If you hold (or you’re about to apply for) a sponsor licence, your key personnel choices are not “form filling”. They are the people the Home Office expects to keep your sponsorship system honest, consistent, and auditable — day in, day out.
When things go wrong, it’s rarely because you didn’t mean to comply. It’s because responsibility was unclear, access was too limited (or too loose), changes weren’t reported on time, or the business quietly drifted away from what was stated in the application.
This guide breaks down the 3 key roles — Authorising Officer, Key Contact, and Level 1 user — plus practical governance tips you can actually implement, so you’re not relying on 1 overworked person and a prayer.
If you’re at the start of the process, you’ll want to read Sponsor Licence Application alongside this, because your key personnel set-up is part of what the Home Office is judging from day 1.
Why key personnel matter more than you think
Your sponsor licence doesn’t run itself. The Home Office’s view is simple: if you want the privilege of sponsoring overseas workers, you must be able to show control.
That control usually shows up in 3 places:
- Decision-making: who is accountable for sponsorship and sign-off.
- Operations: who updates the Sponsor Management System (SMS) correctly and on time.
- Evidence: who can produce records quickly if there’s an audit.
If those 3 areas are fuzzy, you can end up in messy territory — including downgrades, suspension, or revocation. It’s worth reading Sponsor Licence Suspension and Revocation so you’re clear on how serious it can get when the Home Office loses confidence.
And if you’re thinking, “We’re a good business — we’ll be fine,” that’s exactly the trap. Sponsor compliance is mostly about repeatable processes, not good intentions. The practical expectations are set out in Sponsor Licence Compliance.
Authorising Officer: what the role really means
The Authorising Officer (AO) is the senior person the Home Office holds responsible for sponsor compliance. Put bluntly: if your sponsorship house is on fire, the AO is the person expected to explain how it happened — and what you’ve done to fix it.
What the AO should do (in real life)
You’re aiming for someone who can:
- take accountability for sponsor duties and resourcing
- oversee HR and recruitment systems (or at least challenge them intelligently)
- approve key SMS actions (assigning CoS, reporting significant changes, replacing users)
- maintain a culture of compliance, not shortcuts
In smaller organisations, the AO is often a director or senior manager. In larger businesses, it may be HR leadership — but it still needs senior weight.
Common AO mistakes that cause problems
1) Appointing someone “senior on paper” but absent in practice
If the AO is never involved, never reviews risks, and doesn’t understand sponsorship, you’ve created a governance gap.
2) Making the AO the only person who knows what’s going on
This seems safe, but it’s risky. If the AO is off sick, leaves the business, or is simply unavailable during a compliance visit, you can end up scrambling.
3) Forgetting the AO’s role during corporate changes
Mergers, acquisitions, TUPE, new trading names, and address changes can trigger reporting duties and sometimes bigger structural action. If you’ve not built “sponsor reporting” into your change-management process, you’re exposed. The blog Business changes that trigger sponsor reporting is a good reality check.
A good AO mindset
A strong AO doesn’t micromanage the SMS. They make sure:
- the right people are trained
- access and controls are sensible
- reporting deadlines are not missed
- records exist before they’re requested
- there is cover if someone leaves
Key Contact: not just an email address
The Key Contact is your organisation’s main point of contact with UKVI. People sometimes treat this as an admin label — but it can matter a lot when something urgent lands.
What the Key Contact actually does
Depending on how your licence is managed, the Key Contact may:
- receive queries from UKVI and coordinate responses
- help manage requests for extra documents or clarifications
- act as the “communications bridge” between the Home Office and your business
- ensure the right person replies, with the right documents, within the right timeframe
In practice, the best Key Contact is someone who:
- responds quickly and calmly
- understands where HR evidence sits (and how to retrieve it)
- escalates issues early rather than “hoping it goes away”
- can coordinate internal stakeholders (HR, payroll, line managers, directors)
Key Contact pitfalls
1) Choosing someone junior with no authority to chase information
If they can’t get documents from payroll or operations quickly, you can lose valuable time.
2) Using an inbox that nobody checks
This sounds obvious, but it happens more than you’d think — especially in busy HR teams.
3) No cover arrangements
If the Key Contact is on leave and nobody is watching the relevant mailbox, you can miss something time-sensitive.
If you’re getting support from specialists, you might decide to have legal advisers involved in sponsor communications. That’s often part of a broader service approach like Sponsor Licence Applications, where the goal is to reduce risk, not just “get the licence”.
Level 1 users: the people who keep the SMS alive
Your Level 1 user is the day-to-day operator of the Sponsor Management System (SMS). They are often the person who does the reporting, assigns Certificates of Sponsorship, updates work locations, and requests changes.
This is the role where operational discipline matters most — because missed deadlines or incorrect reporting can snowball quickly.
What Level 1 users typically handle
Depending on your set-up and licence rating, a Level 1 user often deals with:
- assigning and managing CoS (including salary/role details)
- reporting sponsored worker changes (start dates, changes to role, work location)
- reporting certain business changes
- tracking key dates and deadlines internally
- maintaining an audit trail of what was done and why
This sits alongside the wider sponsored-worker journey — for example, the visa route itself. If you’re sponsoring under the main work route, Skilled Worker Visa is the core page to understand the end-to-end process.
The biggest Level 1 user risks
1) Only 1 person has Level 1 access
This is one of the most common “how did we end up here?” stories. If that person leaves, is on long-term sick leave, or is simply overwhelmed, you’ve got a live compliance risk.
2) Level 1 user is expected to “just figure it out”
The SMS is not complicated, but sponsor compliance rules can be. A Level 1 user needs training, clear internal rules, and a way to escalate uncertain issues.
3) Poor handover notes
If your Level 1 user changes, you need continuity: login processes, internal trackers, reporting templates, and a clear record-keeping approach.
How many Level 1 users should you have?
There isn’t a single right number, but as a practical baseline:
- Have at least 2 Level 1 users wherever possible.
- Make sure they are in different “risk buckets” (for example, not 2 people who always take leave at the same time).
- Ensure someone senior (often the AO) can step in if needed.
If you’re running sponsorship in a more entrepreneurial structure (including self-sponsorship models), governance is even more important because the Home Office will look closely at genuineness and control. It’s worth understanding the Self-Sponsor Skilled Worker Visa and the broader guide UK Self Sponsorship Visa so you can design a set-up that doesn’t create conflicts of interest or credibility issues.
Where employers get caught out: “governance gaps” you can fix
Most sponsor compliance failures are not “fraud”. They are governance gaps.
Here are the ones that show up repeatedly.
1) No written ownership of sponsorship tasks
If you can’t answer “who does what, and by when?” you’re at risk.
Fix: build a simple RACI:
- Responsible: Level 1 user
- Accountable: Authorising Officer
- Consulted: HR / legal / payroll (as needed)
- Informed: relevant line manager / finance (as needed)
You don’t need fancy software. A 1-page internal document works.
2) Recruitment and sponsorship are operating as 2 separate worlds
If HR recruits, payroll onboards, and sponsorship is treated as a bolt-on admin function, reporting errors become inevitable.
Fix: add sponsor checks into your hiring workflow:
- right-to-work checks (and how they’re recorded)
- role and salary alignment with sponsorship requirements
- start date confirmation and reporting triggers
- work location and hybrid arrangements recorded properly
3) Business changes happen without sponsor reporting being considered
Businesses change. The sponsor licence obligations don’t disappear during a restructure.
Fix: make “sponsor reporting impact” a mandatory question in any change process (new office, new trading name, acquisition, TUPE, etc.). Use Business changes that trigger sponsor reporting as your internal checklist starter.
4) Too much access, or not enough access
Both are dangerous:
- too much access = uncontrolled reporting, inconsistent decisions, messy audit trail
- too little access = single point of failure
Fix: limit Level 1 access to trained individuals, but always have cover.
5) No internal audit routine
If you only check your sponsor records when you panic, you’re already late.
Fix: do a quarterly mini-audit:
- sponsored worker list vs payroll list
- addresses and work locations current
- absences recorded correctly
- CoS details match role reality
- reporting deadlines met and evidenced
This is the kind of approach aligned with Sponsor Licence Compliance — consistent, documented, and ready for scrutiny.
Governance tips that actually work in day-to-day business
Here’s a practical governance model you can implement without turning your HR team into a bureaucracy.
Set up a “Sponsor Licence folder” that is audit-ready
Whether it’s SharePoint, Google Drive, or a secure internal system, your sponsor evidence should be structured and consistent:
- sponsor licence documents and grant letter
- key personnel list (with dates of appointment)
- sponsored worker tracker (roles, CoS numbers, start dates, visa expiry dates)
- reporting log (what was reported, when, by whom, evidence)
- right-to-work check records
- HR policies that relate to attendance, absence, and reporting triggers
Run a monthly 20-minute sponsorship check-in
You don’t need weekly meetings. But you do need a rhythm.
A simple monthly agenda:
- any changes in sponsored workforce (starts, leavers, role changes)
- any business changes coming up (office moves, reorganisations)
- upcoming expiries and extension plans
- issues or near-misses (and how you prevent repeats)
Train Level 1 users like it’s a real job (because it is)
A Level 1 user should know:
- your internal “when to report” rules
- where evidence is stored
- how to log decisions
- when to escalate to AO/legal
If you don’t have internal expertise, getting professional support can be a safety net — particularly if sponsorship is critical to hiring plans. That’s where a broader support page like UK immigration lawyers can be relevant, because you’re not just buying a form-check, you’re buying risk management.
How this fits into your wider immigration strategy
Sponsor governance is not isolated — it supports your wider talent plan.
For example, you might sponsor:
- core hires under Skilled Worker Visa
- overseas expansion staff under UK Expansion Worker Visa
- specialist talent who may not even need sponsorship under routes like Global Talent Visa UK
- founders or entrepreneurs under Innovator Founder Visa UK
The common theme: if you rely on international recruitment, your sponsor licence governance needs to be stable, documented, and resilient.
A simple “good governance” checklist for your key personnel
Use this as a quick self-audit:
- You have an AO who is genuinely senior, engaged, and accountable.
- Your Key Contact is responsive and has authority to chase information.
- You have at least 2 trained Level 1 users (not just 1).
- You have written internal rules for reporting and record-keeping.
- You have a central evidence folder that is audit-ready.
- You have a monthly sponsorship check-in routine.
- You have a “business change” trigger that flags sponsor reporting implications.
- You have a quarterly mini-audit process.
- You have a handover process if key personnel change.
- You have escalation routes when you’re unsure.
Need help getting the roles and controls right?
If you want your sponsor licence to support growth — and not become a recurring compliance worry — you need the right people in the right roles, with a governance structure that doesn’t fall apart when someone is on leave.
If you’re applying now or tightening your current set-up, start with Sponsor Licence Application and Sponsor Licence Compliance, and if you want hands-on support, the team can guide you through the key personnel appointments, SMS processes, and day-to-day compliance so you stay audit-ready.
Ready to move forward with your UK immigration plans? Garth Coates Solicitors can guide you at every step — from eligibility checks and document preparation to submission and follow-up. If you’re launching a business, our uk start up visa team can help you build a strong application. Need support with work routes? Speak to a trusted skilled worker visa solicitor today. We also advise on the uk self sponsorship visa for entrepreneurs seeking more control. Studying in the UK? Our student visa solicitors are here to help — contact us now for tailored advice.
