Sponsor Licence Key Personnel: Who Does What

Every sponsor licence application must name the people who'll run it: an Authorising Officer, a Key Contact, and at least one Level 1 user. Name the wrong people and the Home Office can refuse the application before it looks at anything else, because these roles, known as key personnel, are checked for suitability one by one.

This guide covers what each role does, who's allowed to hold it, and the checks that catch employers out. It's part of our sponsor licence series; if you're starting from zero, that page is the place to begin.

The four roles at a glance

• Authorising Officer (AO) — the senior person responsible for everything done under your licence. Named at application.
• Key Contact — your main point of contact with UKVI (UK Visas and Immigration). Named at application.
• Level 1 user — day-to-day licence management in the Sponsorship Management System (SMS). At least one named at application.
• Level 2 user — restricted SMS access for routine tasks. Optional, added after the licence is granted.

One person can hold all of the first three roles, and in smaller organisations one person usually does.

The Authorising Officer

The AO is the most senior role and the one the Home Office scrutinises hardest. They must be a senior and competent person within your organisation, and they carry responsibility for the actions of every person who touches the SMS on your behalf. If a Level 1 user assigns a Certificate of Sponsorship to a role that doesn't qualify, that's the AO's problem.

One detail that surprises people: the AO doesn't automatically get access to the SMS. The role is accountability, not admin. If your AO wants to see or do anything in the system, they also need setting up as a Level 1 or Level 2 user.

The AO doesn't have to be British, and doesn't need settled status. They do need to be based in the UK most of the time, and they can't be a contractor or consultant brought in for a project. In practice the AO is usually a director, an HR director, or the business owner.

The role comes with duties the Home Office expects the AO to personally understand, and "I delegated it" isn't a defence. Our Sponsor Licence Duties and Guidance for Authorising Officers checklist sets them out one by one:

Download the AO Duties checklist →

The Level 1 user

Level 1 users do the actual work: assigning CoS, reporting worker changes, updating your organisation's details, all through the SMS. You need at least one from day one, and you can add more later.

The requirements are tighter than the AO's in one way: at least one Level 1 user must be an employee, partner, or director of your organisation AND a settled worker (a British or Irish citizen, or someone with settled status or Indefinite Leave to Remain). Beyond that first person, additional Level 1 users can include staff from a third-party HR provider you've engaged.

The Level 2 user

Level 2 users get restricted SMS access: they can handle routine reporting for workers they're responsible for, but they can't do the higher-stakes actions, like withdrawing a CoS. You can only appoint them once the licence is granted, and the bar is lower: an agency temp can be a Level 2 user.

They're useful in larger teams, where one person shouldn't be the only pair of hands, and in multi-site organisations where each site reports its own workers.

The Key Contact

The Key Contact is simply who UKVI talks to about your licence. It can be the same person as the AO or a Level 1 user, and it can be a UK-based legal representative, provided they're qualified to give immigration advice. If you're using a representative for your application, they'll often sit here.

The suitability checks

Every named person is vetted before the licence is granted, and the application can fail on any of them. The Home Office looks for unspent criminal convictions for listed offences, fines from UKVI in the past 12 months, a history of breaking immigration rules, unpaid VAT or excise duty, and connections to failed licences: anyone who was key personnel at a sponsor refused in the last six months, or at a sponsor that had its licence revoked in the last 12 (or 24 months, if they've been through more than one revocation).

The practical lesson: check your proposed names against that list before you apply, especially if anyone has worked at another sponsor. A refused application means a wasted fee and, for some refusal grounds, a cooling-off period before you can try again.

When key personnel change

People leave, and the licence doesn't pause while you recruit. Changes to key personnel need reporting to UKVI through the SMS, and an organisation with no working AO or Level 1 user is an organisation that can't meet its sponsor duties, which is a compliance problem in itself.

The single-point-of-failure version of this is common and avoidable: one person holds all three roles, that person resigns, and sponsorship management stops dead. If your whole licence lives in one colleague's head, fix that before they hand their notice in.

Sponsor licence key personnel FAQs

Does the Authorising Officer have to be British?

No. The AO needs to be senior, competent, and based in the UK most of the time. It's the first Level 1 user who must be a settled worker as well as an employee, partner, or director.

Can one person be the AO, Key Contact, and Level 1 user?

Yes, and in small organisations one person often is. Just weigh the single-point-of-failure risk: if that person leaves, nobody's running the licence.

Can our HR provider or solicitor manage the SMS for us?

Partly. A third-party HR provider's staff can be additional Level 1 or Level 2 users, and a qualified UK-based legal representative can be your Key Contact and, once the licence is granted, a Level 1 or 2 user. But your first Level 1 user must come from inside the organisation, and the AO must too (a UK Expansion Worker licence is the one exception).

What happens if our AO leaves?

Report the change through the SMS and appoint a replacement promptly. The licence carries on, but a gap with no AO leaves nobody accountable, and that's the kind of detail a compliance visit picks up.

How many Level 1 users can we have?

More than one, and for resilience you should. There's no practical cap that matters for most employers; add the people who genuinely need day-to-day access and no more.

One licence, several names, no gaps

Key personnel is where sponsorship stops being a form and starts being an org chart. The roles are easy to fill on paper and easy to get wrong in practice, usually by loading everything onto one person and hoping they stay.

Borderless Immigration gives your AO and Level 1 users one place to see the whole licence: every worker, every deadline, every report, with a 95% average compliance score among employers 90 days after joining. Book a demo to see it with your own set-up in mind.