Who Can Be an Authorising Officer? Complete 2026 Sponsor Guide

Every organisation applying for a UK Worker or Temporary Worker sponsor licence must nominate an Authorising Officer. This is not simply an administrative name placed on the application. The Authorising Officer is the senior person with overall responsibility for the organisation’s activities as a licensed sponsor.

Choosing somebody who is too junior, outside the organisation, unsuitable or unable to oversee sponsor compliance can result in the sponsor licence application being refused. An existing sponsor may also face compliance action if it no longer has an eligible Authorising Officer.

This guide explains who can be a sponsor licence Authorising Officer, who should not be appointed, the person’s responsibilities and how to replace them.

This article reflects the Home Office sponsor guidance version 05/26, valid from 20 May 2026.

Quick answer: who can be an Authorising Officer?

An Authorising Officer must normally be:

• A paid employee or an office holder within the sponsoring organisation.
• Based in the United Kingdom while holding the role.
• The most senior person responsible for recruiting sponsored workers and ensuring compliance with sponsor duties.
• Competent and sufficiently knowledgeable about sponsorship.
• Given genuine authority over recruitment, HR compliance and Sponsorship Management System users.
• Suitable under the Home Office’s criminality, civil penalty and compliance-history requirements.
• The holder of a valid National Insurance number, unless genuinely exempt.

A managing director, company director, business owner, partner, senior HR director or senior compliance manager may qualify. The deciding factor is not the person’s job title. They must genuinely be the most senior person responsible for sponsored recruitment and sponsor compliance.

The detailed requirements are contained in Part 1 of the Workers and Temporary Workers sponsor guidance.

What is an Authorising Officer?

The Authorising Officer is one of the mandatory “Key Personnel” connected with a sponsor licence.

An organisation must nominate:

• One Authorising Officer.
• One Key Contact.
• At least one eligible Level 1 User.

The same person may hold all three positions if they satisfy the separate requirements for each role. Alternatively, the organisation may divide the positions between different people.

The Authorising Officer has overall responsibility for the organisation’s sponsorship activity. The Key Contact communicates with UK Visas and Immigration, while Level 1 Users perform day-to-day work through the Sponsorship Management System.

An organisation can have only one Authorising Officer at a time, even where its licence covers several branches or sponsored work routes.

What does “the most senior person” mean?

The Home Office requires the Authorising Officer to be the most senior person responsible for:

1. Recruiting all sponsored workers; and
2. Ensuring that the organisation complies with its sponsor duties.

This does not automatically mean that the chief executive must be appointed. The correct person will depend on how the organisation is managed.

For example:

• In a small company, the managing director or owner may be the correct person.
• In a larger organisation, the HR director or head of people may be the most senior person responsible for sponsored recruitment.
• In a group structure, it may be a senior director with authority across all branches included on the licence.
• Where the organisation does not recruit the workers it sponsors, the Authorising Officer must be the most senior person responsible for its activities as a licensed sponsor.

A junior HR assistant should not be named simply because that person completes forms or uses the SMS. Operational familiarity does not replace the required seniority and authority.

Who can normally hold the position?

Possible candidate	Can they be the Authorising Officer?
Managing director or chief executive	Usually, if genuinely responsible for sponsored recruitment and compliance
Company director	Yes, if they meet the seniority, suitability and UK-based requirements
Business owner	Usually, provided they are an internal office holder or otherwise satisfy the requirements
Senior HR director or head of people	Yes, where they are the most senior person responsible for sponsored recruitment and compliance
Senior recruitment or compliance manager	Possibly, if nobody more senior has responsibility for these functions
Partner in a partnership	Potentially, if their formal position and responsibilities meet the requirements
Sole trader	Usually the sole trader or an eligible senior paid employee, depending on the business structure
Charity trustee or other office holder	Potentially, if they are genuinely an office holder and the most senior person with sponsor responsibility
Sponsored worker	Potentially, but only after their immigration status, actual authority and separate Level 1 User requirements have been carefully checked
External immigration adviser	No, not merely in their capacity as an external representative
Outsourced HR consultant	No, they cannot act as the Authorising Officer
Temporary agency worker	No
Junior administrative employee	Normally inappropriate because of the seniority requirement
Overseas-based person	Normally no, except for the specific UK Expansion Worker arrangement

The appointment must reflect the organisation’s real management structure. Creating an impressive job title solely for the application will not overcome a lack of genuine authority.

Must the Authorising Officer be a director?

No. A director may be an appropriate choice, but directorship is not mandatory.

A senior employee can be appointed where that employee is genuinely the most senior person responsible for sponsored-worker recruitment and compliance.

However, an organisation should be prepared to explain:

• Why the person was selected.
• Their position within the management structure.
• Who reports to them.
• What authority they have over recruitment and HR systems.
• Whether they can direct other SMS users.
• Whether they have access to the resources needed to correct compliance problems.

An organisational chart, job description, employment contract, board minute and written appointment record may help demonstrate the person’s actual position.

Must the Authorising Officer be paid?

The person must be either:

• A paid member of staff; or
• An office holder within the organisation.

A director is generally an office holder, even where their remuneration arrangements differ from those of an ordinary employee. Nevertheless, their position must be genuine and verifiable.

An external consultant cannot be converted into an eligible Authorising Officer merely by describing their consultancy fee as payment from the sponsor.

Must the Authorising Officer be based in the UK?

Yes, normally. Key Personnel must be based in the UK for the period during which they hold the position. They must also have a valid National Insurance number unless they are exempt and can explain or evidence the exemption.

An individual who mainly lives and works overseas will not normally be an appropriate Authorising Officer for an ordinary Skilled Worker sponsor licence.

UK Expansion Worker exception

There is a specific exception for certain UK Expansion Worker sponsor licence applications.

If the overseas business does not have a suitable person already based in the UK, a senior employee of the overseas business may be appointed as Authorising Officer while overseas. That individual will normally also be the Level 1 User and may assign their own Certificate of Sponsorship to apply for entry clearance as a UK Expansion Worker.

Once the Authorising Officer enters the UK, the sponsor must complete the relevant post-arrival actions. The detailed requirements are explained in the Home Office guidance for sponsoring a Global Business Mobility worker.

This is a narrow exception and should not be applied to an ordinary Skilled Worker sponsor licence.

Can a sponsored worker be the Authorising Officer?

The Authorising Officer rules do not impose the same general “settled worker” requirement that applies to the primary Level 1 User. Therefore, holding time-limited immigration permission is not automatically listed as a prohibition against being the Authorising Officer.

However, this does not mean every sponsored worker will be suitable. The organisation must confirm that the individual:

• Is lawfully permitted to undertake the position and its responsibilities.
• Is genuinely based in the UK.
• Is an internal paid employee or office holder.
• Is genuinely the most senior person responsible for sponsored recruitment and compliance.
• Has sufficient continuity and authority to oversee the licence.
• Meets every suitability requirement.
• Is not being given an artificial title to facilitate their own or another person’s immigration application.

The organisation must also maintain an eligible primary Level 1 User who is both internal and a settled worker, unless a specific exception applies.

Because an incorrect appointment can affect the entire licence, individual advice should be obtained before appointing a sponsored worker as Authorising Officer.

Can an external immigration adviser be the Authorising Officer?

No. The Home Office guidance specifically states that a representative or someone from another organisation cannot be appointed as the Authorising Officer.

A properly authorised UK-based immigration representative may, where permitted:

• Act as the Key Contact.
• Be appointed as an additional Level 1 User after the licence is granted.
• Act as a Level 2 User.

The representative cannot replace the sponsor’s internal senior management responsibility. The sponsoring organisation remains responsible for activity carried out by its representatives and SMS users.

The only external-person exception for the Authorising Officer role arises when an organisation enters administration. In that situation, the appointed insolvency practitioner must become the Authorising Officer.

Can the Authorising Officer also be the Key Contact and Level 1 User?

Yes. One eligible person may hold all three roles.

However, the person must separately satisfy the requirements of each position.

Position	Main function	Automatic SMS access?
Authorising Officer	Senior oversight and responsibility for sponsorship activity and SMS users	No
Key Contact	Main contact between the sponsor and UKVI	No
Level 1 User	Day-to-day licence and worker management through the SMS	Yes

The primary Level 1 User must normally be:

• An employee, director or partner within the organisation; and
• A settled worker.

Therefore, an Authorising Officer who does not meet the primary Level 1 User requirements cannot simply be given that additional role.

The GOV.UK sponsorship management roles guidance provides an official summary of the different positions.

Does the Authorising Officer automatically receive SMS access?

No. Being appointed as Authorising Officer does not automatically create an SMS account.

To use the Sponsorship Management System, the Authorising Officer must also be appointed as:

• A Level 1 User; or
• A Level 2 User after the licence has been granted.

If the Authorising Officer does not have SMS access, an eligible Level 1 User can perform day-to-day work. However, the Authorising Officer remains responsible for deciding who should have access and for overseeing the conduct of all SMS users.

Main responsibilities of an Authorising Officer

The Authorising Officer’s work should not end when the sponsor licence is granted.

1. Accepting senior responsibility

The Authorising Officer must understand that the organisation is making commitments to the Home Office. They should have sufficient authority to intervene where HR, payroll, recruitment or sponsored-worker management is not compliant.

2. Approving the sponsor licence application

Following submission of the online application, all pages of the submission sheet must be signed and dated by the Authorising Officer.

The submission sheet and mandatory documents must normally be emailed to the Home Office within five working days. Through the declaration, the organisation confirms that it accepts its sponsor duties.

The Authorising Officer and Key Contact should remain available while the application is being considered because UKVI may request additional information.

3. Controlling SMS access

The Authorising Officer decides:

• How many people need SMS access.
• Whether each person should be a Level 1 or Level 2 User.
• Whether access remains necessary.
• Whether users are sufficiently trained and supervised.
• Whether users who leave or change position are removed promptly.

SMS usernames and passwords must never be shared.

4. Supervising SMS users

The sponsor is responsible for actions completed by its SMS users, including external representatives where they have been properly appointed.

The Home Office recommends that the Authorising Officer checks Certificates of Sponsorship assigned by SMS users at least once every month. This review should ideally be documented.

5. Overseeing sponsor duties

The organisation’s sponsor duties include:

• Reporting relevant worker changes.
• Keeping required documents and records.
• Conducting proper right-to-work checks.
• Monitoring attendance and unauthorised absence.
• Monitoring visa expiry dates.
• Maintaining current residential addresses and contact information.
• Paying sponsored workers correctly.
• Ensuring the actual job matches the Certificate of Sponsorship.
• Reporting significant organisational changes.
• Complying with immigration law and wider UK law.

Worker changes generally have a ten-working-day reporting deadline, while many organisational changes must generally be reported within twenty working days. The precise deadline depends on the event. The full requirements are set out in Part 3 of the sponsor duties and compliance guidance.

The Level 1 User may complete the report, but the Authorising Officer should ensure that the organisation has systems capable of identifying reportable events in time.

6. Ensuring Certificates of Sponsorship are accurate

Before a Certificate of Sponsorship is assigned, the organisation should confirm:

• There is a genuine vacancy.
• The occupation code is appropriate.
• The job description accurately reflects the position.
• The salary and working hours satisfy the relevant route.
• The worker has the necessary skills, experience or registration.
• The proposed work location is recorded correctly.
• The candidate is expected to perform the sponsored role.
• Any prohibited costs have not been passed to the worker.

The Authorising Officer should require evidence-based approval procedures rather than allowing Certificates of Sponsorship to be assigned without review.

7. Maintaining compliance systems

The Authorising Officer should ensure that HR, recruitment and payroll systems communicate effectively. A reportable change may be missed if, for example, payroll reduces a worker’s salary without notifying the Level 1 User.

8. Preparing for compliance checks

UKVI can conduct compliance checks before or after granting a licence. The Authorising Officer should be able to explain:

• Why the organisation needs to sponsor workers.
• How sponsored vacancies are approved.
• Who operates the SMS.
• How Certificates of Sponsorship are checked.
• How attendance and absences are monitored.
• How immigration expiry dates are tracked.
• How worker and organisation changes are reported.
• Where documents are stored.
• How payroll is checked against the Certificate of Sponsorship.

For businesses operating virtually with little or no physical office space, the Home Office guidance states that a compliance check with the Authorising Officer is highly likely and may include a visit to their physical address.

Recommended monthly Authorising Officer review

A practical monthly review may include:

1. Reviewing every Certificate of Sponsorship assigned during the month.
2. Confirming that each sponsored worker has started work.
3. Checking unauthorised absences and unpaid leave.
4. Reviewing salary, hours, job-title and duty changes.
5. Confirming current work locations and remote-working arrangements.
6. Checking upcoming visa expiry dates.
7. Confirming right-to-work records remain complete.
8. Reviewing outstanding SMS messages and change requests.
9. Checking whether any SMS user has left or changed responsibilities.
10. Recording identified issues, corrective action, responsible staff and completion dates.

This review does not remove the need for immediate action when a reportable event occurs.

Home Office suitability checks

The Home Office makes checks on nominated Key Personnel when considering the application. Checks can include Home Office records and the Police National Computer. They may be repeated after the licence is granted or when new Key Personnel are nominated.

An appointment may cause refusal or revocation where the relevant person:

• Has an unspent conviction for a relevant offence.
• Has received a relevant civil penalty.
• Is legally prohibited from acting as a company director, including because of relevant bankruptcy restrictions, unless suitable court permission applies.
• Was recently Key Personnel at an organisation whose sponsor licence application was refused.
• Was Key Personnel at an organisation whose licence was revoked within the relevant period.
• Is connected with unpaid Home Office legal costs.
• Is subject to relevant UK or United Nations sanctions.
• Has acted in a manner not conducive to the public good.
• Otherwise presents a risk to immigration control.

Previous involvement with a refused or revoked sponsor does not always have the same consequence. The current guidance contains specific periods, including six months for certain refusals and twelve or twenty-four months for certain revocations.

The organisation should obtain complete and truthful information about a proposed Authorising Officer’s previous sponsor involvement before nominating them.

Is the Authorising Officer personally liable?

The sponsor licence belongs to the organisation, and Home Office action will normally be directed at the sponsor. Appointment as Authorising Officer does not, by itself, create automatic personal liability for every organisational mistake.

However, the person’s conduct can still have serious consequences. Their criminality, civil penalties, previous sponsor history or misuse of the sponsorship system may affect:

• Their suitability to remain Key Personnel.
• The organisation’s licence application.
• The sponsor’s licence rating.
• The organisation’s ability to assign Certificates of Sponsorship.
• Future sponsor licence applications involving that person.

Separate personal consequences may also arise under employment, company, civil or criminal law where the individual has personally committed misconduct.

What happens if the Authorising Officer leaves?

A sponsor must have an eligible Authorising Officer throughout the life of its licence. The Home Office states that it will normally revoke a licence where the sponsor has no eligible Authorising Officer or fails to notify UKVI of a change.

The safest approach is to identify and prepare the replacement before the existing Authorising Officer leaves.

A Level 1 User should normally:

1. Access the SMS.
2. Select the function for requesting changes to licence details.
3. Choose “Replace your Authorising Officer”.
4. Enter the new person’s details.
5. Produce and obtain the required signed submission sheet.
6. Send the submission sheet and any requested evidence within five working days.

UKVI will conduct suitability checks on the replacement. Some requests may update automatically where specified conditions are met, while others require consideration by a caseworker.

The general twenty-working-day organisational reporting period expressly excludes replacement of the Authorising Officer and Key Contact. Sponsors should not treat twenty working days as a grace period. Because an eligible Authorising Officer must remain in place throughout the licence, the replacement should be arranged without delay.

The official technical steps are provided in SMS Manual 2: Manage your sponsorship licence.

If nobody has Level 1 SMS access, the sponsor may need to use the sponsor change-of-circumstances form instead.

What if the Authorising Officer is temporarily absent?

A short holiday or ordinary period of leave does not necessarily require replacement. The organisation should nevertheless ensure that:

• An eligible Level 1 User can perform urgent SMS activity.
• Compliance matters are escalated appropriately.
• UKVI correspondence is monitored.
• Reporting deadlines are not missed.
• The Authorising Officer can review important decisions when reasonably possible.

Where the individual will be unavailable for a prolonged period or can no longer exercise genuine oversight, the organisation should consider appointing a replacement.

Can an Authorising Officer assign their own Certificate of Sponsorship?

Only an Authorising Officer who has also been appointed as an SMS user can assign a Certificate of Sponsorship.

An SMS user must not assign a Certificate of Sponsorship to themselves or to their close relative or partner. The narrow exception is an overseas-based Authorising Officer under a provisional UK Expansion Worker licence who is permitted to assign their own Certificate of Sponsorship.

Where the Authorising Officer is also a Level 1 User, an internal second-person review is sensible to reduce error and conflict risk.

Appointment checklist

Before nominating an Authorising Officer, confirm:

• The candidate is genuinely the most senior relevant person.
• Their employment or office-holder status can be evidenced.
• They are based in the UK, unless a valid exception applies.
• They have a valid National Insurance number or documented exemption.
• Their immigration status permits the position.
• They have disclosed relevant convictions and civil penalties.
• Their previous involvement with sponsor licence holders has been checked.
• They understand sponsor reporting and record-keeping duties.
• They have authority over HR, payroll and recruitment processes.
• They can control and monitor SMS users.
• They are available during the application process.
• A succession plan exists if they leave or become unavailable.

Suggested internal appointment wording

[Name and job title] is appointed as the organisation’s Authorising Officer. They are the most senior person responsible for the recruitment of sponsored workers and for ensuring compliance with the organisation’s sponsor duties. They have authority to supervise Key Personnel, control SMS access, review Certificate of Sponsorship activity, require corrective action and escalate compliance concerns to the organisation’s governing body.

The appointment record should be supported by the organisation’s real management arrangements rather than existing only on paper.

Common Authorising Officer mistakes

Appointing someone too junior

A person may understand the SMS but still lack the authority required of an Authorising Officer.

Treating the role as ceremonial

A name-only appointment is dangerous. The Authorising Officer should receive regular compliance information and actively supervise SMS activity.

Appointing an external adviser

A representative may assist with the application and, where permitted, hold other Key Personnel positions. They cannot act as the Authorising Officer merely because they manage immigration work.

Giving the role to the only person who understands sponsorship

Knowledge is important, but the person must also satisfy the seniority requirement. Operational knowledge can be provided by a trained Level 1 User reporting to the Authorising Officer.

Failing to review Certificates of Sponsorship

The Home Office recommends a monthly review. Sponsors should keep a clear audit record showing what was reviewed and how any issues were corrected.

Failing to plan for departure

Waiting until the Authorising Officer has left may leave the sponsor without eligible Key Personnel and create difficulties accessing or updating the licence.

Assuming the Authorising Officer automatically has SMS access

SMS access requires a separate Level 1 or Level 2 User appointment.

Allowing unchecked delegation

Day-to-day work may be delegated, but the sponsor and Authorising Officer remain responsible for SMS users’ activities.

How James Immigration Solutions Ltd can help

James Immigration Solutions Ltd can assist suitable businesses with straightforward sponsor licence and compliance matters within its authorised scope, including:

• Assessing proposed Authorising Officer eligibility.
• Reviewing Key Personnel arrangements.
• Identifying potential suitability concerns.
• Preparing sponsor licence applications and supporting documents.
• Reviewing HR and sponsor-compliance systems.
• Preparing an Authorising Officer responsibilities checklist.
• Assisting with suitable straightforward Key Personnel changes.
• Preparing businesses for possible compliance questions.

A written quotation is provided after the matter has been assessed. No immigration outcome can be guaranteed.

Matters involving sponsor licence suspension or revocation, allegations of deception, serious compliance breaches, appeals, judicial review or work outside our authorised scope may need referral to an appropriately authorised specialist.

Contact James Immigration Solutions Ltd

James Immigration Solutions Ltd
Company No. 15056317
IAA organisation reference: F202538614

Adviser: Fahad Zohaib Asghar
IAA adviser number: 061760

Telephone/WhatsApp: +44 7944 222484
Email: admin@jisl.co.uk
Website: www.jisl.co.uk

Registered office:
Building No. 167–169, 5th Floor
Great Portland Street
London, England
W1W 5PF

Appointments are available by prior arrangement.

Important notice

This article provides general information and does not constitute immigration or legal advice for a particular organisation. Sponsor guidance and Immigration Rules can change. Eligibility should be assessed against the current rules and the organisation’s actual structure before an Authorising Officer is nominated.

Information reviewed and updated on 2 August 2026.