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To apply for a Home Office sponsor licence, an organisation must appoint an Authorising Officer, a Key Contact and a Level 1 User. These are the people the Home Office relies upon to oversee sponsorship, communicate about the licence and operate the Sponsorship Management System (SMS). Their eligibility and the arrangements around them can affect whether the application succeeds and how effectively the licence is managed afterwards.
Immtell advises employers on selecting appropriate key personnel and regularly acts as Key Contact and an additional Level 1 User for clients once their licence is granted. This guide explains the three roles, the requirements to consider and how experienced external support can work alongside an employer's own responsibilities.
What are the three sponsor licence key personnel roles?
Authorising Officer: the senior person accountable for sponsorship
The Authorising Officer (AO) is a senior and competent person within the organisation responsible for its sponsorship arrangements and the activities of its SMS users. The AO needs sufficient authority to ensure the organisation has appropriate systems and follows its sponsor duties.
For a growing business, this may be a director or senior HR or operations leader with real oversight of recruitment and workforce management. Appointing someone solely because of their job title can create problems if they cannot explain how sponsored workers are monitored or how changes reach the people responsible for reporting.
Employers remain responsible for sponsor compliance. Appointing an immigration adviser to assist with the licence does not transfer the AO's responsibilities to that adviser.
Key Contact: the principal point of contact with the Home Office
The Key Contact is the main contact for Home Office communications about the application and licence. They need to be reachable, understand the organisation's sponsorship arrangements and coordinate timely responses when the Home Office requests information.
An eligible external representative may be appointed as Key Contact. Immtell frequently takes on this role, allowing clients to draw on experienced immigration advisers when dealing with sponsorship correspondence and enquiries. The Key Contact role alone does not provide SMS user access.
Level 1 User: managing the Sponsorship Management System
A Level 1 User carries out core tasks through SMS, including requesting or assigning Certificates of Sponsorship (CoS), reporting relevant changes, updating licence information and managing user access within the permissions available.
For most new applications, the primary Level 1 User must be an employee, director or partner who is also a settled worker. Additional Level 1 Users nominated during the application must be internal paid staff or office holders. After approval, eligible UK-based representatives such as Immtell may be appointed as additional Level 1 Users.
Sponsor licence key personnel eligibility at a glance
| Role | Who can be appointed? | Can Immtell undertake it? |
|---|---|---|
| Authorising Officer | An eligible senior paid staff member or office holder within the sponsor, responsible for sponsorship oversight. | No. The employer retains this internal role. |
| Key Contact | An eligible paid staff member or office holder, or a qualifying UK-based immigration representative. | Yes. Including during the application. |
| Initial / primary Level 1 User | Normally an employee, director or partner and a settled worker. Defined exceptions apply. | No. An external representative cannot be nominated in the initial application. |
| Additional Level 1 User (after approval) | Eligible internal personnel, qualifying outsourced HR staff or UK-based immigration representatives. | Yes. Alongside the required internal user. |
| Level 2 User | No new appointments since 9 September 2026. Existing users must be upgraded if eligible or deactivated by 8 March 2027. | No new Level 2 appointments. |
This is a summary of the main requirements. All nominees must meet the relevant Home Office suitability rules; exceptions and transitional provisions can affect individual cases.
Who is eligible to be sponsor licence key personnel?
Every nominated person must meet the general Home Office suitability requirements and the specific rules for their role. They must normally be based in the UK, have a valid National Insurance number unless exempt, and have no relevant suitability concerns arising from their immigration or criminal history. SMS users must keep their personal details accurate, use mandatory multi-factor authentication and access their accounts regularly. Contractors engaged for a specific purpose cannot simply be appointed as key personnel.
Authorising Officer: who can be appointed?
The Authorising Officer must be the most senior person responsible for recruiting sponsored workers and ensuring the organisation meets its sponsor duties. If the sponsor does not recruit those workers itself, the role must be held by the most senior person responsible for its sponsorship activity.
- They must be a paid staff member or office holder within the sponsor organisation.
- They must satisfy the general UK residence, National Insurance and suitability rules, subject to limited exceptions.
- Only one Authorising Officer can be appointed at a time.
- An external immigration representative cannot act as Authorising Officer. A specific exception applies to insolvency practitioners when a sponsor enters administration.
- They do not automatically have SMS access: they must also be appointed as a Level 1 User to operate it.
The Authorising Officer remains responsible for all SMS users, including external representatives. The Home Office recommends checking assigned Certificates of Sponsorship at least monthly. Sponsors must maintain an eligible Authorising Officer throughout the life of the licence.
Key Contact: who is eligible?
The Key Contact must be either a paid staff member or office holder within the sponsor organisation, or an eligible UK-based representative. They must meet the general suitability requirements, and there can be only one Key Contact at a time.
A UK-based immigration consultancy such as Immtell can therefore act as Key Contact during the initial application and afterwards. The Key Contact does not automatically have SMS access.
Initial Level 1 User: requirements when applying for a sponsor licence
For most new sponsor licence applications, at least one nominated Level 1 User (the primary Level 1 User) must meet both requirements:
- Be an employee, director or partner within the applicant organisation.
- Be a settled worker as defined in the Home Office sponsor guidance, unless a specified exception applies.
British citizens and people with indefinite leave to remain will commonly meet the settled-worker definition, but the complete definition and any exceptions must be checked. Having permission to work in the UK does not automatically mean someone is a settled worker.
An external immigration representative cannot be nominated as a Level 1 User in the initial application. Other Level 1 Users nominated at that stage must also be paid staff members or office holders within the applicant organisation. A failure to nominate a qualifying primary Level 1 User can result in refusal.
Exceptions to the settled-worker requirement apply in defined circumstances, including where the Authorising Officer holds permission in specified categories such as Innovator Founder, Global Talent or UK Expansion Worker. There are also special rules for certain international organisations and UK Expansion Worker applications. Sponsors who applied successfully before 1 January 2025 and have continuously held their licence may benefit from transitional provisions under which the internal-person and settled-worker conditions can be satisfied by two different Level 1 Users.
Additional Level 1 Users after approval
Once a sponsor licence has been granted, additional Level 1 Users can be appointed from a wider group:
- Paid staff members or office holders within the sponsor.
- Employees of an organisation engaged to provide all or part of the sponsor's HR function.
- Eligible UK-based immigration representatives, including Immtell.
The sponsor must retain the required qualifying internal Level 1 User (subject to the specific exceptions and transitional rules). An external representative cannot be the only Level 1 User. The Authorising Officer remains accountable for every user's activities and should restrict access to people who genuinely need it.
This is the distinction behind Immtell's service: we can be Key Contact from the application stage, then be added as an additional Level 1 User after approval to assist with CoS work, reporting and SMS administration.
Level 2 Users: no new appointments and a deadline for existing users
From 9 September 2026, the Home Office stopped allowing new Level 2 User appointments. Existing Level 2 Users must be converted to Level 1 Users if eligible, or have their accounts deactivated, by 8 March 2027. The Home Office will deactivate any remaining Level 2 accounts after that deadline.
Some existing Level 2 Users will not qualify for Level 1 access. For example, temporary staff supplied by an employment business cannot be converted simply because they previously held Level 2 permissions. Sponsors should review their SMS user list now and assess who needs access and whether they qualify.
Can the same person be Authorising Officer, Key Contact and Level 1 User?
A single person may fulfil more than one role where they meet each role's requirements. Whether that is sensible depends on the organisation. If one employee controls all sponsorship knowledge and SMS access, their absence or departure can interrupt recruitment and reporting.
Businesses should consider how the AO will maintain oversight, who can respond to Home Office correspondence and how urgent SMS work will be covered. This is particularly important where HR, payroll and recruitment are handled by different teams or external providers.
Can an immigration consultancy act as Key Contact and Level 1 User?
Where the relevant Home Office requirements are met. An eligible representative can act as Key Contact, and an adviser may be appointed as an additional Level 1 User where permitted. The sponsor still needs to maintain its own required appointments, internal oversight and compliance systems.
“We regularly act as Key Contact and a Level 1 User on our clients’ sponsor licences. It means employers have experienced immigration professionals helping with CoS requests, SMS reporting and Home Office correspondence as their recruitment needs change. We work alongside their team, with the Authorising Officer retaining oversight. Having that continuity from application through to ongoing management gives employers greater confidence in the decisions they make.”
Gavin Webster, Founder and Managing Director, Immtell
For employers, this arrangement provides continuity. When a sponsored worker changes role or location, a new CoS is needed or the organisation undergoes restructuring, the immigration implications can be considered promptly by people familiar with the licence and its history.
Immtell's founder, Gavin Webster, has 23 years of UK immigration experience, including 13 years working for the Home Office. We support clients directly with sponsor licence applications, CoS work, SMS reporting and ongoing guidance, with agreed responsibilities and clear communication with the employer's AO and HR team.
Why key personnel decisions affect your licence after approval
Once a licence is granted, the employer must keep prescribed records, monitor sponsored workers and report certain changes. Information may originate in payroll, line management, recruitment or finance rather than with the person operating SMS. The AO needs to ensure that information reaches the right people in time.
For example, a change to a sponsored worker's hours or salary may require assessment of the relevant immigration requirements and reporting duties. A change in ownership may have consequences for the licence itself. An experienced Level 1 User can help identify the appropriate action, but the organisation must supply accurate information and maintain oversight.
Immtell's Head of Sponsor Compliance, Ewen McKenzie, is a former Home Office Regional Compliance Manager who led teams conducting sponsor compliance visits. He leads our mock compliance audits and Desktop Salary Reviews, helping employers assess whether their processes work as intended.
Watch: applying for and managing a sponsor licence
What if an Authorising Officer, Key Contact or Level 1 User leaves?
The organisation must maintain eligible key personnel and suitable SMS access. Relevant changes must be notified to the Home Office through the prescribed process within applicable deadlines. Replacing an AO, changing a Key Contact or removing a Level 1 User can involve different steps and supporting evidence.
We advise employers to plan for continuity before a departure causes an operational problem. Where Immtell already supports the licence, we can assist with the required reporting and updating of appointments.
Common problems we see with key personnel arrangements
- Eligibility overlooked: a proposed individual does not meet the Home Office's requirements for the role.
- Limited AO oversight: the named senior person cannot explain who monitors workers or authorises SMS activity.
- Key Contact and SMS access confused: being the contact for Home Office correspondence does not automatically make someone a Level 1 User.
- Single-person dependency: all SMS knowledge sits with one employee, leaving the business exposed during absences or staff turnover.
- Reporting gaps: HR and payroll changes are not passed to the people responsible for sponsorship in time.
- Responsibility misunderstood: an employer assumes an external adviser has taken over its legal duties.
How Immtell supports your sponsor licence application and ongoing management
We review proposed key personnel as part of our sponsor licence application service, alongside the business's eligibility, recruitment plans, documents and compliance arrangements. After approval, we can support SMS operations and act as Key Contact or an additional Level 1 User where appropriate.
Our approach connects the original application with the decisions employers face throughout the life of the licence. We can also provide training, compliance audits and ongoing support as the organisation grows.
Apply for a sponsor licence with Immtell
We can help you appoint eligible key personnel, prepare your application and manage the licence after approval.
Frequently asked questions
Who are the three sponsor licence key personnel?
An applicant must nominate an Authorising Officer, Key Contact and Level 1 User. These roles cover senior accountability, contact with the Home Office and management of the Sponsorship Management System.
Can one person hold all three roles?
Yes, where that person meets the requirements for each role. Employers should also consider who will provide cover during absences or personnel changes.
Can Immtell act as our Key Contact?
Subject to the Home Office requirements for representatives. Immtell regularly acts as Key Contact for sponsor licence clients.
Can Immtell be a Level 1 User?
Immtell can act as an additional Level 1 User where permitted and authorised. The employer must retain any required internal Level 1 User arrangements and remains responsible for its sponsor duties.
Can an external adviser be our Authorising Officer?
The Authorising Officer must be an eligible senior person within the sponsor organisation. An external immigration adviser cannot take over the employer's accountability simply by managing SMS activity.
What if a key person leaves the business?
The sponsor must maintain eligible key personnel and appropriate SMS access, and report relevant changes using the Home Office's prescribed process and deadlines.
Does appointing an adviser transfer sponsor compliance responsibility?
The licensed organisation remains accountable for complying with its sponsor duties, even where an authorised representative undertakes permitted tasks.
Can new Level 2 Users still be appointed?
No. New appointments ended on 9 September 2026. Existing Level 2 Users must be upgraded to Level 1 Users where eligible or deactivated by 8 March 2027.
Who can be the initial Level 1 User?
For most new applications, the primary Level 1 User must be an employee, director or partner within the sponsor and a settled worker. Defined exceptions apply.
