A Sponsor Licence does not manage itself.
Someone within the organisation has to take responsibility for it, somebody needs to deal with the Home Office, and somebody needs access to the Sponsor Management System.
This is where Sponsor Licence key personnel come in.
When applying for a Sponsor Licence, an organisation will normally need to nominate people to fulfil three principal roles:
- Authorising Officer
- Key Contact
- Level 1 User
For many small businesses, the immediate reaction is:
“Do I need three different employees?”
Usually, no.
The same person can potentially perform more than one of these roles, provided they meet the relevant requirements. In a small owner-managed company, it is quite common for a director or senior employee to take on several sponsorship responsibilities.
The more important question is who should be appointed.
This is not something we would decide simply by choosing whoever happens to be available when the Sponsor Licence application is being completed.
The people named on the licence become part of the organisation’s sponsorship arrangements. Their circumstances can affect the application, and once the licence is granted they may have significant responsibility for keeping the business compliant.
So it is worth getting the structure right at the beginning.
What are Sponsor Licence key personnel?
The Home Office requires Sponsor Licence applicants to nominate certain people who will be responsible for managing different aspects of the organisation’s sponsorship activities.
These are collectively referred to as key personnel.
The principal roles are the Authorising Officer, Key Contact and Level 1 User.
They have different functions.
- The Authorising Officer carries senior responsibility for sponsorship.
- The Key Contact acts as the principal point of contact between the sponsor and UKVI.
- The Level 1 User carries out much of the practical work through the Sponsor Management System.
There can also be Level 2 Users, who have more restricted SMS access, although they are not one of the three principal roles an organisation initially needs to think about.
UKVI sets requirements concerning who can hold these roles, where they are based and their relationship with the sponsor. GOV.UK guidance on sponsorship management roles
The structure sounds more complicated than it normally is. For a large organisation, several different people may be involved. For a small company, it might largely be one director.
Both can work.
Who should be the Authorising Officer?
The Authorising Officer is the senior person responsible for the organisation’s Sponsor Licence and the activities of the people who use the sponsorship system.
This is therefore not a role we would normally give to a junior administrator simply because they happen to be good with online forms.
The Authorising Officer should have sufficient authority within the organisation to oversee sponsorship properly.
For a small company, a director is often the natural choice.
In a larger organisation, it might be a senior HR professional, HR director, operations director or another suitably senior employee.
The exact job title matters less than the person’s position and responsibilities.
What we want is somebody who can genuinely say:
“I have oversight of sponsorship within this organisation and can make sure our duties are being met.”
That is fundamentally what the role is about.
Does the Authorising Officer use the Sponsor Management System?
This is where employers sometimes become confused.
The Authorising Officer role does not automatically mean that the person carries out every daily SMS task.
They may also be appointed as a Level 1 User, in which case they can have the appropriate SMS access.
But the roles are conceptually different.
The Authorising Officer is about overall responsibility and oversight.
The Level 1 User is about operational access and management of the SMS.
In a five-person business, those may be the same person.
In a company employing 5,000 people, they may quite reasonably be different.
The sponsorship structure should reflect the organisation rather than trying to force every company into the same model.
Can a company director be the Authorising Officer?
Yes, and for many smaller companies this is the obvious arrangement.
A director who genuinely runs the business will usually understand its employees, recruitment needs and organisational structure.
That can make them well placed to oversee sponsorship.
However, being a director does not automatically mean somebody satisfies every Home Office requirement for key personnel.
Their immigration status, location, history and relationship with the organisation still need to be considered.
This is why we normally check the proposed key personnel as part of the Sponsor Licence preparation rather than simply entering the directors listed at Companies House.
What does the Key Contact do?
The Key Contact is the main point of contact between the organisation and UKVI.
The Home Office may communicate with the Key Contact about the Sponsor Licence and sponsorship matters.
In practice, this role is often less operationally visible than the Level 1 User.
That does not make it unimportant.
The contact information needs to remain current, and somebody should actually monitor the relevant communications.
There is little value in appointing somebody as Key Contact if their email inbox resembles an archaeological excavation.
Home Office correspondence should reach somebody who will see it and deal with it.
For smaller businesses, the Key Contact is often also the Authorising Officer or Level 1 User.
Can an immigration adviser be the Key Contact?
Potentially, yes, subject to the relevant Home Office requirements.
The sponsorship rules allow certain representatives to act in relevant sponsorship roles, but there are restrictions on who can hold particular positions and the organisation itself must retain appropriate responsibility for its licence.
This distinction is important.
A professional representative can help prepare and manage sponsorship matters.
But a Sponsor Licence does not become the adviser’s licence.
It remains the employer’s.
The organisation remains responsible for complying with its sponsorship duties.
That is why good professional support should help a business manage sponsorship properly rather than create a situation where nobody inside the company knows what is happening.
What is a Level 1 User?
For most employers, the Level 1 User is the key day-to-day operational role.
This person has access to the Sponsor Management System and can perform important sponsorship activities.
Depending on the permissions and circumstances, Level 1 activity can include matters such as assigning Certificates of Sponsorship, viewing licence information, managing certain users, making reports and requesting changes or additional CoS allocation.
The Level 1 User therefore has considerable practical control over the Sponsor Licence.
This is not a login to hand around the office.
The person appointed should understand what they are doing and why.
A Level 1 User who knows how to navigate SMS but does not understand sponsorship rules can still create serious problems.
In some ways, that can be more dangerous than somebody who does not know how to use the system at all.
At least the second person is less likely to confidently press the wrong button.
Who can be the Level 1 User?
The Home Office places specific requirements on Level 1 Users.
For a new Sponsor Licence application, at least one Level 1 User must normally be an employee, director or partner of the organisation and meet the relevant status requirements.
There are limited exceptions and particular provisions depending on the type of organisation and sponsorship arrangement.
This is one area where it is important to check the current rules rather than rely on an old Sponsor Licence article.
The Home Office has changed the requirements concerning key personnel and SMS users over time.
For most ordinary businesses, however, the starting point is straightforward:
identify a suitable senior or responsible person within the organisation who meets the requirements and can genuinely manage the sponsorship system.
Can the Authorising Officer also be the Level 1 User?
Yes, where the individual meets the requirements for both roles.
This is extremely common in smaller businesses.
For example, imagine a company with:
- two directors;
- four employees; and
- no dedicated HR department.
It would make little sense to invent an elaborate sponsorship hierarchy merely to make the application look impressive.
One director might reasonably be:
Authorising Officer + Key Contact + Level 1 User.
That can be perfectly workable.
Alternatively, the director could act as Authorising Officer while an experienced office or HR manager becomes the Level 1 User.
The right arrangement depends on who actually runs the relevant parts of the business.
Do you need three different people for a Sponsor Licence?
No.
This is one of the simplest misconceptions to clear up. The three principal roles do not necessarily require three different individuals. One suitable person can potentially hold all three roles. Two people can divide them. Or a larger organisation can allocate them separately.
The question is not:
“How do we find three names?”
It is:
“Who is best placed to perform these responsibilities?”
For a small company, simplicity is often preferable.
Adding people unnecessarily can create more SMS access, more changes to manage when employees leave and more potential confusion over who is actually responsible.
What is a Level 2 User?
A Level 2 User has more limited Sponsor Management System permissions than a Level 1 User.
They can be useful where an organisation wants somebody to perform certain routine sponsorship functions without giving them the broader access available to Level 1 Users.
Not every business needs Level 2 Users. For a small company sponsoring one or two employees, they may add very little. For a larger organisation with several HR staff and significant sponsorship activity, restricted user access can be useful.
The principle should be the same as with any important business system:
give people the access they need to do their job, rather than giving everybody access to everything.
What requirements must key personnel meet?
The Home Office applies suitability requirements to key personnel.
Current public guidance states that the organisation and its proposed key personnel must satisfy requirements concerning matters including criminal history, immigration compliance and previous involvement with sponsorship.
For example, certain unspent criminal convictions can prevent a person from being suitable, including specified immigration offences and offences such as fraud or money laundering.
UKVI can also consider previous Sponsor Licence history and other relevant conduct. GOV.UK Sponsor Licence eligibility guidance
This does not mean that every historical issue automatically prevents somebody from being appointed. The exact rules and circumstances need to be considered. But if there is something potentially relevant in a proposed key person’s history, it should be looked at before the Sponsor Licence application is submitted.
Does immigration status matter for key personnel?
Yes.
The Home Office imposes immigration-status requirements on people holding certain sponsorship roles.
In particular, at least one Level 1 User for a new application will normally need to satisfy specific requirements concerning their status and relationship with the sponsor. This can become important in small businesses where the directors themselves hold temporary immigration permission.
It does not automatically mean the organisation cannot obtain a Sponsor Licence.
It means the key personnel structure needs to be planned properly.
Suppose a company has two directors and both are in the UK on time-limited visas.
Rather than submitting the application and discovering a key personnel issue afterwards, we would want to establish at the outset who can fulfil each role and whether any alternative arrangement is required.
Do key personnel need to be based in the UK?
Generally, key personnel are expected to be based in the UK, subject to specific provisions and exceptions in the Sponsor Guidance.
That makes practical sense.
These individuals are responsible for managing a UK Sponsor Licence and interacting with UKVI.
For businesses with international management structures, however, this can require some planning.
A multinational company might have its ultimate HR director based overseas while UK HR operations are handled locally.
The Sponsor Licence roles need to be structured around the Home Office requirements rather than simply copying the company’s global reporting hierarchy.
Can family members be key personnel?
Potentially. There is no universal rule saying that two people cannot both be key personnel simply because they are related.
This comes up quite often in family-run companies.
A husband and wife may both be directors.
A parent and adult child may run the company together.
Two siblings may operate the business.
What matters is whether each person genuinely performs the relevant role and satisfies the requirements.
The Home Office is interested in the reality of the organisation.
Being related does not make somebody unsuitable.
Putting somebody’s name down purely because they are related to the owner and convenient to use is a different matter.
Can an external HR consultant be a Level 1 User?
There are circumstances where representatives and other individuals can have SMS access, but the Home Office places restrictions around external users and the organisation must maintain an appropriate eligible Level 1 User arrangement.
This is an area where businesses should check the current requirements carefully.
The answer should not be assumed merely because somebody manages HR for the company.
The sponsorship rules distinguish between employees, office holders and representatives.
That legal relationship matters.
If an organisation outsources most of its HR function, we would therefore look at who actually meets the Home Office requirements before deciding how SMS access should be structured.
What happens if your Level 1 User leaves?
This is where poor planning becomes visible. Imagine a business appoints its HR manager as its only active Level 1 User. Two years later, the HR manager resigns.
They leave on Friday.
On Monday, the business suddenly needs to assign a Certificate of Sponsorship.
Nobody else has the necessary access.
That is avoidable.
When a person with sponsorship responsibilities leaves, the organisation should consider their Sponsor Licence role as part of the offboarding process.
That includes checking whether they are:
- Authorising Officer;
- Key Contact;
- Level 1 User; or
- Level 2 User.
The relevant access and key personnel arrangements should then be updated properly.
Sponsored businesses should not allow former employees to retain unnecessary access to SMS.
Should you have more than one Level 1 User?
For some businesses, yes.
This is partly a resilience issue.
If only one person has the necessary operational access and that person becomes unavailable, sponsorship activity can become difficult.
A second suitable Level 1 User can provide continuity.
However, this does not mean every business should create multiple users simply for the sake of it.
More access also means more people capable of making sponsorship changes.
For a small company, one carefully chosen primary user plus an appropriate backup may be sufficient.
For a larger sponsor, several Level 1 Users may be sensible.
The structure should reflect the level of sponsorship activity.
Should the Level 1 User be somebody from HR?
Not necessarily.
HR professionals are often excellent choices because they already manage employees, contracts, absence records and recruitment.
But many small businesses do not have HR departments.
A director, operations manager or another suitable senior employee may be perfectly capable of performing the role.
What matters is whether they:
- understand the organisation;
- have access to the necessary employment information;
- can use SMS responsibly;
- know when something needs escalating;
- and have enough time to actually perform the role.
The last point matters.
Appointing the busiest person in the company because they are the most senior can be counterproductive if sponsorship administration permanently sits at number 47 on their to-do list.
Key personnel and Sponsor Licence compliance
Choosing key personnel is not simply part of getting the application approved.
The decision affects how the licence operates afterwards.
The Home Office places ongoing duties on sponsors relating to record keeping, reporting, immigration compliance and monitoring sponsored workers.
Your key personnel structure needs to support those duties.
For example, the Level 1 User may be responsible for reporting changes through SMS.
But how will they know a change has happened?
If line managers handle employee absences, payroll handles salary changes and directors make decisions about office locations, there needs to be some method of getting relevant information to the sponsorship team.
This is where key personnel and HR systems meet.
The strongest arrangement is not necessarily the one with the most people.
It is the one where information reaches the right person at the right time.
Does the Authorising Officer need to know the immigration rules?
They do not need to become an immigration lawyer.
But appointing an Authorising Officer who knows absolutely nothing about the Sponsor Licence is not a particularly convincing compliance structure.
The person should understand at least the basic responsibilities that come with sponsorship.
They should know that the organisation has duties relating to matters such as:
- right-to-work compliance;
- record keeping;
- monitoring;
- reporting relevant changes;
- managing Certificates of Sponsorship; and
- keeping licence information accurate.
Where specialist issues arise, professional advice can be obtained.
The Authorising Officer does not need every answer stored in their head.
They do need to recognise when there is a question that requires an answer.
What if the wrong person was nominated on the application?
It depends on what is wrong.
If the person does not meet the Home Office requirements, this can create a substantive problem with the Sponsor Licence application.
If information is simply inaccurate or circumstances change, the correct response depends on the stage of the application and the nature of the issue.
The worst approach is usually to spot a potential problem and decide:
“We’ll see if they notice.”
Sponsor Licence applications are not improved by crossed fingers.
If an issue with proposed key personnel is identified before submission, deal with it before submission.
If it is identified afterwards, establish the appropriate corrective action.
Can key personnel affect whether the Sponsor Licence is granted?
Yes.
The Home Office assesses the suitability of the organisation and relevant people involved in sponsorship.
This is why key personnel checks form part of proper Sponsor Licence preparation.
Most applications will not involve dramatic background issues.
Often the exercise is simply confirming:
- Who are these people?
- What is their relationship with the company?
- Are they based appropriately?
- Do they meet the immigration-status requirements?
- Is there any relevant sponsorship history?
- Are they suitable for the role?
If everything is straightforward, excellent.
We have confirmed it rather than assumed it.
What should a small business do?
For a small business, I would generally favour a simple and accountable structure.
Imagine a company with one managing director, an operations manager and five other employees.
One possible arrangement might be:
Managing Director — Authorising Officer and Key Contact
Operations Manager — Level 1 User
Alternatively, if the director is going to personally manage sponsorship:
Managing Director — Authorising Officer, Key Contact and Level 1 User
Either could work if the individuals meet the relevant requirements.
There is no prize for creating the most complicated Sponsor Licence hierarchy.
In fact, the more complicated the structure becomes, the more important it is that everybody knows exactly what they are responsible for.
What should a larger organisation do?
A larger employer may need a different structure.
If the organisation sponsors dozens or hundreds of workers, relying entirely on one director to personally manage SMS would probably be impractical.
Instead, there may be:
a senior HR director as Authorising Officer;
an immigration or global mobility manager as Key Contact;
several appropriately authorised Level 1 Users;
and additional Level 2 Users performing limited functions.
There should also be internal procedures determining who can assign CoS, who approves sponsorship, who reports changes and who reviews compliance.
The principle remains exactly the same.
The structure should fit the organisation.
Key personnel should be reviewed after the licence is granted
The people appointed when a Sponsor Licence is first obtained will not necessarily remain the right people forever.
Businesses change.
Employees leave.
Directors retire.
HR teams expand.
Responsibilities move.
An organisation should therefore periodically review its key personnel and SMS access.
A simple annual review might ask:
- Is the Authorising Officer still appropriate?
- Is the Key Contact information current?
- Who currently has Level 1 access?
- Who has left the organisation?
- Does anybody have access they no longer require?
- Do we have sufficient cover if the principal Level 1 User is unavailable?
This is not particularly exciting compliance work.
Most good compliance work isn’t.
That’s partly why it works.
Common mistakes when choosing Sponsor Licence key personnel
The most common problems are often avoidable.
They include:
- choosing people without checking whether they meet the requirements;
- assuming three separate people must be appointed;
- appointing a junior employee as Authorising Officer without considering seniority;
- using somebody’s name merely because they are available;
- failing to check immigration status;
- misunderstanding the rules for representatives or external HR providers;
- having only one SMS user and no continuity plan;
- failing to update key personnel when somebody leaves;
- allowing former employees to retain SMS access; and
- assuming the Authorising Officer has no responsibility once the licence is granted.
The solution is not complicated.
Decide the structure deliberately.
Preparing key personnel before a Sponsor Licence application
When we prepare a Sponsor Licence application, key personnel are something we prefer to establish relatively early.
There is little value in preparing the entire application and then discovering that the intended Level 1 User does not meet the relevant requirements.
We want to understand the organisation first.
- Who owns it?
- Who runs it?
- Who manages employees?
- Who deals with HR?
- Who will oversee sponsorship?
- Who should actually have SMS access?
Once we know that, the appropriate structure usually becomes fairly obvious.
For a straightforward business, this may take very little time.
Where there are overseas directors, outsourced HR arrangements, previous sponsorship history or unusual corporate structures, it can require closer consideration.
Do you need professional help choosing key personnel?
You can select and nominate Sponsor Licence key personnel yourself.
The Home Office guidance is publicly available, and for many straightforward businesses the eventual structure is not complicated.
But the consequences of choosing incorrectly can be disproportionate to the amount of time it takes to check the position properly beforehand.
Professional preparation is particularly useful where:
- directors hold temporary immigration permission;
- HR is outsourced;
- the organisation has overseas management;
- there has been previous Sponsor Licence involvement;
- the proposed personnel have unusual employment arrangements;
- the business is unsure who should have SMS access; or
- nobody internally has previously managed sponsorship.
This is also why we prefer to deal with key personnel as part of the whole Sponsor Licence application, rather than simply answering the question:
“Whose name goes in this box?”
The box is the easy part.
The important question is whether it is the right person’s name.
Need help with your Sponsor Licence application?
If your business is preparing a Sponsor Licence application, we can review the organisation and establish an appropriate key personnel structure as part of the wider application.
That includes considering the proposed Authorising Officer, Key Contact and Level 1 User, alongside the company’s eligibility, supporting evidence, HR systems and intended sponsorship.
Where the organisation has already obtained its licence, we can also assist with changes to key personnel, SMS users and wider sponsorship-management issues.
A good Sponsor Licence structure should be simple enough that everybody understands it and robust enough that the business is not dependent on one person remembering everything.
Choose the right people at the beginning and a great deal of the administration afterwards becomes easier.
FAQs
1. What are key personnel on a Sponsor Licence?
Key personnel are the people nominated to take responsibility for important aspects of an organisation’s Sponsor Licence. The three principal roles are the Authorising Officer, Key Contact and Level 1 User. They have different responsibilities covering overall sponsorship oversight, communication with the Home Office and practical management of sponsorship through the Sponsor Management System.
2. Can the same person be Authorising Officer, Key Contact and Level 1 User?
Yes, one person can potentially hold all three roles where they meet the relevant Home Office requirements. This is common in smaller businesses where a director manages sponsorship personally. Larger organisations may prefer to divide the responsibilities between several people. The structure should reflect how the organisation genuinely manages sponsorship rather than unnecessarily creating separate roles.
3. Who should be the Authorising Officer for a Sponsor Licence?
The Authorising Officer should be an appropriately senior and competent person with responsibility for overseeing the organisation’s sponsorship activities. In smaller businesses this is often a director. Larger organisations may appoint a senior HR or operations professional. The individual should have sufficient authority to ensure that the organisation properly complies with its sponsorship responsibilities.
4. What does a Sponsor Licence Key Contact do?
The Key Contact acts as the principal contact between the sponsor organisation and the Home Office. They may receive communications relating to the Sponsor Licence and should therefore have current contact details that are properly monitored. The Key Contact can potentially also perform other key personnel roles where they meet the relevant requirements.
5. What is a Level 1 User on a Sponsor Licence?
A Level 1 User has significant access to the Sponsor Management System and performs practical sponsorship activities. Depending on the circumstances, these can include assigning Certificates of Sponsorship, reporting changes, viewing licence information, managing certain users and making sponsorship requests. The person should therefore understand both the SMS and the responsibilities behind the actions they perform.
6. Does a small business need three people for a Sponsor Licence?
No. A small business does not normally need three different individuals simply because there are three principal key personnel roles. One suitable person can potentially act as Authorising Officer, Key Contact and Level 1 User. The important consideration is whether the individual satisfies the relevant requirements and can genuinely perform the responsibilities attached to each role.
7. Can a company director be a Level 1 User?
Yes, a company director can potentially act as a Level 1 User where they satisfy the relevant Home Office requirements. This is common in smaller owner-managed businesses. The director should have sufficient knowledge and availability to manage sponsorship properly, as Level 1 access allows important actions to be taken through the Sponsor Management System.
8. What happens if my Authorising Officer or Level 1 User leaves?
The organisation should review and update its key personnel and SMS arrangements when somebody with sponsorship responsibilities leaves. Their access should not simply remain active indefinitely. Employers should consider succession before departure where possible, particularly if the person is the only Level 1 User, so that necessary sponsorship activities can continue without avoidable disruption.
9. Can an immigration adviser be Sponsor Licence key personnel?
A professional representative can potentially perform certain sponsorship roles where the Home Office rules permit this, but restrictions apply to particular roles and SMS access. The sponsor organisation itself remains responsible for its licence and compliance duties. Employers should therefore establish exactly which role the representative can perform rather than assuming sponsorship responsibility can simply be outsourced completely.
10. Do key personnel affect a Sponsor Licence application?
Yes. The Home Office applies requirements to key personnel and can consider matters including their relationship with the organisation, immigration status, location, relevant criminal history and previous sponsorship involvement. This is why proposed personnel should be checked before submission. An otherwise strong Sponsor Licence application can be unnecessarily complicated by appointing somebody who does not meet the requirements.