A sponsor licence needs names attached to it.
There must be an Authorising Officer. There must be a Key Contact. There must be at least one Level 1 User with the necessary eligibility to manage the licence.
It is easy to approach those appointments as part of completing the application form.
Who is the most senior person? Put them down as Authorising Officer.
Who deals with correspondence? Make them the Key Contact.
Who will use the Sponsorship Management System? Give them Level 1 access.
That can work.
But the better question is not simply who is eligible to hold each title. It is who should hold it, given how the business actually operates.
Sponsor management sits somewhere between immigration, HR, recruitment, payroll and senior management. A salary change can become an immigration issue. An employee leaving can create a reporting obligation. A company changing address can require action on the Sponsorship Management System. A sponsored worker being absent without permission can move quickly from a line-management issue to a sponsor compliance issue.
Someone has to connect those events.
That is why choosing sponsor licence key personnel deserves more thought than completing three boxes on an application.
What are sponsor licence key personnel?
When an organisation applies for a Worker or Temporary Worker sponsor licence, it must nominate people to manage the licence.
The Home Office refers to these people as Key Personnel.
For a new sponsor licence application, the three principal roles are:
- Authorising Officer
- Key Contact
- Level 1 User
The same person can hold more than one role, provided they meet the requirements for each one.
A small owner-managed business might therefore have one director acting as Authorising Officer, Key Contact and Level 1 User.
A larger organisation may divide the responsibilities. A senior HR director might be the Authorising Officer, another member of the HR team the Key Contact, and several trained employees Level 1 Users.
Neither structure is automatically better.
The right arrangement depends on the organisation.
What matters is that the people appointed are eligible, understand what they are responsible for and have access to the information they need.
The Authorising Officer: senior ownership of sponsorship
The Authorising Officer has the most senior sponsorship role.
Current Home Office guidance requires the Authorising Officer to be a paid member of staff or an office holder within the organisation. A legal representative or somebody from another organisation cannot ordinarily be appointed to this role.
The person should be the most senior individual responsible for the recruitment of sponsored workers and ensuring the organisation meets its sponsor duties. Where the organisation does not directly recruit the workers it sponsors, the role should be held by the most senior person responsible for the organisation’s activity as a licensed sponsor.
Only one Authorising Officer can be appointed at any given time.
This is not necessarily the chief executive or managing director.
In a large organisation, responsibility for recruitment and sponsorship may properly sit with a senior HR professional.
In a smaller company, a director may be the obvious choice.
The key word is responsibility.
The Authorising Officer should have enough seniority to ensure that sponsorship obligations are actually taken seriously across the organisation.
If payroll needs to change a process, they should be able to make that happen.
If line managers need to report certain events to HR, the organisation should be capable of putting that procedure in place.
If somebody is using the Sponsorship Management System incorrectly, the Authorising Officer should have the authority to intervene.
Putting a junior administrator in the role simply because they will do most of the immigration paperwork misses the purpose of the appointment.
The Authorising Officer does not automatically have access to the SMS
This causes some confusion.
Being the Authorising Officer does not, by itself, give the person access to the Sponsorship Management System, usually called the SMS.
If the Authorising Officer also needs to perform day-to-day activity on the system, they must also be appointed as a Level 1 User.
This distinction is useful.
The Authorising Officer is responsible for the organisation’s sponsorship activity and the conduct of its SMS users.
The Level 1 User is the person actually operating the system.
Those can be the same person, but they do not have to be.
For a small company, combining the roles may be efficient.
For a larger organisation, separating oversight from daily administration can make more sense.
The Authorising Officer remains responsible for SMS users
Delegation does not remove responsibility.
The Home Office makes clear that the Authorising Officer is responsible for the activities of the organisation’s SMS users.
Current guidance recommends that the Authorising Officer checks Certificates of Sponsorship assigned to workers at least once a month.
That is worth noticing.
The Authorising Officer is not intended to be a ceremonial name sitting on the licence while everybody else gets on with sponsorship.
There should be genuine oversight.
That might involve a monthly review of CoS activity, reporting undertaken through the SMS, upcoming immigration expiries, sponsored-worker changes and any unresolved compliance issues.
For a business sponsoring one employee, that review may take very little time.
For an organisation sponsoring hundreds of workers, it may need a structured governance process.
The principle is the same.
Someone senior should know what is happening.
“The Authorising Officer should not be the person whose name happens to fit the application form. They should be somebody who can take ownership of sponsorship inside the organisation. If a compliance issue is identified, that person needs enough authority to get it corrected.”
Abdul Jabbar, Principal Immigration Adviser
The Key Contact: who should UKVI speak to?
The Key Contact is the main point of contact between the sponsor and UK Visas and Immigration.
During the sponsor licence application, UKVI may contact the Key Contact about the application, supporting documents or payment.
After the licence is granted, that contact role continues.
The Key Contact can be the Authorising Officer, another eligible person within the organisation or, unlike the Authorising Officer, an eligible UK-based representative.
Only one Key Contact can be appointed at a time.
Again, the title can make the job sound more administrative than it really is.
The important question is whether the person will actually deal with correspondence.
If the Home Office asks a question about the licence, the message should reach somebody who understands what it means and knows who needs to act.
There is little value in appointing the managing director as Key Contact if their inbox is screened by somebody else and immigration correspondence is unlikely to reach the right person promptly.
The same applies to generic email addresses.
Current Home Office guidance requires email addresses provided for Key Personnel to be secure, personal to and accessible only by the named individual.
Sponsor management should not depend on a shared inbox that half the company can access.
The Level 1 User: where most day-to-day sponsorship activity happens
The Level 1 User is normally the person most closely involved in the practical management of the licence.
Level 1 Users can carry out a wide range of activity through the Sponsorship Management System.
This includes:
- assigning Certificates of Sponsorship
- applying for Defined Certificates of Sponsorship for Skilled Workers
- requesting changes to Certificate of Sponsorship allocations
- reporting relevant changes affecting sponsored workers
- reporting changes to the organisation
- updating certain licence details
- adding or removing eligible SMS users
- withdrawing Certificates of Sponsorship
- accessing messages and information held within the SMS
These are not minor administrative permissions.
A Level 1 User can take actions that affect both the sponsor licence and the immigration position of sponsored workers.
The person appointed therefore needs more than basic computer literacy.
They need to understand what they are doing.
Who can be the primary Level 1 User?
For a new sponsor licence application, the organisation must nominate at least one Level 1 User who meets the Home Office requirements for the primary Level 1 User.
Under the current guidance, that person must normally be:
- an employee, director or partner within the organisation, and
- a settled worker for sponsorship purposes
There are exceptions, including particular arrangements applying to UK Expansion Worker sponsors and certain other immigration categories.
The primary Level 1 User requirement is important because a business cannot simply outsource the entire sponsor licence from day one and have no eligible internal person responsible for SMS access.
Once the licence has been granted, additional Level 1 Users can potentially be appointed.
Those additional users can include paid staff or office holders, employees of organisations providing outsourced HR functions, and eligible UK-based representatives.
The organisation remains responsible for what those users do.
How many Level 1 Users should you have?
There is no single answer.
A business with one sponsored employee may not need several people accessing the SMS.
Giving unnecessary people powerful system access can itself create risk.
The Home Office recommends keeping the number of Level 1 Users to what is genuinely necessary.
But there is another side to the question.
Having only one person who knows how sponsorship works can leave the business exposed.
Imagine the only Level 1 User goes on holiday for three weeks.
Or leaves unexpectedly.
Or is on long-term sick leave.
A reporting deadline does not necessarily wait for them to return.
For many organisations, the sensible arrangement is enough access to provide continuity, but not so much access that control becomes diluted.
That might mean two trained Level 1 Users in a medium-sized business, with a clear understanding of who ordinarily carries out which tasks.
For a very small business, one Level 1 User may still be appropriate, but the organisation should think about what it would do if that person became unavailable.
The Home Office itself recommends having enough eligible Level 1 Users to cover periods of absence.
Level 2 Users are being phased out
This is an area where older sponsor licence articles can now be misleading.
Historically, sponsors could appoint Level 2 Users with more restricted SMS permissions.
From 9 September 2026, sponsors can no longer appoint new Level 2 Users.
Organisations that already have Level 2 Users must either convert eligible individuals to Level 1 Users or deactivate their accounts.
That must be dealt with by 8 March 2027. After that point, remaining Level 2 User accounts will be deactivated by the Home Office.
For a business applying for its sponsor licence now, the practical position is straightforward.
Plan the management of the licence around the Authorising Officer, Key Contact and appropriately controlled Level 1 Users.
Do not design the structure around adding new Level 2 Users later.
SMS security now matters even more
The Sponsorship Management System contains information and functions that can have significant immigration consequences.
Usernames and passwords should never be treated as shared office credentials.
Home Office guidance expressly states that SMS users must not give their password or multi-factor authentication passcode to anybody else.
Doing so can put the sponsor licence at risk.
Multi-factor authentication is now being introduced across the Sponsorship Management System.
For organisations granted a sponsor licence on or after 9 September 2026, mandatory MFA applies.
The wider rollout began on 3 September 2026 and the Home Office expects it to cover all sponsors by November 2026.
For Level 1 Users, this makes accurate personal contact information increasingly important. The Home Office needs appropriate personal details, including the user’s email address, mobile number and date of birth, for the authentication process.
The practical lesson is simple.
An SMS account belongs to the named user.
It should not be the office’s sponsorship account.
It should not be accessed by whichever employee happens to be available.
And the credentials should not be stored somewhere for everybody in HR to use.
Inactive users can now create a separate compliance risk
Another recent change concerns inactivity.
Under current Home Office guidance, an SMS account can be treated as inactive where the user has not accessed it for 12 months or more.
The Home Office can then require action to keep that account active.
If an inactive user no longer needs access, the account should be removed.
More seriously, if the process results in the sponsor having no active Level 1 Users, the Home Office can suspend the licence. The sponsor would then have a limited period to nominate an eligible Level 1 User before revocation would normally follow.
This makes regular SMS housekeeping part of sponsor management.
The Home Office currently recommends that a Level 1 User accesses the account at least once a month.
Even a sponsor with very little activity should not obtain a licence and then ignore the system for a year.
Can an immigration adviser manage the sponsor licence?
An eligible UK-based immigration representative can play a role in sponsor management.
A representative can act as Key Contact.
Once the sponsor licence has been granted, an eligible representative can also potentially be appointed as an additional Level 1 User.
But there is an important boundary.
A representative cannot ordinarily act as the Authorising Officer.
Nor can an external representative replace the sponsor’s own responsibility for compliance.
The business remains the sponsor.
It is responsible for what happens under its licence, including actions taken by external users acting on its behalf.
That distinction matters.
Professional support can be useful for interpreting the sponsor rules, dealing with technical SMS activity, considering reportable changes, preparing Certificates of Sponsorship and advising on compliance.
But information still has to come from the business.
An adviser cannot know that an employee has stopped attending work unless somebody tells them.
They cannot know that payroll has reduced a salary unless the business reports it.
They cannot know that the company has changed its trading address if the sponsor itself fails to identify the change.
External support works best when responsibilities are divided clearly.
The adviser deals with the immigration consequence.
The business retains control of the facts.
Payroll may know something before the Level 1 User does
Sponsor management can fail even when everyone involved is competent.
The problem is often information flow.
Consider a sponsored employee who asks to reduce their working hours.
Their manager agrees.
Payroll receives the instruction.
The salary changes.
Nobody tells the Level 1 User.
From the company’s perspective, this might look like a routine employment variation.
From a sponsorship perspective, salary and working arrangements can be highly significant.
Now consider another situation.
A sponsored employee stops attending work.
Their line manager assumes HR will deal with it.
HR assumes the manager is handling the employee.
The Level 1 User does not hear about the problem for three weeks.
Again, the weakness is not necessarily lack of immigration knowledge.
It is that the right person did not receive the information.
A functioning sponsorship system therefore needs to identify who in the business can generate information that matters.
Usually that includes some combination of:
- HR
- payroll
- recruitment
- line managers
- finance
- senior management
- the sponsored employee
- the person controlling the SMS
Those people do not all need to become immigration specialists.
They do need to know when something should be escalated.
The Level 1 User should not be the only person who understands sponsorship
This is a subtle but important distinction.
The Level 1 User needs enough knowledge to operate the SMS properly.
But good sponsorship governance does not mean sending every immigration responsibility to one person.
A line manager should understand that prolonged unauthorised absence needs to be reported internally.
Payroll should know not to alter the salary of a sponsored worker without checking whether sponsorship needs to be considered.
HR should recognise that a change in duties, work location or employment status may need review.
Senior management should understand that mergers, acquisitions and substantial organisational changes can have sponsor licence consequences.
The organisation works better when sponsorship is part of relevant business processes rather than knowledge held entirely inside one person’s head.
“The Level 1 User may operate the system, but they cannot manage information they never receive. Good sponsor management is partly about making sure the rest of the business knows when to involve them. Payroll does not need to know the Immigration Rules. It does need to know that changing a sponsored worker’s salary should trigger a conversation.”
Abdul Jabbar, Principal Immigration Adviser
Reporting deadlines make internal communication important
The Home Office requires certain changes affecting sponsored workers to be reported within defined periods.
Unless another period applies, changes in a sponsored worker’s circumstances generally need to be reported within 10 working days of the relevant event.
Specified changes to the sponsor organisation generally need to be reported within 20 working days.
The Level 1 User may be responsible for making the report.
But the reporting deadline begins because something happened, not because the Level 1 User eventually learned about it.
That makes internal escalation important.
If the company moves office on 1 October but the person managing sponsorship only hears about it on 25 October, the fact that they acted immediately after finding out does not necessarily solve the underlying problem.
The sponsorship system should therefore be connected to normal business decision-making.
The earlier the licence manager is involved, the easier it usually is to establish what action is required.
One person can hold all three roles, but should they?
For smaller businesses, one person acting as Authorising Officer, Key Contact and Level 1 User can be entirely sensible.
A founder-director may genuinely be responsible for recruitment, receive Home Office correspondence and manage the SMS.
Creating an artificial separation of duties would achieve very little.
But concentration has a cost.
If that person leaves the business, becomes unavailable or simply misses an important message, there may be nobody else who understands the licence.
A business using one person for all three roles should therefore consider continuity.
Where are the relevant records?
Who knows which employees are sponsored?
Who knows when their immigration permission expires?
Who knows which reports are pending?
How would the organisation respond if the Level 1 User were unavailable tomorrow?
This does not always mean appointing more people to the SMS.
It may simply mean ensuring somebody else understands the process and that records are maintained centrally rather than in a personal inbox.
Large organisations face the opposite problem
A large business is more likely to have several HR teams, different offices, separate payroll functions and multiple people involved in recruitment.
Its challenge may be fragmentation rather than concentration.
Someone recruits the employee.
Someone else prepares the offer.
A central immigration team handles sponsorship.
Payroll sits elsewhere.
The employee’s day-to-day manager may be in another city.
Corporate changes are handled by a company secretarial team.
Each part of the process may be perfectly competent.
The question is whether they communicate when something affects sponsorship.
Large organisations therefore benefit from defined escalation routes.
For example:
Recruitment identifies where sponsorship may be required.
Immigration or HR checks eligibility before an offer is finalised.
The Level 1 User manages the CoS and SMS.
Payroll flags proposed salary changes involving sponsored workers.
Line managers escalate attendance, location and role changes.
Corporate or legal teams notify the sponsor function of structural changes.
The Authorising Officer provides oversight.
The labels will differ between businesses.
The principle will not.
What happens if a key person leaves?
People change jobs.
A good sponsorship structure assumes that at some stage somebody named on the licence will leave, change role or become unavailable.
The organisation must continue to have an eligible Authorising Officer and appropriate Level 1 User throughout the life of the licence.
The Home Office states that it will normally revoke a licence where a sponsor does not have a suitable and eligible Authorising Officer in place or fails to report a change of Authorising Officer.
The same underlying risk applies to losing the necessary Level 1 User.
The practical response is not to hope nobody ever leaves.
It is to manage handovers properly.
Before a relevant employee departs, the business should consider:
- whether they are named as Key Personnel
- whether another eligible person needs to be appointed
- whether their SMS access needs to be removed
- whether their personal contact information is used anywhere on the licence
- what outstanding sponsor activity they are managing
- whether relevant records and knowledge have been transferred
This becomes particularly important when departures are sudden.
Keeping sponsor records organised makes the transition considerably easier.
Who should not manage the sponsor licence?
Eligibility rules aside, there are some practical warning signs.
A person may be a poor choice if they:
- do not have enough seniority for the responsibility assigned to them
- rarely check correspondence
- do not understand the significance of SMS actions
- are likely to leave the business shortly
- do not have access to HR, recruitment or payroll information
- treat sponsor management as occasional form filling
- are uncomfortable taking responsibility for deadlines
- cannot maintain confidential personal system credentials
- have no realistic time to carry out the role
The question is not whether they are intelligent or capable.
It is whether the sponsorship role fits their actual position within the business.
A sensible structure for a small business
Consider a company with twelve employees.
The managing director oversees recruitment.
An office manager handles HR administration and payroll information.
The business expects to sponsor two Skilled Workers.
A sensible arrangement might be:
Authorising Officer: Managing Director
Key Contact: Office Manager
Primary Level 1 User: Office Manager, if eligible
Additional Level 1 User: Managing Director, if the business considers additional cover necessary and the individual meets the requirements
The office manager deals with day-to-day activity.
The managing director retains senior oversight.
Both understand that salary, attendance and job changes involving sponsored workers require consideration.
That arrangement is simple.
It is also much more credible than appointing three different people purely because the form provides three different titles.
A sensible structure for a larger business
Now consider a company with 400 employees and an established HR function.
A possible structure might be:
Authorising Officer: HR Director
Key Contact: Head of People Operations
Primary Level 1 User: Immigration or HR Manager
Additional Level 1 Users: A limited number of trained HR professionals who require SMS access
Here, it would be reasonable for the Authorising Officer not to handle daily SMS activity.
But they should retain genuine oversight.
The Level 1 Users should have defined responsibilities and sufficient cover.
The wider HR and management structure should know how relevant worker changes reach the sponsorship team.
Again, the exact job titles matter less than the working arrangement.
Questions to ask before appointing key personnel
Before confirming the sponsor licence key personnel, we would want the business to consider:
Who has genuine senior responsibility for sponsored recruitment?
That person is likely to be relevant when choosing the Authorising Officer.
Who will actually monitor Home Office correspondence?
Not who could theoretically receive it.
Who will read it and act?
Who will operate the Sponsorship Management System?
The person needs suitable eligibility, time and understanding.
Who knows when employment circumstances change?
If the Level 1 User is outside the normal HR process, how will information reach them?
What happens during holidays or sickness?
Is there enough cover?
What happens if somebody leaves the business?
Can access and responsibility be transferred promptly?
Who reviews sponsorship activity?
The Authorising Officer should not disappear from the process once the licence is granted.
Are personal SMS details accurate and secure?
With mandatory multi-factor authentication and increasing focus on inactive accounts, this now deserves particular attention.
Sponsor management should be deliberately boring
Once sponsorship is working properly, much of it should be routine.
A Certificate of Sponsorship is assigned because the relevant checks have already happened.
A change reaches the right person because the internal process says it should.
A report is made within time because somebody knows the deadline.
The Authorising Officer can review licence activity without discovering surprises.
Records can be found when needed.
SMS users have their own secure access.
Nobody is scrambling to establish who was supposed to do what.
That is what good sponsor management looks like.
Not complicated.
Not theatrical.
Simply controlled.
The problems usually begin when sponsorship depends on memory, informal conversations or one employee who happens to know how everything works.
Choosing the right sponsor licence key personnel is therefore not just a requirement of the application.
It is one of the first decisions a business makes about how sponsorship will operate after the licence is granted.
Next in the Employing International Talent series: From Sponsor Licence to Sponsored Employee: Understanding the Next Steps
Need to review how your sponsor licence will be managed?
If your business is applying for a sponsor licence, reviewing its key personnel or considering how sponsorship responsibilities should be managed internally, you can request a Free Case Assessment.
Tell us about the organisation, how recruitment and HR are currently managed and any sponsored workers or proposed hires involved.
We can then consider whether Knightsbridge Immigration can assist.
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