than simply changing the user’s account status.

 

5. Shared SMS Credentials

 

A significant compliance risk arises if employers respond to reduced SMS access by allowing employees to share accounts.

SMS access is personal to the authorised user. Login credentials and authentication information should not be shared so that another person can carry out sponsorship activity through an account that is not their own.

This means a former Level 2 User should not continue performing SMS functions by logging into a colleague’s Level 1 account after their own access has been deactivated.

Shared access also undermines accountability because it becomes difficult to establish which individual actually performed an action recorded against a particular SMS account.

If an employee needs direct SMS access, the sponsor should determine whether that individual can be properly authorised for the appropriate role. If they cannot, SMS actions should be completed by somebody who is authorised.

 

6. Stale and Unnecessary SMS Accounts

 

The Level 2 transition also provides an opportunity to identify SMS accounts that should no longer exist.

Over time, sponsors can accumulate user accounts belonging to people whose responsibilities have changed or who rarely use the system.

This may include users who:

 

• have moved to another role;
• have left the organisation;
• no longer perform sponsorship work;
• were originally given access for a temporary project;
• have responsibilities now handled by another team; or
• no longer require direct access to the SMS.

 

Employers should not convert stale Level 2 accounts merely to preserve them.

The transition should instead be used to remove unnecessary access and ensure that remaining SMS permissions reflect current organisational responsibilities.

 

7. Insufficient Level 1 User Coverage

 

Employers should also consider whether they will have sufficient Level 1 User coverage after Level 2 access disappears.

The Home Office requires sponsors to maintain at least one eligible Level 1 User, but relying on a single individual may create practical vulnerabilities for an organisation with substantial sponsorship activity.

For example, the sole active Level 1 User could be:

 

• on annual leave;
• absent through illness;
• unavailable when an urgent sponsorship action is required;
• moving to another role;
• working their notice period; or
• leaving the organisation unexpectedly.

 

For sponsors with significant sponsored worker populations, multiple sites or frequent CoS activity, appropriate contingency arrangements may therefore be important.

This is a governance consideration rather than a statement that every sponsor is required to appoint multiple Level 1 Users.

The organisation should determine the level of coverage appropriate to its sponsorship activity and risk profile.

 

8. Inadequate Knowledge Transfer

 

Where a Level 2 User has been responsible for particular sponsored workers or sponsorship processes for a significant period, they may hold substantial operational knowledge.

Simply deactivating their SMS account does not transfer that knowledge to another user.

A proper handover may therefore need to cover:

 

• current sponsored workers;
• planned sponsorship applications;
• CoS already assigned;
• worker changes that may require reporting;
• internal deadlines;
• cases awaiting information;
• ongoing immigration applications;
• previous sponsorship decisions; and
• internal records or processes used to manage compliance.

 

Employers should ensure that relevant information is retained within organisational systems rather than depending on the knowledge of a single SMS User.

 

9. Insufficient Training for Newly Converted Level 1 Users

 

An existing Level 2 User may understand the functions they have historically performed but have limited experience of the wider SMS functionality available to Level 1 Users.

Conversion should therefore be accompanied by appropriate training where required.

This may include training on:

 

• the individual’s new SMS permissions;
• sponsor reporting responsibilities;
• CoS management;
• changes to sponsor details;
• internal escalation procedures;
• the organisation’s approval controls;
• record keeping and audit trails;
• security and authentication requirements; and
• when specialist advice should be sought.

 

The extent of training required will depend on the user’s responsibilities and the functions the sponsor expects them to perform.

Providing broader system access without ensuring that the user understands how that access should be exercised can increase rather than reduce compliance risk.

 

10. Weak Authorising Officer Oversight

 

The Authorising Officer has an important oversight role in relation to the sponsor’s SMS Users and sponsorship arrangements.

The Level 2 transition should therefore not be managed solely as a technical IT or HR administration exercise.

The Authorising Officer should have appropriate visibility over:

 

• who currently has SMS access;
• which Level 2 Users will be converted;
• which accounts will be deactivated;
• why individuals require Level 1 access;
• how sponsorship responsibilities are being redistributed; and
• whether appropriate controls and supervision remain in place.

 

Home Office sponsor guidance recommends that the Authorising Officer checks the Certificates of Sponsorship assigned to workers at least once a month.

This provides an important governance context for the Level 2 transition. Sponsors should ensure that changes to user access do not weaken oversight of CoS activity or make it unclear who is carrying out sponsorship functions.

 

11. Confusing Home Office Requirements with Internal Governance Measures

 

Employers should distinguish between actions specifically required by the Home Office and additional controls adopted by the organisation as part of good sponsorship governance.

For example, the Home Office determines matters such as who can hold particular SMS roles and the permissions available to those users.

An employer may separately decide to require:

 

• internal approval before a CoS is assigned;
• second-person review of particular sponsorship decisions;
• periodic internal access reviews;
• additional training before a user performs specified functions;
• documented handover procedures when an SMS User leaves; or
• internal registers showing responsibility for sponsored workers.

 

These additional controls can support effective sponsor management, but they should not be presented as universal Home Office requirements unless the applicable guidance expressly requires them.

Keeping this distinction clear helps employers understand both their mandatory sponsor duties and the additional governance measures they have chosen to implement.

 

12. Failing to Maintain Active Level 1 Access

 

Sponsors should ensure that Level 1 access remains active and usable throughout the transition.

The Home Office requires an eligible Authorising Officer and at least one eligible Level 1 User to remain in place throughout the life of the sponsor licence.

A sponsor that discovers it has no active Level 1 User with SMS access should address the position promptly through the applicable Home Office process.

Employers should not assume that an existing Level 2 User can compensate for the absence of the required Level 1 arrangements.

The Level 2 transition therefore provides a useful trigger for sponsors to review their wider Key Personnel arrangements as well as the individual accounts being withdrawn.

 

13. Treat the Level 2 Transition as a Governance Exercise

 

The safest approach is to treat the withdrawal of Level 2 access as a review of the organisation’s sponsorship governance rather than merely an exercise in changing user permissions.

By the end of the transition, the sponsor should be able to identify:

 

• every person with authorised SMS access;
• why each person requires that access;
• which functions each user is expected to perform;
• who is responsible for particular sponsored workers and sponsorship activity;
• how SMS activity is supervised;
• how responsibilities are covered during absence or staff changes;
• how users are trained for the functions they perform; and
• how unnecessary access is identified and removed.

 

The sponsor remains responsible to the Home Office for actions carried out through its SMS Users, while the Authorising Officer is responsible for overseeing SMS Users and their activities.

A controlled transition from Level 2 access can therefore do more than meet the immediate Home Office deadline. It can also provide an opportunity to strengthen the organisation’s wider management of sponsor licence access, accountability and compliance.

 

 

Back to top

 

 

Section L: Level 2 User Transition Checklist

 

Employers with existing Level 2 Users should complete a structured review of their Sponsor Management System arrangements before the Level 2 role is withdrawn.

The purpose of the review is not simply to identify which accounts need changing. Sponsors should also establish who currently performs each sponsorship function, whether continued SMS access is required, whether the individual is eligible for Level 1 access and how responsibility for sponsored workers will be maintained after the transition.

The following checklist provides a practical framework for managing the change.

 

1. Identify Every Existing Level 2 User

 

Start by identifying all existing Level 2 User accounts connected with the sponsor licence.

For each user, record:

 

• the individual’s name;
• their role within or relationship with the organisation;
• the department, business unit or location they support;
• why they were originally given Level 2 access;
• whether they still use the SMS;
• which sponsorship functions they currently perform; and
• whether they are expected to require direct SMS access after the Level 2 role ends.

 

This exercise may identify dormant or unnecessary accounts that do not need to be replaced.

 

2. Decide Whether Continued SMS Access Is Necessary

 

For each existing Level 2 User, determine whether direct access to the SMS is genuinely required.

An individual may still be involved in sponsorship administration without necessarily needing their own SMS account.

For example, they may be able to continue preparing information, maintaining internal records, monitoring dates or supporting an authorised Level 1 User without personally carrying out actions within the SMS.

Where direct access is no longer necessary, the employer should plan to deactivate the Level 2 account rather than automatically convert it.

 

3. Check Eligibility for Level 1 Access

 

Where continued SMS access is required, determine whether the individual is eligible to become a Level 1 User.

Existing Level 2 status does not automatically establish Level 1 eligibility.

Eligibility depends on the individual meeting the applicable general requirements for Key Personnel and the specific requirements applying to Level 1 Users.

Particular care should be taken where the existing Level 2 User is:

 

• an external representative;
• an employee of an outsourced HR provider;
• a contractor;
• temporary staff supplied by an employment business; or
• someone whose relationship with the sponsor has changed since their original appointment.

 

Temporary staff supplied by an employment business and not employed by the sponsor cannot be converted from Level 2 to Level 1.

 

4. Decide Whether Broader Level 1 Access Is Appropriate

 

Where the individual is eligible for Level 1 access, the sponsor should separately decide whether giving them broader SMS permissions is appropriate.

The employer should consider:

 

• what the individual currently does in the SMS;
• why they historically held Level 2 rather than Level 1 access;
• which additional functionality they would receive as a Level 1 User;
• whether their responsibilities justify that additional access;
• whether they have appropriate knowledge and training;
• whether their activity can be adequately supervised; and
• whether another existing Level 1 User could perform the relevant functions.

 

This prevents the transition from becoming an automatic upgrade of every restricted account to broader Level 1 access.

 

5. Identify the CoS and Workers Associated with Each Level 2 User

 

For each Level 2 User, identify the Certificates of Sponsorship and sponsored workers for which they currently have responsibility.

This is important because a Level 2 User’s ability to view, manage and report against CoS is restricted by CoS ownership.

The review should establish:

 

• which CoS the Level 2 User created;
• which CoS have been transferred to them;
• which sponsored workers they currently administer;
• whether any sponsorship actions remain outstanding;
• whether any worker changes may require reporting; and
• who will assume responsibility if the Level 2 account is deactivated.

 

This information should be established before access is removed.

 

6. Convert Eligible Users Where Continued Access Is Required

 

Where an existing Level 2 User is eligible for Level 1 access, genuinely requires continued access and the sponsor considers the broader permissions appropriate, the employer should take the necessary steps to convert the user.

The relevant change will ordinarily need to be made by an appropriately authorised Level 1 User through the available SMS user-management functionality.

Employers should allow sufficient time for the process and should not assume that every change will necessarily be instantaneous, particularly where Home Office consideration or additional action is required.

Once the change has been completed, the sponsor should confirm that the user’s access operates as expected and that the individual understands their revised responsibilities.

 

7. Deactivate Users Who Will Not Be Converted

 

Where a Level 2 User will not become a Level 1 User, the sponsor should plan for the account to be deactivated.

Before deactivation, confirm that:

 

• necessary sponsorship responsibilities have been reassigned;
• relevant CoS and sponsored workers have been identified;
• outstanding reporting matters have been addressed or allocated;
• another authorised user can perform the required SMS functions;
• necessary knowledge and records have been transferred; and
• the former user understands that they must not access the SMS through another person’s account.

 

Where possible, the handover should be completed before the account is removed rather than attempting to reconstruct the user’s responsibilities afterwards.

 

8. Reallocate Sponsorship Responsibilities

 

Changing the user’s account does not itself reallocate the operational work previously performed by that person.

The sponsor should expressly determine who will take responsibility for:

 

• future CoS creation and assignment;
• existing sponsored workers;
• worker reporting;
• monitoring sponsorship-related changes;
• internal sponsorship records;
• liaison with recruitment and HR teams; and
• urgent sponsorship issues.

 

For larger sponsors, this may require responsibilities to be redistributed between several Level 1 Users rather than transferred to a single individual.

 

9. Check Level 1 User Capacity and Business Continuity

 

Review whether the organisation will have sufficient Level 1 User capacity after all Level 2 accounts have been dealt with.

The sponsor must maintain at least one eligible Level 1 User, but the minimum requirement may not provide sufficient operational resilience for every organisation.

Consider factors such as:

 

• the number of sponsored workers;
• the volume of CoS activity;
• the frequency of sponsor reporting;
• the number of operating locations or business units;
• annual leave and sickness cover;
• staff turnover;
• planned recruitment involving sponsorship; and
• the ability to deal with urgent SMS actions.

 

Where necessary, the sponsor should consider appointing additional eligible Level 1 Users rather than becoming excessively dependent on one individual.

This is a business continuity and governance consideration rather than a requirement for every sponsor to maintain multiple Level 1 Users.

 

10. Update Internal Procedures and Access Records

 

Once the future user structure has been decided, update internal sponsorship procedures to reflect the new arrangements.

This can include documenting:

 

• who has Level 1 access;
• which functions each user is expected to perform;
• who is responsible for particular sponsored worker groups;
• internal CoS approval arrangements;
• worker reporting responsibilities;
• escalation procedures;
• absence and contingency arrangements; and
• how SMS access will be reviewed when staff roles change.

 

These measures form part of the employer’s internal governance arrangements and should not be confused with separate mandatory Home Office requirements unless expressly required by the sponsor guidance.

 

11. Provide Training Where Responsibilities Change

 

Existing Level 2 Users who become Level 1 Users may require additional training because their SMS access and responsibilities can become significantly broader.

Training should reflect the functions the individual will actually perform and may cover:

 

• Level 1 SMS functionality;
• CoS management;
• sponsor and worker reporting;
• internal authorisation procedures;
• record keeping;
• security and authentication;
• escalation of unusual sponsorship issues; and
• the sponsor’s internal compliance controls.

 

Relevant replacement users should also receive an effective handover where they are assuming responsibility previously held by a Level 2 User.

 

12. Check Contact, Authentication and SMS Access Arrangements

 

The sponsor should ensure that remaining SMS Users can access their accounts correctly and that their details are current.

Each authorised user should operate through their own SMS account and authentication arrangements. Credentials should not be shared.

Mandatory multi-factor authentication is being rolled out across SMS access. It already applies to organisations granted a sponsor licence on or after 9 September 2026 and is being introduced to existing sponsors on a phased basis, expected to be completed by November 2026. Employers should ensure that users understand and can operate the applicable authentication process when MFA applies to their account.

The Home Office also recommends that Level 1 Users access the SMS regularly, including at least once a month, and keep their user details up to date.

This is particularly important where an organisation has several Level 1 Users but some accounts are rarely used. An account that exists on paper but is not actively maintained may provide less effective operational resilience than the sponsor assumes.

 

13. Confirm Authorising Officer Oversight

 

The Authorising Officer should have appropriate oversight of the revised SMS access structure.

The sponsor remains responsible to the Home Office for actions carried out through its SMS Users, while the Authorising Officer is responsible for overseeing SMS Users and their activities.

As part of the transition, the Authorising Officer should understand:

 

• which Level 2 Users currently exist;
• which users are being converted;
• which users are being deactivated;
• who will hold Level 1 access afterwards;
• how sponsorship responsibilities are being redistributed; and
• whether adequate supervision and continuity arrangements remain in place.

 

Home Office guidance recommends that the Authorising Officer checks the Certificates of Sponsorship assigned to workers at least once a month.

The transition provides an opportunity to ensure that this oversight remains effective under the organisation’s new user structure.

 

14. Complete the Transition Before the Deadline

 

Sponsors should aim to complete the review, conversion, handover and deactivation process before the end of the transitional period.

The key date is 8 March 2027.

Employers should not rely on automatic Home Office deactivation as their transition strategy. By the time the Level 2 role disappears, the organisation should already have a functioning replacement structure in place.

This means confirming that:

 

• all existing Level 2 Users have been reviewed;
• eligible users requiring continued access have been dealt with appropriately;
• users who will not continue have been or will be deactivated;
• sponsorship responsibilities have been reassigned;
• affected CoS and sponsored workers have been accounted for;
• adequate Level 1 User coverage exists;
• relevant users have been trained;
• internal procedures have been updated; and
• the Authorising Officer understands the final access structure.

 

15. Level 2 User Transition Action Table

 

Action	Key Question	Employer Response
Identify Level 2 Users	Who currently holds Level 2 access?	Create a complete list of existing Level 2 accounts
Review operational need	Does the individual still require direct SMS access?	Retain only where continued access is genuinely required
Check eligibility	Can the individual satisfy the applicable Level 1 requirements?	Assess current eligibility before conversion
Review broader access	Should the individual receive Level 1 permissions?	Consider role, responsibilities, training and governance
Map CoS ownership	Which CoS and workers does the Level 2 User currently manage?	Identify ownership and outstanding sponsorship activity
Convert eligible users	Is continued Level 1 access required and appropriate?	Take the necessary user-management action in sufficient time
Deactivate other users	Will the Level 2 User cease to have SMS access?	Complete the handover and deactivate the account
Reallocate responsibilities	Who will perform the user’s existing sponsorship functions?	Assign responsibility to an appropriately authorised user
Check Level 1 capacity	Will sufficient operational coverage remain?	Consider additional eligible Level 1 Users where appropriate
Update procedures	Do internal controls reflect the new access structure?	Update responsibilities, approvals and contingency arrangements
Train users	Do new or converted Level 1 Users understand their responsibilities?	Provide role-appropriate training and handover
Check access arrangements	Are user details, authentication and accounts current?	Confirm individual access and remove inappropriate or stale arrangements
Confirm AO oversight	Does the Authorising Officer understand and supervise the new structure?	Review access, responsibility and ongoing oversight arrangements
Complete transition	Will the sponsor be ready before 8 March 2027?	Complete necessary changes before the Level 2 role ends

 

The transition should leave the sponsor with a deliberate SMS access structure in which each authorised user has a clear purpose, appropriate permissions and defined sponsorship responsibilities.

For employers with multiple Level 2 Users, large sponsored worker populations or decentralised sponsorship administration, the review may also provide an opportunity to strengthen wider sponsor licence governance before the Level 2 role disappears.

 

 

Back to top

 

 

Section M: Common Questions About Level 2 Users

 

Can a Sponsor Still Appoint a New Level 2 User?

No. Sponsors have not been able to appoint new Level 2 Users since 9 September 2026.

The role is being phased out of the Sponsor Management System. The transitional arrangements apply only to individuals who already held Level 2 access.

An employer that now needs another person to access the SMS will need to consider whether that individual can be appointed as a Level 1 User under the applicable Home Office requirements.

 

Can an Existing Level 2 User Still Access the SMS?

Yes. Existing Level 2 Users can continue to use their accounts during the transitional period, subject to the permissions and restrictions applying to the Level 2 role.

The sponsor should, however, review each existing account and decide whether the user should be converted to Level 1, where eligible and appropriate, or whether their Level 2 account should be deactivated.

 

When Does the Level 2 User Role End?

Existing Level 2 User accounts need to be dealt with by 8 March 2027.

By that point, sponsors should have converted eligible Level 2 Users who require continued access to Level 1 or deactivated accounts that are no longer required or cannot be converted.

The Home Office has stated that remaining Level 2 User accounts will be deactivated after the deadline.

 

Can a Level 2 User Assign a Certificate of Sponsorship?

Yes. An existing Level 2 User can create and assign Certificates of Sponsorship, subject to the functions available to the user and the status and sponsored routes on the organisation’s licence.

Technical permission to assign a CoS does not determine whether the proposed sponsorship is compliant. The sponsor must still ensure that the relevant sponsorship and immigration requirements are satisfied and that the information entered on the CoS is accurate.

 

Can a Level 2 User Access Defined CoS?

A Level 2 User cannot access the Defined CoS submenu within the Workers section of the SMS.

A Level 2 User cannot access the Defined CoS submenu and therefore cannot apply for, create or assign a Defined Certificate of Sponsorship. Their separate ability to report worker activity remains subject to the ordinary Level 2 ownership rules for CoS transferred to them by a Level 1 User.

Functions requiring access to the Defined CoS submenu will need to be handled through the appropriate Level 1 access.

 

Can a Level 2 User Report Changes About Sponsored Workers?

Yes, but only within the restrictions applying to Level 2 access.

A Level 2 User can report activity relating to a CoS they own. This includes CoS they created and assigned themselves and CoS that have been transferred to them through the appropriate SMS functionality.

They do not automatically have access to report against every sponsored worker under the organisation’s licence.

 

Can a CoS Be Transferred to a Level 2 User?

Yes. During the remaining transitional period, a CoS can be transferred to an existing Level 2 User through the appropriate SMS functionality.

This can allow the Level 2 User to view, manage and report against the CoS within the functions available to their role.

Transferring the CoS does not expand the individual’s wider SMS permissions. They remain a Level 2 User and continue to be subject to the restrictions applying to that role.

 

Can a Level 2 User Manage the Sponsor Licence?

Not generally. Level 2 Users have restricted operational access rather than the broader licence-management functionality available to Level 1 Users.

They cannot access the Licence summary, applications and services functions available through appropriate Level 1 access and cannot carry out the wider range of sponsor licence administration associated with the Level 1 role.

 

Can a Level 2 User Change the Sponsor’s Details?

A Level 2 User does not have the broader licence-management permissions required to make general changes to the sponsor’s licence details.

Changes requiring the relevant licence-management functionality need to be dealt with through an appropriately authorised Level 1 User or, where applicable, through the relevant Home Office process.

 

Can a Level 2 User Be Converted to a Level 1 User?

Yes, where the individual satisfies the applicable requirements for Level 1 access and the sponsor decides that continued SMS access is required and appropriate.

Eligibility depends on the individual meeting the applicable general requirements for Key Personnel and the specific requirements for Level 1 Users.

Employers should also consider that Level 1 access is materially broader than Level 2 access. Conversion should therefore not be treated merely as an administrative change of user title.

 

Will a Level 2 User Automatically Become a Level 1 User?

No. There is no automatic conversion from Level 2 to Level 1.

The sponsor needs to review the individual, determine whether continued SMS access is necessary, check whether they are eligible for Level 1 access and decide whether the broader permissions are appropriate.

If conversion is not appropriate, the Level 2 account should be deactivated and the individual’s SMS responsibilities should be reallocated.

 

Can Temporary Agency Staff Be Converted from Level 2 to Level 1?

No, where the individual is temporary staff supplied to the sponsor by an employment business and is not employed by the sponsor.

An affected individual who already held Level 2 access may continue using that existing access during the transitional period, subject to the applicable rules, but they cannot be converted to a Level 1 User.

The sponsor will therefore need to identify another eligible person to take over the SMS functions currently performed by that Level 2 User.

 

Can an External Representative Become a Level 1 User?

In certain circumstances, an eligible UK-based representative can act as an additional Level 1 User, provided the applicable Home Office requirements are met.

Similar provisions can apply to eligible employees of outsourced HR providers.

This should not be interpreted as meaning that an external representative can automatically act as the sponsor’s sole or primary Level 1 User. The sponsor must continue to satisfy the specific Home Office requirements governing its required Level 1 User arrangements.

 

What Happens If a Sponsor Does Nothing Before 8 March 2027?

The Home Office has stated that remaining Level 2 User accounts will be deactivated after the transitional deadline.

This can create an operational problem if the organisation still relies on those users to assign CoS, administer sponsored workers or make permitted reports.

Sponsors should therefore complete the transition in advance and ensure that responsibility for affected sponsorship activity has been transferred to appropriately authorised users.

 

Should Every Existing Level 2 User Be Converted to Level 1?

No. Automatic conversion is not necessarily appropriate.

The sponsor should consider both eligibility and operational need.

A Level 2 User may no longer require direct SMS access, or their existing responsibilities may be capable of being handled by another Level 1 User. In other cases, the individual may not be eligible for Level 1 access or the sponsor may decide that giving them broader Level 1 permissions would be inappropriate.

The transition should therefore be used to review access rather than simply preserve every existing user account.

 

Can a Former Level 2 User Still Help with Sponsorship Administration?

Yes. A person does not necessarily need direct SMS access to assist with sponsorship administration.

A former Level 2 User may, depending on their role, continue to collect information, prepare sponsorship records, maintain internal files, monitor relevant dates, liaise with workers or managers and support an authorised Level 1 User.

However, actions that need to be completed within the SMS must be carried out by an appropriately authorised user through their own account.

 

Can a Former Level 2 User Use a Level 1 User’s Login?

No. SMS access credentials and authentication arrangements are personal to the authorised user and should not be shared.

A former Level 2 User should not continue accessing the SMS through another person’s Level 1 account after their own authorised access ends.

If direct SMS access is required, the employer should determine whether the individual can properly be appointed to an eligible user role. Otherwise, the relevant SMS activity should be carried out by somebody who is authorised.

 

What Should Employers Do Now About Existing Level 2 Users?

Employers should identify all existing Level 2 Users and carry out a structured review of each account.

For each user, the sponsor should establish:

 

• whether continued SMS access is required;
• whether the individual is eligible for Level 1 access;
• whether granting broader Level 1 permissions is appropriate;
• which CoS and sponsored workers the user currently manages;
• whether any sponsorship actions or reports are outstanding;
• who will take responsibility if the account is deactivated;
• whether sufficient Level 1 User capacity will remain; and
• whether training, handover or changes to internal procedures are required.

 

The employer should then convert eligible users where continued Level 1 access is required and appropriate, or deactivate Level 2 accounts after the necessary responsibilities have been transferred.

The objective should be to complete the transition before 8 March 2027 with a clear, controlled and operationally effective SMS access structure.

 

Back to top

 

 

Section N: Need Assistance?

 

The withdrawal of the Level 2 User role requires sponsors with existing Level 2 accounts to review their Sponsor Management System access arrangements and decide how sponsorship responsibilities will be managed going forward.

For some employers, the change will be relatively straightforward. For others, particularly organisations with multiple Level 2 Users, decentralised sponsorship functions or significant sponsored worker populations, the transition may require a wider review of SMS access, Key Personnel arrangements and sponsorship governance.

DavidsonMorris advises employers on all aspects of sponsor licence management and Home Office compliance.

We can assist with:

 

• reviewing existing Level 2 User arrangements;
• assessing whether continued SMS access is required;
• considering Level 1 User eligibility and appointment requirements;
• reviewing existing Level 1 User and Key Personnel arrangements;
• identifying sponsorship responsibilities currently held by Level 2 Users;
• reviewing CoS ownership and responsibility for sponsored workers;
• planning the transfer of sponsorship responsibilities before Level 2 accounts are deactivated;
• reviewing the governance implications of providing broader Level 1 access;
• supporting changes to SMS user arrangements;
• reviewing sponsor reporting and record-keeping procedures;
• developing internal sponsorship processes and controls;
• training Authorising Officers, Level 1 Users and relevant HR personnel;
• conducting sponsor licence compliance audits; and
• advising on wider sponsor licence compliance risks identified during the transition.

 

Where an existing Level 2 User cannot be converted to Level 1, we can also help employers determine how their existing sponsorship responsibilities should be reallocated and whether additional eligible Level 1 User arrangements are required.

The transition can also provide an opportunity to review whether the organisation’s existing SMS access structure remains appropriate more generally, including whether user access reflects current roles, whether sufficient operational cover exists and whether the Authorising Officer has appropriate oversight of sponsorship activity.

Employers should aim to complete any necessary changes before the Level 2 User transitional arrangements end, rather than relying on the Home Office to deactivate remaining accounts.

For advice on Level 2 Users, Level 1 User arrangements or wider sponsor licence management, speak to our business immigration specialists.

 

Back to top

 

 

Section O: Conclusion

 

The Level 2 User role is being withdrawn from the Sponsor Management System, requiring employers with existing Level 2 accounts to review how those users and their sponsorship responsibilities will be managed.

Since 9 September 2026, sponsors have not been able to appoint new Level 2 Users. Existing Level 2 Users can continue to operate during the transitional period within the permissions and restrictions applying to their accounts, but those arrangements are temporary.

By 8 March 2027, sponsors should have dealt with their remaining Level 2 User accounts by either converting eligible users to Level 1 where continued access is required and appropriate, or deactivating the accounts and reallocating their responsibilities.

Employers should not treat conversion as an automatic administrative replacement for Level 2 access.

A Level 1 User has materially broader access to the SMS than a Level 2 User. Before conversion, the sponsor should therefore establish both that the individual meets the applicable Level 1 User requirements and that providing the individual with broader SMS access is appropriate for their role.

Where a Level 2 User cannot be converted, the employer should identify the sponsorship functions they currently perform and ensure those responsibilities are transferred to an appropriately authorised user before their access ends.

Particular attention should be given to:

 

• which Level 2 User accounts remain active;
• whether each user still requires direct SMS access;
• whether the individual is eligible to become a Level 1 User;
• whether broader Level 1 access is appropriate;
• which Certificates of Sponsorship and sponsored workers the individual currently manages;
• whether any worker reports or sponsorship actions are outstanding;
• who will assume responsibility where the Level 2 account is deactivated;
• whether sufficient Level 1 User capacity will remain;
• whether users require additional training or handover; and
• whether internal sponsorship procedures need to be updated.

 

CoS ownership is particularly important during this exercise because a Level 2 User’s ability to view, manage and report against Certificates of Sponsorship is restricted by ownership. Sponsors should therefore understand which CoS are associated with each Level 2 User before changing or removing their access.

Employers should also pay particular attention to Level 2 Users who are temporary staff supplied by an employment business and are not employed by the sponsor. While an existing user in this position may continue under the transitional Level 2 arrangements, they cannot be converted to Level 1 and alternative arrangements will therefore be required.

The sponsor must continue to maintain an eligible Authorising Officer and at least one eligible Level 1 User. The sponsor also remains responsible to the Home Office for actions carried out through its SMS Users, while the Authorising Officer is responsible for overseeing SMS Users and their activities.

The withdrawal of Level 2 access should therefore be treated as more than an account-management exercise. It provides sponsors with an opportunity to review who has access to the SMS, why that access is required, how sponsorship responsibilities are allocated and whether appropriate supervision and business continuity arrangements are in place.

By completing this review before the transitional arrangements end, employers can move away from the Level 2 User structure with a controlled and workable SMS access model that supports ongoing sponsor licence management and compliance.

 

Back to top

 

 

Section P: Glossary

 

Term	Meaning
Authorising Officer	The Authorising Officer is the senior person appointed by the sponsor with responsibility for the organisation’s sponsor licence and for overseeing the activities of its SMS Users. The sponsor remains responsible to the Home Office for actions carried out through its SMS Users, while the Authorising Officer is responsible for overseeing those users and their activities.
Certificate of Sponsorship (CoS)	A Certificate of Sponsorship (CoS) is an electronic sponsorship record created and assigned through the Sponsor Management System to an individual whom the organisation intends to sponsor under an eligible immigration route. A CoS is not a paper certificate or an immigration permission. It contains information about the worker, the proposed role and the sponsorship and generates a reference number that the worker can use as part of the relevant immigration application.
CoS Ownership	CoS ownership is particularly relevant to Level 2 Users because their ability to view, manage and report against a Certificate of Sponsorship is restricted by ownership. A Level 2 User can access relevant CoS functionality in relation to CoS they personally created and assigned, as well as CoS transferred to them by a Level 1 User through the appropriate SMS functionality. They do not automatically have access to every CoS assigned under the organisation’s sponsor licence.
Defined Certificate of Sponsorship	A Defined Certificate of Sponsorship is a type of CoS used in specified Skilled Worker sponsorship circumstances where the applicable immigration and sponsorship rules require a Defined CoS. For the purposes of Level 2 User permissions, Level 2 Users cannot access the Defined CoS submenu within the Workers section of the SMS and therefore cannot apply for, create or assign a Defined CoS. Their separate ability to report worker activity remains subject to the ordinary Level 2 ownership rules for CoS transferred to them by a Level 1 User.
Home Office	The Home Office is the UK government department responsible for the immigration system, including the operation and regulation of the sponsorship system. It grants sponsor licences, publishes sponsor guidance, operates the Sponsor Management System and can take compliance action against sponsors that fail to meet their sponsorship duties.
Key Personnel	Key Personnel are individuals appointed by an organisation to specified roles connected with the management of its sponsor licence. The roles include the Authorising Officer, Key Contact and Level 1 User. The individuals appointed must satisfy the applicable Home Office requirements for their respective roles.
Key Contact	The Key Contact is the person who acts as the sponsor’s main point of contact with UK Visas and Immigration in relation to the sponsor licence. The Key Contact role is distinct from SMS user permissions. Whether the individual can access the SMS depends on whether they also hold an appropriate SMS User role.
Level 1 User	A Level 1 User is an authorised user of the Sponsor Management System with access to a broad range of sponsor licence and sponsorship functions, subject to the organisation’s licence type, sponsored routes, licence status and the specific functionality available within the SMS. Level 1 Users can perform functions that are not available to Level 2 Users, including broader licence-management and user-management functions, subject to the applicable SMS permissions. Sponsors are required to maintain at least one eligible Level 1 User throughout the life of the sponsor licence.
Level 2 User	A Level 2 User is an existing SMS User with more restricted permissions than a Level 1 User. Existing Level 2 Users can create and assign Certificates of Sponsorship and can report worker activity relating to CoS they own, meaning CoS they created and assigned themselves or CoS transferred to them by a Level 1 User. They do not have the broader licence-management access available to Level 1 Users and cannot access the Defined CoS submenu within the Workers section of the SMS. No new Level 2 Users can be appointed from 9 September 2026. Existing Level 2 Users must be converted to Level 1 where eligible and continued access is required, or deactivated, by 8 March 2027.
Multi-Factor Authentication (MFA)	Multi-factor authentication (MFA) is the additional authentication process used to help protect access to the Sponsor Management System. Mandatory MFA is being rolled out across SMS accounts and already applies to organisations granted a sponsor licence on or after 9 September 2026, with phased rollout to existing sponsors expected to be completed by November 2026. SMS Users should use their own account and authentication arrangements. Login credentials and authentication information should not be shared between users.
Sponsor	A sponsor is an organisation that holds a Home Office sponsor licence allowing it to sponsor eligible workers under applicable UK immigration routes. The sponsor is responsible for complying with the duties attached to its licence and remains responsible for actions carried out through its authorised SMS Users.
Sponsor Licence	A sponsor licence is the authorisation granted by the Home Office that enables an eligible organisation to sponsor qualifying workers under the immigration routes covered by its licence. Holding a sponsor licence brings ongoing duties relating to matters including record keeping, reporting, sponsored worker management and compliance with the sponsorship system.
Sponsor Management System (SMS)	The Sponsor Management System (SMS) is the Home Office online system used by licensed sponsors to administer their sponsor licence and carry out permitted sponsorship functions. Depending on the user’s role and permissions, SMS functions can include assigning Certificates of Sponsorship, reporting changes relating to sponsored workers, managing aspects of the sponsor licence and administering authorised users.
SMS User	An SMS User is an individual who has been given authorised access to the Sponsor Management System. The functions available to an SMS User depend on their user role and the permissions available within the system. Following the withdrawal of the Level 2 role, Level 1 User arrangements will become increasingly important for organisations that need multiple people to carry out sponsorship activity through the SMS.
SMS User Deactivation	Deactivation means removing an individual’s authorised access to the Sponsor Management System. Where an existing Level 2 User is being deactivated, the sponsor should first consider whether the individual has responsibility for CoS, sponsored workers, outstanding reports or other sponsorship activity that needs to be transferred to another authorised user.
Sponsored Worker	A sponsored worker is an individual sponsored by a licensed organisation under an eligible work immigration route. The sponsor has ongoing responsibilities in relation to sponsored workers, including specified reporting and record-keeping duties under the applicable sponsor guidance.
Sponsorship Duties	Sponsorship duties are the ongoing obligations imposed on organisations holding a sponsor licence. They include duties relating to record keeping, reporting specified changes, complying with immigration law, monitoring sponsored workers and cooperating with the Home Office. How individual tasks are allocated between employees or SMS Users does not remove the sponsor’s overall responsibility for complying with these duties.
Temporary Agency Staff	For the purposes of the Level 2 User transition, temporary agency staff refers to temporary staff supplied to the sponsor by an employment business rather than employed by the sponsor. Where such an individual already held Level 2 access before the September 2026 change, they may continue to use their existing Level 2 account during the transitional period, subject to the applicable rules. However, they cannot be converted to a Level 1 User. The sponsor will therefore need alternative arrangements if the individual currently performs SMS functions that will still be required after Level 2 access ends.
User Management	User management refers to the SMS functions used to administer authorised users, including relevant actions relating to user access and roles. Level 1 Users have user-management capabilities subject to the specific permissions available within the SMS. Level 2 Users do not have the same user-management functionality.
Level 2 User Transition Period	The Level 2 User transition period is the period following the Home Office’s decision to stop allowing new Level 2 User appointments from 9 September 2026 while permitting existing Level 2 Users to continue temporarily. Sponsors should use this period to review existing Level 2 accounts and either convert eligible users to Level 1 where continued access is necessary and appropriate, or deactivate those accounts and transfer their responsibilities. The key transition deadline is 8 March 2027, after which the Home Office has stated that remaining Level 2 User accounts will be deactivated.

 

Back to top

 

 

Section Q: Useful Links

The following Home Office guidance and Sponsor Management System resources provide the primary official information relevant to Level 2 Users, Level 1 Users and the management of SMS access.

 

Resource	URL
Workers and Temporary Workers: Guidance for Sponsors – Part 1 Home Office – Workers and Temporary Workers: Guidance for Sponsors, Part 1: Apply for a Licence This is the principal sponsor guidance covering Key Personnel and SMS Users. It contains the current Level 2 User transitional provisions, including the rule preventing new Level 2 User appointments from 9 September 2026 and the requirement to convert eligible existing users to Level 1 or deactivate their accounts by 8 March 2027.	https://www.gov.uk/government/publications/workers-and-temporary-workers-guidance-for-sponsors-part-1-apply-for-a-licence
SMS Guide 1: Introduction and Managing User Access Home Office – SMS Guide 1: Introduction and Managing User Access This manual explains the different levels of SMS access, managing SMS Users and the restrictions applying to Level 2 Users. It confirms that Level 2 Users have restricted access, including restrictions on licence-management functions and the Defined CoS submenu, and that their ability to view and report against CoS is limited by CoS ownership.	https://www.gov.uk/government/publications/use-the-sponsorship-management-system-sms-user-manual
SMS Guide 2: Managing Your Sponsorship Licence Home Office – SMS Guide 2: Managing Your Sponsorship Licence This manual provides practical guidance on managing sponsor licence information through the SMS, including Key Personnel, licence details and other sponsor management functions.	https://www.gov.uk/government/publications/manage-your-sponsorship-licence-sms-user-manual
SMS Guide 8: Creating and Assigning a Certificate of Sponsorship Home Office – SMS Guide 8: Creating and Assigning a CoS This manual explains the technical process for creating and assigning Certificates of Sponsorship through the Sponsor Management System. It is relevant to existing Level 2 Users because creating and assigning CoS remains one of the limited SMS functions available to the role during the transitional period.	https://www.gov.uk/government/publications/creating-and-assigning-a-cos-sms-guide-8
Defined Certificate of Sponsorship: SMS Guide 12 Home Office – Defined Certificate of Sponsorship: SMS Guide 12 This manual explains how sponsors apply for, manage and assign Defined Certificates of Sponsorship. Level 2 Users cannot access the Defined CoS submenu within the Workers section of the SMS, making this functionality an important distinction between Level 1 and Level 2 access.	https://www.gov.uk/government/publications/restricted-certificate-of-sponsorship-sms-guide-12
Home Office Sponsorship Guidance Collection Home Office – Sponsorship: Guidance for Employers and Educators The Home Office sponsorship collection provides access to current sponsor guidance, SMS manuals and related official resources. Sponsors should refer to the current versions of the relevant guidance when managing their licence and SMS Users. Important: Home Office sponsorship guidance and SMS functionality can change. Employers should check the current version of the relevant guidance when making changes to Level 1 or Level 2 User arrangements and should ensure that all remaining Level 2 User accounts are addressed before the 8 March 2027 transition deadline.	https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators

 

Back to top