4. Sponsorship management roles

You need to appoint people within your business to manage the sponsorship process when you apply for a licence.

The main tool they’ll use is the sponsorship management system (SMS).

The roles are:

  • authorising officer – a senior and competent person responsible for the actions of staff and representatives who use the SMS
  • key contact – your main point of contact with UK Visas and Immigration (UKVI)
  • level 1 user – responsible for all day-to-day management of your licence using the SMS

These roles can be filled by the same person or different people.

You can also appoint an optional level 2 user once you have your licence. This is an SMS user with more restricted access than a level 1 user, eg they can’t withdraw a certificate of sponsorship.

Suitability checks

You and your staff will be checked to make sure you’re suitable for these roles. You may not get your licence if anyone involved in sponsorship has:

  • an unspent criminal conviction
  • been fined by UKVI in the past 12 months
  • been reported to UKVI
  • broken the law
  • been a ‘key person’ at a sponsor that had its licence revoked in the last 12 months
  • failed to pay VAT or other excise duty

You and your allocated staff must also:

  • be based in the UK most of the time
  • not be a contractor or consultant contracted for a specific project
  • not be subject to a bankruptcy restriction order or undertaking, or a debt relief restriction order or undertaking
  • not have a history of non-compliance with sponsor requirements

Your allocated staff must usually be paid members of staff, or office holders.

Read the full guidance on appointing ‘key personnel’.

HR contractors and agency staff

You must have at least one level 1 user who is your employee. You can have other level 1 or level 2 users employed by third-party organisations contracted to provide you with HR services. Your level 2 user can be a temporary member of staff supplied by an agency.

UK-based legal representatives

You can allocate any of the roles to a UK-based legal representative, apart from the authorising officer role. Your representative must be qualified to give immigration advice or services.