Sponsor licence duties and guidance for authorising officers
You have been named the Authorising Officer on your organisation's sponsor licence, which makes you the person the Home Office holds responsible. This free guide sets out what that means in practice, and what you should be able to see without asking anyone.
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Accountability without visibility is the problem
As the Authorising Officer you are the named person legally responsible for your organisation's sponsor licence. You are accountable to the Home Office for every sponsorship duty, and if things go wrong it is your licence, and the permission of every worker you sponsor, that is at risk. Illegal working alone carries a civil penalty of up to £45,000 per worker for a first breach and £60,000 for a repeat, and a licence can be suspended or revoked on the strength of a single compliance visit.
In most organisations the Authorising Officer does not do the work. Right to work checks happen at each location, reporting happens in HR, and files sit with people who do not report to you. The role is not admin, it is governance, oversight, and compliance, and the gap that catches Authorising Officers out is the one between what they are accountable for and what they can actually see.
What's inside
- Your duties, in plain English. Reporting, record keeping, complying with immigration and wider UK law, and being ready for a compliance visit, and what each one looks like day to day.
- Delegation without abdication. Who can do what on the Sponsorship Management System, what changed when multi-factor authentication became mandatory on 3 September 2026 and new Level 2 users stopped being appointable from 9 September 2026, and what stays yours whoever presses the button.
- Key personnel changes. The reporting duty that attaches when someone named on the licence joins or leaves, and the deadline for it.
- What you should be able to see. The handful of things an Authorising Officer ought to be able to check without asking anyone, and how to get to them.
Authorising officer duties: your questions answered
What does an authorising officer do?
The Authorising Officer is the senior person named on a sponsor licence who takes responsibility for all of the organisation's sponsorship duties and for the people who act on the Sponsorship Management System on its behalf.
Who can be an authorising officer?
A paid member of staff or an office holder, based in the UK, senior enough to be responsible for recruitment and human resources. They must pass the Home Office suitability checks.
Does the authorising officer get access to the Sponsorship Management System?
Not automatically. The Authorising Officer has no SMS access by virtue of the role alone and has to be appointed as a Level 1 user as well if they want to see the account directly.
Is the authorising officer personally liable?
The civil penalty for illegal working is issued to the employer. What sits with the Authorising Officer is accountability to the Home Office for the licence: the Home Office holds the named person responsible for the duties being met, whoever does the work.
What happens when the authorising officer leaves?
It is a reportable change and a new Authorising Officer has to be nominated. Leaving the role vacant puts the licence at risk.
Who this guide is for
Anyone newly named as an Authorising Officer, and anyone who has held the role for a while without a clear view of what sits underneath it. It is written for people who carry the accountability rather than the keyboard: CPOs, HR directors, finance leads, and founders.
About Borderless
Borderless is the UK platform for sponsor licence holders. We run Certificates of Sponsorship, visa applications, right to work checks, and ongoing compliance in one place, for over 500 employers and more than 13,000 sponsored workers across every sector that sponsors.
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