Every sponsor licence application must nominate an Authorising Officer, a Key Contact and at least one Level 1 User. These roles can be held by the same person or different people, provided each individual meets the Home Office’s eligibility and suitability requirements.
The detailed framework is explained in key personnel on a sponsor licence.
Who does what?
The Authorising Officer has overall responsibility for sponsorship activity. They must be a paid member of staff or office holder within the organisation and, except for limited exceptions such as the UK Expansion Worker route, must be based in the UK while holding the role. They should be the most senior person responsible for recruiting sponsored workers and ensuring sponsor duties are met.
The Key Contact is the main point of communication with UKVI and can be a UK-based legal representative.
Level 1 Users manage the licence through the Sponsorship Management System (SMS), including assigning Certificates of Sponsorship, requesting allocations and reporting changes. Level 2 Users are optional and have more restricted SMS permissions.
| Role | Who can normally hold it? | Main responsibility | External representative allowed? |
|---|---|---|---|
| Authorising Officer | Paid staff member or office holder | Overall sponsorship responsibility | No |
| Key Contact | Staff member, office holder or UK-based representative | Main UKVI contact | Yes |
| Primary Level 1 User | Employee, director or partner meeting applicable requirements | Day-to-day SMS management | No at initial application |
| Additional Level 1 User | Eligible internal person or, after grant, certain representatives | SMS administration | Yes after grant |
| Level 2 User | Eligible staff member or representative | Limited SMS functions | Yes after grant |
At least one Level 1 User must normally be an employee, director or partner and a settled worker, subject to specified exceptions. A representative cannot be nominated as a Level 1 User at the initial application stage.
These responsibilities sit alongside wider sponsor duties and compliance.
Suitability checks matter
The Home Office assesses whether nominated personnel are suitable. Relevant matters can include criminal convictions, civil penalties, immigration compliance and previous involvement with sponsor licences that were revoked.
Problems involving key personnel can therefore affect a sponsor licence application or lead to sponsor licence suspension or revocation. Where action has already been taken, see sponsor licence reinstatement after suspension.
Build governance that survives staff changes
Do not rely on one person where the organisation can reasonably appoint additional eligible Level 1 Users. Home Office guidance specifically recommends having enough Level 1 Users to cover absences.
Maintain a current record of who holds each role and review access when employees leave or responsibilities change. Changes involving key personnel should be reported through the SMS as soon as possible. Most other significant organisational changes must normally be reported within 20 working days of becoming aware of them.
Regular internal checks can also help prepare for sponsor licence compliance visits. See sponsor licence management best practice and sponsor licence for SMEs for further guidance.
Organisations operating across locations should also review multi-site and hybrid working.
Frequently asked questions
Can the Authorising Officer be based overseas?
Normally no. Key personnel must generally be UK-based, although specific exceptions apply, including certain UK Expansion Worker cases.
Can our solicitor be a Level 1 User?
Not as the primary Level 1 User when the licence application is submitted. After the licence is granted, a UK-based representative can be added as an additional Level 1 User.
Can one person hold all three main roles?
Yes, provided they meet the eligibility requirements for each role. However, having more than one suitable SMS user can improve resilience.
How quickly should key personnel changes be reported?
Changes should be submitted through the SMS as soon as possible. Other significant organisational changes are generally subject to a 20-working-day reporting deadline.
Employers using the Skilled Worker visa route should keep sponsorship governance under regular review. Official requirements are available in the GOV.UK sponsor guidance.
For support reviewing your licence structure, speak to Garth Coates immigration solicitors.
