Every sponsor licence has named individuals responsible for it. There are four roles, and the restrictions on who may hold each are more specific than most applicants expect.

Authorising Officer

Exactly one required.

The Home Office describes this as "a senior and competent person responsible for the actions of staff and representatives who use the SMS". In practice it must be the most senior person responsible for recruitment and HR in your organisation.

Restrictions:

• Must be UK-based most of the time. The only exception is a UK Expansion Worker licence applicant with no UK-based staff, where an overseas person may hold it
• Cannot be a third-party legal representative
• Subject to suitability checks

This is the role people try to delegate outward and cannot. The Home Office wants someone senior inside the organisation personally answerable for the licence.

Key Contact

One required. The main point of contact with UKVI.

This is the only key personnel role an external adviser can hold. A UK-based legal representative qualified to give immigration advice may be the Key Contact. Same UK-based requirement, same expansion-worker exception.

For an employer using an immigration firm, this is where that firm sits.

Level 1 User

At least one required, named at the application stage. Handles day-to-day management of the licence in the Sponsorship Management System — assigning Certificates of Sponsorship, making reports, updating records.

Restrictions:

• Must be an employee, partner or director of the sponsor organisation, or a settled worker
• May be an HR contractor or temporary agency worker engaged in an HR capacity — but not a contractor engaged for a specific project
• Must be UK-based most of the time
• At the application stage, the first Level 1 User must be either the Authorising Officer or the Key Contact

That last rule catches applicants who plan to appoint an HR administrator as their Level 1 User from the outset. At application, it has to be one of the two senior roles. You can add others after the licence is granted.

Level 2 User

Optional, and appointed only after the licence is granted.

Has more restricted SMS access than a Level 1 User. Notably a Level 2 User cannot withdraw a Certificate of Sponsorship, and cannot create or amend key personnel.

May be a temporary agency worker or HR contractor, subject to the same base restrictions and suitability checks.

Suitability checks

All four roles are checked. A person is barred if they:

• Have an unspent conviction for a listed offence
• Have been fined by UKVI in the previous 12 months
• Were a Key Contact, Authorising Officer or Level 1 User on a licence refused within the previous 6 months
• Were key personnel on a revoked licence within the relevant cooling-off period
• Are subject to bankruptcy restrictions or a debt relief restriction order

One person may hold more than one role. In a small organisation it is common for the same individual to be Authorising Officer, Key Contact and Level 1 User.

Practical points

Keep the roles current. Changes to key personnel must be reported within 20 working days. A licence where the named Authorising Officer left the company a year ago is a compliance failure sitting in plain sight.

Think about continuity. If one person holds all three roles and leaves, you have a problem. Appointing a second Level 1 User after the licence is granted is cheap insurance.

Do not name someone who will not engage. The Authorising Officer is personally responsible for the actions of everyone using the SMS. Naming a director who has no intention of paying attention to it is how sponsors end up with breaches nobody noticed.