Choosing the right Authorising Officer and Level 1 User is central to a sponsor licence application. The Authorising Officer must normally be a paid member of staff or office holder within your organisation and must be the most senior person responsible for recruiting sponsored workers and ensuring sponsor duties are met. Key Personnel must generally be UK-based, although a specific exception exists for some UK Expansion Worker applications.
Your primary Level 1 User has different requirements. For new licence applications, at least one Level 1 User must normally be an employee, director or partner of the organisation and a settled worker, unless a defined exception applies. The full position is covered in key personnel on a sponsor licence.
What each role actually does
The Authorising Officer has overall responsibility for sponsorship activity and for the conduct of SMS users. They do not automatically receive access to the Sponsorship Management System unless they are also appointed as a Level 1 or Level 2 User. Home Office guidance recommends that the Authorising Officer checks assigned Certificates of Sponsorship at least monthly.
The Level 1 User carries out day-to-day SMS work, including assigning CoS, requesting allocations, reporting worker activity and notifying relevant organisational changes. Many of the deadlines covered in sponsor duties and compliance therefore depend on effective Level 1 User management.
The four Key Personnel roles
| Role | Who can normally hold it | Main function | External representative? |
|---|---|---|---|
| Authorising Officer | Paid staff member or office holder | Overall sponsorship responsibility | No |
| Level 1 User | Primary user normally must be employee/director/partner and settled worker | Day-to-day SMS management | Additional user only after grant |
| Level 2 User | Staff member, eligible outsourced HR staff, agency temp or UK representative | Limited SMS functions | Yes |
| Key Contact | Staff/office holder or UK representative | Main contact with UKVI | Yes |
A UK-based immigration representative can act as Key Contact. However, they cannot be nominated as a Level 1 User in the initial application. After the licence is granted, a representative can be added as an additional Level 1 User, but at least one qualifying internal Level 1 User must remain in place.
This is particularly relevant for founders considering self sponsorship, where one eligible director may hold several Key Personnel roles.
Suitability checks
The Home Office checks nominated Key Personnel when considering an application and may repeat those checks while the licence remains active. Issues can include relevant unspent criminal convictions, civil penalties, director disqualification, recent involvement with organisations whose sponsor applications were refused or licences revoked, unpaid Home Office legal costs, sanctions or other matters presenting a risk to immigration control.
Problems with Key Personnel can contribute to refusal or later sponsor licence suspension or revocation. If compliance action has already occurred, see sponsor licence reinstatement after suspension.
Practical choices that last
Choose people with sufficient authority, knowledge and availability. Home Office guidance recommends having enough eligible Level 1 Users to cover absence, but not more than necessary. Temporary agency workers cannot be Authorising Officers, Key Contacts or Level 1 Users; they can only act as Level 2 Users.
Businesses operating across different locations should also review multi-site and hybrid working. Smaller employers can read sponsor licence for SMEs and sponsor licence management best practice.
Get the roles settled before submitting your sponsor licence application. Once licensed, your SMS users will manage sponsorship for each Skilled Worker visa hire and support accurate records for employees who may later qualify for ILR based on long residence. Official requirements are available in the GOV.UK sponsor guidance.
Frequently asked questions
Can a company director be both Authorising Officer and Level 1 User?
Yes, provided they satisfy the eligibility and suitability requirements for both roles. The same person can hold multiple Key Personnel roles.
Does the Authorising Officer need to be a British citizen?
No. British citizenship is not required. The Authorising Officer must normally be UK-based and meet the general Key Personnel and role-specific eligibility requirements. The separate settled-worker requirement primarily applies to the organisation’s qualifying primary Level 1 User, subject to stated exceptions.
Can we change Key Personnel after the licence is granted?
Yes. Level 1 Users can make relevant changes through the SMS. Replacing an Authorising Officer requires a formal request and, where required, a signed submission sheet and supporting documents.
If you are unsure whether your proposed personnel meet the Home Office requirements, speak to our immigration solicitors before submitting the application.
