Sponsor Licence Key Personnel Requirements 2025/26
Understand the three essential roles: Authorising Officer, Level 1 User (must be settled worker), and Key Contact. Meet UK-based personnel requirements to secure your sponsor licence.
2025 Critical Update: Settled Worker Requirement
From 2025, at least ONE Level 1 User must be a settled worker (British citizen, indefinite leave to remain, settled status, or Irish citizen). This person must also be an employee, director, or partner—third-party Level 1 Users can only be additional.
The Authorising Officer does not need to be a settled worker, but must be UK-based with a National Insurance Number.
Every sponsor licence requires three key personnel roles: an Authorising Officer, at least one Level 1 User (who must be a settled worker and employee/director/partner), and a Key Contact. These roles have specific duties, eligibility criteria, and responsibilities for maintaining compliance with UK immigration law.
The Three Key Personnel Roles
Authorising Officer
Senior staff responsible for overall compliance and authorizing actions on SMS
Level 1 User
Settled worker who assigns CoS and manages day-to-day sponsorship duties
Key Contact
Main point of contact for Home Office communication
Authorising Officer (AO) Requirements
What is an Authorising Officer?
The Authorising Officer is a senior staff member (usually director, CEO, or senior manager) who takes overall responsibility for ensuring the organization complies with its sponsor duties. The AO authorizes key actions in the Sponsor Management System.
Eligibility Criteria
Senior Position Required
Must be director, partner, senior manager, or equivalent with authority over sponsored workers
UK-Based and Accessible
Must be physically based in the UK and available to respond to Home Office requests
National Insurance Number Required
Must have a UK National Insurance Number for verification
No Settled Worker Requirement (NEW 2025)
Unlike Level 1 Users, the AO does not need to be a settled worker, but must be UK-based
Authorising Officer Duties
- Compliance oversight: Ensure the organization meets all sponsor duties
- Authorize key changes: Approve changes to key personnel, business structure, or SMS access
- Respond to Home Office: Be available for audits, inspections, and inquiries
- Report breaches: Notify Home Office of any compliance failures within 10 working days
- Maintain records: Ensure accurate record-keeping for all sponsored workers
- Prevent suspension: Implement systems to avoid sponsor licence suspension
Level 1 User Requirements (2025 Update)
Critical 2025 Rule Change
At least ONE Level 1 User must be a settled worker (British citizen, indefinite leave to remain, EU settled status, or Irish citizen).
This settled worker Level 1 User must also be an employee, director, or partner of the organization. Third-party Level 1 Users (e.g., accountants, solicitors) can only be appointed as additional Level 1 Users.
What is a Level 1 User?
A Level 1 User handles day-to-day sponsorship management, including assigning Certificates of Sponsorship (CoS), updating worker records, and reporting changes via the Sponsor Management System.
Eligibility Criteria (2025)
At Least ONE Must Be Settled Worker
British citizen, ILR holder, EU settled status, or Irish citizen
Must Be Employee, Director, or Partner
The settled worker Level 1 User must work for the organization directly—not a third party
Third-Party Level 1 Users: Additional Only
Accountants, solicitors, or HR consultants can be additional Level 1 Users but cannot be the only Level 1 User
UK-Based with National Insurance Number
Must be based in the UK and have a valid National Insurance Number
Level 1 User Responsibilities
- Assign CoS: Issue Certificates of Sponsorship to new hires (see CoS priority service for urgent needs)
- Update worker records: Maintain accurate information on all sponsored workers in SMS
- Report changes: Notify Home Office of worker absences, departures, or changes within 10 working days
- Conduct right-to-work checks: Verify workers' immigration status before employment and when visas are extended
- Maintain compliance: Ensure records are up-to-date and accessible for audits
Key Contact Requirements
What is a Key Contact?
The Key Contact is the main point of contact between the Home Office and your organization. This person receives all official correspondence, compliance notifications, and audit requests.
Eligibility Criteria
Permanent Employee
Must be a permanent employee or director—cannot be a third-party contractor
UK-Based and Available
Must be physically in the UK and able to respond to Home Office communication promptly
Reliable Communication
Must maintain accurate contact details (email, phone) and respond to Home Office within deadlines
Key Contact Role
- Receive Home Office communication: All official emails, letters, and compliance notices
- Coordinate audit responses: Work with Authorising Officer and Level 1 Users during inspections
- Respond to inquiries: Answer Home Office questions about sponsored workers or compliance
- Distribute information: Ensure relevant staff are informed of policy changes or updates
Can One Person Hold Multiple Roles?
Yes, But with Conditions
One person can serve as Authorising Officer, Level 1 User, and Key Contact simultaneously, provided they meet all eligibility criteria for each role.
✅ Recommended for:
- Small businesses or startups with limited staff
- Organizations where one senior person handles all immigration matters
⚠️ Not recommended for:
- Large organizations with high volumes of sponsored workers
- Companies where workload would overwhelm one person
- Scenarios requiring separation of duties for internal control
Consequences of Non-Compliant Key Personnel
Licence Refusal or Revocation
Failing to appoint suitable key personnel—especially the 2025 requirement for a settled worker Level 1 User—can result in:
- Initial application refusal: Home Office will refuse your sponsor licence application
- Licence suspension: Existing licences may be suspended if key personnel become non-compliant
- Licence revocation: Serious breaches lead to permanent revocation and 12-month reapplication ban
- Sponsored workers affected: Workers' visas may be curtailed if licence is revoked
Frequently Asked Questions
What is a settled worker for Level 1 User purposes?
A settled worker is someone with permanent immigration status in the UK: British citizen, indefinite leave to remain (ILR), EU settled status, or Irish citizen. This requirement is new in 2025 and at least one Level 1 User must have this status.
Can I use my solicitor or accountant as the only Level 1 User?
No. From 2025, at least one Level 1 User must be an employee, director, or partner of the sponsoring organization and must be a settled worker. Third-party Level 1 Users (solicitors, accountants) can only be appointed as additional Level 1 Users.
Does the Authorising Officer need to be a settled worker?
No. The Authorising Officer does not need to be a settled worker. However, they must be UK-based, have a National Insurance Number, and be a senior staff member with appropriate authority.
What happens if my key personnel leave the company?
You must report the change to the Home Office within 10 working days via the Sponsor Management System and appoint suitable replacements immediately. Failure to do so can lead to licence suspension.
How many Level 1 Users can I appoint?
You can appoint multiple Level 1 Users (there is no maximum limit), but at least ONE must be a settled worker who is an employee, director, or partner. Additional Level 1 Users can be third parties or other staff members.
Ensure Your Key Personnel Meet 2025 Requirements
Our compliance guides help you understand sponsor duties, avoid suspension, and maintain full compliance with Home Office requirements.
Sponsor Compliance & Management
Sponsor Licence Overview
Complete guide to sponsor licence application, costs, and requirements for UK employers.
Prevent Licence Suspension
800% increase in suspensions. Learn compliance requirements and 10 working days reporting rule.
Hiring Skilled Workers
Once your key personnel are set up, learn how to sponsor Skilled Workers (£41,700 salary).