Every organisation applying for a sponsor licence must nominate suitable people to manage its sponsorship responsibilities.
These people are known as sponsor licence Key Personnel. They are responsible for overseeing the licence, communicating with UK Visas and Immigration and completing day-to-day activities through the Sponsorship Management System.
Selecting Key Personnel is not simply an administrative formality. UKVI considers whether each nominated person is eligible, suitable, appropriately positioned within the organisation and capable of carrying out their responsibilities.
James Immigration Solutions Ltd assists UK organisations with reviewing and selecting their proposed Authorising Officer, Key Contact and Level 1 User before the sponsor licence application is submitted.
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The three principal Key Personnel roles are:
The same eligible person can hold all three roles, or the responsibilities can be divided between different people.
An organisation can only have one Authorising Officer and one Key Contact at a time. It may appoint more than one Level 1 User where additional access is genuinely required.
A further optional role, known as a Level 2 User, can be added after the sponsor licence is granted.
The official responsibilities and requirements are explained in the GOV.UK guidance on sponsorship management roles and Part 1 of the sponsor guidance.
UKVI may conduct checks on every person nominated as Key Personnel.
The Home Office can consider their immigration history, previous involvement with sponsor licences, criminal or civil penalty history, position within the organisation and general suitability to participate in the sponsorship system.
Nominating an ineligible or unsuitable person may result in:
The organisation remains responsible for the actions of its Key Personnel and every person given access to the Sponsorship Management System.
The Authorising Officer is the organisation’s most senior person responsible for recruiting sponsored workers and ensuring that the organisation meets its sponsor duties.
Where the organisation does not directly recruit its sponsored workers, the role should be held by the most senior person responsible for its activities as a licensed sponsor.
The Authorising Officer must normally be:
A legal representative or another external individual cannot normally act as the Authorising Officer.
Only one person can hold the Authorising Officer role at any particular time.
The Authorising Officer has overall responsibility for:
Current Home Office guidance recommends that the Authorising Officer checks the Certificates of Sponsorship assigned to workers at least once a month.
No. Appointment as the Authorising Officer does not automatically provide access to the Sponsorship Management System.
If the Authorising Officer requires SMS access, they must also be appointed as a Level 1 User or, after the licence has been granted, a Level 2 User.
An eligible Authorising Officer must remain in place throughout the life of the sponsor licence.
The organisation must report a change of Authorising Officer and ensure that a suitable replacement is appointed. Failure to maintain an eligible Authorising Officer can place the sponsor licence at risk.
The Key Contact is the principal point of communication between the sponsoring organisation and UKVI.
UKVI may contact the Key Contact about:
The Key Contact should monitor their email account carefully and remain available while the sponsor licence application is under consideration.
The Key Contact can normally be:
The Key Contact may be the same person as the Authorising Officer or another suitable individual.
Only one person can hold the Key Contact role at a time.
No. The Key Contact does not automatically receive access to the Sponsorship Management System.
If SMS access is needed, the individual must also be appointed as a suitable Level 1 User or, following approval of the licence, as a Level 2 User.
The Level 1 User is responsible for the organisation’s day-to-day sponsor licence activities through the Sponsorship Management System.
This is an operational role requiring careful attention, appropriate authority and regular access to relevant employment and immigration information.
A Level 1 User may be responsible for:
The Level 1 User should understand the consequences of inaccurate or unauthorised SMS activity.
Unless a specific exception applies, the organisation must nominate at least one primary Level 1 User who is:
This person must also meet the general eligibility and suitability requirements for Key Personnel.
An organisation that fails to nominate a qualifying primary Level 1 User may have its application refused.
At least one qualifying Level 1 User must remain in place throughout the life of the sponsor licence.
The organisation should also consider how SMS responsibilities will be managed during holidays, illness, resignation or another period of absence.
UKVI recommends that organisations do not appoint more Level 1 Users than genuinely necessary. Each additional account increases the need for proper access control and supervision.
A Level 2 User is optional and can only be added after the sponsor licence has been granted.
A Level 2 User has more restricted SMS permissions than a Level 1 User.
Depending on their permitted access, they may be able to:
They cannot carry out the full range of Level 1 User activities.
The organisation should only appoint a Level 2 User where there is a genuine operational reason for providing that person with SMS access.
The Home Office’s SMS Manual 2 provides guidance on managing Key Personnel and sponsor licence details through the Sponsorship Management System.
Yes. The same person can act as Authorising Officer, Key Contact and Level 1 User if they meet the individual requirements for every role.
This may be practical for a small business where one senior director has sufficient knowledge, authority and availability.
However, concentrating all responsibilities in one person can create operational risks during absence, illness or departure.
Larger organisations may prefer to distribute the roles between suitable senior management, HR and compliance personnel.
The correct structure depends on:
Key Personnel must normally:
Specific exceptions can apply to certain routes and organisations, including some UK Expansion Worker arrangements.
The requirements should therefore be assessed against the route and circumstances of the organisation rather than assumed.
UKVI may conduct checks when a person is first nominated and repeat those checks while the organisation holds its licence.
Possible suitability concerns may include:
This is not an exhaustive list. Any previous sponsor licence involvement should be disclosed and assessed carefully.
An individual’s appointment should not be confirmed merely because they hold a senior job title. Their eligibility, history, responsibilities and practical ability to perform the role must also be considered.
A suitably qualified UK-based immigration representative may be appointed as the Key Contact.
After the sponsor licence has been granted, a qualifying UK-based representative may also be appointed as:
A representative cannot normally act as the Authorising Officer.
A representative also cannot be the organisation’s primary or sole Level 1 User when the organisation first applies for its licence.
The sponsor remains responsible for actions carried out by an external representative or any other SMS user acting on its behalf.
The most suitable person is not always the person with the most senior job title.
The organisation should consider whether each proposed individual:
These practical considerations are important because Key Personnel responsibilities continue after the licence is granted.
We review the organisation’s ownership, management and staffing structure to understand who may be suitable for each role.
The organisation identifies the individuals it wishes to nominate. We consider their proposed roles against the relevant Home Office requirements.
We assess whether each proposed individual appears to satisfy the general and role-specific eligibility criteria.
We ask appropriate questions about previous sponsorship involvement, immigration compliance, civil penalties, convictions and other relevant suitability matters.
We help the organisation decide whether one person should hold several roles or whether responsibilities should be divided.
We explain the responsibilities of the Authorising Officer, Key Contact and Level 1 User so each nominated person understands what will be expected.
We assist with organising the information required for the Key Personnel section of the sponsor licence application.
The organisation should be prepared to provide relevant information about each proposed person, including:
Any personal information should be handled securely and only used for a legitimate application or compliance purpose.
Common problems include:
Each SMS user must use their own account. Login details should not be shared.
Key Personnel selection should not be treated as a one-time application exercise.
Once the licence is granted, the organisation must continue to:
Failure to maintain suitable Key Personnel can lead to compliance action against the sponsor licence.
Yes. One eligible and suitable person can hold all three roles.
The organisation should still consider absence cover and whether concentrating every responsibility in one person creates practical risks.
Yes, provided the director is a paid member of staff or eligible office holder, is appropriately senior and meets the relevant suitability and eligibility requirements.
No. An external immigration representative cannot normally act as the Authorising Officer.
A qualified UK-based representative may act as the Key Contact and may be added as an additional Level 1 or Level 2 User after the licence is granted.
The specific settled-worker requirement normally applies to the primary Level 1 User.
If the Authorising Officer will also act as the primary Level 1 User, that person must meet the applicable Level 1 User requirements unless a specific exception applies.
No. The Authorising Officer must also be appointed as a Level 1 or Level 2 User if SMS access is required.
No. A Level 2 User is optional and can only be added after the licence is granted.
Yes, provided every nominated person meets the relevant requirements.
UKVI recommends limiting Level 1 access to the number genuinely needed while ensuring sufficient absence cover.
The organisation must appoint an eligible replacement and report the change through the correct process.
A sponsor must maintain an eligible Authorising Officer throughout the life of its licence.
No. We review the proposed appointments against the information provided and current guidance, but UKVI makes the final decision and may conduct its own checks.
Suitable Key Personnel help protect the organisation’s sponsor licence and ensure that sponsorship responsibilities are managed effectively.
JISL can review proposed appointments, explain the responsibilities attached to each role and identify potential eligibility or suitability issues before the application is submitted.
Book Your Key Personnel Review
Return to our complete Sponsor Licence Service in the UK for an overview of all six stages.
You can also review our earlier services:
Business and Eligibility Assessment
James Immigration Solutions Ltd is a company registered in England and Wales under company number 15056317 and is regulated by the Immigration Advice Authority under licence number F202538614.
This page provides general information and does not replace advice based on an organisation’s individual circumstances.
Sponsor guidance and Key Personnel requirements can change. The applicable guidance should be checked at the time of instruction and submission.
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